AD vs 337

[Strutwipe]

I know I'm going to get some stick for this question but that's ok because I have thick skin for the beatings from those sticks. I have never come across this situation before.

Without going into dates or aircraft, I have an AD to inspect the cap of the spar. If cracked, a stiffener can be installed and the repaired and inspected every 100hrs. The AD also says if crack or damage is in the spar web a new spar must be installed. The owner says there is a FAA approved 337 repair with fwd and aft doubler sandwiching the spar web in the same area (Both Lt and Rt of CL), so the spar web is not visible. No other damage or cracking is visible. I have not read the 337 but I think it's a moot point.

So between a FAA AD and a FAA approved repair, who wins? Can this be a chicken came before the egg situation?

Finally, yes, I am going to read up on this but I thought it would be an interesting thread.

 

[JAWS]

I would assume the AD is for inspection of an unaltered wing. How do you determine if the spar web is cracked if it is covered over by a previous repair? Is there any reference in the previous repair information regarding the AD inspection requirements?

Too vague for a proper response. But a WAG would be the repair may have to be removed for the AD inspection. Or maybe not.

Have fun.

 

[Bell206]

So between a FAA AD and a FAA approved repair, who wins?

Depends. Not enough info to make a call. But if this repair is part of an AMOC for that AD which provides terminating action for the AD then the repair would win. But in order to pursue that route you would have to get a separate AMOC for your specific aircraft, unless it's a Global AMOC. Now whether the repair needs a separate field approval will depend on if the repair data is inclusive of the AD or the AMOC as both are considered approved data.

 

[Tom-D]

In this case the AD still applies, even though the repair has been made. you still must inspect the spar.

" I have an AD to inspect the cap of the spar. If cracked, a stiffener can be installed and the repaired and inspected every 100hrs."
The only way to make this disappear is to replace the spar.

 

[Strutwipe]

Thanks for the input. According to the AD there is no repair if the crack/damage is in the web. I will admit, I did not think about the AMOC route that the past owner may have applied for. Looking at the 337 repair, I have my doubts. The current owner is going to provide the 337 this week. Is there anything specifically I should look for? The AD is attached.

On another note, the current owner is 85 and my mission is to see him fly his aircraft again. I'm doing the work at no charge so there is no incentive to change out the spars. With that being said, pencil whipping is not an option. I'm really hoping that this works out. The IA wrote up over 20 squawks. The owner is under the impression that the IA is going to sign off on the AD because of the 337 repair. I already have over 50 hours in this project but more importantly, I don't have the heart to tell him so I just want to make sure I get this right.

 

[JAWS]

Hopefully terminating action has been done long ago - within 100 hours from 1959 is a long time ago. I'd be sitting down and be doing some reading in the old logs, if available. If not, start looking at the aircraft and what is there compared to the terminating action in the AD.

Ercoupes are neat airplanes. Good luck.

 

[Tom-D]

The owner is under the impression that the IA is going to sign off on the AD because of the 337 repair. I already have over 50 hours in this project but more importantly, I don't have the heart to tell him so I just want to make sure I get this right.

Is block #4 of the 377 signed off by the FAA?

 

[Bell206]

According to the AD there is no repair if the crack/damage is in the web.

Still need a bit more info, but there is terminating action listed in the AD in one of two ways. And if this is the spar AD I think it is, then I'll bet a nickel it been complied with with no recurring inspection needed.

What is the S/N of the aircraft?

Did the IA write up this AD as a disc or is this something you found separately?

Have you researched all the aircraft records for any write ups on this AD?

The 337 repair you are referring to, has this repair already been complied on this aircraft or do you want to comply with this repair at this time?

 

[Strutwipe]

Thanks folks.

If the repair was accomplished after the AD was issued (1959) then we would have to check to see if the FAA FISDO, not DER or IA, approved the repair and terminated the applicability of the AD against S/N 4XXX. The 337 by itself does not terminate the AD. The 337 repair would be considered an Alternative Means of Compliance (AMOC) and must be approved by the office that issued the AD. The removal of the gusset would have to part of the repair. If this is the case, then all we are concerned about is the corrosion.

If the repair was accomplished before the AD was issued, or if the FISDO did not issue an AMOC, the aircraft operator would have to submit an application to the FISDO approval for an AMOC. Or just replace both rear spars.

If the application is denied, both the rear spars will have to be replaced. Time for composing the application and reply from the FAA will be about six months to a year.
Airworthiness Directive (AD) – Alternative Method of Compliance

 

[Strutwipe]

Still need a bit more info, but there is terminating action listed in the AD in one of two ways. And if this is the spar AD I think it is, then I'll bet a nickel it been complied with with no recurring inspection needed.

What is the S/N of the aircraft?

Did the IA write up this AD as a disc or is this something you found separately?

Have you researched all the aircraft records for any write ups on this AD?

The 337 repair you are referring to, has this repair already been complied on this aircraft or do you want to comply with this repair at this time?

Thanks for your input. I hope my new post addresses your questions. I have left out the S/N due to respecting the privacy of the owner but the AD is applicable.

 

[Strutwipe]

Is block #4 of the 377 signed off by the FAA?

Thanks Tom. I have request, texted, the son to see when the 337 was issued. Most likely the issuing 337 dated form will look different to todays.

 

[Tom-D]

Thanks Tom. I have request, texted, the son to see when the 337 was issued. Most likely the issuing 337 dated form will look different to todays.

If it was ever filed the FAA should have it. (aircraft history records)

block #4 has never changed. there is where the FAA signs it for approval.

