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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2018-1081; Product Identifier 2018-NE-39-AD]
RIN 2120-AA64
Airworthiness Directives; Trig Avionics Limited Transponders
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Notice of proposed rulemaking (NPRM).
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SUMMARY: We propose to adopt a new airworthiness directive (AD)
for
certain Trig Avionics Limited TT31, Avidyne Corporation AXP340, and
BendixKing/Honeywell International KT74 Mode S transponders. This
proposed AD was prompted by the discovery that the retaining cam that
engages in the mounting tray may not withstand g-forces experienced
during an emergency landing. This proposed AD would require a one-time
inspection of the transponder installation to determine if this is a
conventional aft-facing installation, and depending on the findings,
removal of the affected transponder for modification. We are proposing
this AD to address the unsafe condition on these products.
DATES: We must receive comments on this proposed AD by May 6, 2019.
ADDRESSES: You may send comments, using the procedures found in
14 CFR
11.43 and 11.45, by any of the following methods:
Federal eRulemaking Portal: Go to http://www.regulations.gov. Follow the
instructions for submitting comments.
Fax: 202-493-2251.
Mail: U.S. Department of Transportation, Docket Operations, M-30, West
Building, Ground Floor, Room W12 140, 1200 New Jersey Avenue SE,
Washington, DC 20590.
Hand Delivery: Deliver to Mail address above between 9 a.m. and 5 p.m.,
Monday through Friday, except Federal holidays.
For service information identified in this NPRM, contact Trig
Avionics Limited, Heriot Watt Research Park, Riccarton, Edinburgh EH14
4AP, United Kingdom; phone: +44 131 449 8810; fax: +44 131 449 8811;
email: support@trig-avionics.com; internet: https://trig-avionics.com.
You may view this service information at the FAA, Engine and Propeller
Standards Branch, 1200 District Avenue, Burlington, MA 01803. For
information on the availability of this material at the FAA, call 781-
238-7759.
Examining the AD Docket
You may examine the AD docket on the internet at http://www.regulations.
gov by searching for and locating Docket No. FAA-2018-1081;
or in person at Docket Operations between 9 a.m. and 5 p.m.,
Monday through Friday, except Federal holidays. The AD docket contains
this NPRM, the mandatory continuing airworthiness information (MCAI),
the regulatory evaluation, any comments received, and other
information. The street address for Docket Operations (phone: 800-647-
5527) is listed above. Comments will be available in the AD docket
shortly after receipt.
FOR FURTHER INFORMATION CONTACT: Min Zhang, Aerospace Engineer,
Boston
ACO Branch, FAA, 1200 District Avenue, Burlington, MA 01803; phone:
781-238-7161; fax: 781-238-7199; email: min.zhang@faa.gov.
SUPPLEMENTARY INFORMATION:
Comments Invited
We invite you to send any written relevant data, views, or arguments
about this proposal. Send your comments to an address listed under the
ADDRESSES section. Include "Docket No. FAA-2018-1081; Product
Identifier 2018-NE-39-AD" at the beginning of your comments. We
specifically invite comments on the overall regulatory, economic,
environmental, and energy aspects of this NPRM. We will consider all
comments received by the closing date and may amend this NPRM because
of those comments.
We will post all comments we receive, without change, to http://www.
regulations.gov, including any personal information you provide. We
will also post a report summarizing each substantive verbal contact we
receive about this NPRM.
Discussion
The European Union Aviation Safety Agency (EASA), which is the
Technical Agent for the Member States of the European Community, has
issued EASA AD 2018-0247, dated November 13, 2018 (referred to after
this as "the MCAI"), to address the unsafe condition on these
products. The MCAI states:
While testing a new model of transponder, it was detected that
the retaining cam was not meeting the approved design criteria for
crash safety shock in the aft direction (20g sustained). This was
due to an uncontrolled deviation in the manufacturing process of the
retaining cam by the part manufacturer. The retaining cam is a small
nylon part that engages in the mounting tray when the transponder is
installed into the aircraft. Additional tests using affected
retaining cam showed that the transponders meet RTCA/DO-106G Section
7.0 operational shocks and crash safety impulse tests, as well as
RTCA/DO-160G Section 7.0 crash safety sustained tests for all
directions, except the aft direction. As a consequence, units which
have been installed with a control panel orientation that is not
opposite to the direction of flight may not withstand g-forces
experienced during an emergency landing.
This condition, if not detected and corrected, could lead to
detachment of the transponder, possibly resulting in damage to fuel
systems or emergency evacuation equipment, and/or injury to aircraft
occupants.
To address this potential unsafe condition, Trig Avionics
published the applicable SB to provide instructions to inspect the
installation and the transponder, and how to arrange for
modification.
