The FAA wants to expand the AD requiring inspection of the carry-through spars on Cessna 210s to more models of that type and to some versions of the 177 Cardinal. The agency issued a Notice of Proposed Rulemaking requiring inspection of the spars on almost 2,000 additional aircraft that were captured by an earlier AD that took effect a year ago. Specifically, the NPRM, which will be open to public comments until June 25, now includes 3,421 U.S. aircraft models 210N, 210R, P210N, P210R, T210N, T210R, 177, 177A, 177B, 177RG, and F177RG.
The original AD applied to older 210s but since then examples have been found in newer models and the Cardinals. Operators must perform “visual and eddy current inspections of the [carry-through] spar lower cap, corrective action if necessary, application of a protective coating and corrosion inhibiting compound (CIC), and reporting the inspection results to the FAA.” Each inspection will cost about $1827.50 according to FAA calculations.
“some versions of the 177 Cardinal”
The proposed AD covers all Cardinals ever built. Though the 177 carry-through spar is similar to the 210 spar design, the 210 is a much heavier aircraft with greater potential for stress fatigue. As far as I have been able to glean from the NTSB fatal accident records, there has never been a failure, in any model, of the 177 carry-through spar in service, an interval which now spans seven decades. While the proposed eddy-current inspection requirement may be appropriate to gather data about prevalence of significant spar corrosion in the 177 fleet, it will be difficult to perform that on the most of the 210 and and all of the 177 fleets in the next year. One particularly counter-productive clause in the proposed AD would prohibit ferry permits if the carry-through spar inspection finds problems requiring remediation or replacement. This is potentially extremely burdensome and threatening for most owners, since the required level of eddy-current inspection is not available in most airports. Owners and operators should have the option of flying their planes to locations where the required eddy-current expertise and equipment is available, without fearing that the plane will be stranded away from home base indefinitely if a problem that requires remediation, replacement, or further consultation is found. In the worst case, replacement could entail indefinite downtime while Cessna restarts production of 177 spars or while other AMOCs are developed. Cardinal owners shouldn’t have to truck their planes back to their home base if the inspection is unsatisfactory, instead of having the option of a one-time ferry permit. This absolute prohibition of ferry permits is wildly incommensurate with the sterling service record and small potential hazard, and will strongly discourage prompt compliance with the proposed AD’s eddy-current inspection requirement. Hopefully this counter-productive language will be removed after the FAA reviews public comments.
Craig, the scenario you describe is occurring right now in the Piper PA-28 and PA-32 fleet. Neither the FAA or Piper have shown that they did a “Root Cause Analysis”. The Type Certificate Holder and the FAA not responding to owners tells it’s own story. Many mechanics and owners are seeing these A.D.s as attacks on aging aircraft. I would love to have an Aviation Journalist report that convinces me otherwise.
If you’ve not been introduced to ‘Root Cause Analysis’, It’s highly recommended that Aviation Professionals understand and practice this ‘Risk Mitigation’ tool. Transportation is inherently full of risk, we MUST have ‘Risk Mitigation’. The NTSB is advising all transportation organizations exposing themselves to the public to produce and organize a Safety Management System. TapRoot is one company offering this tool to complete your SMS.
Eddy current inspection. We had a group of 6 Piper owners at our airport band together. Between them and the AP wrenching stuff open and closed again and the Eddy Current man who travelled in for the day – the cash outlay per plane was in the order of $600 per inspection.
Given the serous nature of a potential spar failure why would any operator not want to inspect it?
Given the fact that planes are not falling out of the sky, a $2000 inspection is a big expense. The FAA needs to narrow down the parameters that might cause the problem and then target only planes that meet that set of criteria. Doing ALL planes seems like more of a CYA for the FAA than for owners.
An attack on aging aircraft would be one thing if there was actually an affordable new aircraft to replace them. Most owners I know would gladly buy a newer model of their planes if: a) One was actually available (in the case of the 177 and 210, they are out of production and there are no similar alternatives) and b) A person could actually afford the new price. Considering the price of a new 172, a new 177RG would probably cost over $500,000, which is more than ten times their original price. I can’t even afford a half-million dollar home!
