***In my opinion, ETOPS was inacted after government regulators were “Incentivized” into reducing previous airline safety standards, which required that only airliners having 3 or 4 engines be used to transport passengers on extended over-ocean flights, and, is a pitiful and obvious attempt to justify the airlines cutting fuel, and other operating costs, in order to increase profits.

      Recently publicized engine failures on 2-engine airliners prove that, no matter how well they may be designed, built, and maintained, all man-made machines can, and do, fail, and this should be a valid concern to all safety-minded aviation professionals.

      The fact that the ETOPS program even exists, in itself, shows that regulators and airline executives are, and have been, fully aware of the dangers of these 2-engine extended overwater operations, and, therefore, the need for them to fabricate a document (ETOPS) which they hope will cover their asses in case a catastrophic ocean ditching of a 2-engine airliner, loaded with passengers, should occur, after an engine failure(s).

      In spite of its professional image, all ETOPS really does, at the obvious “Request” of various airlines, is to systematically and gradually increase the over-water time and distance from land restrictions, that 2-engine airliners are allowed to carry innocent and non-aviation knowledgeable passengers.

***(From the original 500 miles, and 1 hour from the closest land, at the inception of ETOPS, to the now greatly increased distance of many thousands of miles, and, 5-6 hours from land, (at the reduced single-engine airspeed of only about 250 MPH.)

***However, because ETOPS certification is based on the time required for a 2-engine airliner to reach land with only 1 operating engine, and, because of the very uncertertain speed and performance capabilities of these large 2-engine airliners, after the failure of 1 engine, (as described in the attached NTSB Report), I believe that many long-haul over-water flights, particularly the 2500 mile over-ocean flights to Hawaii, may exceed even the most liberal mileage and flight time extensions/limits/allowances of ETOPS.

***Because of unforseen and/or unanticipated aerodynamic and vibration problems, such as occurred on United Airlines Flight #1175, after the falilure of 1 engine, while enroute from San Francisco to Honolulu, (as described in the previous linked Homepage document titled "14 page NTSB Report") or, because of many other unanticipated and unforseeable circumstances, the actual 1-engine airspeed of a large 2-engine airliner may be undeterminable, and could be much less than 250 MPH, which would greatly increase the time required to reach the closest land with only 1 operating engine.

***Therefore, this uncertain single-engine airspeed of these huge airliners, and, their uncertain abilitiy to maintain altitude with only 1 engine operating, as described by Captain Behnam of UAL Flight #1175, nullifies, and renders the entire ETOPS program as worthless nonsense.

***Captain Behnam stated that, because the circumstances which occurred on UAL # 1175 were never anticipated and never trained for, the training manual was usless.

***Therefore, as stated above, many of these ETOPS certified trans-oceanic flights, particularly the Hawaiian Island flights, and, because of the very uncertain speed and flight capabilities of these very large 2-engine airliners, after the loss of 1 engine, may far exceed even the most expanded and leniant time/distance-from-land requirements of ETOPS, as described above.

***With so many unknown variables possible after an engine failure on an airliner having only 2 engines, in my opinion, only incompetant, aviation ignorant and incredibly greedy airline executives, and/or, corrupted government regulators (Seeking political "contributions"), would risk the lives of airline passengers and crews based on an aircraft manufacturer's stated, and sales-motivated, single-engine performance figures, which were determined under ideal and/or controlled flight conditions, and, which apparently and conveniently overlook the unforseen and unanticipated circumstances which resulted in UAL Flt. #1175 being unable to maintain altitude with only 1 operating engine.

***Therefore, these Hawaiian, and other over-ocean flights, may be operating in violation of even the extended ETOPS time/distance limits, and, therefore, may be illegal, in addition to being unsafe.

***The many unknown variables, which could occur on an airliner, all alone, and many hours away from land, are the reasons why previous FAA regulators, who may have been more concerned with the safety of airline passengers than current FAA regulators, required that airliners, crossing vast ocean expanses, have at least 3 or 4 engines, in order to increase the ability of these airliners to maintain extended flight after engine failure(s), and/or, other unforeseen and unanticipated problems.

***Although these federal agencies are aware of the obvious risks of using airliners having only 2 engines on extended over-ocean flights, these dangers are, apparently, being "Overlooked" by the FAA and NTSB, which, in my opinion, appears to be another improper, negligent, and possibly criminal accomodation, made to the airlines, in order to enable these airlines to reduce their operating costs, and increase their profits, regardless of the dangers to the flying public.

