Daniel Woods

The issues raised in Question 4 pertaining to potential impossibilities in ADs, (actions that cannot be performed) are of significant concern. In the FAA’s reply to the following questions: “Section 39.15. Does an Airworthiness Directive apply if the product has been changed? “Yes, an Airworthiness Directive applies to each product identified in the airworthiness directive, even if an individual product has been changed by modifying, altering, or repairing it in the area addressed by the Airworthiness Directive. “Section 39.17. What must I do if a change in a product affects my ability to accomplish the actions required in an Airworthiness Directive? “If a change in a product affects your ability to accomplish the actions required by the airworthiness directive in any way, you must request FAA approval of an alternative method of compliance [AMOC]. Unless you can show the change eliminated the unsafe condition, your request should include the specific actions that you propose to address the unsafe condition. Submit your request in the manner described in Sec. 39.19. “If a change to a product makes it impossible to comply with the requirements of an AD, then the operator must request an AMOC approval.” These statements would seem to indicate the FAA does not consider the A&P or IA capable of determining an AD’s applicability. The document indicates operators will be required to seek an Alternate Means of Compliance to ensure airworthiness in many instances. Have any studies been performed to determine the economic impact on the aviation community due to the impending “flood” of AMOC submissions? What about the impending “out of service” time associated on aircraft while AMOC’s are hastily being pursued? If an Airworthiness Directive is clearly impossible to perform due to the aircraft’s configuration, what safety benefit would result by requiring an AMOC to document the aircraft condition vs. a logbook entry?