Federal Aviation Administration Central Region
Office of the Regional Counsel
Attention: Docket No. 97-CE-37-AD
601 E. 12th Street
Kansas City, MO 64106
Gentlemen:
The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more than 340,000 pilots and aircraft owners, submits the following petition for reconsideration under 14 CFR Part 11.93 of Airworthiness Directive (AD) 98-05-04 ( text | PDF). This AD, affecting American Champion Aircraft Corporation Model 8GCBC airplanes, calls for the installation of numerous inspection holes in the wing fabric and repetitive visual inspection of the front and rear spars for compression cracks.
There is currently a second AD in the rulemaking process that covers identical issues on all American Champion Aircraft Corporation 7-, 8-, and 11-series aircraft, not just the single model covered by the recently released AD 98-05-04. This proposed AD, contained in docket number 97-CE-79-AD, would also call for the installation of numerous additional inspection holes in the wing fabric and require repetitive visual inspections of the wood wing spars for compression cracks. The proposal has received a high level of adverse public comment and is currently being reexamined by the Chicago Aircraft Certification Office engineering staff. Among the potential significant alterations to the proposed AD could be a different inspection method that would not require the expensive and destructive installation of additional inspection panels in the wings of these aircraft. This inspection method, which has been demonstrated to the Federal Aviation Administration (FAA) by the Citabria Owners Group, would save owners of affected aircraft potentially hundreds of thousands of dollars while preserving the aesthetics and airworthiness of the aircraft.
AOPA maintains that the issuance of a final rule calling for modification and inspection of the 8GCBC aircraft is premature. This final AD substantially mirrors the proposed AD contained in docket number 97-CE-79-AD, which could potentially undergo significant modification, based upon the newly proposed inspection methods. Under the circumstances, we feel that AD 98-05-04 should be withdrawn pending the review and disposition of docket 97-CE-79-AD. AOPA believes that the inspection method proposed by the Citabria Owners Group represents the best known inspection technique available to date and should replace the unsatisfactory requirement for the installation of dozens of new inspection holes in the wings of each of the affected American Champion aircraft. Further, we urge the FAA to combine the withdrawn final AD against the 8GCBC with the proposed AD against all 7-, 8-, and 11-series aircraft and reissue the notice of proposed rulemaking for all affected aircraft reflecting the newly proposed inspection method. In our view, this will meet with significantly less adverse public comment and will provide a successful and consistent inspection process for all aircraft in the product line.
AOPA stands ready to assist the FAA in any manner on this issue, and if there are any questions or a need for additional information, please feel free to contact me at 301/695-2207.
Respectfully,
Douglas C. Macnair
Director
Aviation Standards
March 6, 1998
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