AIR FRANCE 447-A VERY SCARY AIRPLANE CRASH

June 3, 2009 Comments off

Air France Flight 447 is down. Sadly, it is expected that all 228 aboard are lost. The earmarks are all too familiar. Severe weather and a loss of radar contact usually mean in-flight break-up and rapid descent. This would, of course, explain the lack of a distress call and automatic reporting of electrical failure and significant turbulence by the onboard real time condition reporting system.

The aircraft went down in an area called the Intertropical Convergence Zone (see picture above). This is an area where the Northern and Southern hemisphere winds and weather collide to make a perfect condition for severe convective weather. That means severe thunderstorms frequently exceeding 50,000 feet with damaging turbulence, hail, intense rainfall and lightning. On the night of the crash, this area was especially hot with thousands of miles of severe weather making circumnavigation impractical.

Therefore, the only way to get from Rio to Paris was to penetrate this band of severe weather, a daunting task for even the best aircrews flying the most sophisticated airliner. There is no coincidence that shortly after entering this area of severe weather the aircraft was lost. Whether it was due to an encounter with severe turbulence or a lightning strike that exploded a fuel tank can best be determined when the wreckage is found, and surely it will be one day.

The cockpit voice and flight data recorders will also be very helpful but the automatically transmitted data already portends the turbulence, electrical anomalies and tragic end. This is why cockpit voice and flight data recorder information should be transmitted real time to home base.

Coincidentally, an Airworthiness Directive had been issued in 2005 by the French authorities requiring float valve changes in the trim fuel tanks of this aircraft model’s horizontal stabilizers. The purpose was to avoid lightning or static electricity setting off an explosion in those tanks. The compliance time was quite lengthy and, while this aircraft was built in 2005, it is not clear whether it had the benefit of the improved floats. If it didn’t, or the fix was ineffective, a lightning strike on the trim tanks could have been a catastrophe that even the best crew would have been unable to avoid.

It is, therefore, quite possible that the old problem of airliner exploding fuel tanks has reared its ugly head again. While better fuel tank standards have been published and bantered about the industry and governments since TWA 800 exploded in 1996, none of the legacy airplanes have benefited from the new standards and this Airworthiness Directive, which aimed to chip away at the problem.

Aircraft radars have come a long way, providing flight crews with far better weather avoidance information than ever before. Unfortunately, weather avoidance is not weather penetration, but the demands of airline flying and schedules often blur the difference.

Avoidance means not going there, penetration means getting into it and avoiding the damaging weather by skillful use of the radar. The letter works most of the time but not always. Aircraft and human graveyards are full of the results of severe weather penetrations because there are limits on even the best radars. Intense rainfall absorbs signal strength and confuses returns, intense cells hide others just behind and give a false sense of security that safety is just a few miles away, when the worst may be yet to come.

Last year a computer failure pitched an identical aircraft so violently, the crew thought there was a clear air turbulence encounter. The manufacturer said it was impossible and could not have occurred. Later it appeared that indeed the impossible could happen. One out of many computers could cause a dangerous and sudden pitch excursion that might have led to structural failure. That must be ruled out in this case. While turbulence may have been the initiator, computer failure may have increased its lethality.

No one wants an accident. No one deliberately tempts an accident with a planeload of families in the back and pilots who likewise want to get home alive up front. Indeed, they are the first to go. But whether this accident is the result of mechanical failure, the failure to simply remain on the ground in the face of impassable weather or the unlikely act of a saboteur, it is nonetheless the worst of nightmares come true.

Weather. Mechnical failure. Equipment malfunction. It looks like any one of these may have played a role. Whatever the ultimate cause, with today’s technology there is no reason for an airliner accident. With the prospect that this single field of human endeavor may one day be accident free, these deaths must not be in vain.

Stop Faulting the Flight Crew for the Crash of Colgan 3407!

May 12, 2009 Comments off

The flight crew was blameless for this crash and everyone investigating the crash knows it. It’s just easier to blame the dead crew than to blame the manufacturer who failed to equip this airliner with modern anti-ice equipment. The airplane suffered a tail stall as soon as the flaps 15 setting was selected and the crew did what they were taught – they reversed the procedure and retracted the flaps.

The captain, in spite of the hideous criticism for having nonessential conversations below 10,000 feet, was otherwise professional and all required briefings were carried out.

