A ONE TWO PUNCH

Just when owners were starting to get a handle on AD 2008-04-09 (the strut AD revision that superseded AD 2007-16-14) along comes AD 2008-09-18. This is the attach fitting inspection AD mandated for everything Taylorcraft. The poor work and maintenance of a few has prompted the FAA to issue this latest AD affecting Taylorcraft owners. A few more AD's will make scrap prices look attractive for owners of the finest flying machine you'll ever alight in.

The text of the AD follows;

[Federal Register: May 2, 2008 (Volume 73, Number 86)]
[Rules and Regulations]
[Page 24162-24164]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr02my08-12]
––––––––––––––––––––––––––––––––––
DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2008-0177; Directorate Identifier 2007-CE-093-AD; Amendment 39-15499;
AD 2008-09-18]
RIN 2120-AA64
Airworthiness Directives; Taylorcraft, Inc. Models A, B, and F Series Airplanes
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Final rule.
––––––––––––––––––––––––––––––––––
SUMMARY: The FAA adopts a new airworthiness directive (AD) for certain Taylorcraft, Inc.
Models A, B, and F series airplanes. This AD requires you to inspect the wing strut attach fittings for
corrosion or cracks and requires repair or replacement if corrosion or cracks are found. This AD
results from data collected from an accident involving a Taylorcraft Model BF12-65 airplane. The
wing separated from the airplane after the wing strut attach fitting failed due to corrosion. We are
issuing this AD to detect and correct corrosion or cracks in the wing strut attach fittings, which could
result in failure of the wing strut attach fittings and lead to wing separation and loss of control.
DATES: This AD becomes effective on June 6, 2008.
On June 6, 2008, the Director of the Federal Register approved the incorporation by reference of
certain publications listed in this AD.
ADDRESSES: To get the service information identified in this AD, contact Taylorcraft Aviation,
LLC, 2124 North Central Avenue, Brownsville, Texas 78521; telephone: 956-986-0700.
To view the AD docket, go to U.S. Department of Transportation, Docket Operations, M-30,
West Building Ground Floor, Room W12-140, 1200 New Jersey Avenue, SE., Washington, DC
20590, or on the Internet at http://www.regulations.gov. The docket number is FAA-2008-0177;
Directorate Identifier 2007-CE-093-AD.
FOR FURTHER INFORMATION CONTACT: Andy McAnaul, Aerospace Engineer, SATMIDO-
43, 10100 Reunion Place, Suite 650, San Antonio, Texas 78216; telephone: (210) 308-3365;
fax: (210) 308-3370.
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SUPPLEMENTARY INFORMATION:
Discussion
On February 12, 2008, we issued a proposal to amend part 39 of the Federal Aviation
Regulations (14 CFR part 39) to include an AD that would apply to certain Taylorcraft, Inc. Models
A, B, and F series airplanes. This proposal was published in the Federal Register as a notice of
proposed rulemaking (NPRM) on February 20, 2008 (73 FR 9239). The NPRM proposed to require
inspection of the wing strut attach fittings for corrosion or cracks and to require repair or replacement
if corrosion or cracks are found.
Comments
We provided the public the opportunity to participate in developing this AD. The following
presents the comments received on the proposal and FAA's response to each comment:
Comment Issue No. 1: Additional Wording
The Experimental Aircraft Association and four other commenters ask for us to add wording to
the final rule to allow repairing the fitting/fuselage structure in accordance with FAA Advisory
Circular (AC) 43.13-1B. The commenters believe the Taylorcraft fuselage structure, comprised of
welded steel tubing and flat plate fittings, is well within the scope of repair practice for an Airframe
and Powerplant (A & P) mechanic experienced in maintaining aircraft of that vintage. They comment
that it is reasonable to expect an experienced mechanic to have sufficient information and means
available to rebuild the fitting area with guidance from AC 43.13-1B.
We agree that repair of the Taylorcraft fuselage welded structure is within the scope of repair
criteria and guidance provided in AC 43.13-1B. We will add language in paragraph (e)(3) of the AD
to allow for repair of the attach fitting and the associated fuselage structure in accordance with AC
43.13-1B.
Comment Issue No. 2: Requirements Already Exist
Marc Fries and four other commenters believe the AD is redundant and that requirements already
exist to accomplish inspections of the attach fittings. The commenters believe that 14 CFR part 43,
Appendix D already provides sufficient annual/100-hour inspection requirements to inspect the wing
strut attach fittings. Some of the commenters cite poor maintenance practice as the root cause for the
corrosion related fitting failure in the fatal accident airplane. One commenter additionally mentioned
that AD 47-16-03 already covers inspection of Taylorcraft wing attach fittings.
We do not agree with the commenters. AD 47-16-03 only addressed inspection of wing strut
attach fittings for cracks or evidence of poor welds in Taylorcraft Models BC, BF, and BL series
aircraft. The AD was issued for a potential manufacturing quality issue. The AD did not address
corrosion and required an immediate one-time compliance.
