Bellanca-Champion Club
Bellanca-Champion Club
Wing Spar Airworthiness Directive:
A Review by Robert Szego
[Note: This article is reprinted from our January 2001 issue (11-1) as an editorial.
Any and all feedback cheerfully welcome at
Feedback]
AD 2000-25-02 was published in the Federal Register as a final rule the
week before Christmas.
This is the all-encompassing high-wing wood spar inspection that has been
kicking about since 1996, culminating in the 8GCBC Scout AD in 1998, now
extended to all post-war Champion 7, 8- and 11-series aircraft. The FAA
acknowledges the receipt of 'numerous' comments, but followed up with
'we do not concur'
to almost all of these, in spite of their own request for comments and
alleged high regard for the quality of same. No additional accident data was
quoted, only an unspecified number of 'wing spar damage' reports in a review of
the service history of the affected airplanes.
Some items of note:
1. Comment Issue No. 2 states
'the FAA has determined that wing damage incidents are the major cause of
compression cracks and other spar damage in low horsepower and lightweight
airplanes.. therefore a one-time inspection is acceptable...'
but give no indication of in-flight causes in
any
of the affected fleet, nor a rationale for the differentiation. Why then
impose a repetitive inspection on the rest of them?
2. Comment Issue No. 6 states
'we concur that maintenance manuals… and part 43 of the FARs specify
inspecting the wing spars… However, this existing guidance does not provide
instructions for sufficiently accessing the spar or identifying the damage.'
* As we stated in our response to the NPRM, this guidance has been available
all along, both in AC43-13-1B and ACAC Service letter 406A since May 1998. We
have been publicizing, providing and encouraging their use ever since.
3. Comment Issues No. 8 & 9
'eliminate / minimize / require the installation of top inspection covers
'. Here, at least there is no requirement to cut holes on top, but having
included them as an option with reference to the service letters has had the
effect of appearing to be mandatory; this was bought to our attention by calls
from members complaining that their IA will not sign off without it. I
understand that there are (at least) two legitimate points of view on this
point. Given the fact that they are not necessary to accomplish the task, we
strongly recommend against their installation due to the added level of risk
they impose. There has been one call indicating that the positioning of these
holes in SL417C is incorrect; we need further input on this.
4. Comment Issue No. 10
'commenter believes the cost of installing inspection covers will be
significantly greater than we [FAA] estimated.. we infer that the commenter is
referring to the additional costs associated with cosmetic paint
refinishing… Cosmetic considerations are not reflected'
. Hmm.. let's see. We only consider those costs we like, not those the owner
needs to spend in order to bring the airplane back into service without warts.
Two early estimates received by members indicate a cost almost
double
the FAA's $652 for the initial inspection. Not addressed at all were our
comments regarding the significant depreciation of these aircraft due to the
unwarranted AD.
5. Action.
'Inspect (detailed visual)
the entire length
of the front and rear wood spars'
is a major change by stealth, as the original NPRM did not include those
words. [On re-reading, SL406A says
'inspect full span along the front and rear wing spars',
but only
'traditional methods'
and applies only to the Sides/Ends portion.] How will all this be interpreted
in the field?
6. Compliance Time. Convoluted nature of this requirement has resulted in
dozens of calls to this office; our response has been to take a deep breath
first and don't rush. Seems to us this AD will not be effective until January
19th [now past us], but will not be recognized as being complied with until the
next Annual Inspection performed at least 30 days
after that.
Recap: If your Annual is due after February 19, 2001, then you must comply
at that time; if you're due before February 19th then you can wait 13 months till the next one. [This on an AD the FAA
considers to be life-threatening!] Since an Annual is not due until the end of
the 12th month since the last one, we have no idea what to say to those who try to
comply between February 1st and February 18th, except to wait until the 19th?! Wait, there's more. If you think you have already complied, since the
methods and tools have been well known for some time and you have diligently
followed both our long-time recommendations and methods pioneered by Carl
Peterson, you are wrong. If you have recently replaced your wood spars (with
new approved wood spars not metal) and had them recovered, painted and signed
off, you still have not complied.
7. Reporting Requirements. This is the clause that had us wondering; if we
have to inspect each year because the FAA has proof that they are about to
break, why this stringent reporting requirement? A skeptic might get the
impression that they are trying to justify this drastic action retroactively.
* I have come to the conclusion that the FAA is continuing on their path of
micro-managing the maintenance of aircraft through regulatory edict, with total
disregard for the input of mechanics and owners in the field. We were
hoping for a more objective review, especially in light of the large number of
thoughtful, studied and common-sense responses to the NPRM.
If you have opinions pro or con the above, we need to hear it. Your input,
both technical and conceptual helps this Club develop a good integrated case
either way, and good ideas from you will strengthen or modify our position. If
you contact the FAA directly on this issue, please send a copy to this office
as well. There is also a pretty thick skin (not to mention head) behind this
column, so don't hold back if you disagree.
Sincerely,
Robert Szego
President
Bellanca-Champion Club
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