New PA28 AD

Can I comment inappropriately? Something along the lines of, “I don’t even own a Piper and I think the AD writer is a moron.”? ;)
The website notes that the FAA may not publish comments it considers inappropriate. Do as you wish and I'm sure it'll be FINE.
 
is this the complete set of applicable AD's?
Yes, under the Current tab. If you wish to see the revision/supersede history of an AD, if applicable, research the AD number under the Historical tab.
 
Can I comment inappropriately? Something along the lines of, “I don’t even own a Piper and I think the AD writer is a moron.”? ;)
Isn't "AD Writer" and "moron" a bit redundant?

sorry, it's been a lousy morning.
 
I found this: http://www.airweb.faa.gov/Regulatory_and_Guidance_Library/rgAD.nsf/MainFrame?OpenFrameSet
where you can browse and open your aircraft type and see all the AD's. is this the complete set of applicable AD's?
Yes and no. There are ADs on the airframe, the engine and "appliances", which are hoses, avionics, radios, prop, just about everything that is attached to the airplane or the engine. Which means you have to know everything in the airplane, and check all of them. Not just as easy as looking up the ADs from New Piper for the PA28. To make it even more time consuming, there are ADs on the entire product line (e.g. PA28) as well as ADs for specific models and even specific serial numbers. This is where you can do all the research yourself and keep a spreadsheet of everything or depend on the A&P/IA.

There are companies that you can pay a yearly fee just to keep track of everything. I tried it for a year and discovered they identified many ADs that weren't applicable to my aircraft. And missed a few that were.
 
Yes and no. There are ADs on the airframe, the engine and "appliances", which are hoses, avionics, radios, prop, just about everything that is attached to the airplane or the engine. Which means you have to know everything in the airplane, and check all of them. Not just as easy as looking up the ADs from New Piper for the PA28. To make it even more time consuming, there are ADs on the entire product line (e.g. PA28) as well as ADs for specific models and even specific serial numbers. This is where you can do all the research yourself and keep a spreadsheet of everything or depend on the A&P/IA.

There are companies that you can pay a yearly fee just to keep track of everything. I tried it for a year and discovered they identified many ADs that weren't applicable to my aircraft. And missed a few that were.

I spent a ton of time doing exactly this when we got our Cherokee 140. Now I have a very complete list of all the airframe, power plant, prop, and appliance ADs. It was a lot of work. And a lot of A&Ps miss ADs unfortunately.
 
Can I comment inappropriately? Something along the lines of, “I don’t even own a Piper and I think the AD writer is a moron.”? ;)
Make sure to use TOR and DDNS, and few other tools that I am not allowed to discuss in public

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Okay, so my Archer's serial number is in the AD, and my plane was made in 98. Is it even humanly possible for a plane to be flown for 20 years, by 4 different owners, and not one of them would notice that the tank selector was backwards? (It's not, by the way.)

This AD really should get an award for stupidity.
 
Okay, so my Archer's serial number is in the AD, and my plane was made in 98. Is it even humanly possible for a plane to be flown for 20 years, by 4 different owners, and not one of them would notice that the tank selector was backwards? (It's not, by the way.)

This AD really should get an award for stupidity.
Mine is 79 model, there were I think about 7 different owners before me including Air safety institute ...and need an AP to look at something saying left is left to sign it off...grr

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Mine is 79 model, there were I think about 7 different owners before me including Air safety institute ...and need an AP to look at something saying left is left to sign it off...grr

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Comment appropriately on regulation.gov please.
 
If you want a quicker answer to your docket comments, why don't all you Piper owners submit a AMOC request to your local FSDO or the Atlanta ACO per section K of the AD requesting permission to comply with the AD as pilot owner. Draft the request exactly per the available FAA guidance. AMOCs are only given to owner/operators or manufacturers so everyone affected would need to submit. I would think getting a 100 AMOC requests would have more impact than a 100 docket comments.
 
Mine looks more like this, well exactly like this.

503.jpg


But the "place fuel selector on left tank, watch left tank gauge head towards empty then place selector on right and watch right gauge head towards empty seems to work just fine.
That's the style I have, too. The SB that the AD enforces requires you to have an A&P enter in the logs that the AD does not apply to your plane, otherwise your plane is not airworthy after February 7. I think that at least this step could be accomplished by a private pilot, a learning-disabled parakeet, or even an FAA AD author.
 
Okay, so my Archer's serial number is in the AD, and my plane was made in 98. Is it even humanly possible for a plane to be flown for 20 years, by 4 different owners, and not one of them would notice that the tank selector was backwards? (It's not, by the way.)

This AD really should get an award for stupidity.
Yes it is possible, that's why the AD. They are sometimes issued when people ignore mandatory sbs. Like the one in the 172 horizontal. Four annuals with cracked spars.
 
Yes it is possible, that's why the AD. They are sometimes issued when people ignore mandatory sbs. Like the one in the 172 horizontal. Four annuals with cracked spars.
You are absolutely right! Possibly misplaced fuel selector placards are equal to possibly cracked horizontal stabilizer spars. This certainly requires the eyes of a certificated airframe mechanic within the next two weeks! No justification or comment required! Think of the children! It’s only money and asinine regulatory behavior safety first!

(That was sarcasm)
 
If you want a quicker answer to your docket comments, why don't all you Piper owners submit a AMOC request to your local FSDO or the Atlanta ACO per section K of the AD requesting permission to comply with the AD as pilot owner. Draft the request exactly per the available FAA guidance. AMOCs are only given to owner/operators or manufacturers so everyone affected would need to submit. I would think getting a 100 AMOC requests would have more impact than a 100 docket comments.
Is there a form for AMOCs or does one just write a letter to the FSDO proposing the alternative method of compliance?
 