The aircraft pitch up and airspeed loss has occurred dozens of times in Cessna Caravans just before control is lost in ice. It is a pitch up when the tail loses its ability to provide required down force due to ice contamination. The airspeed bleeds off rapidly and the stick shaker and pusher react. The crew knows that the standard recovery of lowering the nose won’t work so they pull back like they were taught. Lateral control is then lost, followed by pitch control as well.

This aircraft was never certified to fly in freezing drizzle or rain and the crew, like every other airline crew, was misled into believing it was. No one is told that if the conditions are anything other than moderate – clear or rime – the airplane cannot fly. The use of outdated rubber boots, which allow the ice to accumulate before activation, aggravates the situation and just leads to trouble.

It is true that the captain was not the world’s best pilot and the first officer was a kid. Their training stunk and their non-pertinent discussions below 10,000 feet demonstrated poor judgment. However, the transcript from the cockpit voice recorder, read in context, reveals that nothing in their past or their conduct on that flight caused this accident.

No one should confuse legal liability for a crash with blame placed by investigating authorities. Legal responsibility belongs to Continental, Colgan, Pinnacle, and Bombardier and they will pay for all the losses. Blaming this crew is a hideous attempt to hide the truth. Airplanes with deicing boots no longer have a place in commercial aviation.

Pilatus PC-12 Crash Stinks

March 23, 2009 Comments off

Fourteen people killed in an aircraft that can only carry 10 has the stench of carelessness all over it. Most PC-12s can safely hold only six to nine passengers and one or two pilots. Why were there so many aboard and where were they seated? These youngsters and adults were going skiing. Where was the baggage and where was it stowed? How much did it weigh? Why did the aircraft divert? What were the qualifications and experience of the pilot? Was there a second pilot aboard?

These preliminary answers are needed to explain why this aircraft fell out of the sky nose down before several eyewitnesses. Did it aerodynamically stall because it got too slow on final approach? Did it accumulate ice when flying at altitude and suffer a tail stall when the final flaps were selected? The weather at the accident site looked good but there was an area of significant icing en route. Did the engine quit as it has a number of other times in PC-12s, dooming the aircraft to a crash short of the airport?

My calculations show that to stay within the gross weight limits, the pilot could only have put about 160 gallons of fuel aboard, less than what is required for a two and one-half hour flight plus reserves. The payload of a PC-12 is about 3,900 pounds. Seven adults weigh a minimum of 1,300 pounds. Seven children weigh about 500 pounds minimum. Baggage is figured at about 1,000 pounds total which includes skis, boots, poles, clothes, etc. Together, that comes to 2,800 pounds, leaving about 1,100 pounds available for fuel or about 160 gallons.

The flight plan was for two and one-half hours en route which, together with required reserves, would have left very little useable fuel at the time of arrival and would have explained the diversion to a closer airport. Essentially the National Transportation Safety Board needs to look at whether the fuel was managed properly, or whether the engine quit on a short final approach with the fire coming from unusable fuel that misted or perhaps there was more unusable fuel than certified.

Other questions must also be answered. Some of the equipment on board may have had a nonvolatile memory chip that could be helpful but the fire and impact may have destroyed that forever.

The PC-12 like so many other turboprops has deicing boots that inflate to remove accumulated ice. These boots have proved inadequate in many other turboprops and if runback ice accumulated on the tail or on the wings at altitude and could not be shed, the extension of flaps might have shifted the center of lift aft and caused a tail stall which would have pitched the nose down sharply as described by witnesses. Coming on the heels of Continental flight 3407 at Buffalo for similar reasons, it is long overdue that turboprops be prohibited from flying in icing conditions until they all are retrofitted with anti-ice instead of deice equipment. That way ice is not permitted to accumulate at all on aircraft that have proved time and time again their inability to fly in icing conditions safely.

This crash like most will be found to have been preventable and unnecessary. How horrible for these parents and their families!

Why Turboprop Aircraft Shouldn’t Fly in Ice – The Continental 3407 Crash Reminds Us of Long-Forgotten Lessons

February 13, 2009 Comments off

Continental 3407 is just the most recent example of why turboprop passenger aircraft are unable to safely fly during icing conditions.

The American Eagle ATR 72 in Indiana, the Embraer 120 in Michigan, and some fifty Cessna Caravan crashes, all demonstrate the need to reassess whether turboprop aircraft, all equipped with long outdated and discredited deicing boots for ice protection, should be permitted to be dispatched when the weather looks like ice might be experienced, as in winter clouds.

