The final ruling on the wing spar AD - 98-CE-121-AD
The National Aeronca Association (NAA) is an aircraft "type-club" with
a membership approaching 1,500, most of whom are Aeronca owners. The goals of the
organization are to promote safety, to provide organized activities which involve the
membership technically and socially and to assist members in locating needed aircraft
information and parts.
In November of 1998 the Federal Aviation Administration issued a proposed
Airworthiness Directive (AD) which, if enacted, would require that each Aeronca owner's
aircraft undergo a special inspection in order to comply with the AD. This quickly
became a vocal issue with the NAA membership and other Aeronca owners.
The NAA publishes a quarterly membership magazine. Jim Thompson, the NAA
president, has addressed the AD issue in the "President's Message" section of
the magazine for the last five issues. In order to keep our website viewers well
informed concerning Aeronca matters, we have elected to post those messages. New
developments will appear here as the NAA makes the information available.
Note: The following are the President's Message as
they appeared in the NAA magazines.
One the Lighter Side
The following letter was received at the National
Aeronca Association head-
quarters, along with hundreds of others, during the comment period for the
notice of Proposed Rule Making which resulted in AD. No. 2000-25-02. I have
no way of knowing if it was actually sent to the FAA, but I decided to reprint
thinking that perhaps many of our members and other Aeronca owners would
experience a chuckle or two while reading it.
Jim Thompson, President
President's Message - #8
The FAA has recently revised their policy regarding the
development of Airworthiness Directives (ADs). We
have observed indications in recent years that they were recognizing the need to
their procedure. Other aviation organizations were also observing the change in
attitude, as there have been comments in several EAA publications as well as
publication, the AOPA Pilot.
Early last summer, AOPA hosted a meeting which was well attended by
representatives from the FAA, AOPA, EAA, and about a dozen different type-clubs.
purpose of this meeting was to give the FAA an opportunity to explain their new
proposal and to obtain reaction from the type-club representatives. Then at Air
2000 (Oshkosh), the EAA hosted a second meeting with basically the same
attendees. This meeting was largely a repeat of the first meeting.
The FAA’s process of generating an AD is of necessity both lengthy and complex.
An explanation of the complete procedure is beyond the scope of this message.
it appears that a greatly simplified explanation will help provide
the FAA’s logic for their policy change.
The typical AD comes about as a result of a safety concern, usually detected by
the manufacturer, who issues a service bulletin to advise those affected and to
a procedure for dealing with the problem. Meanwhile the FAA is working on risk
assessment and other factors to determine if the concern produces sufficient
risk to require an AD. If so, the manufacturer’s service bulletin usually
becomes the compliance document. Unless it’s an emergency, Congress requires
before issuing an AD. the FAA must publish a Notice of Proposed Rule Making (NPRM)
to make provisions for public comments. After evaluating these comments the FAA
final decision regarding the proposed AD.
While not without fault, this procedure has worked very well where the concern
involved a product associated with an active type certificate. It is when the
is no longer in production or the original manufacturer is no longer in business
FAA uses the words “orphaned airplanes”), that we have a greater potential for
with the process. The FAA is quick to point out that the manufacturers are
for the safety of their products and, under these circumstances, there is no
manufacturer to develop a service bulletin. This leaves the FAA in an awkward
as they must develop a compliance document for the AD with a minimum of
The FAA has recognized in the last few years that the type-clubs are the best
sources of technical information for the “orphaned airplanes.” Therefore, they
revised their AD development policy to include input from the type-clubs before
generate the NPRM, rather than after.
This appears to be a response to some basic problems with which the
FAA is confronted. The first being that the employment longevity of their
staff is decreasing, which means that many of the more mature employees who were
familiar with the older airplanes (they speak of the “aging fleet”), have
are, therefore, relying on the type-clubs for expertise. In fairness, this is
understandable as we sure shouldn’t expect them to be experts in all areas.
second area of concern is to “get it right the first time.” In too many cases
issued an NPRM only to have the associated type-club point out a much simpler
to resolve the issue. The FAA, in many cases, must then rework and in some cases
reissue the NRPM. Additionally, if you follow ADs you probably have noted that
amended and then the amended AD gets amended. Some ADs may be amended a half
times. All of this adds time to the process and is counterproductive to the
Will this policy change work? It is certainly a step in the right direction and
can result only in the improvement of the process. We all have the same goal—the
the type-clubs, and the aircraft owner—all want safe airplanes and the basic
of an AD is improve safety. There is a need for ADs. However, ADs add to the
flying and, as I have stated in previous President’s Messages, the NAA remains
in our opposition to any unnecessary restrictions on our aircraft or flying
and will be actively involved with any NPRM which affects either.