As previously mentioned, the Cardinal community has already been addressing those inspections, both visually and using eddy current where appropriate. But so far, they have had the ability to return their planes to home base where they can address the findings, rather than being stuck at a remote airport if a problem is discovered. To date there have been no problems with that process. Over ten years ago, the former owner of my Cardinal had his mechanic visually inspect the spar and then had it painted with zinc chromate primer. It looks pristine today, but there was no eddy current inspection done, so now I don’t know if my plane complies with the propose AD or not. Another typical FAA overreaction to an issue.
Usually, you can get some idea of what’s going on internally with an airplane by the way it looks on the outside. If the airplane is in pristine condition, it likely hasn’t been parked outside and is in great shape. At Sun n Fun, I spent some time at Winter Haven where a lot of the C177 owners go to park them. Every C177 I saw fit the above description. Quite a few had some solar powered active engine dehumidification systems on them, in fact. That’s borderline anal but is a perfect example of the care these “cult” airplanes get. There’s NO WAY that those airplanes need some expensive test; a visual would do. Just taking down the headliner is a major PITA but would likely suffice for an in depth visual determination for most of the airplanes. An eddy current inspection should be reserved only for those that fail a visual plus logbook exam.
This is a lot like the Martha Lunken story … which STILL frosts my cookies. She was guilty of turning off her ADS-B because the FAA said so and that’s that. Fuhgetabout the fact that she denies doing that … doesn’t count. They didn’t get into her airplane and fly it down that river gorge w/ ADS-B ON to see if the signal disappeared. No sir … they decided she’s guilty as charged and that’s that. In this case, all C177’s are gonna fall out of the sky therefore you can’t even RTB in them … and that’s that. This isn’t fun anymore. Maybe badgering GA owners is also part of their “grand plan?”
Many regulators seems to be of the option these days that the safest flight is no flight. And this is the result you get.
I don’t see the connection with the Lunkin incident. And if you want to try to make a connection at least get the facts straight. As reported on avweb Martha contacted ATC after flying under the bridge and they could not see her target. Not even Martha is claiming the loss of adsb out was due to terrain blocking. She claims there was an unexplained intermittent problem with her adsb. Which apparently the FAA did not find credible given the circumstances.
…and her long history of reckless regulation-and-safety-defying behavior.
The connection is the FAA is now making conclusions WITHOUT investigation. Tie that with the fact that you can’t appeal their decisions and they become just another “because we say so” Federal agency.
BINGO, Art !!
Guess I’ll have to get out my FAA Mission Statement t-shirt again, the one that says, “We’re not happy until you’re not happy.” I thought we were getting past that crap.
I’ll admit I was an illegal type.
Many times in the past, I had ferried planes with no permit.
My thoughts then – who is going to check?
Larry, I can’t say that all Cardinals are like the ones you saw at Winter Haven, but I agree that 177 owners in general take very good care of them. We have a very active owners’ group that has been involved in the spar inspection issue ever since the original service letter came out. No owner that I know questions the need to inspect the spar and make sure it is in good condition and properly protected from future corrosion. But, all of us are frustrated by the FAA’s zeal to throw us in with the 210 and take the approach that we are all defective until proven otherwise. My concern is that the FAA will basically ignore any of the public comments they are receiving and take the worst case approach to this. After all, they have done just that in the past on several occasions. Just ask the former ECI company people how that works. BTW, sorry I missed you at Winter Haven. I didn’t make it to SnF this year. Look me up next year and I will buy you an adult beverage. (PS: My Cardinal has one of those fancy engine dryer thingies on it too.) 🙂
OK … I’ll do that, John. I have a friend who winters in a tiny aviation subdivision walking distance from that ramp area where I usually stay. You’d love to hear HIS story as a retired Captain. And he always has beer. 🙂