The Aircraft Owners and Pilots Association has objected to a proposed airworthiness directive on Model 35 and 36 Learjets because it is an inappropriate use of the AD process and could set a bad precedent that would affect all of general aviation.
"The FAA continues to try to 'fix' operational or educational problems with airworthiness directives," said Dennis Roberts, AOPA vice president and executive director of government and technical affairs. "Airworthiness directives should only be used to address flaws in equipment, not the operator."
The AD in question would require affected Learjet operators to insert a new page in the airplane flight manual. The page would add an emergency procedure requiring the flight crew to don oxygen masks when the cabin altitude warning horn sounds. (The horn indicates some failure of the cabin pressurization system.)
"AOPA certainly supports FAA efforts to properly alert and educate pilots about the need to use oxygen in case of pressurization problems at altitude," said Roberts, "but the FAA has not identified an airworthiness problem in this action."
The FAA cited several instances of Learjet crew incapacitation (the most notable being the accident that claimed golfer Payne Stewart and five others last October), which the agency believes were due to hypoxia. An FAA special certification review of Learjet models 35, 35A, 36, and 36A did not find an aircraft design flaw or a mechanical cause for the accidents.
AOPA told the FAA that a pilot's failure to don an oxygen mask was an operational and educational concern. The association said the FAA should alert all owners and operators of affected Learjet models of the need to incorporate a training regime addressing the emergency cabin pressurization procedures but not use an AD to do it.
"AOPA has consistently opposed ADs that deal with operational or educational concerns," said Roberts. (He noted that the FAA has withdrawn some such ADs, such as the Beechcraft fuel selector AD that would have required a placard warning the pilot that improperly positioning the fuel selector could stop fuel flow.)
"Our real concern is the precedent that this sets," Roberts added. "The FAA's goal should be more education and less regulation."
The 360,000-member Aircraft Owners and Pilots Association is the world's largest civil aviation organization. More than one half of the nation's pilots are AOPA members.
July 26, 2000