DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2020-0472; Project Identifier 2018-CE-060-AD; Amendment
39-21295; AD 2020-21-22]
RIN 2120-AA64
Airworthiness Directives; Textron Aviation Inc. Airplanes
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Final rule.
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SUMMARY: The FAA is adopting a new airworthiness directive (AD)
for all
Textron Aviation Inc. (Textron) Models 180, 180A, 180B, 180C, 180D,
180E, 180F, 180G, 180H, 180J, 180K, 182, 182A, 182B, 182C, 182D, 185,
185A, 185B, 185C, 185D, 185E, A185E, and A185F airplanes. This AD was
prompted by a report of cracks found in the tailcone and horizontal
stabilizer attachment structure. This AD requires inspecting the
tailcone and horizontal stabilizer for corrosion and cracks and
repairing or replacing damaged parts as necessary. The FAA is issuing
this AD to address the unsafe condition on these products.
DATES: This AD is effective December 7, 2020.
The Director of the Federal Register approved the incorporation by
reference of a certain publication listed in this AD as of December 7,
2020.
ADDRESSES: For service information identified in this final rule,
contact Textron Aviation Customer Service, P.O. Box 7706, Wichita,
Kansas 67277, (316) 517-5800; customercare@txtav.com; internet:
https://txtav.com. You may view this service information at the FAA,
Airworthiness Products Section, Operational Safety Branch, 901 Locust,
Kansas City, Missouri 64106. For information on the availability of
this material at the FAA, call (816) 329-4148. It is also available on
the internet at https://www.regulations.gov by searching for and
locating Docket No. FAA-2020-0472.
Examining the AD Docket
You may examine the AD docket on the internet at https://www.regulations.
gov by searching for and locating Docket No. FAA-2020-
0472; 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 final rule, the regulatory evaluation, any comments received, and
other information. The address for Docket Operations is U.S. Department
of Transportation, Docket Operations, M-30, West Building Ground Floor,
Room W12-140, 1200 New Jersey Avenue SE, Washington, DC 20590.
FOR FURTHER INFORMATION CONTACT: Tara Shawn, Aerospace Engineer,
Wichita ACO Branch, 1801 Airport Road, Room 100, Wichita, Kansas 67209;
telephone: (316) 946-4141; fax: (316) 946-4107; email:
tara.shawn@faa.gov or Wichita-COS@faa.gov.
SUPPLEMENTARY INFORMATION:
Discussion
The FAA issued a notice of proposed rulemaking (NPRM) to amend 14
CFR part 39 by adding an AD that would apply to all Textron Aviation
Inc. (Textron) (type certificate previously held by Cessna Aircraft
Company) Models 180, 180A, 180B, 180C, 180D, 180E, 180F, 180G, 180H,
180J, 180K, 182, 182A, 182B, 182C, 182D, 185, 185A, 185B, 185C, 185D,
185E, A185E, and A185F airplanes. The NPRM published in the Federal
Register on May 14, 2020 (85 FR 28890). The NPRM was prompted by a
report of cracks found in the tailcone and horizontal stabilizer
attachment structure on a Textron Model 185 airplane. The FAA
discovered similar conditions on 29 additional Textron 180 and 185
series airplanes and determined that the combination of the attachment
structure design and high loads during landing contribute to the
development of cracks in the tailcone and horizontal stabilizer
attachment structure. The NPRM proposed to require inspecting the
tailcone and horizontal stabilizer for corrosion, cracks, and loose or
sheared rivets and repairing or replacing damaged parts as necessary.
The FAA is issuing this AD to prevent failure of the horizontal
stabilizer to tailcone attachment, which could lead to tail separation
with consequent loss of control of the airplane.
Comments
The FAA gave the public the opportunity to participate in
developing this final rule. The following presents the comments received
on the
NPRM and the FAA's response to each comment.
Support for the NPRM
Two individual commenters supported the NPRM.