President's Message - #7
Perhaps this message should begin with a brief review of the National
Aeronca Association’s efforts regarding the AD listed above.
The FAA issued a Notice of Proposed Rule Making (NPRM)
on November 3, 1997, which would require annual spar inspections of all
wood-spar American Champion Aircraft Corporation aircraft, including
Aeronca-built 7 and 11 series aircraft (Champs and Chiefs).
selected a team of very knowledgeable and well-respected members from the NAA roster and we went to work to develop an NAA reaction plan. After much
discussion, we concluded that the Aeronca-built airplanes, and some early
Champion models, were of lower horsepower, weight, and speed, than the later
aerobatic aircraft built by Champion Aircraft Corporation. For that and
other reasons, they should be excluded from the proposed rule. The
statistics associated with the Service Diffi-
culty Reports (SDRs), applicable to the Aeronca 7s and 11s, supported our
point of view. Therefore, the initial focus of our efforts were directed
toward the exclusion of Aeronca-built, and the early Champion-built
aircraft, from the proposed AD.
We then obtained a label listing of all registered
owners of the previously identified aircraft. Then, nearly 13,000 pages of
informational material was generated to be used in a mailing to more than
4,200 registered owners advising them of the impending AD and encouraging
them, if their point of view agreed with ours, to write the FAA with
comments supportive of the exclusion of Aeronca airplanes from the
forthcoming AD. One of our board members is also a member of the Flying
Angels, a flying club in New
Carlisle, Ohio, and they volunteered to
stuff, label, stamp and mail the “special alert” for us. This worked well,
as we received copies of hundreds of well-written letters which you, the
owners, had mailed to the FAA.
Since the more prominent aviation organizations
associated with general aviation had previously indicated they also believed
that including the lower-horsepower Aeronca airplanes was not justified, we
at the NAA felt that the FAA had received comments of such substance and
number that the final rule would be different from the NPRM, and our Aeronca
airplanes would not be subject to the proposed AD...but it was not to be!
When the FAA published their response to comments they
had received concerning the NPRM, they rejected all of the many hundreds of
comments regarding the exclusion of the lower-horsepower 7s and 11s from the
final rule. However, all was not lost! Someone had suggested that they
withdraw the currently existing wing spar inspection AD on the Scout (8GCBC)
and combine it with the AD they were now proposing for the Decathlon (8KCAB)
and the other 7s and 11s. The FAA agreed. While this approach was very
logical, it further increased the scope of the proposed AD and made it even
more absurd to mandate the
requirements for all aircraft. More importantly perhaps. bringing the Scout
AD into the proposal would require that they issue a new NPRM and provide
for a second comment period. This would provide us with one more opportunity
to mail in comments, which hopefully would convince the FAA to make a
distinction between the lower-horsepower 7s and 11s and the later-built
aircraft which were heavier and faster.
When I first viewed the new NPRM, I
was shocked to learn that the second comment period was limited to 45 days.
I immediately wrote the FAA a letter requesting that this time period be
extended and they agreed. (See a copy of FAA letter posted following this
President’s Message.) We now had time to make a concentrated effort to bring
The NAA task force team was hard at work in an effort
to develop a plan that would resolve the issue. The NAA and the FAA have the
same basic goal. Both groups want safe airplanes. The FAA database of SDRs
supports the position that our Aeronca airplanes have a safety record
indicating that they are not a safety threat. And, since we judge the future
by the past, we should not have a future wood spar safety problem. However,
the FAA seemed concerned about the completeness of the past record. Since
SDRs are not mandatory, there may have been spar cracks discovered by A&P/IAs
that were not reported to the FAA.
Slowly a plan evolved. We would go for a
one-time inspection of all the lighter-weight, lower-horsepower aircraft.
The decision was made to make the cut-off point at 90 horsepower. This 90
horsepower cut-off would take care of all our Aeronca 7 and 11 series
airplanes as well as some early model Champions. The plan would assure the
FAA and us that
our Aeronca spars were crack free and that we would be flying safe
Once again we obtained a label list of owners of all
registered 7 and 11 series Aeronca and early Champion-built aircraft
originally equipped with 90 horsepower engines or smaller. Next, a new
mailing was prepared. This time nearly 17,000 sheets were printed. In them
we explained our revised position concerning the proposed AD and suggested
that, if the owners’ thinking agreed with ours, they write comments to the
FAA supportive of the plan. This mailing went to the registered owners and
to the major general aviation organizations. For a second time the Flying
Angels flying club did a fantastic job of getting the 4,200 plus "special
alert” letters stuffed, labeled, stamped and mailed.