It it was never signed, you are probably out of luck, the FAA is WAY Slow these days.

 

[Strutwipe]

Thanks Tom. I just saw one mistake, FISDO in lieu of FSDO; fixed. Also, in reading AC 39-10 (Attached) the AMCO require ACO approval. I'm still waiting to hear back from the owner's son.

I'm always amazed at the experience afforded to us all through POA.

 

[Bell206]

I was hoping to sign off the AD so the IA can sign off the annual.

I think you might be getting ahead of yourself. First, there were no AMOCs back in 1959 so drop that part for now. Lets look at the AD. It had to be complied with in 1959. So in 1959 the mechanic had 3 options available:

1) the aft spar was serviceable at which time it was required to be reinforced by stiffener angle P/N F-13109 or equivalent, or it was considered satisfactory if previously reinforced with P/N 415-13108 or equivalent. Full stop. The AD is complete.

2) the aft spar was damaged/cracked but not into the web then it was required to be repaired with stiffener angle P/N F-13109 or equivalent, and a AD recurring 100 hour inspection was required. If in 1959 this were the case then there should be a sign off for every AD 100hr inspection up to today.

3) the aft spar was damaged/cracked into the spar web then it was required to install a new spar and stiffener back in 1959. Full stop. AD completed.

So which one of the 3 above does the ercoupe fit into back in 1959? Unless it falls under item 2 above then the AD was complete back in 1959 and unless your 337 repair is also dated 1959 the repair has zero bearing on the AD as it would have been signed off 61 years ago. Do you follow?

The reason for my asking the aircraft S/N is that Ercoupe came out with a Service Letter that installed the F-13109 stiffener (referenced in the AD) and also stated that all ercoupes S/N 4869 and subsequent came with that stiffener installed from the factory. This means if your ercoupe S/N is higher than 4869 then the AD was complied with at delivery. I can’t get the Univair site to come up but there is a copy of that Service Letter there for your review.

It’s your call, but I’d get the AD sorted out first before trying to mix the 337 repair into things.

 

[Strutwipe]

I think you might be getting ahead of yourself. First, there were no AMOCs back in 1959 so drop that part for now. Lets look at the AD. It had to be complied with in 1959. So in 1959 the mechanic had 3 options available:

1) the aft spar was serviceable at which time it was required to be reinforced by stiffener angle P/N F-13109 or equivalent, or it was considered satisfactory if previously reinforced with P/N 415-13108 or equivalent. Full stop. The AD is complete.

2) the aft spar was damaged/cracked but not into the web then it was required to be repaired with stiffener angle P/N F-13109 or equivalent, and a AD recurring 100 hour inspection was required. If in 1959 this were the case then there should be a sign off for every AD 100hr inspection up to today.

3) the aft spar was damaged/cracked into the spar web then it was required to install a new spar and stiffener back in 1959. Full stop. AD completed.

So which one of the 3 above does the ercoupe fit into back in 1959? Unless it falls under item 2 above then the AD was complete back in 1959 and unless your 337 repair is also dated 1959 the repair has zero bearing on the AD as it would have been signed off 61 years ago. Do you follow?

The reason for my asking the aircraft S/N is that Ercoupe came out with a Service Letter that installed the F-13109 stiffener (referenced in the AD) and also stated that all ercoupes S/N 4869 and subsequent came with that stiffener installed from the factory. This means if your ercoupe S/N is higher than 4869 then the AD was complied with at delivery. I can’t get the Univair site to come up but there is a copy of that Service Letter there for your review.

It’s your call, but I’d get the AD sorted out first before trying to mix the 337 repair into things.

I agree with you that I am getting ahead of myself. I'm just trying to understand the full situation before talking with the owner's son. I've attach the SM for your review. The S/N of the ACFT is <4869 so the AD is applicable.

My understanding is the owner believes the 337 eliminates the AD requirement, if a AMOC is in place, it would. I personally do not believe there is an AMOC in this case but I have not seen the 337, or any other documentation for the repair. The IA issued a letter with about 20 squawks to the owner, which included this AD. I was just working on the IA's squawks that are repairable under the MM or AC 43.13-2 (Safety wire, clamping, cowling repair, brakes, and other small discrepancies). I thought it would be a good idea to make sure the project could move forward regrading this AD. I have tried to contact the IA but I've heard he is working in Mexico and has not responded to my inquires yet.

If the spars require replacement, that will be their decision. My mission was to see the owner fly in his ACFT again. On the bright side, I have learned a lot in the past 18 hours.

 

[Bell206]

My understanding is the owner believes the 337 eliminates the AD requirement,

We're still missing something here. What did the IA write up exactly about the AD? If the owner is correct then the 337 would need to have been dated in 1959 in order to connect with the AD because otherwise the AD was required to be signed off in 1959. Do you have access to all the aircraft records?

 

[Strutwipe]

We're still missing something here. What did the IA write up exactly about the AD? If the owner is correct then the 337 would need to have been dated in 1959 in order to connect with the AD because otherwise the AD was required to be signed off in 1959. Do you have access to all the aircraft records?

I agree and you are reading my mind. I've been told that the owners have all of the log books. I'm hoping to get the full records this week so I can review all the information. I now have a better understanding what is required and what information I'm actually looking for.

Here is what the IA wrote in his letter: Discrepancies.... 6) Compliance "with" AD 59-05-04. See 337 filed April 29, 1962 explaining a rear spar sandwich repair that obscures the rear spar from inspection in compliance with this AD.