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![]() Where did you find this? Exact link please. There is no exact link. Your best link will be to your SSA Regional Director (in the US). I provided this info to Todd (and other folks I know that own Grob 102's) because I know he has one. This info is provided by the AOPA to what they call "type clubs". That includes the SSA and other type clubs like the Bonanza Society, the Commanche Organization and the 1-26 Association. It is part of the FAA's Airworthiness Concern Coordination Program outlines in the "Airworthiness Concern Process Guide" available he http://www.faa.gov/aircraft/air_cert...airworthiness/ If you open that Word document and scroll through it a bit, it will describe the process the FAA uses to create AD's and buried in the body of the document you will find a listing of contacts for the type clubs; incredibly outdated for gliders, but I can assure you that the contact information for the SSA is being updated now. This process is also described in the AOPA web site he http://www.aopa.org/whatsnew/regulat...orthiness.html The Process Here's the deal (bear with me a bit): The FAA writes AD's for US type certificated aircraft. They write AD's based solely (almost) upon recommendations from the manufacturer of the aircraft (or engine, or appliance manufacturer, etc.) and maybe sometimes (rarely) from service information such as SDR's or M or D reports. They do not write AD's because they think the glider community needs one right in the middle of soaring season. The only information the FAA has about the apparent unsafe condition comes from the manufacturer; typically in the form of a manufacturer's service bulletin and, in some cases, a foreign AD, but those also typically come from a manufacturer's service bulletin (or TN or whatever). Almost always (never say never, right?) a foreign (foreign to the US anyhow, this is a Big Forum) AD against a glider will be followed by a US AD. *Note to DG 300/303 owners.* Manufacturers are required by rule to report unsafe conditions, at least in the US they are - and I'm sure in other countries as well. So, that's why the manufacturers are telling the FAA that they have an unsafe condition, whether it be known failures, possible failures, manufacturing defects, etc., ad infinitum. They simply are required to report to the FAA bad problems that they think will cause significant issues like hull loss, injury or fatalities. It's a Part 21 and 25 rule. OK, 33 as well, but we're talking gliders here. This is not YOUR FAA, it is the Aircraft Certification FAA, not Flight Standards FAA that you guys find sitting in the cube or answering the phone at the FSDO. Different guys. Engineer guys. For gliders, it's the guys in the Small Airplane Directorate in KC, for Boeings and the like, it's here in Seattle, in the building across the parking lot. The FAA engineer guys get the bad news from the manufacturer and they are required by rule and FAA policy to write the AD. Now, they do this with the best of intentions - to protect the flying public (you) from the design problem that caused the unsafe condition. Many issues are brought to the FAA engineer guys that do not become AD's - for various reasons. Mostly because they are not design or manufacturing issues. Every once in a blue moon, a service (meaning, no or poor maintenance, or inadequate maintenance instructions, especially lubrication) problem drives an AD, but normally, it's design, certification or manufacturing problems that drive AD's. Normally. Not always. The FAA engineers have to work hard to convince FAA engineering management that they NEED an AD. Just like you convincing your finance department that you need this capital expenditure for your pet (OK, needed) project, or whatever you need from whomever you have to convince in your huge corporate structure - anyhow, you get the picture. These guys don't just make this stuff up and mail it out to unsuspecting owners. The manufacturer of your aircraft is the first to know about the problem, the FAA is second and you are third, or maybe last. Once the FAA engineer has convinced FAA engineering management that the AD is worthy, now they have to write it. But first, like all good engineers (and these are really good guys, good engineers, and just maybe in one or more cases, a good glider pilot) they have to do their engineering due diligence and determine all sorts of things before they publish the proposed AD for public comment in the form of an NPRM (Notice of Proposed Rulemaking in the public docket, just google it). So they have come up with this ACCS process to get some GOOD input from industry, operators, owners, type clubs and other experts with good, valuable, valid and important information that they can use in the process of creating the substatiation for the contents of the AD, like: Cost of the AD Validity of the unsafe condition Suggested compliance time (emergency, 30 days, 180 days, 1`8 months, etc.) Availibilty of required spares Availibility of repair facilities (I'm personally having some difficulty with this today after a request from our local SSA Regional Director - not easy to figure out and I'm one of "Them" that should know) and any other information the type clubs, industry(manufacturers), repair facilities (through ARSA) and organizations like teh EAA, AOPA, SSA and other would