The next step involved follow-up with the aviation
organizations. This was done by phone and was simply an effort to call
attention to the informational package they had received from us concerning
the NPRM and to solicit their support. The Antique Airplane
Association in Blakesburg, Iowa, wrote a very supportive letter. The Vintage
Airplane fellows came through with multiple letters. The Experimental
Aircraft Association wrote an excellent letter. The Aircraft Owners and
Pilots Association was very positive when first contacted. However, for some
unexplained reason, they called the next morning to advise me that they
would not be supporting our plan.
By chance, we had made contact with the Bellanca
Champion club in Coxsackie, New York, and their President wrote a fine
letter to the FAA in support of our proposal. (Incidentally one of our NAA
team members owns a Citabria and is a member of this club. He speaks very
highly of their substantial support program for their Citabria line of
aircraft.) No other aviation orga-
nizations or type clubs
expressed support for the one-time inspection of the lower-horsepower 7s and
11s. Again we received copies of hundreds of letters that the owners had
mailed to the FAA. The comment period ended and we had put forth our best
effort. Now it was “wait and see."
The wait ended on December 18, 2000. The Federal
Register contained a release from the National Transportation Safety Board
of AD No. 2000-25-02. This was the final rule.
A detailed reading of the AD was a rewarding
experience. The FAA had at long last acknowledged that, while all the 7s
were made under the same type certificate and the 11s' wing was of “like
design”, the lower-horsepower, slower airplanes were less likely to suffer
wood spar wing damage. Furthermore, they had divided the fleet into two
groups. The AD required that Group1, the 90-horsepower or less group,
receive a one-time-only inspection of the wood spar. Group 2, the heavier,
higher-powered models, would be required to have recurring spar inspections
at the next annual inspection or at 500-hour flight time intervals,
whichever occurs first.
The distinction made in the AD, as reflected in the
different AD compliance requirements for the two groups of planes, also
places a positive face on another concern that the NAA task force team and I
had shared, As long as the 7 series remains an active type certificate and
American Champion Aircraft Corporation continues to manufacture the
higher-powered aerobatic aircraft, there will be other ADs. The precedent
established in this AD of dividing the fleet into two groups will help us
avoid a situation where our Aeronca-built airplanes are automatically
included in future ADs for 7-series Citabrias and the 8-series Scouts and
Decathlons. A second positive note concerning the AD is that by having a
spection, we have
avoided the stigma associated with a recurring AD that has no provision for
If we examine the AD from the FAA’s point of view, they have
done their job well. The major component of the FAA’s mission is aviation
safety and ADs provide a vehicle to enhance that effort. Consider how they
used this AD to assure the safety of the fleet. In a matter of thirteen
months, all active wood spar 7s, 8s, and 11s will have received a spar
inspection. Furthermore, with
the mandatory reporting requirement of the AD, the inspecting A&P/IA will
issue a written SDR for every cracked spar found. The AD also contains the
requirement that if the aircraft is involved in an accident or incident that
has the potential to damage the wing spar, it must receive a wing-spar
inspection prior to further flight. If one of the FAA’s initial concerns was
that they needed more data concerning the current wood spar integrity of
American Champion’s 7,8, and 11 aircraft, they will certainly have that data
in the next thirteen months.
Compression cracks in wood spars are not new.
They have been around since wings have been made. In our Aeronca airplanes
they are, almost without exception, “event related.” As a result of some
“event” the wing spar becomes overstressed and the compression crack occurs.
But it is a different kind of crack. If we were to examine our spruce wing
spar though an optical device capable of very high magnification, we would
find that the spar is not solid, but of cellular structure. These tiny cells
are stronger in tension than compression. Therefore, if we overstress the
wing in an upward direction the cells are deformed along a vertical line
from the top of the spar toward the bottom, with the greatest deformation
occurring on the very top surface of the spar. The spar does not separate
along the crack line but, as a
result of the
deformation of the cells, the strength of the spar at this point is reduced.
Continued use of the aircraft has the potential, as a result of the changing
flight loads on the wing, to furiher reduce the strength of the spar at the
point of fracture and ultimately result in catastrophic failure.
Compression cracks are difficult to detect. The
greatest cellular deformation occurs on the top or the bottom surface of the
spar, dependent upon whether the overstress was in an upward or downward
direction. Therefore, these two surfaces are where the greatest surface
imperfection will appear and where the compression crack can be most easily
The compliance document, Service Letter 406, Revision
A, offers the A&P/IA a choice of two possible procedures for the inspection.