While 14 CFR part 43, Appendix D requires inspection of wing and center section components
for general condition and security of attachment, the FAA has heard from Taylorcraft owners that
they were unaware of the existence of drain holes in the bottom of the wing strut attach fittings. Also,
some owners were unaware of the potential situation where fabric may cover the attach fitting and
drain holes on re-covered airplanes. This condition was a contributing factor in the fatal accident, as
it fostered the corrosion environment that led to eventual fitting failure. The FAA believes this
condition is likely to exist in other Taylorcraft airplanes of the same type design and inspection of all
affected airplanes is warranted for continued operational safety.
We are not changing the final rule AD action based on this comment.
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Conclusion
We have carefully reviewed the available data and determined that air safety and the public
interest require adopting the AD as proposed except for the change previously discussed and minor
editorial corrections. We have determined that this change and these minor corrections:
• Are consistent with the intent that was proposed in the NPRM for correcting the unsafe condition;
and
• do not add any additional burden upon the public than was already proposed in the NPRM.
Costs of Compliance
We estimate that this AD affects 3,119 airplanes in the U.S. registry.
We estimate the following costs to do the inspection:
Labor cost Parts cost Total cost per
airplane
Total cost on
U.S. operators
2 work-hours × $80 per hour = $160 Not applicable $160 $499,040
We estimate the following costs to do any necessary replacements that would be required based
on the results of the proposed inspection. We have no way of determining the number of airplanes
that may need this repair/replacement:
Labor cost per fitting Parts cost per fitting Total cost per airplane
(for two fittings)
30 work-hours × $80 per hour = $2,400 $200 $5,200
Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to issue rules on aviation safety.
Subtitle I, Section 106 describes the authority of the FAA Administrator. Subtitle VII, Aviation
Programs, describes in more detail the scope of the agency's authority.
We are issuing this rulemaking under the authority described in Subtitle VII, Part A, Subpart III,
Section 44701, ''General requirements.'' Under that section, Congress charges the FAA with
promoting safe flight of civil aircraft in air commerce by prescribing regulations for practices,
methods, and procedures the Administrator finds necessary for safety in air commerce. This
regulation is within the scope of that authority because it addresses an unsafe condition that is likely
to exist or develop on products identified in this AD.
Regulatory Findings
We have determined that this AD will not have federalism implications under Executive Order
13132. This AD will not have a substantial direct effect on the States, on the relationship between the
national government and the States, or on the distribution of power and responsibilities among the
various levels of government.
For the reasons discussed above, I certify that this AD:
1. Is not a ''significant regulatory action'' under Executive Order 12866;
2. Is not a ''significant rule'' under the DOT Regulatory Policies and Procedures (44 FR 11034,
February 26, 1979); and
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3. Will not have a significant economic impact, positive or negative, on a substantial number of
small entities under the criteria of the Regulatory Flexibility Act.
We prepared a summary of the costs to comply with this AD (and other information as included
in the Regulatory Evaluation) and placed it in the AD Docket. You may get a copy of this summary
by sending a request to us at the address listed under ADDRESSES. Include ''Docket No. FAA-2008-
0177; Directorate Identifier 2007-CE-093-AD'' in your request.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by reference, Safety.
Adoption of the Amendment
Accordingly, under the authority delegated to me by the Administrator, the Federal Aviation
Administration amends part 39 of the Federal Aviation Regulations (14 CFR part 39) as follows:
PART 39–AIRWORTHINESS DIRECTIVES
1. The authority citation for part 39 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 44701.
§ 39.13 [Amended]
2. FAA amends § 39.13 by adding a new AD to read as follows:
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FAA
Aircraft Certification Service
AIRWORTHINESS DIRECTIVE
www.faa.gov/aircraft/safety/alerts/
www.gpoaccess.gov/fr/advanced.html
2008-09-18 Taylorcraft, Inc.: Amendment 39-15499; Docket No. FAA-2008-0177; Directorate
Identifier 2007-CE-093-AD.
Effective Date
(a) This AD becomes effective on June 6, 2008.
Affected ADs
(b) None.
Applicability
(c) This AD applies to all serial numbers of Taylorcraft Models A, BC,
BCS12-D, BCS, BC12-D1, BC-65, BCS12-D1, BCS-65, BC12D-85, BC12-65 (Army L-2H),
BCS12D-85, BCS12-65, BC12D-4-85, BC12-D, BCS12D-4-85, (Army L-2G) BF, BFS, BF-60,
BFS-60, BF-65, BFS-65, (Army L-2K) BF 12-65, BFS-65, BL, BLS, (Army L-2F) BL-65, BLS-65,
(Army L-2J) BL12-65, BLS12-65, 19, F19, F21, F21A, F21B, F22, F22A, F22B, and F22C airplanes
that are certificated in any category.