Request To Clarify Why the AD Is Necessary
Three individual commenters requested the FAA clarify why an AD is
necessary. The commenters stated the proposed inspection is already
performed at every annual inspection. One of these commenters stated
the current service bulletin is also sufficient to address this issue,
and unlike the seat rail AD, which was necessary to remove subjective
interpretation from the inspection measurements, this issue is more
objective. The FAA infers that the commenter is referring to AD 2011-
10-09, Amendment 39-16690 (76 FR 27865, May 13, 2011).
The FAA disagrees. Although 14 CFR 43.15 and Appendix D to Part 43
do require that 100-hour and annual inspections include an inspection
of the tailcone and horizontal stabilizer attachment structure, this AD
requires an inspection directed towards specific areas with a history
of cracking. Data obtained during evaluation of this unsafe condition
indicated that the current routine maintenance and inspection
procedures alone are not adequate to address it. Also, while an
operator may incorporate into its maintenance program the inspections
in the service bulletin referenced by the commenters, not all operators
are required to do so. In order for these inspections to become
mandatory, and to correct the unsafe conditions identified in the NPRM,
the FAA must issue an AD. The compliance times as proposed should allow
the inspections to be completed during the annual/100 hour inspection,
thereby minimizing the costs on operators.
The FAA did not make any changes to the proposed AD based on these
comments.
Request To Address Cause of the Cracking
An individual commenter requested the AD address the cause of the
cracking instead of changing the affected parts so that the cycle time
between inspections could be increased. As examples, the commenter
stated that if the cause is vibration, then propeller balance should be
required to correct the vibration; if the cause is corrosion, then
corrosion prevention should be required.
The FAA disagrees. The FAA determined that a combination of the
attachment structure design and the high design loads during landing
contribute to the development of cracks in the tailcone and horizontal
stabilizer attachment structure. The FAA evaluated the failures and
determined that the appropriate corrective action was to replace the
parts if corrosion or cracks are detected during the inspection. The
FAA did not make any changes to the proposed AD based on this comment.
Request Change to Applicability
The Aircraft Owners and Pilots Association (AOPA) requested the FAA
clarify why the proposed AD applies to Model 182-series airplanes,
because the airplanes found with cracking and corrosion damage were
Textron Model 180- and 185-series airplanes that have a different
landing gear configuration with higher loads during landing. Citing the
same or similar reasons, three individual commenters requested that the
proposed AD not apply to Model 182-series airplanes.
The FAA agrees to provide additional information explaining why the
proposed AD would apply to Model 182-series airplanes. While the
landing stresses for the Model 182-series are not equal to that of the
Model 180- and 185-series, the FAA determined that the development of
cracks in the tailcone and horizontal stabilizer attachment structure
is a combination of landing stresses and the attachment structure
design. Models 182 through 182D airplanes have the same tailcone design
as Model 185-series airplanes. After the FAA issued an Airworthiness
Concern Sheet about this issue on February 8, 2017, requesting
information on Model 180- and 185-series airplanes, Textron released
Single Engine Mandatory Service Letter SEL-55-01, dated December 7,
2017 (SEL-55-01), which included Models 182 through 182D. Inspection
results from SEL-55-01 have included multiple reports of cracking on
Models 182 through 182D.
The FAA did not make any changes to the proposed AD based on these
comments.
Another individual commenter requested the proposed AD require
inspections for Model 182-series airplanes that have been converted to
tail wheel airplanes and not require inspections for Model 180- and
185-series airplanes on floats, if the cause is vibration from
landings.
The FAA disagrees. The FAA has determined that the development of
cracks in the tailcone and horizontal stabilizer attachment structure
is a combination of the attachment structure design and high landing
loads. The high loads encountered during landing are not specifically
the result of vibration. Data obtained during evaluation of the unsafe
condition identified cracking on aircraft with and without floats.
The FAA did not make any changes to the proposed AD based on this
comment.
The same individual commenter also requested the proposed AD not
apply to lower time airplanes, such as those with 3,000 hours or less.
The commenter did not provide justification for this request.
The FAA disagrees. This AD was proposed to address corrosion and
cracks in the tailcone and horizontal stabilizer attachment structure.
As corrosion may develop over time, regardless of how many flight hours
the airplane accumulates, the commenter's suggestion, if adopted, would
not adequately address the unsafe condition.
