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We have taken the necessary time, we believe, to analyze this general proposal thoroughly, and to view all of the ramifications and implications incident to it in an objective manner. As one producer of personal aircraft we offer herein not only our opinions on the proposal, but also our reasons for these opinions. · There are as follows:

1. We heartily favor any intelligently conceived program which will share the costs incident to the research, experimental and development work involved in the eventual production of new models and types of aircraft. The producers of light aircraft have almost without exception borne these costs single-handledly as an implicit part of their over-all cost of doing business, and this has, to a degree, made their approach to the development of new designs singularly conservative.

2. Any such program must, however, maintain in full economic focus all of the multiple factors which extend before and beyond the mere creation of a single prototype aircraft of whatever design or intrinsic capabilities.

3. The formulation of design requirements and specifications by a general council supported by government funds, as is proposed, becomes unwieldy if one realizes that using agencies such as Air Force are fully capable of reciting their own requirements and that the requirements of such a using agency are not necessarily compatible with or adaptable from designs intended primarily for industrial or private use.

4. Also, the guidance of such a general council in this development of designs intended for industrial and private use would not insure that developed designs would ever be put into production. The average light plane manufacturer has developed an unusually canny knowledged of what the general public wants badly enough to be willing to pay for, and such a manufacturer might not want to take the risk of producing an item the demand for which could be considered debatable.

5. Further, during the period of incubation attendant to new design development and by reason of the publicity surrounding such a project, sales of current models would probably suffer. Some potential buyers would await the development of this “ideal” aircraft soon to be produced. (We refer you to Air Commerce Bulletin, vol. 5, No. 6, dated December 15, 1933, for a parallel circumstance, i. e., a $700 airplane.)

6. However, we believe, that the psychological and economic factors underlying the mass public acceptance of personal aircraft are the basic determinants in this entire situation. Any product, no matter what it is nor how good it is must be sold to the public. Public acceptance is a matter of gradual evolution. It involves overcoming prejudices and inertia and conservatism. It also involves timing in the working out of a multiplicity of interrelated factors.

7. We do not believe it possible to revolutionize our industry and to turn it into a high volume business in any short span of time merely by creating an airplane “differing radically” from those available today. Such a step would help, were it possible, but mass acceptance is a matter of decades, not a few years, as a little backward looking will reveal.

8. In reviewing the personal plane industry and its growth and development over a period of nearly three decades, it is our considered opinion that the evolutionary pattern which has observably developed is attributable to the inherent advantages of the airplane over other transportational forms. Such advantages are basically two in number and are (a) speed, and (6) flexibility. The evolutionary process has tended toward harnessing these advantages in a competitively economic fashion, which involves not only cost but also, by logical extension, reliability and safety.

9. We maintain, and are adequately supported in our contention by the numerous disasters of a financial nature which have overtaken designers and manufacturers who, in the past, have tried to go contrary to the evolutionary trend, that an airplane is a vehicle of great utility but that such utility is specifically circumscribed by physical and economic limitations. Projects of this sort fail of their purpose because one characteristic is emphasized at the expense of a balanced design.

10. We, therefore, view with considerable suspicion any proposal which centers around the development of a "radically different” aircraft to create "greater utility”. We assume that the intention underlying such a proposal is to combine in a single package as many features, based on known principles as will enable such an aircraft to perform beyond the inherent capabilities of presently available aircraft. This is to be done without sacrifice of present favorable characteristics and without disturbing substantially the present cost structures.

11. We wish to point out that while slow and hovering flight characteristics have been developed, as in the autogiro and helicopter, that this has been done at vast increases in initial, operating and maintenance costs, and at the expense of advantageous weight and speed characteristics. Aircraft of this type have thereby been rendered useful for specific applications only and removed from a general utility category.

12. We point out, too, that utility is a matter of availability in time. Aircraft inherently incapable of safe flying at night or in "weather” have a potential use factor of less than 50 percent, i. e., perhaps 8 hours average out of the 24 over a year's period. We hold that an extension of this potential use factor to approximately 95 percent which has been achieved in military and airline flying is the result of a compendium of developments including ground facilities instrumentation, electronic devices, and equipment, and pilotage techniques and is not necessarily an extension of the basic capabilities of the aircraft.

13. We believe that the achievement of "greater utility” in personal and industrial aircraft is a far broader problem than can be answered fully by just designing a "radically different” aircraft. We deem it impossible to construct an aircraft at economically feasible cost which will combine in one package the mobility of an automobile, the speed and flexibility of a fighter and the availability of an airliner, while retaining the simplicity and dependability of a Piper Cub.

14. We do favor concerted effort to design and to build aircraft to accomplish specific purposes and to provide specific utility within the periphery of the multiple compromises which must always be made to achieve such specific purpose and utility, provided a solid requirement for an economically feasible quantity of such aircraft exists.

