Question Update from SWPC re: the NPRM that affects all Cubs and Short Wing Pipers

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11 Jan 2024 16:35 - 11 Jan 2024 16:36 #4176 by Jen D
Important information from the Short Wing Piper Club: Short Wing Piper Club Steve Carruthers
  As you know we asked for and received a 90-day extension on the NPRM for the rudder. The closing date is February 20, 2024, so there is still plenty of work to be done and very little time to accomplish our goal. We have so far received 1% of the 31,000 planes affected in the survey. With that small cross section responding, with an accumulation of over 1,000,000 hours flown with zero rudder failures! This speaks volumes for the safety of these planes and is helpful to our cause.
The survey will be up for a few more days, so if you have not yet completed the survey, please do it now. There are so many people working this on your behalf and a mere thank you is not enough, for the time and effort they are putting into this effort. Sometime in the next 2 weeks we will have a very strong comment to submit to the FAA. There are currently 265 responses to the NPRM and we need to double that number. You can make multiple comments to the NPRM and we encourage you to continue to submit comments.
We need to point out things like the accident aircraft were not in compliance with the TCDS/ STC. We must continue to address the incomplete docket and request that they comply and fill in the missing information in the docket.
Lastly, request that the FAA completely withdraw this NPRM due to the fact that it is based on non-airworthy aircraft and if it is issued as an AD the FAA would be rendering the Type Certificate and STC irrelevant.
We will continue to fight this overreach until the closing date. Let’s continue to maintain our aircraft to the best of our abilities and continue to be safe! We are the custodians of these planes and we need to be responsible and continue in the tradition that we have over the last 75 plus years.
Thank you!

The following are some links you may find useful in researching the NPRM and making comments to it.
  - To view the NPRM go to  www.regulations.gov/document/FAA-2023-1893-0001 - To make a comment on the NPRM, click on the blue comment box just below the title at the above web page.- To browse posted comments, go to the above website and click on the box “Browse Posted Comments”. The comments are sorted by date, but that can be changed by clicking on the “Sort By” link on the right had side of the comment page.- To view the Structural analysis of the rudder failure go to  www.ntsb.gov/investigations/AccidentReports/Reports/AIR2202.pdf - You may find other reports relevant to this NPRN at  data.ntsb.gov/Docket?ProjectID=101415 - The Type Certificate for the PA-12 aircraft is listed at  shortwingpiperclub.org/wp-content/uploads/2024/01/a-780.pdf - The STC requirements for floats on the PA-14 aircraft are listed at  crairmotive.com/products/sa1-644-for-pa-..._sid=caf426a10&_ss=r .- To respond to the survey of aircraft affected by the NPRM go to  shortwingpiperclub.org/vintage-fabric-piper-survey-2/ - This comment by David Schober is an excellent example of what needs to be included in an effective response  shortwingpiperclub.org/wp-content/upload...246_attachment_1.pdf
  Please send in your comments. If the NPRM becomes an Airworthiness Directive and the wording/requirements don’t change, it could cost you $3000 to $4000 and some time to change out your rudder post.
Last edit: 11 Jan 2024 16:36 by Jen D.

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