The flexible probe borescope, which is probably the better of the two, and
the use of a Bend-A-Light. If using the borescope, the surface imperfections
created by the compression crack, are most readily detected if the probe is
placed such that the viewing angle very nearly parallels the top surface of
the spar. The light for viewing may come from any angle.
Best results will be obtained from a Bend-A-Light if
the probe is positioned such that the high-intensity light source very
nearly parallels the top surface of the spar. The spar top surface may then
be viewed from any suitable angle. In this situation. it is important that
most of the available light is coming from the Bend-A-Light, for it is at
the correct angle to make the surface imperfections that are the
characteristic of compression cracks more readily visible. This means that
if your wing is uncovered and you are inspecting the spar prior to covering,
it is perhaps best that the inspection be made in subdued light.
Do not rush to judgment. There are spars which, when
were spliced on both the
horizontal and vertical axis. Bellanca did a lot of this when they owned and
manufactured the Citabria line. To the eye of an inexperienced A&P/IA, the
horizontal glue line may appear to be a crack. If your wing has been
repaired and has had ribs replaced, it is not unusual for the side surface
of the spar to have been scratched in the process. These scratches may at
first glance look like a crack. Compression cracks are most likely to appear
at the point on the spar where the greatest stress "pile-up" occurs. This,
in the case of a ground loop, will be just outboard of the plywood doubler
where the lift strut attaches to the wing. Don’t overlook the rear spar.
Should you find a genuine compression crack, be
thankful. Not thankful that the crack was there, but thankful that your
A&P/IA detected it in a hangar, rather than have you discover it at pattern
One of the NAA team members, under the heading of, “How
to Avoid Wing Spar Compression Cracks”, compiled a list of “Don'ts”.
Don’t fly aerobatics... Don’t nose the airplane over onto its back.. Don’t
do ground loops... Don’t run the wing tip into the gas pump.
I have seen two letters recently, which contained
statements that AD 2000-25-02 required inspection holes be added to the
leading edge of the top surface of the wing. Read the compliance
document, Service Letter 406, Revision A, carefully. The need for additional
inspection holes, top or bottom, is left to the judgment of the inspecting
A&P/IA. They are not mandatory. In both cases these letters were part of a
promotional brochure distributed by individuals who hoped to profit from the
AD by selling a product, service, or both, to the aircraft owner. If you
have the normal number of inspection holes in the bottom surface of the
wing, an experienced A&P/IA familiar with our type
should be able to successfully complete your inspection without additional
inspection holes. American Champion’s Service letter 4l7, Revision C, may be
used as a guide for the proper location of inspection holes. Notice the use
the word “guide.” Your A&P/IA, familiar with Champs and Chiefs, will be an
excellent judge of this.
The NAA’s principal theme throughout this effort was
that our lower-power, lighter-weight aircraft were less likely to suffer
spar damage than the larger, more powerful, aerobatic aircraft. Initially
the FAA was not receptive to our position. Several factors were very
important in providing them with sufficient information in a positive manner
so that they recognized the need to develop an AD that reflected this point
of view. It was just not logical that the range of aircraft covered by their
proposal be required to meet the same AD compliance requirements. Almost all
of the major general aviation organizations had expressed support for our
position. Most importantly, we thank you for the many hundreds of
letters you, our NAA members, and other Aeronca owners mailed to the FAA
with approving comments.
In reviewing the NAA’s involvement in this AD
development process, several thoughts come to mind... the NAA has other functions
which perhaps did not receive as much attention as they would have
otherwise.... Printing, mailing, and other costs made it necessary to
establish new priorities for our limited budget.... Selected NAA members
willingly contributed their time and knowledge to the effort All of these
thoughts ask a question. If a similar situation should arise would
I do it again? ABSOLUTELY!
'Til Next Time,
Letter from the FAA extending the deadline.
President's Message - #6
The comment period for the FAAs proposed
spar AD, applicable to all wood-spar wing Aeronca, Champion, and Bellanca 7, 8, and 11
series aircraft (Docket 98-CE-121-AD), has ended. We now have to wait for the FAA to
prepare their responses to the many comments and announce their final decision.
After the FAA approved our
extension request and extended the comment period until September 10, 1999, we once again
mailed a "special alert" message to all registered owners of the affected
aircraft suggesting that they mail comments to the FAA. This was a productive effort as we
received copies of hundreds of comments/letters from you owners. If we are successful, and
I believe that we will be, in getting the FAAs safety concern to be realistic in
real-world conditions, it will be largely a result of you the Aeronca owners becoming
involved. For that your National Aeronca Association thanks you.
