Checkout_my_Six
Touchdown! Greaser!
Happy Easter Tom..... 
E/AB engines
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Tom-D
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2U2.Happy Easter Tom.....
Clip4
Final Approach
You certainly think about using junk parts a lot.
Kenny Phillips
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Kenny Phillips
The bottom line: Say that the FAA issues an AD for cracking against the crankshaft in that very Frankenental engine you cobbled together from bits and pieces (used, reconditioned*, PMA, OEM, whatever). Also assume that the FAA won't bother to enforce it for E/AB aircraft (even if they technically could). And say that by inspecting the crankshaft, you may find that it's not in danger of cracking, but that inspection requires a complete tear down.
Are you going to ignore the AD?
Not me. I've had a crank let loose on a blown alcohol drag bike (I used to do jaunty things in the olden days); it wasn't pretty, and was quite hairy slowing down with oil on the rear slick. That was absolutely harrowing at ground level. There is zero chance that I'm going to fly that plane without some serious investigation.
*I'm of the belief that many parts can be reconditioned or remanufactured to the point of continued airworthiness (though it may not be economically feasible to do so.)
Are you going to ignore the AD?
Not me. I've had a crank let loose on a blown alcohol drag bike (I used to do jaunty things in the olden days); it wasn't pretty, and was quite hairy slowing down with oil on the rear slick. That was absolutely harrowing at ground level. There is zero chance that I'm going to fly that plane without some serious investigation.
*I'm of the belief that many parts can be reconditioned or remanufactured to the point of continued airworthiness (though it may not be economically feasible to do so.)
AMOCs are not "part" of the AD. They have to be requested by someone outside the FAA and are available for every AD. It can be as simple as requesting a change to the compliance time to whatever. I've done 2 personally and helped on several others. In the case of entire fleets being hit with an AD, the manufacturer has been known to get involved and get a Global AMOC approved that can be used by anyone. As to the expense, if a phone call or email is too much to spend then I can't help you there as each one I was involved with cost just a phone call.
Tom-D
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and usually isn't
Doesn't matter how or who, it's still gets approved by the FAA, and most ADs never have one put requested.
May be in your world, but the 2 of the ones I did were done over the phone with the assigned AMOC rep and they faxed the AMOC to me. I contacted the local FSDOs and sent them a copy. One was for a 10 day extension on the AD compliance date and the other was to authorize the pilot of a private helicopter to perform the daily recurring inspection for 30 days once I performed/signed the initial inspection. The last one was over a decal requirement. So it really depends. Unfortunately most A&Ps and owners don't know AMOCs exist at all.
FYI: AMOCs are approved to the person/aircraft so 99% of them are not out in the public domain unless they're a Global AMOC which is put out by a mfg'r/certificate holder, or like the one in your example by the holder of the STC rather than making their STC customers each have to get an AMOC.
Tom-D
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I tried to get one for the MA3SPA carb venturi FSDO stone walled me. then they re=wrote the AD 4 times, in the end it was what we wanted. "leave it in place, and inspect every 100 hours.
Interesting. While AMOC instructions tend to change with each AD, I've never seen a FSDO directly involved in the AMOC process except if it was a 135/121 ops as they require contacting the assigned PMI. Part 39.19 states to contact your "principal inspector" but most GA level ops in my experience are not assigned a PMI, so you are given the option to send it direct to the AMOC manager which is how I did it. The only other time I've seen the FSDO involved is you are required to inform your local FSDO prior to using the AMOC. The approvals normally come out of the ACO level or higher and the person designated to approve AMOCs for the specific AD is listed in the body of the AD like this current AD 2019-07-02:
(f) Alternative Methods of Compliance (AMOCs)
(1) The Manager, Los Angeles ACO Branch, FAA, may approve AMOCs for this AD. Send your proposal to: Danny Nguyen, Aerospace Engineer, Los Angeles ACO Branch, Compliance and Airworthiness Division, FAA, 3960 Paramount Blvd., Lakewood, California 90712; telephone (562) 627-5247; email 9-ANM-LAACO-AMOC-REQUESTS@faa.gov.
(2) For operations conducted under a 14 CFR part 119 operating certificate or under 14 CFR part 91, subpart K, we suggest that you notify your principal inspector, or lacking a principal inspector, the manager of the local flight standards district office or certificate holding district office before operating any aircraft complying with this AD through an AMOC.
Was there a reason you didn't directly submit to the AMOC approval manager listed in the AD?
Tom-D
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Sea FSDO was the ones who issued the AD, and in the 90s the issuing FSDO was the MOC manager.
Well if the SEA FSDO told you they issued an AD then they BS'd you beyond belief. All ADs can only be authorized/issued from the Directorate level or above. It's been that way for years and way before the 90s. There are several guidance docs that state this specifically. I'll send you a copy when I find it. I miss the GADO days as they had people who actually knew the regs.
Tom-D
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I don't know where you are getting your info..
but this came right off the AD
Note 2: Information concerning the existence of approved alternative methods of compliance with this airworthiness directive, if any, may be obtained from the Seattle Aircraft Certification Office.
(g) Special flight permits may be issued in accordance with sections 21.197 and 21.199 of the Federal Aviation
Regulations (14 CFR 21.197 and 21.199) to operate the aircraft to a location where the inspection requirements of
this AD can be accomplished.
(h) The actions required by this AD shall be done in accordance with the following Precision Airmotive
Corporation SBs:
FOR FURTHER INFORMATION CONTACT:
Richard Simonson, Aerospace Engineer, Seattle Aircraft Certification Office, FAA, Transport Airplane Directorate,
1601 Lind Avenue, SW, Renton, WA 98055-4056; telephone (425) 227-2597, fax (425) 227-1181.
Doc Holliday
En-Route
Seattle FSDO has nothing to do with Seattle Aircraft Certification Office. Two totally separate entities.
Well, Mr. Simonson doesn't work at the Flights Standard District Office (FSDO). It maybe in the same building, but an ACO which is part of a Directorate is exactly the info I was talking about. So if you mistook Mr. Simonson to be your PMI at the FSDO, well I can't help you there my friend. If you still want a link to the FAA Order on ADs let me know.
Tom-D
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When these people all work in the same building and for the same organization, they are all the same to me.Well, Mr. Simonson doesn't work at the Flights Standard District Office (FSDO). It maybe in the same building, but an ACO which is part of a Directorate is exactly the info I was talking about. So if you mistook Mr. Simonson to be your PMI at the FSDO, well I can't help you there my friend. If you still want a link to the FAA Order on ADs let me know.
I attended 4 conferences about this AD, Terry Stodard wrote the AD and had to do it 4 times to get it right.
The whole mess was completed on the FSDO side of the house then passed off.
X3 Skier
En-Route
Interesting position to take. If true, you would go to a building that holds the DMV, the Building inspector, the tax collector and the Sheriff, you would have no problem asking the building inspector or Sheriff to review your tax return. The all work for the County Government in my location.
Cheers
Tom-D
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They all become city Bureaucrats with different phone numbers.
Ha! But just a word of caution: the next time you walk into a hospital make sure the doctor's name tag doesn't say "OB-GYN" BEFORE YOU SAY yes.
Checkout_my_Six
Touchdown! Greaser!
yup....that'd be the baby division of the FSDO. 