Federal Aviation Administration Central Region
Office of the Chief Counsel, Room 1558
601 E. 12th Street
Kansas City, MO 64106
Attention: Rules Docket No. 97-CE-114-AD
Gentlemen:
The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more then 340,000 pilots and aircraft owners, submits the following comments to the proposed airworthiness directive (AD) applying to Cessna Aircraft Company Model 150, 152, 172, 177, 180, 182, 185, 188, 206, 207, 210, and 337 series airplanes. The AD proposes to require measuring the visible length of standpipe in the top assembly of the fuel strainer and replacing the assembly if it does not meet the specified minimum dimensions. The need for this inspection appears to be the result of a manufacturing defect that allowed the fuel filter standpipes to be incorrectly installed in the assembly housing top between December 1996 and September 1997.
AOPA agrees with the Federal Aviation Administration (FAA) that aircraft suspected of having this faulty fuel strainer assembly should be inspected and the faulty assembly should be replaced immediately. However, AOPA is unequivocally opposed to the application of this AD to all aircraft in the fleet on which this particular assembly could be installed. By taking this approach, the FAA has made what could be a relatively minor AD into a massive inspection program impacting an estimated 50,000 airplanes.
Given that there is a known range of dates during which the faulty parts were manufactured (December 1996 to September 1997), it seems only reasonable that the affectivity of this proposed AD would be limited to aircraft whose fuel strainer assemblies were modified or replaced after December 1, 1996. This simple modification to the AD would limit the number of effected aircraft to a few hundred and reduce the cost impact of this AD from $3.1 million to just over $100,000. This $3 million cost savings would in no way compromise safety or the integrity of the AD and would capture all 300 of the faulty strainer assemblies.
AOPA strongly urges the FAA to review the compliance requirements of this proposed AD and modify them accordingly. We stand ready to assist the FAA and look forward to working further with you on this important issue to general aviation aircraft owners.
Respectfully,
Douglas C. Macnair
Director
Aviation Standards
July 31, 1998
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