The FAA did not make any changes to the proposed AD based on this
comment.
Request for Credit for Previous Actions
AOPA and two individual commenters requested the FAA revise
paragraph (h) of the AD to allow credit for previous actions performed
by using SEL-55-01 if the airplane was also inspected for loose or
sheared rivets. The commenters suggested there are no significant
differences between SEL-55-01 and the proposed AD. AOPA also requested
credit for actions performed during the prior annual inspection.
The FAA agrees that operators may take credit for previous
compliance with SEL-55-01; however, a change to the AD is unnecessary.
Paragraph (f) of this AD requires compliance unless already done. Thus,
the AD already allows credit for the initial inspection specified in
SEL-55-01 if completed before the effective date of the AD. Similarly,
operators may take credit for actions performed during the prior annual
inspection if those actions are identical to the procedures specified
in SEL-55-01.
The FAA did not make any changes to the proposed AD based on these
comments.
Request To Delay Issuance of AD
An anonymous commenter requested the FAA delay issuing the AD to
allow more research into the problem and solutions. The commenter
stated that the AD is too invasive and that removing and replacing the
tail every 500 hours could be far more dangerous to the airplane than
the cracks.
The FAA disagrees. The AD does not require removing the tail in
order to complete the visual inspection. SEL-55-01 provides
instructions to gain access to the inspection area without removal of
the tail. The FAA has received feedback from operators that this
inspection has been completed during annual maintenance. No delay in
the effective date of the AD is warranted.
The FAA did not make any changes to the proposed AD based on this
comment.
Comment Concerning Potential Causes of Damage
AOPA requested the FAA clarify whether all causes of potential
damage have been scrutinized. AOPA suggested that other sources of
damage to the tailcone and horizontal stabilizer area attachment
structure, such as wear from ground personnel moving the aircraft by
the horizontal stabilizer, may have resulted in the cracking and
corrosion discovered.
The FAA agrees to provide additional information. Damage to the
tailcone and horizontal stabilizer could be a result of ground
personnel moving the aircraft by the horizontal stabilizer. In
addition, high loads due to a number of potential causes in combination
with the attachment structure design could result in damage to the
tailcone and horizontal stabilizer. However, even if the FAA could
identify the exact sources of high loads, it would not likely alter the
actions required by the AD to correct the identified unsafe condition.
The FAA did not make any changes to the proposed AD based on this
comment.
Comment Concerning Parts
An anonymous commenter stated that parts to repair are not
available. The commenter did not provide supporting data with this
comment.
The FAA is not aware of the unavailability of replacement parts. To
the extent operators may have difficulty obtaining replacement parts,
the FAA cannot base its AD action on whether spare parts are available
or can be produced. While every effort is made to avoid grounding
aircraft, the FAA must address the identified unsafe condition.
The FAA did not make any changes to the proposed AD based on this
comment.
Request Regarding Costs
One individual commenter requested the FAA require that Textron
provide a service kit that addresses the design flaw and assists with
the costs mandated by the AD. The commenter stated that this AD focuses
on a known vulnerable area in all tail wheeled Cessna aircraft, caused
by a systemic design flaw that is a major safety of flight condition.
The FAA, as a federal agency, is responsible for all directives,
policies, and mandates issued under its authority. The FAA does not
have the authority to require a manufacturer to bear AD costs incurred
in modifying or repairing privately-owned aircraft. The general
obligation of the operator to maintain its aircraft in an airworthy
condition is vital, but sometimes expensive. If the manufacturer
determines it will cover the cost of implementing a particular action,
then the manufacturer does so voluntarily. The FAA did not make any
changes to the proposed AD based on this comment.
Comment Regarding the Service Information
An individual commenter stated the proposed AD does not reference
or coincide with Cessna Supplemental Inspection Document 53-10-01,
which covers the tailcone inspection.
The commenter's statement does not include a suggestion specific to
the AD or a request the FAA can act on. The FAA did not make any
changes to the proposed AD based on this comment.
Conclusion
The FAA reviewed the relevant data, considered the comments
received, and determined that air safety and the public interest
require adopting this final rule as proposed.