All of these aircraft have wings that have high aspect ratio, meaning they are long and thin from front to back. All of them have tiny horizontal tails and use deicing technology rather than anti-icing technology to be certified for flight in known icing conditions. In short, the manufacturers of each of these aircraft convinced their certifying authorities to approve the aircraft to fly in weather conditions conducive to the formation of airframe icing because their deicing boots (inflatable rubber boots on the leading edges) could discharge enough ice to allow them to continue flying safely.

The reality is that large airplane manufacturers gave up deicing boots fifty years ago because they knew that they don’t work effectively. By design, deicing boots assume that ice will be allowed to collect on the wings and tail of the airplane and then be shed when the boots are inflated. The flaw in that theory is that most boots do not shed all the ice; in fact, residual ice continues to build, further impeding their performance until they just don’t work well at all. Additionally, deicing boots are usually limited to five percent of chord – the distance from front to back of the wing – so runback icing which collects beyond the boot coverage is unaffected by boot inflation.

Why do turboprops use boots? Simple. Turboprop manufacturers have been slow to utilize state-of-the-art anti-icing technology like heating the leading edges of the wings or extruding glycol from the leading edges (which then runs back and keeps the wings free of ice). To heat the leading edge, one must extract heat from the engines, compromising power and increasing fuel consumption. Also, many turboprop engines just don’t have enough bleed air to use for this purpose. The TKS, or glycol system, requires plumbing, a wire mesh leading edge that needs frequent cleaning as well as glycol, which increases the aircraft’s weight.

This age-old problem is what took Continental 3407 down. The weather from a warm front that had overridden cold air at the surface consisted of rain that was falling into the cold air and becoming SLD, super-cooled large droplets. These drops, still liquid but below freezing, immediately turn to ice when they touch a cold surface like an aircraft wing or tail and then run back past the boot coverage, contaminating the airfoil and destroying its ability to create lift. What pilots are not told is that no aircraft is certified to fly in freezing rain or drizzle so if they are dispatched in such weather, they are test pilots.

In most instances the exposure to SLD is brief but for Continental 3407 it wasn’t brief enough. It encountered freezing rain, and as a result, accumulations of ice on the wings and windshield, a condition which was discussed by the crew. They activated the deicing equipment and fully expected it to take care of the encounter. What they didn’t know was that the aircraft was never certified or equipped to handle freezing rain or drizzle and that ice was collecting on the tail, aft of the boot coverage, which they could not see.

As they descended for their instrument approach, the crew was unaware that another danger awaited, the extension of their wing flaps. With the flaps up, the tail was barely able to exert a down force on the aircraft sufficient to keep the nose where the crew directed it. Once the flaps and landing gear were extended, however, the tail would have to counteract the tendency toward a down nose pitch caused by those extensions. It simply could not do that as a result of the ice contamination. Just as soon as the flaps were extended, the load requirement on the tail increased, it stalled, quit flying, and the nose of the aircraft pitched suddenly down. Ice on the wings aft of the boots rendered the ailerons less effective in controlling roll, and the aircraft rolled violently as well. The crew immediately attempted to retract the landing gear and flaps, just as they were taught to do, but they had insufficient altitude to recover and insufficient elevator authority left in the tail to arrest the steep pitch down. The aircraft struck the ground in a near vertical attitude, perhaps flattened at the last moment due to the flight deck crew’s quick thinking to retract the flaps. However, it was insufficient to arrest the descent and all aboard were killed instantly.

This accident was a duplicate of the ATR-72 and Embraer accidents of years ago and similar to many of the Caravan crashes as well.

What do all these aircraft have in common? They all have deicing boots instead of anti-icing equipment. While many of the Caravan crashes have occurred in very benign icing environments, deicing boots have repeatedly shown their inability to safely see an aircraft through winter flying conditions that can be anticipated. The accident rate and its toll on human lives are simply unacceptable. The manufacturer of the Dash 8 Q400 that was Continental 3407 knew better than anyone that boots were wrong for aircraft of this size and use. It doesn’t use boots on any other aircraft it manufactures and for good reason.