There is no doubt about the
need for ADs. They promote safety, which is our highest priority. However, ADs should be
based on a real, not a perceived need. You, the aircraft owner, pilot, rebuilder, and
those who maintain your aircraft, are in many cases the best judges regarding the
justification for an AD. You live in the real world and deal with the problems on a daily
basis. Our communication with the FAA regarding this particular proposal seems to indicate
that they are beginning to recognize the importance of involving the "type
clubs" and other knowledgeable groups before issuing a proposal. I certainly hope so!
We have a very capable team
working on this task and they and your National Aeronca Association remain committed to
providing support to the membership in the area of safety, with a minimum of regulatory
restraint on our aircraft and flying environment.
In all the
National Aeronca Association sent three separate letters to the FAA within the comment
time period. A copy of the first letter was sent to all Aeronca and some early Champion
owners alerting them to the latest AD proposal. It addressed the many changes that
occurred after the Champion Aircraft Corporation of Osceola, Wisconsin, began modifying
our faithful low-gross weight, low-horsepower Aeronca 7 series airplane. The FAA approved
it for aerobatics, gave it a red line speed of 162 MPH, a 150-hp engine and a gross weight
of 1,650 pounds. They did all this without requiring any significant change in the wing
design. We also addressed the fact that after a year and a half and hundreds of comments
from concerned Aeronca and Champion owners, the National Aeronca Association was very
disappointed in the lack of any change in the FAAs position: keeping our early 7 and
11 series Aeronca and Champion airplanes in with the higher gross weight and higher
horsepower 7 and 8 series aerobatic models.
There was much more
to this letter as we spelled out the excellent service record of the low-horsepower 7 and
11 series airplanes with statistics and the FAAs own data to back it up. We
concluded with a new proposal for the FAAs consideration. The NAA proposed that
those 7s and 11s powered by a 90-hp engine or lower be subject to a one-time spar
inspection AD as prescribed in the AD proposal. The succeeding spar inspections,
would not be mandated by the AD. This would assure that this aircraft group would be free
of wing damage, and with the implementing of the FAA proposed mandatory spar inspection,
following any accident or incident (such as a wing tip strike) which has the potential for
spar damage, the group should remain spar-damage free.
By incorporating this change
into the proposal we would be assured of a safe airplane and at the same time avoid the
stigma associated with a recurring structural AD that has no terminating provisions.
The second letter referenced
the fact that Docket 98-CE-121-AD should, from the FAAs perspective, be a dream
document. It covers 30 different airplane models manufactured over a 50-year period and
includes models certificated under two different sets of certification regulations (part
23 and FAR 4A). Five different type certificates are included. The 7 series has more than
20 modifications, all of which are covered by the AD proposal. The engine horsepowers
range from 60 to 180 and the red-line airspeeds from 129 to 162 mph. The lowest gross
weights is 1220 pounds and the highest is 2540. This list could go on and on. It looks
like the only necessity for listing model numbers is to make sure that all models are
included. Yet despite its apparent administrative appeal to the FAA, it is fatally flawed
by its lack of distinction. The need for distinction is readily apparent to those
thousands of aircraft owners of affected airplanes.
Including all models in the
proposed AD and requiring the same compliance procedure for all aircraft reminds one of
the school teacher who kept the entire class after school for the poor behavior of one or
two students. Punishing the whole class offers an easy solution from a class management
perspective and yet the innocent class members are being treated unjustly.
of the letter addressed another inadequacy of the proposal that has been an
often-discussed topic among Aeronca owners. The wings of some of our 7 and 11 series
airplanes have been completely rebuilt, including spar replacement, with FAA approved PMA
spars. Here is an aircraft owner taking the necessary measures to insure that he has an
airplane which incorporates a wing spar of unquestionable structural integrity and the
spar AD proposal offers no recognition of this fact. We share the owners concern and
have offered the following proposal: Those 7 and 11 series airplanes powered by engines of
90 hp or less which have been fitted with spar-replaced rebuilt wings in the last five
years, and have in the same time frame no history of wing damage, will be exempt from the
mandatory spar inspection portion of the AD. These airplanes would be subject to the usual
non-mandated spar inspections during the regular annual inspection and the proposed
AD-required spar inspection should the aircraft be involved in an accident or incident
having the potential to damage the wood spar.
The last letter to the FAA had to do with the experience
and training of the A&P-IA. Also one more reminder of the excellent service record of
the early 7 and 11 series airplane and a list of models that would fall into the
NAAs proposal to the FAA.