For the reason described above, this [EASA] AD requires a one-
time inspection of the transponder installation to determine whether
this is a conventional installation, as defined in this [EASA] AD,
and, depending on findings, removal from service of the affected
transponder for modification.
You may obtain further information by examining the MCAI in the AD
docket on the internet at http://www.regulations.gov by searching for
and locating Docket No. FAA-2018-1081.
Related Service Information Under 1 CFR Part 51
We reviewed Trig Avionics Ltd. Service Bulletin (SB) SUP/TT31/027,
Issue 1.0, dated October 1, 2018; Trig Avionics Ltd. SB SUP/AXP340/002,
Issue 1.0, dated October 1, 2018; and Trig Avionics Ltd. SB SUP/KT74/
005, Issue 1.0, dated October 1, 2018. Trig Avionics Ltd. SB SUP/TT31/
027, Issue 1.0, dated October 1, 2018, describes procedures for
determining the direction of the Trig Avionics Limited TT31 Mode S
transponder installation and removal of these affected transponders for
replacement or repair. Trig Avionics Ltd. SB SUP/AXP340/002, Issue 1.0,
dated October 1, 2018, describes procedures for determining the
direction of the Avidyne Corporation AXP340 Mode S transponder
installation and removal of these affected transponders for replacement
or repair. Trig Avionics Ltd. SB SUP/KT74/005, Issue 1.0, dated October
1, 2018, describes procedures for determining the direction of the
BendixKing/Honeywell International KT74 Mode S transponder installation
and removal of these affected transponders for replacement or repair.
This service information is reasonably available because the interested
parties have access to it through their normal course of business or by
the means identified in the ADDRESSES section.
FAA's Determination
This product has been approved by EASA, and is approved for
operation in the United States. Pursuant to our bilateral agreement
with the European Community, EASA has notified us of the unsafe
condition described in the MCAI and service information referenced
above. We are proposing this AD because we evaluated all the relevant
information provided by EASA and determined the unsafe condition
described previously is likely to exist or develop in other products of
the same type design.
Proposed AD Requirements
This proposed AD would require a one-time inspection of the
transponder installation to determine if this is a conventional aft-
facing installation, and depending on the findings, removal of the
affected transponder for modification.
Costs of Compliance
We estimate that this proposed AD affects 2,390 transponders
installed on airplanes of U.S. registry.
We estimate the following costs to comply with this proposed AD:
Estimated Costs
|
Action
|
Labor cost
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Parts cost
|
Cost per
product
|
Cost on
U.S. operators
|
|
Inspect the
transponder installation
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0.5 work-hours x $85 per hour
= $42.50 |
$0
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$42.50
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$101,575
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We estimate the following costs to
do any necessary repairs that
would be required based on the results of the proposed inspection. We
have no way of determining the number of aircraft that might need these
repairs:
On-Condition Costs
|
Action
|
Labor cost
|
Parts cost
|
Cost per
product
|
|
Replace the
transponder
|
1 work-hour x $85 per hour =
$85 |
$2,872
|
$2,957
|
According to the manufacturer, some
of the costs of this proposed
AD may be covered under warranty, thereby reducing the cost impact on
affected individuals. We do not control warranty coverage for affected
individuals. As a result, we have included all costs in our cost estimate.
Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. Subtitle VII: Aviation Programs,
describes in more detail the scope of the Agency's authority.
We are issuing this rulemaking under the authority described in
Subtitle VII, Part A, Subpart III, Section 44701: "General
requirements." Under that section, Congress charges the FAA with
promoting safe flight of civil aircraft in air commerce by prescribing
regulations for practices, methods, and procedures the Administrator
finds necessary for safety in air commerce. This regulation is within
the scope of that authority because it addresses an unsafe condition
that is likely to exist or develop on products identified in this
rulemaking action.
This AD is issued in accordance with authority delegated by the
Executive Director, Aircraft Certification Service, as authorized by
FAA Order 8000.51C. In accordance with that order, issuance of ADs is
normally a function of the Compliance and Airworthiness Division, but
during this transition period, the Executive Director has delegated the
authority to issue ADs applicable to engines, propellers, and
associated appliances to the Manager, Engine and Propeller Standards
Branch, Policy and Innovation Division.
Regulatory Findings
We determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would not
have a substantial direct effect on the States, on the relationship
between the national Government and the States, or on the distribution
of power and responsibilities among the various levels of government.
For the reasons discussed above, I certify this proposed
regulation:
(1) Is not a "significant regulatory action" under Executive
Order 12866,
(2) Is not a "significant rule" under the DOT Regulatory Policies
and Procedures (44 FR 11034, February 26, 1979),
(3) Will not affect intrastate aviation in Alaska, and
(4) Will not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.
The Proposed Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
1. The authority citation for part 39 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 44701.
Sec. 39.13 [Amended]
2. The FAA amends Sec. 39.13 by adding the following new airworthiness
directive (AD):
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