Related Service Information Under 1 CFR Part 51
The FAA reviewed Textron Aviation Single Engine Mandatory Service
Letter SEL-55-01, dated December 7, 2017. The service information
contains procedures for inspecting the stabilizer hinge brackets,
tailcone reinforcement angles, corner reinforcements, stabilizer hinge
reinforcement channel, stabilizer hinge assemblies, stabilizer aft spar
reinforcement, and the lower half of the stabilizer aft spar from
station (STA) 16 on the left side of the stabilizer aft spar to STA 16
on the right side for cracks and corrosion. 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.
Differences Between This AD and the Service Information
The service information applies to airplanes with more than 3,000
total hours time-in-service or 10 years in service, while this AD
applies regardless of the airplane's time-in-service. This AD requires
inspecting for and replacing loose or sheared rivets, which is not
specified in the service information.
Costs of Compliance
The FAA estimates that this AD affects 6,586 airplanes of U.S.
registry.
The FAA estimates the following costs to comply with this AD:
Estimated Costs
Action
|
Labor cost
|
Parts cost
|
Cost per
product
|
Cost on
U.S. operators
|
Inspection |
2 work-hours x $85 per hour =
$170 |
Not applicable
|
$170
|
$1,119,620
|
The FAA estimates the following costs
to do any necessary
replacements that would be required based on the results of the
inspection. The FAA has no way of determining the number of aircraft
that might need these actions:
On-Condition Costs
Action
|
Labor cost
|
Parts cost
|
Cost per
product
|
Replace left-hand (LH) stabilizer
hinge bracket. |
4 work-hours x $85 per workhour
= $340
|
$551 |
$891 |
Replace right-hand (RH) stabilizer
hinge bracket. |
4 work-hours x $85 per workhour
= $340 |
530 |
870 |
Replace LH tailcone reinforcement
angle. |
12 work-hours x $85 per workhour
= $1,020 |
2,291 |
3,311 |
Replace RH tailcone reinforcement
angle. |
12 work-hours x $85 per workhour
= $1,020. |
3,006 |
4,026 |
Replace LH corner reinforcement. |
6 work-hours x $85 per workhour
= $510 |
169 |
679 |
Replace RH corner reinforcement. |
6 work-hours x $85 per workhour
= $510 |
390 |
900 |
Replace LH stabilizer hinge reinforcement
channel.
|
6 work-hours x $85 per workhour
= $510 |
99 |
609 |
Replace RH stabilizer hinge
reinforcement channel. |
6 work-hours x $85 per workhour
= $510 |
99 |
609 |
Replace LH stabilizer hinge assembly. |
1 work-hours x $85 per workhour
= $85 |
570 |
655 |
Replace RH stabilizer hinge assembly. |
1 work-hours x $85 per workhour
= $85 |
694 |
779 |
Replace LH stabilizer aft spar
reinforcement. |
(*) |
825 |
825 |
Replace RH stabilizer aft spar
reinforcement. |
(*) |
466 |
466 |
Replace stabilizer aft spar.
(* includes work-hour cost
for replacing stabilizer aft spar reinforcement parts)
|
28* work-hours x $85 per workhour
= $2,380 |
563 |
2,943 |
Remove and replace horizontal
and vertical stabilizers
and rig flight controls. |
8 work-hours x $85 per workhour
= $680 |
Not applicable |
680 |
Since corrosion may affect any or
all of the parts subject to the
inspection in this AD differently and the severity of the corrosion on
each part would affect the time necessary to correct the condition, the
FAA has no way to determine an overall cost per product for removing
the corrosion. Similarly, loose or sheared rivets may also affect any
or all of the parts subject to the inspection in this AD differently,
and the time necessary to correct the condition on each product would
be different. Therefore, the FAA has no way to determine an overall
cost per product for replacing loose or sheared rivets.
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.
The FAA is 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.
Regulatory Findings
This AD will not have federalism implications under Executive Order
13132. This AD will 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 that this AD:
(1) Is not a ``significant regulatory action'' under Executive
Order 12866,
(2) Will not affect intrastate aviation in Alaska, and
(3) 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.
Adoption of the Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA amends 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:
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