EAA is imploring the FAA to reconsider an AD it says would be impossible to achieve and unnecessarily broad in scope. The agency is proposing action that would require replacing the rudders on almost 31,000 legacy high-wing Pipers. “EAA believes this AD is flawed in regulatory process, scope, and requirements,” the organization said in its comments on the AD. “It is based on limited data, the required action is not possible in the timeframe required, the affected models list is vast, and the action required is excessive.” EAA wants the FAA to rescind it in favor of a Special Airworthiness Bulletin and do more studies on whether it’s needed at all.
The incidents involved in-flight rudder post failures on a Piper PA-12 Super Cruiser and a PA-14 Family Cruiser. In both cases, the pilots were able to land safely. Both aircraft were on floats, had aftermarket 160 horsepower and rudder-mounted beacons “which likely altered the stress on the rudder posts.” EAA says. The AD calls for the fleet replacement of stock rudders that were made of 1025 carbon steel with new rudders made with 4130 low-alloy steel in two, three or five years depending on model. EAA said at current production rates, supplying the rudders would take 75 years. EAA’s Vintage Aircraft Association also filed comments and suggested an inspection and repair alternative to replacing the rudders.
