Why was "unless already done" left out of the ASI test requirement? The chart which sets out the proposed requirements allows an "unless already done" credit...for everything *except* the airspeed indicator inspection & report requirement. (e.g.) "(ii) We will allow 'unless already done' credit for inspections done within the last 25 hours TIS before the effective date of this AD or within the last 3 months before the effective date of this AD, and you may use the results from that inspection for the reporting requirement in parargraph (f)(10) of this AD." This language does NOT appear in the block for the ASI testing & reporting. Why not? I just bought a brand new ASI & had it installed, at a cost of several hundred dollars. Each time the instrument shop tested the old ASI, and the replacement ASI, they charged a flat $60, for a test that took just a few minutes. Why should I have to pay for such a test again (and report to the FAA) on a brand new, and just-newly-tested, ASI? Why was "unless already done" left out of the ASI test requirement? And, since instrument shops won't install an ASI unless it passes their bench test, what about an exemption for ASIs less than 1 year old? Secondly, the Ercoupe was certificated before the FAA existed, and before TSO requirements were invented. We are therefore entitled to use the accuracy standard in effect at the time certificated, i.e. accurate +/- 5mph. I found AC 23-8B, Appendix 9, nearly incomprehensibly technical. IF there is a standard of accuracy in there that will be interpreted to replace our hard-won right to use the +/- 5 mph standard, then I protest.
Respectfully submitted,
Linda T. Abrams
Linda Abrams
This is comment on Rule
Airworthiness Directives: Univair Aircraft Corp. Models 415-C, 415-CD, 415-D, E, G; F-1 and F-1A; A-2 and A2-A; and M10 Airplanes
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