like to provide to teh FAA. The vehicle for providing this additional, substantive information to the FAA during the process of creating the AD (again - before it goes out for public comment in the NPRM docket sustem) is through the Airworthiness Concern Coordination Process detailed in the publications noted above. The Reason Why: Here's the important part: Normally, the comments provided in the ACP process will not (maybe) stop an AD, but they can, and have, helped to shape the requirements so that they are based on factual information and are less onerous to the owner/operator. Think about this - if you are an engineer with information from the manufacturer about an in-service condition that could cause damage or hull loss and you received no comments from industry, owners or operators about other mitigating factors that you are required by policy to consider and would help you to decide when to make the AD applicable or what it should require, then it would be easy to accept the inspection criteria and compliance times outlined in the manufactuer's SB without modification, even if the SB was written in 1991. The FAA recognizes that this is most likely not a good basis to make decisions, so the FAA went to industry and type clubs and organizations like the EAA, AOPA and SSA to get this input beforehand so that they could react to the operator's concerns before they started to get complaints after the AD goes out in the mail. The FAA took this action in response to requests, concerns and complaints from you, the flying pilots. Sometimes the FAA engineers guys become human and make mistakes (don't get me started on the bad AD's I've had to deal with) and the result is a bad AD that maybe has an error. This is just as bad for the FAA as it is for the owner/operators. Really good input and a second set of eyes is valuable to the AD writers, so they welcome your input and quality control. Nobody reads these AD's like the people affected - just ask an air carrier engineering department, they literally dissect AD's and are ruthless if there is a factual error. Many AMOCs are issued to correct errors or grant immediate relief within hours of an AD being published. The FAA engineers want to know about ANY problems before the AD gets published, believe me! If this diatribe rubs you the wrong way because you don't like the gubmint no matter what, personally I don't care - but consider this: I do not believe any of the other countries in this world afford this kind of influence early on in their small aircraft AD development process. Of course, I could be wrong, and I usually am. Evidence to the contrary always welcome. What Action You Can Take: It is important that you - the owners, operators, glider repair stations, SSA members, glider parts suppliers, club members that have financial interests in your collectively-owned fleets - to have input to the creation of these rules. This is real influence that is provided to you, as a service, by the FAA through your type club, affiliation, organization or whatever. Take advantage of it and help the FAA get the good and valid information they need to create the airworthiness documents that affect you as a glider pilot and aircraft owner. Join the AOPA because they started this for the small airplane crowd and have borne the burden of managing this program. Join the SSA because they are your (the glider owner) pipeline to the ACP process - you can only go through the SSA to the AOPA to the FAA ACP. A private owner has no avenue for input except through the organization or type club listed in the documents above. Send a message to your Regional Director with your concern for your affected aircraft. Comment on AD NPRM's when they are published. Google AD NPRM - I did, and I get Seaplane Owners Association, Bonanza Society, Short Wing Piper Club, etc. These people are taking advantage of this program to influence their AD's before they are published, not to mention knowing about them well ahead of the letter in the mail, sometimes even before they get the service bulletin from the manufacturer. If you own an experimental glider, consider accomplishing all TN's and SB's even though they will not be mandated by AD in the US - what difference does it make to you if the propeller is going to fly off your Nimbus 4DT because of defective bolts if it's an AD or not? The D means dual (Duo?) and that means you have a passenger that is relying on you to be doing the right thing, right? Put an ELT in your glider - and do it right: (for example, mount the antenna in accordance with the installation instructions, which means for an AmeriKing, within 20° of vertical) http://www.jimphoenix.com/jimphoenix...Nfuselage.html Comply with the FARs when maintaining or altering your glider. Nobody that I know enjoys receiving a Letter of Investigation from the FAA. Normally, it does not go well. Support your local glider repair station and suppliers with all of your spare parts purchases, maybe you'll save twenty bucks by buying your transponder on ebay, but that's twenty bucks your glider supplier or repair station won't have to keep their door open - then who you gonna get to change your driveshaft on your Stemme, or tow your 1-26? Check the AD's on your installed appliances, like your Becker comm, United altimeter and Goodyear tire. Jim |
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