**(Several decades ago, the University of Chicago economist George Stigler pointed out that the problem with regulation is that the regulatory agencies are sooner or later captured by the regulated industry and become servants of the industries they were created to regulate.)

***From Wikipedia – “Dick Taylor, then Boeing's director of engineering, approached FAA Administrator J. Lynn Helms in 1980 about the possibility of an exemption to the 3 or 4 engine FAA requirement.

** Mr. Helm's famous response was "It'll be a cold day in Hell before I let twins fly long haul, overwater routes".
**Therefore, according to Mr. Helms, who was a very experienced pilot, the opinions expressed in this report are not conspiracy theories, but, were shared by the highest level FAA officials of the past, who may have been more responsible, more safety minded, and, less concerned with accomodating business interests.

**The world’s oceans are certainly just as vast, cold, and deep, today, as they were during the FAA Administration of Mr. Helms, and, engine failures continue to regularly occur today, just as they did in the past.

      In spite of the many recent reports of engine failures, which are obviously well-known in the aviation community, ETOPS, nevertheless, is intended to give “Cover” to airline executives, the NTSB, the FAA, and other regulatory agency personnel, by deceptively implying that the existance of this fabricated and obviously bogus ETOPS program will shield these airline executives and government regulators from the responsibility and consequences of their dangerous cost-cutting policies.
***Incredibly, these airline executives and federal regulators have, apparently and conveniently, and, contrary to logic, convinced themselves that the nonsense contained in a paper document (ETOPS), can, by itself, artificially increase uncertain aircraft performance capabilities, reduce the number of aircraft engine failures, and, should a catastrophic airliner ocean-ditching occur, relieve them from responsibility.

      ETOPS attempts to convey that certain “Higher maintenance and other standards” on ETOPS over-water certified airplanes, can eliminate or reduce the possibility of engine failures.
***This implies that non-ETOPS commercial airliners are maintained and equipped to a lower standard.
***However, if the quality of maintenance “Standards” can be increased in order to reduce the possibility of engine failures on ETOPS over-water certified airplanes, then, we must ask why these higher standards aren’t applied to all aircraft engines, and, not only to ETOPS over-ocean operations.

***The original requirements, necessary for an ETOPS certification, required that an advanced rated aviation mechanic perform an extra maintainence check on an airliner immediataly before this airliner was about to fly an extended over-ocean route.

***I believe these additional required aircraft inspections, (No longer required -see below), show that the FAA, the NTSB, and, the airlines, are, and have been, fully aware, from the very beginning, of the dangers of these 2-engine extended over-ocean airliner flights, and, the need for these special and unusual additional inspections.

***However -- From recent FAA ETOPS Documents - - - - - - "We find that, because of the lack of enough qualified mechanics, these pre-flight inspections are impracticable because these regulations, as currently written (Pre-flight inspections) are overly burdensome on the airlines" ---------------- "ya right".

***So, as another concession to the airlines, the FAA, once again, has elimated its own previously required pre-trans-ocean flight inspection, the existance of which was originally used to justify and sell the 2-engine ETOPS program.

      From ETOPS -  “It must be demonstrated that, during the single-engine diversion flight, “That the probability of the remaining engine failing is extremely remote”, and, that the flight crew “Is not unduly burdened by extra workload due to the lost engine” ? ? ?.

      UAL Flt. #1175 (see: Youtube Video "UAL #1175 fan blade out interview" -noted on NTSB Report - linked on Home Page), did, in fact, have an extra third pilot on the flight deck, (not normally present), who proved to be essential and indispensable in assisting the normally 2-pilot flight crew in successfully completing this flight, after the engine failure, and, after some other unanticipated aerodynamic problems which severely challenged the airplanes single-engine capabilities.

***So, in regular operations, without this third pilot, would the crew of UAL #1175 have been “Unduly burdened”? ? ?

      These are obviously ridiculous, deceptive, pitiful and desperate CYA statements, as one would hope that regulations on all commercial flights, whether over water or land, would require the same high maintenance standards as ETOPS certified over-water aircraft, and that the “Probability” of an engine failing is equally remote in all airline operations.

***How could anyone determine that an aircraft jet-engine, regardless of age, and, which operates continuously, and for many hours, under tremendous stresses and temperature extremes, has a lower probability of failure than any other aircraft engine ???

      An absolutely absurd statement as any man-made machine can fail at any time, proven by the many recent engine failures which have occurred on ETOPS certified airliners i.e. United Airlines flights #328 and #1175, and others.