Likewise Continental knew, or should have known, that it was dispatching Flight 3407 into freezing rain and drizzle and its aircraft was not certified for that flight condition. More likely than not, Colgan Airways, the Continental contract carrier operating the flight, was likely told the Dash 8 could operate in all winter weather that could be anticipated. In fact, it simply could not.

The NTSB will investigate and the Canadian Transportation Safety Board will participate. The result will be long and expensive studies into icing once again. That’s what governments do – they study, study and re-study but they do not fix the problem. The fix is simple. Restrict the flight conditions under which turboprops can be dispatched. They are already restricted, but obviously the airlines don’t yet get it. Then re-equip all turboprops used for passenger transportation with more effective anti-icing equipment. Lastly, prohibit the extension of flaps for any landing where accumulations of ice are suspected on the aircraft. Turboprops, and especially booted turboprops, have no place any more in the transportation of people. Their time has come and gone. Good riddance!

HAWKER 800 Crash in Minnesota – Cockpit Voice Recorder Transcript Released

February 13, 2009 Comments off

The NTSB just released a transcript of the cockpit conversations of the captain and first officer of a crash that took their lives and six others in Minnesota last summer. There were no surprises here. The flight crew flew into an area of very severe weather with the airport literally surrounded by thunderstorms that reached as high as fifty thousand feet and had spawned at least one tornado. They experienced turbulence and heavy rain as they approached the airport, which had a wet runway from a recent very heavy shower.

The crew violated the sterile cockpit rule – no non-pertinent conversation below ten thousand feet, distracted themselves by fooling with the radar tilt when they had the runway in sight, and failed to properly conduct both the approach checklist and the pre-landing checklist. Worse yet, they failed to extend full flaps, dooming their flight. Without full flaps deployed they could not activate the lift dump feature in the Hawker jet, an absolutely mandatory condition if they ever hoped to luck out and stop on a runway that was too short for this aircraft under those conditions.

The lift dump system extends spoilers both above and below the wing. Without it, the airplane doesn’t place enough weight on the wheels early enough to spin them up and allow the anti-skid equipment to work. In fact, with the engines at idle thrust, an attempted go-around was futile given the normal time it takes for a crew to react and change the aircraft configuration.

As in most aircraft accidents, there is more than one cause. Anxiety over the weather, the rough ride, the short runway, the non-pertinent conversation, and the failure to complete the checklist all combined to doom this flight. The failure to anticipate the heavy weather, the effect of water on the short runway, the inability of the aircraft to safely operate within the available runway contributed to poor decision-making by this crew. Sadly, even a crew that is well trained, skillful and has the best of intentions also becomes the victim of a combination of events that only they could avoid – a chain that must be broken if they and their passengers are to survive. It didn’t happen, and they too paid with their lives.

Every pilot talks about the near accident he has had with the bravado that only a hero (in his own mind) can bring to the discussion. The problem is that if the stars line up and the events build in an inexorable combination of troubles, one day those pilots won’t be able to tell their story. No doubt these pilots were careful, decent, well-intentioned men. Unfortunately this disaster began with faulty pre-flight planning, faulty appreciation of the heavy weather that would be at the destination, faulty cockpit crew coordination that led to the careless skipping of what for this airplane was critical to a successful landing, full flaps.

This accident will mean nothing if it doesn’t serve as a lesson to all pilots that the Federal Aviation Regulations, known as operating rules, are minimum standards. That means that even if they are complied with to the letter, they may not be enough to successfully complete a flight. The failure to meet those minimum requirements, however, is a virtual guarantee of an accident.

Regardless of what position The Wolk Law Firm must take in the litigation for the deaths of the passengers that follows this accident, all of us, including the families of those passengers who have suffered unspeakable losses, lament the unnecessary deaths of everyone aboard.

The FAA Still Doesn’t Get It

February 3, 2009 Comments off

The FAA Still Desn’t Get It — The Boeing 737 Still Needs A Reliably Redundant Rudder

In the face of sweeping NTSB Safety Recommendations with respect to modifying the Boeing 737 rudder system with one that is reliably redundant, the FAA’s response is, “We need to get to the Board about what that [term] means.” That’s scary!

The dictionary defines reliable as “consistent and dependable”. That same dictionary defines redundant as “exceeding what is usual or necessary and supplied as a backup”. In other words, what the 737 rudder system needs, according to the NTSB, is a consistently dependent duplicate system or backup.

