If that is the case then you have to comply with the 2000hr/12 yr requirement and not the less restrictive 6000hr/12 yr requirement?smoss wrote:Per this recently released FAA notification, changes to the airworthy limitations are NOT mandatory to do. Although it's a bit confusing, after reading it a few times, appears to say only the original airworthy requirements submitted with the original type design are mandatory, unless the new ones are also issued as an AD.
Possible Airworthiness Issue for 2001-05 DA40s
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- Karl
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Re: Possible Airworthiness Issue for 2001-05 DA40s
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Re: Possible Airworthiness Issue for 2001-05 DA40s
This is based on the fact that only the FAA can legally mandate new requirements via the AD process. The FAA is unwilling to delegate such authority to the manufacturers (I think rightly so).Steve wrote:I received this by email from the FAA a few days ago, and that was my read as well. It appears that as a Part 91 operator, I do not have to comply with more restrictive airworthiness limitations issued after the original TC (e.g. MSI), but am permitted to apply less restrictive requirements which are issued after the TC (e.g. rudder cable replacement).smoss wrote:Per this recently released FAA notification, changes to the airworthy limitations are NOT mandatory to do. Although it's a bit confusing, after reading it a few times, appears to say only the original airworthy requirements submitted with the original type design are mandatory, unless the new ones are also issued as an AD.
Hard to believe...
The manufacturers have been trying to back door into getting this legal power for a few decades. Hence the manufacturer "mandatory service bulletins", referencing another section which they are permitted to update....
Each time, the FAA has come out with a statement saying no. They do have the power to do so.
Tim
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Re: Possible Airworthiness Issue for 2001-05 DA40s
Question:
Does an operator have to follow the original AMM airworthiness limitations in its entirety? The original AMM required the rudder cables to be replaced at 5 years. Can an operator pic and choose which items to follow out of the different revisions!
If an operator chooses to follow the original manual is it possible he/she may trigger a rudder cable
replacement?
Does an operator have to follow the original AMM airworthiness limitations in its entirety? The original AMM required the rudder cables to be replaced at 5 years. Can an operator pic and choose which items to follow out of the different revisions!
If an operator chooses to follow the original manual is it possible he/she may trigger a rudder cable
replacement?
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Re: Possible Airworthiness Issue for 2001-05 DA40s
I read through the SAIB and the underlying FAA Chief Counsel's opinion, then discussed with AOPA legal (I have the legal services plan) to see what they recommend I should do. His advice to me, for what's it worth, was that the FAA was likely to accept my either complying with the original AMM in its entirety or with the AMM as it currently stands in its entirety. Whether I can pick and choose which versions of the AMM to comply with, i.e., not do the inspections but take advantage of the relaxation of the rudder cable requirement, however, is an open question that has not been addressed by the FAA. He suggested that I might have our owner's group approach FAA flight standards to get their opinion on this. What do you all think?
Bernie Seward, IR, AGI
2003 DA40 N377DS
KCHO Charlottesville, VA
2003 DA40 N377DS
KCHO Charlottesville, VA
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Re: Possible Airworthiness Issue for 2001-05 DA40s
Why rock the boat? Use your own interpretation.
Steve
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Re: Possible Airworthiness Issue for 2001-05 DA40s
There is no relaxation as such for rudder cables.blsewardjr wrote: i.e., not do the inspections but take advantage of the relaxation of the rudder cable requirement,
Early aircraft had steel cables that need replacement at the interval specified. Later aircraft had stainless steel cables which are on condition. I doubt Diamond sell steel cable any longer so any OEM supplied replacement will almost certainly be stainless and be on condition.