Note: This AD applies to all Taylorcraft models listed above, including those models not listed in
Taylorcraft Aviation, LLC Service Bulletin No. 2007-002, dated November 8, 2007. If there are any
other differences between this AD and the above service bulletin, this AD takes precedence.
Unsafe Condition
(d) This AD results from data collected from an accident involving a Taylorcraft Model BF12-65
airplane. The wing separated from the airplane after the wing strut attach fitting failed due to
corrosion. We are proposing this AD to detect and correct corrosion or cracks in the wing strut attach
fittings. This condition, if not corrected, could result in failure of the wing strut attach fittings and
lead to wing separation and loss of control.
Compliance
(e) To address this problem, you must do the following, unless already done:
(1) Initially inspect the left and right wing lift strut attach fittings, part number (P/N) A-A11, for
corrosion or cracking following Taylorcraft Aviation, LLC Service Bulletin No. 2007-002, dated
November 8, 2007, using the following compliance times:
(i) For airplanes that have never been equipped with floats or snow skis: Within the next 90 days
after June 6, 2008 (the effective date of this AD).
(ii) For airplanes equipped with or that have ever been equipped with floats or snow skis: Within
the next 30 days after June 6, 2008 (the effective date of this AD).
(2) If the airplane is equipped with floats or snow skis at the time of the initial inspection
required by paragraph (e)(1) of this AD or at any time after the initial inspection required by
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paragraph (e)(1) of this AD, you must repeat the inspection required in paragraph (e)(1) of this AD as
follows:
If the following exists: Then:
(i) The airplane is equipped with
floats or snow skis at the time of the
initial inspection required by
paragraph (e)(1) of this AD.
Inspect no later than 48 months following the initial
inspection and repetitively inspect thereafter at intervals not
to exceed 48 months. Continue these repetitive inspections
until removal of floats or snow skis, at which time you must
follow paragraph (e)(2)(ii) of this AD.
(ii) You remove floats or snow skis
at any time following the initial
inspection required by paragraph
(e)(1) of this AD.
Inspect no later than 48 months following the last inspection.
After the inspection following removal of floats or snow
skis, no further inspections are required unless floats or snow
skis are re-installed at a later date, at which time you must
follow paragraph (e)(2)(iii) of this AD.
(iii) You install floats or snow skis at
any time since the initial inspection
required by paragraph (e)(1) of this
AD.
Inspect no later than 48 months following the last inspection
or before further flight after installation of floats or snow
skis, whichever occurs later, and repetitively inspect
thereafter at intervals not to exceed 48 months. Continue
these repetitive inspections until removal of floats or snow
skis, at which time you must follow paragraph (e)(2)(ii) of
this AD.
(3) If you find cracking or material loss due to corrosion during any of the inspections required
in paragraph (e)(1) or (e)(2) of this AD, before further flight, do the following:
(i) Contact Taylorcraft Aviation, LLC at 2124 North Central Avenue, Brownsville, Texas 78521;
telephone: 956-986-0700 to obtain an FAA-approved repair scheme or replacement procedure; or
refer to FAA Advisory Circular AC 43.13-1B CHG 1, dated September 27, 2001; and
(ii) Repair or replace the left and/or right wing lift strut attach fitting(s), P/N A-A11.
Alternative Methods of Compliance (AMOCs)
(f) The Manager, Fort Worth Airplane Certification Office, FAA, has the authority to approve
AMOCs for this AD, if requested using the procedures found in 14 CFR 39.19. Send information to
ATTN: Andy McAnaul, Aerospace Engineer, SAT-MIDO-43, 10100 Reunion Place, Suite 650, San
Antonio, Texas 78216; telephone: (210) 308-3365; fax: (210) 308-3370. Before using any approved
AMOC on any airplane to which the AMOC applies, notify your appropriate principal inspector (PI)
in the FAA Flight Standards District Office (FSDO), or lacking a PI, your local FSDO.
Material Incorporated by Reference
(g) You must use Taylorcraft Aviation, LLC Service Bulletin No. 2007-002, dated November 8,
2007, to do the actions required by this AD, unless the AD specifies otherwise.
(1) The Director of the Federal Register approved the incorporation by reference of this service
information under 5 U.S.C. 552(a) and 1 CFR part 51.
(2) For service information identified in this AD, contact Taylorcraft Aviation, LLC, 2124 North
Central Avenue, Brownsville, Texas 78521; telephone: 956-986-0700.
(3) You may review copies at the FAA, Central Region, Office of the Regional Counsel, 901
Locust, Kansas City, Missouri 64106; or at the National Archives and Records Administration
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(NARA). For information on the availability of this material at NARA, call 202-741-6030, or go to:
http://www.archives.gov/federal_register/code_of_federal_regulations/ibr_locations.html.
Issued in Kansas City, Missouri, on April 23, 2008.
David R. Showers,
Acting Manager, Small Airplane Directorate, Aircraft Certification Service.
[FR Doc. E8-9397 Filed 5-1-08; 8:45 am]