Statements made by the FAA in response to the Safety Recommendation are frightening. For example, the 737 is the only air carrier airplane that was designed with a single panel rudder controlled by a single actuator. The FAA said, “You want to hesitate about changing something such as the rudder system on an airplane…. What scares us regulators is the possibility of introducing an unintended safety risk.” In the face of two and possibly three airplanes that have rolled on their backs and crashed, killing hundreds of people, the FAA is scared about fixing the airplane, it complains.

What is even more scary, is the FAA’s comment that, “In this 737 PCU it takes two jams internally to get hardover.” What’s frightening about it is that it demonstrates that thirty years after the 737 certification, and eight years after United 585 came crashing into the ground in Colorado Springs, the FAA still doesn’t know that it only takes one jam in the rudder servo valve to cause a reversal or hardover, which can’t be controlled by the flight crew.

Either the FAA can’t read, write or understand plain English, or it doesn’t understand hydraulics, or perhaps it simply doesn’t want to understand it because it would look so guilty for the unnecessary loss of life that it alone allowed to happen by ignoring its certification responsibilities.

Part 25 of the Federal Aviation Regulations required then and requires now that there be a redundant control system for the rudder, and that other flight controls be able to overcome a single failure in the rudder control system. Neither was true with the Boeing 737, and the FAA ignored it in certification, ignored it when problems cropped up in the field and before there was a fatality, and still ignored it after there were multiple fatalities.

Indeed, even after there were two and possibly three 737 crashes due to rudder control system failures, the FAA certificated an entirely new generation of Boeing 737s with a single rudder actuator design. There is a point below which incompetence becomes inexcusable. We’ve reached that point.

The old adage “Close enough for government work” should no longer be the standard to which the FAA aspires. Shame on the FAA!

Continental Airlines Crash Update

January 1, 2009 Comments off

Continental Airlines Crash Update – The Spin Doctors Take Over

The latest from the Continental Airlines B-737 accident at Denver is the claim that a sudden gust of wind caused the aircraft to swerve off the runway. So, a pilot with 11,000 hours of flying time and a very experienced first officer couldn’t do a successful crosswind take-off in one of the simplest of all airliners? Not!!!

These same spin doctors said the B-737 accident at Colorado Springs in 1991 was caused by a sudden, theretofore never heard of, wind shear in the form of a rotor that rolled down the mountainside, followed the aircraft around the traffic pattern and rolled it over, killing 25 people.

The spin doctors were out in full force again when USAir’s B-737 rolled over and dived to the ground, killing 133 more people near Pittsburgh in 1994. Then they said that wake turbulence (a wind gust from a preceding aircraft) miles away rolled the aircraft up into a ball.

Following that, it was a faulty connection to a pilot’s altitude indicator that rolled a B-737 into the ground in Panama, though the broken wire had nothing to do with that instrument’s function, it was later learned.

Oh, and of course, it was a pilot’s suicide that caused another 737, this time in Indonesia, to roll in from altitude, killing all aboard. The co-pilot on that one was either in the lavatory or reading the paper, I guess.

Here’s the deal. The current National Transportation Safety Board (NTSB) is more incompetent, or politically too sensitive, than the NTSB that existed in 1991 to 1994. The government needs to throw out all the party participants like the airline, pilots’ union and manufacturers and bring back some of the investigators who reluctantly accepted my findings, and those of other experts, and concluded correctly that the rudder is the problem. While the rudder may be blameless on this one, a sudden gust of wind sure in hell wasn’t the reason for this crash either.

Continental 737 Crash at Denver

December 22, 2008 Comments off

Continental 737 Crash at Denver–Better Look at the Rudder

Yet another Boeing 737 crashes, but this time no one was killed. The flight crew masterfully rejected a takeoff that went wrong. Loud noises were heard that were reminiscent of the sounds identified just before domestic flights on United 585 and USAir 427 rolled over and dived to the ground, killing a total of 152 people in 1991 and 1994 respectively, and overseas airlines COPA 201 and SilkAir 185 crashed, taking the lives of another 151 people in 1992 and 1997.

If I were the NTSB investigator in charge, I would pull the rudder actuator and take some SEM photographs to see if the actuator bears a resemblance to the three other actuators that showed witness marks of jamming.