Is there a form for AMOCs or does one just write a letter to the FSDO proposing the alternative method of compliance?
The FAA rules that I've found seem to say that if you don't have a PI then send the letter, email, or call the guy listed on the AD. I'm trying to figure out the text of the AMOC request so that it can be approved. As best I can tell the AMOC must provide an equivalent level of safety as the AD and there apparently should be some justification such as "a better means of compliance"

If someone has a link to and example AMOC request letter or majic google search words to find such a letter it would surely be appreciated. So far I've drawn a blank.
 
I read the AD, nodded off then woke up and tried to read it again. It isn't clear exactly who can sign this off and/or how the entry must read.
 
I read the AD, nodded off then woke up and tried to read it again. It isn't clear exactly who can sign this off and/or how the entry must read.
Bell posted the language he believes is required for owner/pilot to complete the inspection.

Certainly the cost calculation contemplates a certificated airframe mechanic charging for inspection, documentation, and ass scratching. If anyone spends half an hour on this something is wrong.
 
Advisory Circular 39-10 is here: https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_39-10.pdf

It spells out what you need to provide in an AMOC request. Go ahead and flood their fax machine with requests. Here's one thought on how to word it (I am not an aviation lawyer; I am not your lawyer; I am just some guy on the internet (SGOTI) who is frustrated that he needs to buy a brand of beer he doesn't even like for an A&P to look at his plane in the next two weeks and confirm that this AD doesn't apply to it):

This is an alternative means of compliance for the recent airworthiness directive covering Piper PA-28 series aircraft. As required by AC 39-10, I am the requester and my complete name and mailing address are:

...

The affected product is the Piper PA-28..., serial number ..., registered in the state of ..., and manufactured in the year of .... I am the registered owner of this airplane. I hold a private pilot certificate. The AD number is 2018-02-05. The specific AD paragraph to which this proposal applies is paragraph (g) "Inspect Fuel Selector Cover."

The AMOC proposal is for the owner, who holds at least a private pilot certificate, to obtain a copy of Piper Service Bulletin (SB) 1309, which is mandated by this AD, and proceed as follows:

The private pilot-owner may comply with Part I, Inspection, Steps 1 (RC - Identifying Fuel Selector Cover Configuration) and 2 (RC - Identifying Placard Configuration). Provided that SB 1309 does not apply according to Part I, Step 1, or that no replacement is required according to Part I, Step 2, the private pilot-owner may comply with Part IV, Documentation of Compliance.

This AMOC will achieve the same level of safety that the AD achieves because a private pilot-owner is equally capable of looking at the pictures in SB 1309 and determining whether the fuel selector cover in his or her airplane looks anything like the affected fuel selector cover and whether the placards are in the same locations as depicted in those pictures. The airplane described in this AMOC has been in service for ... years without any known losses of engine power due to the quality control issues addressed by SB 1309 and AD 2018-02-05. On inspection, SB 1309 does not apply to this airplane (or no replacement is required). There is no additional level of safety that can be provided by having a certificated mechanic inspect the fuel selector cover and document compliance with the AD beyond the level of safety that is provided by the private pilot-owner doing so.
 
Did you ever let guys in school copy your homework? Would you let someone copy your AMOC request? (Asking for a friend)
Someone else gets the credit. See post 68. I changed the wording some to show the AMOC was better since it incurred no direct costs for the owner/operator. One of the things listed in the FAA approval guidance is that the AMOC is somehow better than the AD.
 
Someone else gets the credit. See post 68. I changed the wording some to show the AMOC was better since it incurred no direct costs for the owner/operator. One of the things listed in the FAA approval guidance is that the AMOC is somehow better than the AD.
Oops, I didn't see it thar!
 
No worries. Lots of contributors in this thread.
 
Someone else gets the credit. See post 68. I changed the wording some to show the AMOC was better since it incurred no direct costs for the owner/operator. One of the things listed in the FAA approval guidance is that the AMOC is somehow better than the AD.
Ok, just finished mine...did you send it by fax, email, mail? I note that the AD lists the Atlanta ACO Branch Manager's info...
 
Ok, just finished mine...did you send it by fax, email, mail? I note that the AD lists the Atlanta ACO Branch Manager's info...
emailed it. The FAA says they prefer snail mail but timing of the AD does not allow that. The FAA notes that they accept snail mail, email, fax, and telephone call AMOC requests and are required to document each request.
 
It spells out what you need to provide in an AMOC request.
First, iamtheari gets the Gold Star for the week!

Second, if the feds start approving these AMOCs, remember you will need to reference the AMOC and its date when making the AD entry and signing it off per 43.9... with your certificate number.

Third, be sure to inform your local FSDO you are using an AMOC if you sent the request direct to the Atlanta ACO.

Good luck.
 
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I emailed out mine...not that it should matter, but I logged in from home to my work email to send it, which also ends in a ".gov" address. I removed my normal signature, and my work email is a nonsensical acronym, so maybe I'll leave them wondering exactly who is requesting the AMOC.
 
Ok, just finished mine...did you send it by fax, email, mail? I note that the AD lists the Atlanta ACO Branch Manager's info...
There are online fax applications that will take your email and send it as a fax. Some are free, some are a small cost (e.g. $1 or less a page).

Just in case.
 
I emailed out mine...not that it should matter, but I logged in from home to my work email to send it, which also ends in a ".gov" address. I removed my normal signature, and my work email is a nonsensical acronym, so maybe I'll leave them wondering exactly who is requesting the AMOC.
I thought the AMOC request had to include the requester's name and address.
 
I thought the AMOC request had to include the requester's name and address.
It did. But my point was, my name and address, by themselves, would not explain why my request is coming from a .gov address.
 
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