Strut Airworthiness Directive (AD) (merged VI)

[N74DV]

Re: Strut Airworthiness Directive (AD) (merged III)

if it hasn't already been posted, here's the link to view the comments on the docket. I see some familiar names have already commented

http://dms.dot.gov/search/searchResultsSimple.cfm?numberValue=28478&searchType=docket

On the same site is instructions on how to file your own. I will be entering my comment today and all of you should do the same.

PLEASE FILE A COMMENT!

[Ragwing nut]

Re: Strut Airworthiness Directive (AD) (merged III)

I just submitted by review. It have been longer but was pressed for time

mike

[Victor White]

Re: Strut Airworthiness Directive (AD) (merged III)

I think this AD goes to unnecessary extremes; putting undo hardships on Taylorcraft owners. Once the struts have been found to be rust-free and in airworthy condition, it is unreasonable to re-inspect every 24 months; struts that have been in service over sixty years, have not had an in-flight failure (even struts that have been outside in harsh weather!) A rust-free-strut will not rust to unserviceable limits, within 24 months; especially, after being treated with corrosion inhibitor.
Everyone should have their struts inspected, true; BUT it would be easier if we could use the same method as the Piper strut inspection. This inspection has proved to be very effective, over the years. We Taylorcraft Owners wonder why we cannot use the same process.

Vic White

[cpirrmann]

Re: Strut Airworthiness Directive (AD) (merged III)

I agree. More and more I'm inclined to the experimental route. I can get better performance, better safety, more up-to-date method, materials and equipment, and I can get from under the thumb of the FAA,which as far as I am concerned has many times exceeded their mandate in many areas and failed to fulfill it in others.

[Robert Lees]

Re: Strut Airworthiness Directive (AD) (merged III)

[Mr McAnaul's] ...lack of knowledge on the subject of Taylorcrafts

I don't know Mr McAnaul's background, but possibly even he would not argue that point, we are the experts. It is up to us to politely & respectfully educate him as best we can.

Rob

[N74DV]

Re: Strut Airworthiness Directive (AD) (merged III)

5 entries into the docket so far today.

http://dms.dot.gov/search/searchResultsSimple.cfm?numberValue=28478&searchType=docket

keep them coming guys! take 5 minutes to register and post your comment to the docket. The more concern we show towards the hastiness of this AD the more chance we all have to get it corrected/amended.

[barnstmr]

Re: Strut Airworthiness Directive (AD) (merged III)

Just added mine.

Did anyone see the cost analysis? FAA says $400 for initial inspection and over $900 to do recurrent inspections.

[Ragwing nut]

Re: Strut Airworthiness Directive (AD) (merged III)

I agree. More and more I'm inclined to the experimental route. I can get better performance, better safety, more up-to-date method, materials and equipment, and I can get from under the thumb of the FAA,which as far as I am concerned has many times exceeded their mandate in many areas and failed to fulfill it in others.

You are not exempt even if your Taylorcraft is experimental. Under Part 39, AD's must be complied with on all certificated aircraft. "Experimental" is a certification.

Mike

[N74DV]

Re: Strut Airworthiness Directive (AD) (merged III)

yes, but being experimental if you hold the repairmans certificate it sure as hell makes the process nearly as easy to swallow as warm jello. Right now I feel like I'm trying to swallow a loaf of bread with no water.

how are some of you guys re-certificating a Tcraft as experimental??!!???

[Guest]

Re: Strut Airworthiness Directive (AD) (merged III)

yes, but being experimental if you hold the repairmans certificate it sure as hell makes the process nearly as easy to swallow as warm jello. Right now I feel like I'm trying to swallow a loaf of bread with no water.

how are some of you guys re-certificating a Tcraft as experimental??!!???

The AD and related NDT testing is still required just like Mike said so how do you "save" with regard to the strut AD?

Dave

[N74DV]

Re: Strut Airworthiness Directive (AD) (merged III)

by being able to do the actual r&r of the struts yourself.... it's been hell trying to find an A&P/IA out here who will touch a tube/fabric aircraft.

but we're getting off on a tangent here.

The offering by Aircraft Inc. for seald struts at less than $1800 for all four looks promising.

[VictorBravo]

Re: Strut Airworthiness Directive (AD) (merged III)

Simmer down, guys. There is no need to start tearing up your standard airworthiness certificates...

REALITY CHECK:

Removing and replacing the wing struts is relatively simple. It's about three end wrenches, three sockets, and a six foot stepladder with a couple of old tires and some pillows.

If you want to remove all four struts at the same time, add another ladder and tire.

You can take all four off in about two or three hours conservatively. It would be a great time to have a good look at your bolts, replace with new bolts, nuts, washers, etc. Those bolts ay not have been taken out and looked at in 20 years or more.

It becomes easier and safer if you put the tailwheel up on a three foot stepladder and chock the wheels with good old heavy bricks so it won't move. That levels the bottom of the wingtips so the pillows won't slide out.