***The ETOPS fallacy that engine failures, on 2-engine airliners, are more serious over water, than they are over land, and, therefore, these engines require a higher standard of maintenance, is blatantly false.
***An engine failure, on a 2-engine airliner, during the first few seconds after lift-off, can be just as serious, or, can have even worse consequences, as an engine failure over water.

***Pilot’s practice engine failures, on take-off, regularly, but, without the unexpected aerodynamic problems, severe vibration, extra drag problems, and engine instrument failures, which had confused the pilots of UAL Flt. #1175 as to what had actually happened to the airplane, and, delayed their response to the engine failure for 30 seconds. (see: enclosed NTSB Report-UAL #1175- YouTube video))

***Because of these unanticipated problems, which had never happened before, the pilots of UAL #1175 reported that there was no way they could have been given training on the problems that had occurred on this flight. (They had to "Wing-it")

***Fortunately, UAL Flt. #1175 was cruising at high altitude when the engine failure occurred and the pilots had the extra time and sufficient altitude and airspeed to analyze and troubleshoot the problems.

       An engine failure occurring immediately after lift-off, however, would give the pilots no such precious time, altitude, and airspeed, and, regardless of any unanticipated aerodynamic problems, possible pilot stress, fear, or fatigue, which may be present, or, any other pilot confusion, hesitation, or delay, which may occur, as happened on UAL Flt. #1175, would, nevertheless, require immediate, split-second, and flawless pilot reactions, in order to enable an airliner, close to the ground, and, heavily loaded with passengers and fuel, to continue to climb with only one operating engine, and, with only one-half the normal take-off power.

      Therefore, although a properly loaded 2-engine airliner should be able to continue its take-off after an engine failure, stress induced pilot mistakes or delayed reactions, or, many other unanticipated problems, which could occur following an engine-failure during the first critical 15-20 seconds after lift-off, could cause a catastrophic accident to occur on take-off, regardless of the airplanes single-engine climb capabilities and pilot training.

***In adition, should the departure airport be located in a metropolitan area, a serious crash would be fatal, not only for the passengers aboard the airplane, but, also, for people living below the aircrafts flight path, making an airplane crash, over land, actually a greater potential catastrophe than an over-ocean crash.

***For the above, and many other reasons, the engines on every airliner, regardless of the manufacturer, and regardless of the the routes to be flown, should be maintained to the highest quality and reliability standards as is humanly possible to obtain.

***Therefore, in my opinion, the ETOPS statement, that ETOPS certified engines, used on extended over-water flights, will be maintained to a higher safety standard than non-ETOPS certified engines, is - - - - stupid.

      ETOPS is an obvious attempt to justify the un-justifiable, and, should a 2-engine airliner carrying many hundreds of passengers, including many children and infants, be forced into a catastrophic ocean ditching, in order for these airlines to cut expenses, (imagine a night ditching), and, because airline executives and government officials have been fully aware of this obviously dangerous and irresponsible policy of allowing 2-engine airliners to cross vast ocean expanses, and, which is perpetuated on innocent, unknowing, and trusting airline passengers, a catastrophic airliner ditching, caused by this deliberate reduction of airline safety standards, would certainly result in the financial ruin of the affected airline, as happened to TWA, after their Flight #800 New York City disaster, and to PanAm, after their Flight #103 Lockerby Scotland disaster, (Although these incidents were not caused by airline mis-management).

***Therefore, in my opinion, if the Boards of Directors of the affected airlines were really concerned with the longterm welfare of their stockholders, they would never allow this reckless and dangerous 2-engine over-ocean airliner policy.

*** Regarding the Hawaiian flights, the catastrophic ocean-ditcing of an airliner, filled with tourists, believing they were on their way to a vacation in Paradise, would certainly have a devastating affect on the future Hawaiian economy, and, therefore, probably would, and, in the opinion of this writer, should, result in the criminal prosecution of all involved, including these airline executives and government regulators who permitted, and carried out, these dangerous cost-cutting practices.

***Therefore, in the opinion of this writer, by the airlines ignoring this obvious risk to the tourist based economy of the Hawaiian Islands, and, in order to cut their operating costs and increase profits, these airlines, especially Hawaiian Airlines, (Which is the "Flagship" airline of Hawaii), are showing a great amount of self-interest, and, disregard for, not only the lives of their passengers and crews, but also for the welfare of the citizens and businesses of Hawaii.

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