Flight Training - March 2019 - 41

THE PROCESS

I won't bore you with the details of the process but
generally speaking, if the FAA suspects, based on
reports of safety issues, that an AD is required, the
agency publishes a notice of proposed rulemaking
(NPRM) to solicit public comment from affected
parties-pilots, owners, manufacturers, flight
schools, and more-then ultimately issues what's
called a final rule that establishes the AD. An exception to this process is the emergency airworthiness
directive, or EAD, when the FAA determines that an
unsafe condition requires immediate action, such as
the FAA's grounding of Boeing 787s following a pair
of internal lithium-ion battery fires.
Once a final rule is issued, the AD literally
becomes part of the federal aviation regulations. For
analogy, if the FARs were the U.S. Constitution (God
forbid), ADs would be amendments to the constitution. So just how many amendments to the FAA's
constitution are there? The FAA's website currently
lists more than 15,000.
Some of the ADs are simple and cheap to take
care of. Others are frighteningly expensive (see "On
Your Side," p. 42). The Cessna seat rail AD is an $85
inspection. On the other hand, compliance with
an AD affecting ECi cylinders used on more than
6,000 Continental engines cost owners an estimated
$11,500 per engine.
So where do the safety concerns that generate ADs
originally come from? They can originate with manufacturers, holders of supplemental type certificates,
foreign authorities (aviation is global), Service Difficulty
Reports from mechanics or owners, notifications from
type clubs, and-sadly-from National Transportation
Safety Board investigations. For example, when an
AT-6F lost its wing in flight in 2005, crashing and killing
two, it resulted in AD 2005-12-51, requiring inspections
of the wing attach angles on virtually all T-6s.
THE NUTS AND BOLTS OF AN AD

Once issued, an AD might apply to all aircraft of
a make and model; to airplanes in a certain serial
number range; or to specific engines, propellers, or
instruments that might be installed on a variety of
airframes. ADs may require a simple inspection, a
replacement, or a modification. Some are one-off,
requiring a single one-time inspection or repair, while
others are periodic, requiring ongoing inspections
based on calendar time, time in service, or both.

AD 2018-07-03, affecting 17,957
Piper PA-28 models, mandates
the change of fuel tank selector
placards in some airplanes, which
apparently were installed backwards in an unknown number of
Piper airplanes, causing a fuel
starvation risk, according to the
FAA. The AD allows private pilots
to check the placards as part
of a preflight, and if they need
to be replaced, the estimated
average cost to owners for compliance is $42.50 per airplane.
It could have been much higher.
The FAA's original proposed AD
did not allow private pilots to
check. The FAA pushed back the
compliance deadline three times
to accommodate alternative
method of compliance (AMOC)
requests from AOPA that saved
owners more than $763,000
in labor costs.
Recurring ADs, like airplanes themselves, are
eternal unless they are suspended by a subsequent
AD or have a terminating action, such as a cylinder
removal or replacement.
WHO'S RESPONSIBLE FOR AN AD?

Legally, the owner and operator of an airplane is
responsible for ensuring that all ADs are compiled
with, and while-in most cases-an FAA-certificated
mechanic must complete the work and sign off in
the airframe, powerplant, or propeller logs that it
was complied with, the buck stops with the pilot
in command. FAR 91.103 requires us to become
familiar with "all available information," and FAR
91.7 requires us to ensure that any airplane we fly is
in airworthy condition; and an airplane that is not in
compliance with an AD is technically not airworthy
(see "Flyable versus Airworthy," page 40).
WWW.AOPA.ORG/FT 41

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Flight Training - March 2019

Table of Contents for the Digital Edition of Flight Training - March 2019