Compression cracks are
difficult to see and with todays A&P training emphasizing aluminum aircraft
construction, many of the A&P-IAs are much more attuned to fatigue cracks and
corrosion than to compression cracks and wood rot. Perhaps when approving curricula for
the residential A&P schools and when validating work experience for the A&P test,
the FAA should give more consideration to compression cracks. There are still thousands of
wood spar wings out there and as long as we have airplanes with tail wheels, the ground
loop, with the wing tip striking the ground will be the leading event-related cause of
compression cracks for non-aerobatic airplanes. Issuing ADs is an ineffective way to train
aircraft mechanics to detect compression cracks.
Consider the excellent service
record of the 11-series aircraft. After more than fifty years and thousands of hours of
flying there is not one spar-related SDR or accident. This statement can be worded
differently: The 11-series has the best possible spar-related safety record.
There are several spar-related
SDRs, for the low-hp 7 series aircraft, most of which are of questionable history and
heritage, but again no accidents. Considering that Aeronca made 8,199 model 7s and they
have been flying for thousands of hours over a period of fifty years, this is quite a
remarkable safety record.
The National Aeronca
Association remains adamant in its belief that the excellent service record of the low-hp
7s and 11s merits a change in the current AD proposal.
Should the FAA see fit to make
the NAAs proposed change to the current AD proposal, the following models would be
included: 7AC, S7AC, 7BCM, S7BCM, 7CCM, S7CCM, 7DC, S7DC, 7EC, S7EC, 7FC, 7JC, 7ACA, L16A,
L16B, 11AC, S11AC, 11BC, S11BC, 11CC, and S11CC.
Thank you again for your help
and support of the latest spar AD proposal. We will keep you informed of any new
The FAA has once again changes
their position relative to the availability in printed form of their publication
"Alerts." Originally available to anyone free for the asking, the FAA recently
announced that it would be available only from the FAAs Internet website. This
apparently produced considerable response from the aviation maintenance community, as a
recent FAA announcement advised of the "Alerts" publication being available in
printed form on a subscription basis of $25 per year from the: Superintendent of
Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954.
'Til Next Time.
President's Message - #5
The FAA's proposed wood spar AD (Docket No. 97-CE-79-AD), which includes all Aeronca 7 and
11 series aircraft, continues to be an issue with the membership of the National Aeronca
As currently worded, the proposal mandates an annual
inspection of the spar. The inspection procedure and recurrence rate contains no
distinction as to the model aircraft. In other words, a 65-hp 7AC Champ, which has
never-exceed speed (Vne) of 129 mph, would receive the same spar inspection and just as
frequently as a 150-hp aerobatic Citbria, which has a Vne of 162 mph. It is true
that each plane has the same size spar; however, the structural demands on the Citabria
spar are much greater than those on your 7 and 11 series Aeroncas. (How basic can we
get?) The FAA's "one size fits all" approach is inappropriate.
The FAA's AD proposal states, "The proposed AD
results from a review of the service history of the affected airplanes that incorporated
wood wing spars." Let's look at service history as it relates to Aeronca-built
The Aeronca 11 series aircraft has not one
spar-related accident or service difficulty report (SDR). The Aeronca-built 7-series
aircraft show 8 spar-related SDRs (some are of questionable history and heritage) and no
spar-related accidents. And this is with thousands of Aeronca airplanes having flown
thousands of hours over a fifty-year period.
Why are Aeronca built aircraft being included in the AD
proposal? Your guess is as good as mine. You hear statements like, "The wings
are the same". Very true. However, the airplanes are sure different. The
7AC Champ has a gross weight of 1220 lbs and is being grouped with the aerobatic
7KCAB Citabria which
|has a gross weight of
1650 lbs. Sure, our spars need to be thoroughly inspected, and by A&P-IAs who
are familiar with our type airplanes and who know where and what to look for in the way of
cracks. However, our Aeroncas do not need the stigma associated with a structural AD
which is unjustified, has no terminating provisions, and will result in a decrease in the
value of our Aeronca airplanes by thousands of dollars.
The National Aeronca Association will continue to provide
you with additional information as it becomes available.
In this issue, Gottfried Esser from Germany, write about
the restoration of his 7EC. He also said he would be glad to answer letters if
anyone would like to know more about flying in Europe, especially in Germany. His
address is at the end of the story.
Please don't forget we can always use many more stories
and photos for the magazine.
'Til Next Time.
Letter to FAA requesting extention
June 7, 1999
Federal Aviation Administration
Office of the Regional Counsel
Attention: Rules Docket No. 98-CE-121-AD
601 E. 12th Street
Kansas City, MI 64106
Reference: Docket No. 98-CE-121-AD
The referenced AD proposal has a requirement that comments must be
received on or before July 16, 1999. This leaves 43 days from the date of
publication in the Federal Register for the information to be disseminated to those
interested parties and for them to prepare their responses. Since most of the
concerned people will become aware of the proposal by reading monthly aviation journals,
the National Aeronca Association believes that this time is inadequate and hereby requests
that the comment period be extended to 60 days.
