Mr. Scott West Aerospace Engineer Federal Aviation Administration Wichita ACO Mid-Continent Airport 1801 Airport Road, Room 100 Wichita, KS 67209
Dear Mr. West:
This letter is in response to the issuance of airworthiness directive (AD) 99-05-13 that requires the installation of a placard on the fuel selector "to warn of the no-flow situation that exists between the fuel tank detents." The Aircraft Owners and Pilots Association (AOPA) represents the interests of more than 345,000 pilots and aircraft owners, many of whom are affected by this AD.
AOPA has provided its views to the Federal Aviation Administration (FAA) regarding the placarding of aircraft on a number of occasions. In the past, the FAA appeared to propose the use of placards as a "catch all" or easy way out of safety related problems that could more effectively be handled using other appropriate means. AOPA holds that there are more reasonable alternatives to mandatory installation of placards that would ensure a high level of safety for all users. For example, the Aircraft Flight Manual (AFM) or the Pilots Operating Handbook (POH) are excellent examples of more appropriate vehicles for the conveyance of normal operating or procedural information.
AOPA understands that AD 99-05-13 was issued in response to reports of engine stoppage resulting from incorrect positioning of the fuel selector valve. However, AOPA believes that mandatory installation of a placard reminding pilots to correctly position the fuel selector valve will have little or no impact on the safety of flight operations in aircraft affected by this AD. We believe this on the grounds that the position of the fuel selector in most models of affected aircraft would prohibit the pilot from seeing, let alone reading, any placard or warning. Additionally, most new models of aircraft affected by AD 99-05-13 currently include (in the POH) a warning regarding the proper positioning of the fuel selector valve.
Most importantly, AOPA holds that a pilotï¿½s failure to properly position the fuel selector is an operational issue rather than an airworthiness concern. It is AOPAï¿½s firm belief that the military doctrine regarding the use of placards should be utilized by the FAA. The military has an extremely strict standard regarding the use of placards on everything from aircraft to tanks, and reserves such warning placards solely for emergency information. If the FAA continues to mandate the installation of placards for non-safety critical information, the true emergency information will become lost in the muddle of general operating data. In the interest of aviation safety, AOPA recommends that the FAA exercise extreme care when determining what warrants the installation of a placard. It is AOPAï¿½s sincere hope that the FAA will utilize placards solely for emergency information, rather than for general operating data.
In summary, AOPA requests that AD 99-05-13 be rescinded on the grounds that a pilotï¿½s failure to properly position a fuel selector valve is an operational issue rather than an airworthiness concern. We believe that it is in the best interest of aviation safety to reserve placards solely for emergency information. Furthermore, AOPA holds that it is more appropriate to present operational and performance information, such as this, in the AFM or POH rather than in a placard format.
Thank you for your time and consideration on this matter. AOPA stands ready to assist the FAA in reconsidering AD 99-05-13.
Douglas Macnair Director Regulatory and Certification Policy
AOPA thanks our members for their continued support in protecting the freedom to fly.