15. To summarize our thinking let us say that we believe the achievement of greater utility in personal aircraft, which is the basis of the NASAO proposal, will come through the development of many types of aircraft for many specific jobs and not through the development of one type with all-embracing capabilities. We further believe that the production of any type of aircraft, insofar as its greatest utility is concerned, is interwoven with the concurrent development of navigational aids, radio, radar, ground facilities and similar adjuncts the cost of which is eventually brought within the economic grasp of the personal and industrial user. In short, when the cost per mile per person involved in personal flying approaches that of competitive transportational forms, and when the user of the personal plane can be certain of its safe availability in bad weather as well as good and in darkness as in daylight, then personal flying will have come of age, and industrial applications will follow.

We stand ready to be accused of being reactionary in our viewpoint, but feel, instead, that we are being realistic. We like to think of our product as a business machine which has many economic applications in all phases of man's activities throughout the world. We cannot today think of it, at its present stage of evolution and development (age 46), as aught but a complicated mechanism to be treated with respect and subject to limitations which are too frequently misunderstood. Very truly yours,


Executive Vice President. The CHAIRMAN. Have you any opinion about the other prototype bills now before the committee?

Mr. Snow. Yes, sir; but not as well formulated as this one.
I have thought about two of them, of the number of other bills.

The CHAIRMAN. We have 237, 426, 2301, 2984, 3504, and that is the one that the Departments are for, and then the last one introduced was 3507.

Mr. Snow. Those are the two. I have not opinion on any except those last two, and I have, for what it may be worth, some opinions on those; 3504 is the one that calls for a testing program.

The CHAIRMAN. That is right. Mr. Snow. Costing 1272 million.

It seems to me offhand that the objective is good. We are way behind on jet airplane development, the turbo-prop. But I wonder,

way of this: Why cothe use in air which had pa

one, if that bill goes far enough and, two, if there is not a much simpler way of accomplishing what that bill intends to accomplish, and it is merely this: Why could not the appropriate Federal regulations be amended to permit the use in air cargo and air mail operations of uncertificated aircraft of this type which had passed certain types of flight tests?'

In other words, why could they not be put into a test program carrying cargo and mail? Why could not the contractors be paid for them as any mail and cargo carrier is, and why could not the Government recover its cost through the carriage of the mail and cargo? I mean why do you have to set up a separate program? Why could not that be fitted right into the activities of the CAB without any specific appropriation or change in the law?

On 3507, I have checked that against our criteria for any bill, and I do not think there is any basic difference between a research and development program for small aircraft and large ones. I mean the same principles should apply, and I am afraid that 3507 runs counter to a good many of the things that we feel should be implicit in any such plan.

It sets up a new Government agency which we do not feel is necessary. It calls for Government agencies doing the work which we do not believe is the way it should be done.

So, in principle, I think we are opposed to some of the details of 3507; and 3504 we think is a good idea, but think it might be accomplished in another way.

The CHAIRMAN. But it would take a great deal more money accomplishing it your way. Mr. Snow. I would think it would take less, sir.

The CHAIRMAN. Well, it would take a larger initial outlay of money, at least.

Mr. SNOW. Well, as I understand it, 3504 will not help anybody to build or put together the aircraft that are going to be used.


Mr. Snow. So that has got to be done by private industry anyway. I understand that the CAA will be empowered to contract with people to operate these jets or turbojets over what have been called dummy routes.

Well, now, all I suggest is that the CAB establish a type of certification which would permit those aircraft, instead of going over dummy routes, to be operated over regular routes and regular service, but not carrying passengers.

Now the Government is constantly paying airlines for carrying mail and certain types of cargo. Why not pay them for carrying them on these turboprops and jets? In other words, why not give them a real service test and not a dummy service test?

Senator BREWSTER. Are you familiar with the testimony here that apparently the tests will be with the British jets?

Mr. Snow. I have read some of it, Senator, and I know, of course, that the Comet and the Avro jet planes are the only jets flying outside of Russia today.

Senator BREWSTER. They have about six models that have been developed, and the testimony of the aircraft industry here Tuesday was that they did not know of any immediate plans for the production of a jet prototype in this country.


· Mr. Snow. How about the Convair, with the General Motors turbo-prop?

Senator BREWSTER. Well, I used language rather carefully. I said a jet transport.

Mr. Snow. Yes, sir.

Senator BREWSTER. You see, I realize full well the distinction, and they spoke of that.

Mr. Snow. I see.