There are thousands of Aeronca-built aircraft on the Federal
Aircraft Registry, and the pilot/owners of these aircraft are easily the largest affected
group by the AD proposal. We therefore request that they be given sufficient time to
become informed and react.
Awaiting you prompt reply.
Jim Thompson, President
National Aeronca Association
Copy: William Rohder
President's Message - #4
The following is a letter I've recently written the FAA. Copies were mailed to the
FAA in Kansas City and to FAA personnel involved with the proposal in the Chicago
area. We are working and will continue to work on this and will keep you posted.
Please don't forget we can always use more stories for the
magazine. With so many of you doing much of the restoring and maintenance on your
Aeroncas, you probably have a lot of tips you may be able to share (technical or
otherwise). So please keep those stories and pictures coming.
'Til Next Time,
AN OPEN LETTER TO
Your announcement last
fall of a propsed AD (Docket No. 97-CE-79-AD) applicable to American Champion Aircraft
Corp. (ACAC) 7, 8, and 11 series aircraft with wood spar wings, has produced much
discussion among the fifteen hundred or so National Aeronca Association members
pilot/onwers. Aircraft included in this proposal are Aeronca build 7 and 11 series
airplanes, as well as some early Champion built examples manufactured to the same basic
configuration and hp as the last of the 7 series Aeronca.
The National Aeronca Association shares and applauds your
commitment to safety. We too recognize the importance of thorough inpecstions by
competent mechanics as an aid in achieving safe flight.
From 1945 through 1951, Aeornca built 8,199 Aeronca
Champions and 2,418 Aeronca Chiefs, for a total of 10,617. There are still 4,268
Aeornca 7 and 11 series aircraft on the register. Today, fifty two years later, you
have not one record on an Aeronca built 7 or 11 series accident due to wing spar failure.
Think of the thousands and thousands of hours flown by these airplanes. If we
are to judge the future by the past, and we do, is a wing spar AD needed for Aeronca built
aircraft? I think not!
I am aware that cracks have been found in a small number
of Aeronca 7 series wing spars and may I point out that it is my understanding that you
have no record of spar cracks in the 11 series aircraft. If cracks are bing
reported and there are not accidents it seems to indicate that the current inspection
system is working. This is not to say that is can't be improved upon.
I am disappointed that ACAC did not see fit to mail
Service Letter 406 to the registered owners of Aeornca built 7s and 11s. The
original 406 was dated March 28, 1994 and I know of no Aeronca 7 series or 11 series owner
who have received one. Perhaps ACAC did not consider the spar problem a safety
threat to the non-aerobatic Aeronca aircraft. It appears that rather than an AD for the
Aeronca built aircraft we need awareness and information.
You, the FAA, have an awesome amount of power. With
one news conference and a negative statement about their safety record, you can destroy
the financial future on an airline. May I encourage you to use this power with care.
There is a stigma associated with ADs, especially those pertaining to the
structural integrity of an airplane. Should a wing spar AD be issued to include
Aeronca built aircraft, it will reduce the market value of each Aeronca by several
Is an AD the only means of achieving the spar inspection
goal? Back to a point made in an earlier paragraph, do we need an AD or awareness
and information? I think the latter. If a copy of Service Letter 406, Revision
A, was simply mailed to each registered 7 and 11 Aeronca owners, it would most likely
result in the desired inspections without the stigma associated with an AD.
Perhaps the situation can best be described by the cliche:
"If it isn't broke, don't fix it."
Jim Thompson, President
National Aeronca Association
President's Message - #3
The National Aeronca Association was instrumental in arranging for the FAA's Mr. Nick
Miller to make a presentation at the Sun 'n Fun 98 Aeronca forum. This was a last
minute change and required some schedule adjusting by Charlie Lasher, ever the Aeronca
supporter, and the usual forum presenter.
Mr. Miller is one of the two persons responsible for the
development of the American Champion Aircraft Corporation models 7, 8, and 11 wood
wing-spar AD. He made an excellent presentation which was well received by the more
than seventy-five forum attendees. Nick called attention to the difficulty of seeing
compresssion cracks and emphasized the importance of knowing where and what to look for.
He had sample spar parts which contained compression cracks and demonstrated the
use of Crastman Bend-A-Light in a simplified inspection procedure which eliminates the
requirement for inspection holes in the top surface of the wing.
holes are not mandatory; however, some may be necessary should the initial Bend-A-Light
inspection result in questionalble findings.
