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Advocacy Advocacy Briefs Regulatory Brief -- FAA issues changes to V-tail Bonanza ADs

Regulatory Brief -- FAA issues changes to V-tail Bonanza ADs

Regulatory Brief

FAA issues changes to V-tail Bonanza ADs

The issue:

In October 2002, the FAA published two Airworthiness Directives (ADs), 94-20-04 R1 and 2002-21-13, affecting Raytheon/Beech Models 35 through V35B. These ADs revise and supersede AD 94-20-04 and AD 98-13-02. Both proposals are also intended to condense and clarify the information presented in AD 94-20-04 as well as provide a means to eliminate the operating limitations currently imposed upon affected airplanes. AD 94-20-04 R1 addresses all V-tail models except models 35, 35R, A35, and B35, which are addressed in AD 2002-21-13.

The importance to our members:

These ADs affects approximately 12,411 US registered aircraft. Although the ADs are intended to clarify AD 94-20-04, AOPA is concerned about the FAA's inspection procedures including those procedures referenced in Raytheon Service Bulletin No. SB 27-3358, Issued: February 2000. In particular, AOPA feels that many of these inspection parameters are unwarranted and places an undue burden on the owners of models 35, 35R, A35, and B35 who want to eliminate the more restrictive operating limitations. The final provisions of the final ADs remove much of the concern over the compliance provisions set forth in Raytheon Service Bulletin No. SB 27-3358.

Significant provisions:

AD 94-20-04 R1:

  • Revises AD 94-20-04, which currently requires ruddervator inspections, modifications, and operating limitations on certain Raytheon Beech Models 35, 35R, A35, B35, C35, D35, E35, F35, G35, H35, J35, K35, M35, N35, P35, S35, V35, V35A, and V35B airplanes.
  • Condenses and clarifies the information presented in AD 94-20-04 and removes the Beech Models 35, 35R, A35, and B35 airplanes from the applicability of AD 94-20-04.
  • Actions applicable to the Beech Models 35, 35R, A35, and B35 airplanes are placed into AD 2002-21-13
  • Actions specified by the AD are intended to continue to prevent structural failure of the V-tail, which could result in loss of control of the airplane.

AD 2002-21-13:

  • Supersedes AD 98-13-02, which currently requires operating limitations on Raytheon Beech Models 35, 35R, A35, and B35 airplanes.
  • Is the result of Raytheon developing inspection and modification procedures that, when accomplished on the affected airplanes, would eliminate the need for the operating limitations.
  • Retains the operating limitations for the affected airplanes until the AD required inspection and modification procedures are accomplished, and requires repetitive inspections of the fuselage structure.
  • Actions specified by the proposed AD are intended to continue to prevent structural failure of the V-tail, which could result in loss of control of the airplane.
  • Issues raised in AOPA and industry comments to the proposed AD and corresponding FAA actions in final AD:
    • In Service Bulletin (SB) 27-3358, Raytheon is specifying certain test equipment that does not currently exist at Raytheon's own service centers. Skin thickness determination by sonic testing (ultrasound) is not necessary. Direct measurements taken at a lap joint or similar area using a micrometer or similar tool should be more than sufficient to determine the overall thickness of the skin.
      • Final AD specifies several acceptable methods for identifying skin thickness.
    • The skin thickness specifications should directly reflect the actual production specifications for each model affected.
      • Final AD references specific skin thicknesses that are specific to each airplane serial number and the location of each skin part number.
    • Skin thickness measurements should only be taken one time. Repetitive measurements are unwarranted since it is a virtual impossibility to surface clean the skin below acceptable production tolerances. A one-time inspection will catch any replacement skins that are below tolerance.
      • Final AD requires only a one-time skin thickness inspection.
    • Propeller balancing should be done with any equipment that meets or exceeds the specifications. The requirement for propeller balancing should be based on a Time-In-Service since the last overhaul thereby not placing an additional burden on operators who have recently overhauled their propeller.
      • Final AD does not require propeller balancing.
    • A Designated Engineering Representative (DER) should not be required to review the airplane logbooks and documents of prior major modifications. Maintenance personnel holding an FAA Inspection Authorization (IA) certificate can sufficiently conduct this required review. If needed, the IA mechanic could request a DER review of any modification deemed questionable by the IA. Many of these older modifications may not have data that is suitable by newer FAA standards and that a DER review of older modification data may result in declaring the airplane not airworthy. If an IA mechanic has serious concerns or questions regarding a modification, a DER may be used for further review.
      • Final AD does not require DER review of major structural modifications.

AOPA position:

AOPA agrees that the previous V-Tail ADs were confusing with respect to their applicability and required action and concurs with the FAA on its effort to provide more clarity. AOPA is pleased that FAA has addressed concerns made in our comments by revising proposal 2000-CE-44-AD and incorporating crucial changes recommended by AOPA and the American Bonanza Society.

Status:

  • On October 24, 2002, FAA published final AD 2002-21-13
  • On October 21, 2002, FAA published final AD 94-20-04 R1
  • On March 26, 2001, the FAA issued Notices of Proposed Rulemaking 93-CE-37-AD and 2000-CE-44-AD.
  • On May 25,2001, AOPA submitted comments to the FAA regarding 93-CE-37-AD and 2000-CE-44-AD.

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