IMPORTANT: FAA Proposed Rulemaking for PA-28/32 Aircraft: Wing Spar - Comments due Nov. 4th and 7th
The FAA has proposed AD 2024-00033-A for certain Piper aircraft (PA-28 models and PA-32 models) which would require using the calculated service hours (CSH), as opposed to the factored service hours (FSH), which was previously noted in AD 2020-26-16, for determining when an inspection is required of each main wing spar. This AD would require, “Calculating the CSH for each main wing spar; repetitively inspecting the lower main wing spar bolt holes for crack(s) and non-crack damage and taking corrective actions as needed; and replacing or modifying main wing spars at a specified time.” This AD also removes a few Piper models and adds a new airplane model. Comments can be posted to the FAA by November 7, 2024.
Click Here to read the Proposed AD
Read the two attachments: Piper's Letter to Owners and Piper's Response to the FAA
Comments on this proposed AD are due to the FAA by November 7th.
COMMENTS DUE NOVEMBER 4th ON ANOTHER PROPOSED AD
Another proposed AD, AD 2024-00008-A, would require a review of airplane maintenance records to determine if an eddy current inspection of the lower main wing spar bolt holes was done, and depending on the result, doing a one-time eddy current inspection of the lower wing spar bolt holes for crack(s), and replacing any cracked main wing spar. This AD also adds new models that were not included in the previous AD 2020-26-16. Comments can be posted to the FAA by November 4, 2024. See comments below for more information.
Click Here to Read the Proposed AD - Comment button is at the top of this page as well
Diana Jones, Owner Piper Owner Society
Comments
Thank you so much Diana for providing these letters of clarification. Even though my PA28-180E has been registered properly with FAA since 2017. I have never received a copy of any service bulletin, AD, or any other information about my plane from either Piper, or the FAA. My only reliable source has been through the membership of this organization. The value of this clarification alone makes the years of subscribing well worth the cost. My compliments in helping to provide this information for us.
Jim Curns
This was recently posted to the FAA comments, supporting the Piper findings with pretty detailed statistical analysis.
Tom Jackson
PA28RT-201, N3022U
Tappahannock, VA (KXSA)
A&P/IA, Private Pilot, IR/A
If you would like to send a comment to the FAA regarding this AD, here is the pertinent information to get it to the right place:
Click Here to Comment on the Proposed AD. Once here, click on the box at the top that says "SUBMIT A PUBLIC COMMENT". You can also read all of the posted comments thus far.
If your plane is affected by this AD, we strongly recommend that you post your comment with the FAA. We suggest that you include information on how this proposed AD will affect you personally. Feel free to use Piper Aircraft's response if it makes sense (see attachment above labeled: Piper Response to FAA-10-07-2024)
Please comment here if you have suggestions for members. For example, share how this proposed AD would affect you.
Diana Jones, Owner Piper Owner Society
Welp, if the FAA is going to ignore industry experts for engineering inputs and insist on using ~20 year old labor rates, I guess it is simply time to hit the singles Beech.
ALSO IMPORTANT:
There is a second Notice of Proposed Rulemaking, AD-24-00008-A that lists Piper models not included in AD-24-00033-A. So if you read 33A and breathed a sigh of relief after going through the affected aircraft, not so fast! AD-24-00008-A requires an eddy current inspection, potentially damaging removal of wing attach bolts, etc. The comment period for this AD expires BY NOVEMBER 4TH ! Please submit your comments now. Many of the points raised by Piper are also valid here. Some of you may remember the debacle in 1989 which resulted in the FAA, by their own conclusions after the uproar, in rescinding a similar AD.
Here is a link to AD 2024-00008-A and the button to submit a comment is on the page upper right.
Regards,
Mike
Mike, thank you for clarification of the wider scope NPRM and its suspense date for comments.
If my read is correct, the difference in the two NPRMs is that one addresses the Hershey Bar wing, and one goes into drag-net mode to include the newer Tapered wing in an effort to touch all PA-28 and 32s.
While both NPRMs have logic inconsistencies, the Hershey Bar proposal looks like a death by repetitive invasive inspections, and appears to recognize a risk of these inspections is causing damage that the AD professes it wants to avoid. Brilliant, right?
The Tapered proposal seems more tame in comparison by setting a one-time invasive inspection at 12,000 hours of time in services; although its supporting logic appears more of arbitrary guilt by association rather than correlation to actual scientific evidence or industry expertise.
Among the head scratchers in the Hershey Bar NPRM is a statement that the FHS method remains the best tool for determining when to perform an invasive inspection, yet goes on to declare the CHS as better. Huh?
Oh, and fun puzzler in the Hershey Bar NPRM: Can anybody spot the total number of "Groups" that this NRPM addresses? While I see two clearly defined "Groups" (by way of referencing Piper SB 1372), the NPRM appears to call-out a third undefined Group. Another bonus! Perhaps this third (unlimited?) secret group is the NPRM for the Tapered wing? Tough to tell without specificity.