Senator BREWSTER. And that, of course, is simply an attempt at adaptation. How far that meets the problem, why, of course, only time can tell; they hope that will be available sometime within the next year, but meanwhile here are the jet transports that are operating, and the bill contemplates that they can make contracts with any foreign country, so that it is fair to assume then, and certainly no one refuted them, neither Mr. Rentzel or the aircraft industry or the airlines, but what they would go ahead and test the jets.

Mr. Snow. Could they not do that under my proposal just as well?

Senator BREWSTER. Now you come to getting the Comet or one of the others—the Viscount I saw over there more than a year ago, which I was operating, and to put them on our airlines. Mr. Snow. Yes, sir. Senator BREWSTER. Does that appeal to you?

Mr. Snow. It is better than not doing anything, sir. You can understand the reluctance-

Senator BREWSTER. Well, the only consolation I might see would be that it would stir up our own aircraft industry to do something. They have not been agreeable to the plans we have had for the development of prototypes, and they do not have anything of their own immediately other than the ones you speak of. Perhaps this would be a spur, but if you actually introduced those on our airlines as a commercial operation, I should imagine it might present some problem.

Mr. Snow. That is what I assume you want to find out. It is the problem that they would present or the problems that they would present that we have got to overcome as a part of this whole program.

Senator BREWSTER. If you put them on New York-Washington flights, for instance, there is quite a lot of congestion, and you know what has happened over the Washington Airport.

Mr. Snow. I do not think you could there, so you would have to use them initially in much less densely populated air routes.

Senator BREWSTER. I did not know what they meant by dummy routes. I assumed they contemplated that as they tried out the Boeing Stratoliner on the Alaskan route, they did that for 2 or 3 years on freight.

Mr. SNOW. I assumed that dummy routes were routes that had no utility for anything except test purposes; maybe between two airports that were not even near cities, that is all.

The CHAIRMAN. I have one other question that was handed me, and it seems to me it is quite pertinent in view of your testimony.

If Government airworthiness regulations are simplified, as you suggest, would it be at the expense of air safety? Mr. Snow. I believe it would be just the opposite, sir.

I am afraid that the present regulations pertaining to small aircraft have had the opposite than the desired effect, and I will tell you why, if I may take a moment.

The Federal Government requires very careful engineering analyses, and approval, and what not of personal-type aircraft, and there have been many, many cases, we all know them, of structural failures of certificated personal aircraft, such as pieces flying off.

It happens.

No matter how sure the CAA is because something has met empiric standards, that it will stay together-it does not.

Now there is a procedure which we think should be followed, which is actually followed in the case of racing aircraft. Anyone who wants to race in Cleveland has to have his ship approved. They do not care what goes into the design. They say take it up and fly it; dive it, and see how the controls work, and, if it passes that test, go ahead and race it. I do not know of a case of structural failure of aircraft used in racing. That is the proof of the pudding.

I think that aircraft which have been tested that way, by what they do rather than what the drawings indicate they might do, are a good deal safer than the other way.

The other thing is the certification of requirements, in that most manufacturers, once they have had an aircraft certificated, are very reluctant to make any change that practice indicates should be made, because it takes months and months, and thousands of dollars to get the change approved.

So, as a practical matter, and this is very unfortunate, changes that you or I would make if we had a free hand, or the manufacturer would, because it would make it safer, very rarely are made, and I can cite instances of that.

The CHAIRMAN. Does that conclude your testimony, Mr. Snow? Mr. Snow. It does, sir; and I want to thank you again for your courtesy.

The CHAIRMAN. We are very glad to have you here. You make a very good witness.

I wanted to insert in the record a letter from Wayne Weishaar, who is secretary of the Aeronautical Training Society of Washington, who was unable to be here, and who asked that his letter go into the record. It is pertinent to this subject, and if there is no objection, we will include it as part of the record. (The letter referred to follows:)


Washington, D. C., May 9, 1950. Hon. EDWIN C. Johnson, Chairman, Senate Interstate and Foreign Commerce Committee,

Washington, D. C. DEAR SENATOR JOHNSON: We appreciate greatly your telegram of May 2, 1950, announcing that your committee will conduct hearings at 11 a. m., May 11, on pending prototype aircraft legislation and inviting our organization to present testimony before that hearing. Since the notification did not reach me until May 3 due to Aeronautical Training Society holding its annual membership meeting in Dallas, Tex., that day, we were unable to have discussion of the merits in your committee's hearings. However, due to the courtesy of Col. A. B. McMullen, executive secretary of the National Association of State Aviation Officials, who provided us with a copy of S. 2984 and requested consideration of this bill on the ATS annual meeting agenda, there was general discussion on S. 2984.

Because informal surveys have indicated that members of ATS most years distribute or sell at retail 40 to 60 percent of all the personal aircraft manufactured in the United States, the consideration at the meeting was not only interested but generally well informed as to past and present problems in production of light

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