Just leave the stepladders and pillows in place, no need to remove the upper wing bolts or even fool with the aileron turnbuckles.

Any IA who is afraid of doing it is the wrong IA. This is just the most basic, simple, garage level stuff. Don't make it rocket science. Get with the local EAA chapter or Vintage aircraft chapter or EAA Warbirds chapter or IAC aerobatic chapter. There should be someone in that pile who is not afraid of fabric airplanes.

The NDT needs to be performed by someone who is qualified to look at thin tubular aircraft structures. That is worth going to have done someplace that does airplane NDT if you don't have someeone locally who can come out and do it.

Your Taylorcraft has lived 60+ years with a standard airworthiness certificate, and don't be so quick to toss that away.

[astjp2]

Re: Strut Airworthiness Directive (AD) (merged III)

You are not exempt even if your Taylorcraft is experimental. Under Part 39, AD's must be complied with on all certificated aircraft. "Experimental" is a certification.

Mike

Mike, an experimental is not a TYPE certified aircraft. It is issued an experimental certificate. Since it does not meet type design it is not required to comply with any AD's, (IAW FAR 39.5b)..... look at the BD-5, probably killed more people than anyother airplane and not 1 single AD that I can find. The only regulatory requirement is for either the manufacturer or an A&P to perform the condition inspection. There are NO limitations on who can perfrom any maintenance on said experimental aircraft. I have not seen an AD on any experimental aircaft yet, and I have not found a regualtion that requrires an AD to be complied with because an experimental aircraft is not issued an STANDARD AIRWORTHINESS CERTIFICATE because it does not meet type design. If I peel the data plate off of a Lycoming what ever and put my own on with my specs, then I would not have to comply with any Lycoming AD's because the engine is of my own design. Tim

Can Anyone quote what the FAA considers airworthy?

[Garry Crookham]

Re: Strut Airworthiness Directive (AD) (merged III)

For those of you with thoughts of certifying your Taylorcraft experimental please review FAR 21.191 and FAA Order 8130.2F change 3. There are 9 different experimental categories and placing your Taylorcraft in the experimental, amateur built category is not an option per 8130.2f,3:

"NOTE: A rebuilt, altered, or repaired type-certificated aircraft DOES NOT meet the intent of § 21.191(g) and DOES NOT meet the § 21.191(g) requirement that the major portion of the aircraft be fabricated and assembled."

Most of the other 8 categories are far more restrictive than the amateur built category, requiring such things as yearly program letters detailing where you will fly, etc. You will find that in most instances an A&P certificate will be required to perform maintenance. I've been involved with aircraft certified in the exhibition, air racing, amateur built, and compliance with regs, and I don't think you want try to go there.

Complying with the strut AD is the easiest and most cost effective way to go.


Garry Crookham
N5112M
Tulsa

[Guest]

Re: Strut Airworthiness Directive (AD) (merged III)

Mike, an experimental is not a TYPE certified aircraft. It is issued an experimental certificate. Since it does not meet type design it is not required to comply with any AD's, (IAW FAR 39.5b)..... look at the BD-5, probably killed more people than anyother airplane and not 1 single AD that I can find. The only regulatory requirement is for either the manufacturer or an A&P to perform the condition inspection. There are NO limitations on who can perfrom any maintenance on said experimental aircraft. I have not seen an AD on any experimental aircaft yet, and I have not found a regualtion that requrires an AD to be complied with because an experimental aircraft is not issued an STANDARD AIRWORTHINESS CERTIFICATE because it does not meet type design. If I peel the data plate off of a Lycoming what ever and put my own on with my specs, then I would not have to comply with any Lycoming AD's because the engine is of my own design. Tim

Can Anyone quote what the FAA considers airworthy?

Thanks Tim for the info.

You inspired me to read parts or part 39.

I cheated I knew where to look it up;

b. Airworthy. The term “airworthy” is not defined in Title 49 of the United States Code (49 U.S.C.), or in 14 CFR; however, a clear understanding of its meaning is essential in making an airworthiness determination. Furthermore, the definition of airworthy applies to type-certificated products (aircraft, aircraft engine, or propeller), and parts thereof. Title 49 U.S.C. section 44704(c) and 14 CFR section 21.183(a), (b), and (c) state that the two conditions that must be met for issuance of an airworthiness certificate are:
(1) The product must conform to its type certificate (TC). A product conforms to its TC when its configuration and the components installed are as described in the drawings, specifications, and other data that are part of the TC, which includes any Supplemental TypeCertificates (STC), Airworthiness Directives (AD), and field approved alterations incorporated into the product; and
(2) The aircraft (product) must be in a condition for safe operation.
NOTE: If one or more of these conditions are not satisfied, the product would be considered not to be airworthy.

I also noticed that the wings with spring plane that Perry Virgin has is still subject to the AD because of this;

39.15 Does an airworthiness directive apply if the product has been changed?
Yes, an airworthiness directive applies to each product identified in the airworthiness directive, even if an individual product has been changed by modifying, altering, or repairing it in the area addressed by the airworthiness directive.