If the FAA was more mature in the approach with these NPRMs, it would have prevented the harsh blow-back from Piper by way of advance coordination of effort. Instead, Piper calls-out the FAA for ignoring inputs. Icing on the cake 😑
confused ! is the PA-28 140 exempt from the A.D.
It is NOT exempt. See this portion of the AD 24-00008-A:
The comment period for this proposed AD ends November 4th.
Regards,
Mike
applicable to your 140 (or 150, 160 or 180) if one of these two apply:
To make sure I’m understanding all this correctly, these two new proposed AD’s are basically stating that:
1. All Pipers with that same cold bended wingspar shall have maintenance records reviewed and if it is shown that it has never had a Eddy Current test or is missing any logs that at ET will be performed and
2, Certain models will now go by a calculated service hours and maintenance will be determined by what group it falls under instead of time in service hours..
Hi Cherokee 1,
#2 is true but #1, not exactly.
While cold bend wing spars are mentioned in AD 2024-00033-A as a justification for the AD, a cold bend spar is not necessary to require compliance. It is simply one of the arguments the FAA is putting forth to justify the AD. In fact Piper, in their comment to the NPRM, states that "it is incorrect to state machined spars [of certain serial numbers] do not require inspections...." The FAA puts forth many reasons WHY the aircraft will be listed in the AD. As is common with all NPRM, scroll down in the file to get to the actual AD they are proposing, after all the explanation and justification which can go on for many pages! If your aircraft is listed in the "Applicability" section, you must comply within the time periods described in the "Compliance" sections.
For AD 2024-00008-A, eddy current testing is to begin "Within 100 hours TIS after complying with paragraph (g) of this AD [logbook review] or within 100 hours TIS after a main wing spar accumulates 12,000 hours TIS, whichever occurs later," and for AD 24-00033-A at 3000 CSH for Group 1 aircraft, or, as you said, if the history of the spar is unknown in either case, "within 100 hours TIS or 60 days after the effective date of this AD, whichever occurs later."
I understand how confusing all this is and, as an aircraft owner myself potentially affected by -00008-A, I had to read it many times with a fine tooth comb!
Regards,
Mike
The two NPRMs (proposed ADs) apply to two groups. 2024-21652 applies to later Piper models mostly that typically have the Taper Wing. 2024-21209 applies to earlier models that typically have the Hershey Bar wing.
I am not a lawyer and the wording of these is full of difficult to understand legal mumbo jumbo.
The NPRM (2024-21209) affecting the Hershey Bar Cherokees appears to apply to aircraft such as the PA28-140, 150, 160, 180 as stated above by poster: benscluff. Here is the table in the NPRM listing the aircraft subject to that proposed AD (page 76756).
TABLE 1 TO THE INTRODUCTORY TEXT OF PARAGRAPH (c) -APPLICABILITY
Model Serial Nos.
PA–28–140 .......... All serial numbers.
PA–28–150 .......... All serial numbers.
PA–28–160 .......... All serial numbers.
PA–28–180 .......... All serial numbers.
PA–28S–160 ........ All serial numbers.
PA–28S–180 ........ All serial numbers.
PA–28–236 .......... All serial numbers.
PA–28–201T ........ All serial numbers.
PA–32–300 .......... All serial numbers greater than and including
32–7940001.
PA–32R–300 ........ All serial numbers.
PA–32RT–300 ...... All serial numbers.
PA–32RT–300T ... All serial numbers.
PA–32–301FT ...... All serial numbers.
PA–32–301XTC ... All serial numbers.
PA–32R–301 (HP) All serial numbers.
PA–32R–301 (SP) All serial numbers.
PA–32R–301T ...... All serial numbers.
PA–32–301 .......... All serial numbers.
PA–32–301T ........ All serial numbers.
----------------------------------------------------------------------------------------------------------
For the above models, the proposed AD applies if:
(1) Aircraft has accumulated 12,000 or more total hours time-in-service (TIS) on a wing spar; or
(2) Aircraft has missing or incomplete maintenance records.
It appears the Piper Service Bulletin SB-1412 recommends the same thing as the above proposed AD, except that Piper does include missing or incomplete maintenance records as a reason for requiring the inspections. Apparently the FAA included (2) to cover older aircraft for which the TIS could not be determined from the maintenance logs.
This is my interpretation of the NPRM, and I could be wrong. So you should probably have your IA (or aviation attorney) provide an expert opinion.
Jack
"(2) Aircraft has missing or incomplete maintenance records.
It appears the Piper Service Bulletin SB-1412 recommends the same thing as the above proposed AD, except that Piper does include missing or incomplete maintenance records as a reason for requiring the inspections. Apparently the FAA included (2) to cover older aircraft for which the TIS could not be determined from the maintenance logs." [Jack]
And stuff like this is why you should make digital copies of all your logs.... including AD compliance, part numbers from engines, etc.
This AD does not really seem complete as it does not cite any simple part (like an exhaust clamp) that is impossible to obtain as essential for satisfying the AD.... Maybe these details are buried in the SB?
Eric Panning
1981 Seneca III
Hillsboro, OR (KHIO)