In my opinion, the Boeing 737 still does not have a reliably redundant rudder control system, and even after hundreds of deaths, the FAA allowed Boeing to build an entirely new generation of B-737’s with a single rudder actuator when all of its other aircraft have at least two.

Noises heard on earlier cockpit voice recorders were the death sounds of an aircraft about to go out of control. These sounds are generated by the hydraulic system telegraphing its agonizing inability to control the rudder. At speeds below 190 knots, the rudder will cause a rapid roll of the aircraft that cannot be stopped before tragedy occurs.

While redesigned after the accidents of the 1990’s, the rudder control system still has no true redundancy. If the flight crew of this aircraft sensed that they were about to lose directional control, they saved themselves and all their passengers from certain death.

The airplane is trashed and some people were hurt, but everyone will ultimately go home to their families this Christmas. Congratulations to a “heads up” Continental crew.

Madrid MD-82 Crash, Déjà Vu

September 18, 2008 Comments off

Two decades ago in Detroit Michigan, Northwest Airlines Flight 255, an MD-82, crashed on takeoff, killing all aboard except for a toddler. The crew had failed to extend the wing flaps and the takeoff configuration warning was disabled due to lack of electrical power to the device, so no warning was sounded.

Now it appears that first witness reports about an engine explosion on Spanair MD-82 upon its takeoff in Madrid, Spain on August 20 were in error. Instead, investigators have found that the plane did not have its wing flaps deployed when it stalled and crashed to the runway killing 153 of its 175 passengers and crew. Once again, it appears that the crew failed to extend the wing flaps, thus ignoring that item on the pre-takeoff check list. The cockpit voice recorder should confirm or deny whether the crew announced the need to set flaps for takeoff.

Typically, takeoff configuration warnings do not sound because they have been disabled due to frequent false warnings. A warning system is useless if it frequently malfunctions because flight crews will just ignore the warnings as unreliable. On the other hand, pre-takeoff check lists, which include challenge and response by the flight crew working together, should have resulted in proper flap extension. It has not yet been determined why the takeoff warning on the Spanair aircraft didn’t work and it was never determined why it didn’t work on the Northwest aircraft more than 20 years ago.

The flight path of both the Northwest and Spanair aircraft are eerily similar, with the nose seen coming up to takeoff altitude, followed by an aerodynamic stall resulting in a rapid descent to the ground with a large loss of life.

The fact that Spanish investigators heard no takeoff configuration warning on the cockpit voice recorder is just a “same-old, same-old” repeat of the well-known adage that aircraft always telegraph their intention to fail long before an accident. This problem has been around for at least 20 years and obviously a fix has not been ordered by the FAA, the agency responsible for ensuring aircraft safety.

It is hideous that the manufacturer hasn’t fixed this known fatal flaw that has now taken hundreds of lives.

Criminalization of Air Disasters

September 9, 2008 Comments off

Nothing good comes of criminal prosecutions following air disasters. While such proceedings may satisfy the public’s zeal to punish those responsible, the result is that the flow of information necessary to correct aviation problems dries up over the long term because of the fear that such information will be used for criminal prosecution in the event of accidents.

It is bad enough that manufacturers and airlines now hide what they do, or more importantly what they don’t do, in an effort to escape civil liability for accidents. Criminalization has always been fraught with the specter of witnesses using their Fifth Amendment rights not to incriminate themselves (which has the effect of impeding investigations that might result in safety improvements).

Moreover, public authorities, whether prosecutors or public investigators, do a terrible job at investigating aircraft accidents and are too often the tools of manufacturers and airlines. Plaintiffs’ lawyers do the majority of aircraft accident investigations in the United States and spend far more, examine more intensively and extensively, and take sworn testimony more often to get to the bottom of these accidents. Criminalization will impede, not enhance, these efforts. What we need is more zealous sanctions when airlines and manufacturers hide information from the certifying authorities, distort warnings received from the field and flat out lie during civil proceedings. We need fewer judges who are selected for their promise to deter plaintiffs’ lawsuits; we should go back to hiring judges based on their demonstrated lack of bias and predilection.

This issue has been around for years and is most often discussed in countries where civil litigation does not exist the way it does in the United States. Where there is no suitable vehicle to get to the truth civilly, criminalization is the fall-back position taken out of frustration. The real solution is to expand civil litigation systems in countries that don’t currently have them so that safety is enhanced rather than deterred by the regressive effects of criminalization.

Arthur Alan Wolk