Service Letter No. 406 and Service Letter No. 417, which
are applicable to the propsed AD, have once again been revised by American Champion
Aircraft Corporation. Both revisions have resulted in an improvement in substance
and language. Service Letter 406 Revision A, which will logically be the compliance
requirement for the proposed AD and is printed in its entirety elsewhere in this issue,
contains the Bend-A-Light inspection as an approved procedure for the inspeciton of wood
spar wings on 7s, 8s and 11s.
Service Letter 417, Revision C, which first appeared as a
five page document, has been reduced to two pages and contains no inspection information.
It is anticipated that the FAA is at least a month away
from issuing the spar AD.
Copies of Service Letter 406 Revision A and 417 Revision C
are available form:
Champion Aircraft Corp.
P.O. Box 37
32032 Washington Ave., Hwy. D
Rochester, WI 53167
The National Aeronca Association
will provide you with additional information as soon as it is available.
'Til Next Time.
President's Message - #2
We would like to thank all of you who responded to the FAA's notice of proposed rule
making, Docket No. 97-CE-79-AD. It was gratifying, knowing so many of you took the
time not only to let us know that the NAA letter made you aware of the proposal, but you
also included a copy of your reply to the FAA for us to see. We will try to keep
you as informed as possible on this issue and will let you know as soon as we hear more.
It's not too early to start thinking about the Aeronca
convention in Middletown, Ohio, June 19, 20, 21, 1998, and we hope to see many of you
there. More on the convention and motel numbers can be found elsewhere in this
Some of you have shown an interest in bringing Aeronca
parts to sell at the convention, so we've decided to try it this time and see how it works
If you've got something left over from your
project or even a complete project, large, small, new or used parts, you're welome to
bring them to the convention. Please remember this is for NATIONAL AERONCA
ASSOCATION MEMBERS only and only AERONCA PARTS. We're still working out some of the
details so if
drop us a line and we'll have an informational letter for you soon.
Just as this was ready to go to the printer, I received
word that American Champion Aircraft Corp. had revised their Service Letter 417.
Having read the revised letter carefully, it appears that the installation of additional
inspection holes in the wing surface is no longer mandatory. The final answer on
this will be known only if or when the AD is issued. You may obtain a copy of
Service Letter 417: Revision B by making a request to:
American Champion Aircraft Corp.
P.O. Box 37
32032 Washington Ave., Hwy. D
Rochester, WI 53167
'Til Next Time.
President's Message - #1
Early in November the Federal Register contained a notice of proposed rule making (NPRM)
by the FAA which called for an AD applicable to all American Champion Aircraft Corp.
(ACAC) 7 series, and 11 series aircraft with wood spars. (The 8GCBC was excluded as
th FAA already had a similar AD proposal applicable to that model.) the proposed AD
would include all Aeronca-built 7 and 11 series aircraft. There is some confusion
regarding the 11CC as it is not amoung the aircraft listed. However, it is my
understanding that this was a mistake and the 11CC will be considered to be in the
proposal. ACAC owns the Aeronca 7 series type certificate No. A-759, the 11AC and
11BC type certificate No. A-761, and the 11CC type certificate No. A-796.
The proposal would require compliance with ACAC's Service
Letter No. 417 which requires the installation of 12 additional inspection holes, rings,
and covers in the bottom of each wing panel. Additionally, two rectangular
inspection holdes would be cut in the top of each wing just above the front left-strut
attach fitting. The wing spars would then be inspected for loose
nails as well as longitudinal and compression
cracks. There would be repeated spar inspections at each annual inspection.
After discussing the matter with selected members of the
National Aeronca Association, our conclusion was that that service record fo the
Aeronca-built (and some early Champion) 7 and 11 series aircraft justified excluding them
from the proposal. I therefore prepared a letter which was mailed to the FAA
explaining and giving reasons for the position of the NAA relative to the proposed AD.
4252 mailing labels were then obtained for all registered
Aeronca 7 and 11 series owners as well as the owners of some early Champion models
included in the
|proposal. A three-page
mailing was prepared and sent to the owners encouraging them, if their point of view
agreed with the position taken by the NAA, to write their comments to the FAA.
The closing date for comments was in January, and at the
time of this writing the final FAA decision on the matter has not been made. Typically, it
is serval months after the closing date before a final rule is published.
The National Aeronca Association believes that the Aeronca
7 and 11 series wing-spar has proven to be very sound design when properly maintained and
operated within the original design envelope. However, any wood spar is subject to develop
cracks and there is no substitute for a very thorough inspection by an A&P or IA who
is familiar with wood spars and has insight regarding the appearance and location of the
usual failure points.
Your NAA magazine will contain additional information of
the proposal as soon as it is available.
'Til Next Time.