Proposed American FAA AD on ASW-15 for Root Rib Inspection/Replacement

[raylov...@gmail.com]

See proposed AD at:
https://www.govinfo.gov/content/pkg/FR-2022-03-23/pdf/2022-05873.pdf

As a side note: How does the FAA come up with a shop rate of $85/hour? Seems a tad low.

Ray Lovinggood
W8

[Hank Nixon]

50+ year old gliders with wood root ribs. Not surprising. I've seen a 15 with this problem.
UH

[JAB]

On Wed, 23 Mar 2022 06:21:27 -0700 (PDT), "raylov...@gmail.com"
<raylov...@gmail.com> wrote:

>How does the FAA come up with a shop rate of $85/hour? Seems a tad low.

Unknown, but they may use U.S. Bureau of Labor Statistics

https://www.bls.gov/bls/blswage.htm

On another FAA topic
<https://www.faa.gov/regulations_policies/policy_guidance/benefit_cost/media/econ-value-section-7-labor-cost-factors.pdf>

https://www.faa.gov/regulations_policies/policy_guidance/benefit_cost/

[Michael Fadden]

When the AD says On Condition Cost - Cost per Product they are talking about a per rib cost? An ASW 15 group has people paying $1300 for parts and an all-in total of around $7000. One reputable repair station is ballpark estimating 40 hours for the work, not 8. Something is not right, here.

Mike

[Mark Mocho]

On Friday, April 1, 2022 at 8:12:19 AM UTC-6, mdfa...@gmail.com wrote:
> When the AD says On Condition Cost - Cost per Product they are talking about a per rib cost? An ASW 15 group has people paying $1300 for parts and an all-in total of around $7000. One reputable repair station is ballpark estimating 40 hours for the work, not 8. Something is not right, here.
>
> Mike

FAA estimates on cost of repair are total fantasies to make it look like the expense is insignificant to pilots/owners of affected aircraft. Low repair estimates make it easier to get the AD approved by the bureaucracy, as well as reducing the number of objections received in the "Comments" supposedly considered in the NPRM.

Several years ago, an AD was issued on the Centrair Pegase 101A glider. Apparently, several gliders may have been shipped with aileron and elevator hinge pins that were of inferior material. In spite of the fact that only a limited number of gliders were directly affected, and Centrair had issued a Service Bulletin specifically referring to the serial numbers of the affected ships, the author of the AD expanded it to include ALL Pegase 101A gliders. The cost of repair was listed in the AD as something like 6 hours at $65/hour and $1 for parts. In reality, the job involved removing the ailerons and elevator, drilling out the rivets from 30+ hinge pins, pressing out the pins with a special tool (which had to be fabricated) and replacing the pins and rivets. After that, the control surfaces had to be checked for balance and reinstalled. The part cost was 30 pins at 14 Euros each and 30 rivets at 1 Euro each, for a parts cost of 450 Euros, not including shipping. My local shop estimated 30 hours at $80/hour for a total of $2,400 labor and $450 parts, not $390 and $1 quoted in the AD. After some squealing to the Small Aircraft Directorate, the AD was revised to only apply to the serial numbered aircraft referred to in the original Centrair Service Bulletin.

It is also worth noting that the author of this AD was also the dumbass who issued the infamous 3,000 hour life limit AD that ordered Pegase owners to cross out ALL references in the POH and Maintenance Manual to the 3,000 hour inspection and essentially ground all Pegase101 gliders once the "limit" was reached. It took a nine-year battle to find a "fix" that allowed us to keep flying for another 1,500 hours. Fortunately, the AD author was booted out of the Certification office and sent to work in some other FAA division, where he is (hopefully) diligently reviewing documentation to determine whether all other FAA employees have the proper waste basket size in their offices commensurate with their GS service rating.

[Hank Nixon]

On Friday, April 1, 2022 at 10:12:19 AM UTC-4, mdfa...@gmail.com wrote:
> When the AD says On Condition Cost - Cost per Product they are talking about a per rib cost? An ASW 15 group has people paying $1300 for parts and an all-in total of around $7000. One reputable repair station is ballpark estimating 40 hours for the work, not 8. Something is not right, here.
>
> Mike

I suspect that the estimate is the cost of inspection. When the inspection is done the determination is made as to whether the service bulletin to do the update is required. The ball park sounds about right for the first one to be done, given that there are some tools to be made and tricks to be learned.
FWIW
UH

[Michael Fadden]

>
> Several years ago, an AD was issued on the Centrair Pegase 101A glider. Apparently, several gliders may have been shipped with aileron and elevator hinge pins that were of inferior material. In spite of the fact that only a limited number of gliders were directly affected, and Centrair had issued a Service Bulletin specifically referring to the serial numbers of the affected ships, the author of the AD expanded it to include ALL Pegase 101A gliders. The cost of repair was listed in the AD as something like 6 hours at $65/hour and $1 for parts. In reality, the job involved removing the ailerons and elevator, drilling out the rivets from 30+ hinge pins, pressing out the pins with a special tool (which had to be fabricated) and replacing the pins and rivets. After that, the control surfaces had to be checked for balance and reinstalled. The part cost was 30 pins at 14 Euros each and 30 rivets at 1 Euro each, for a parts cost of 450 Euros, not including shipping. My local shop estimated 30 hours at $80/hour for a total of $2,400 labor and $450 parts, not $390 and $1 quoted in the AD. After some squealing to the Small Aircraft Directorate, the AD was revised to only apply to the serial numbered aircraft referred to in the original Centrair Service Bulletin.
>
> It is also worth noting that the author of this AD was also the dumbass who issued the infamous 3,000 hour life limit AD that ordered Pegase owners to cross out ALL references in the POH and Maintenance Manual to the 3,000 hour inspection and essentially ground all Pegase101 gliders once the "limit" was reached. It took a nine-year battle to find a "fix" that allowed us to keep flying for another 1,500 hours. Fortunately, the AD author was booted out of the Certification office and sent to work in some other FAA division, where he is (hopefully) diligently reviewing documentation to determine whether all other FAA employees have the proper waste basket size in their offices commensurate with their GS service rating.

I suspected as much but have never owned a glider when a new AD was issued. These estimates are wildly off and if its a safety of flight issue, I don't see the point in grossly underestimating the cost. As you mention the Pegase ADs, I'll add that my other glider is a Peg and I would never have bought it if it hadn't been for the work put in by Bob and yourself to get the 3000 hr. limit changed. For anyone who interested in what is involved in beating city hall, have a look at the timeline during that debacle (if you can find it). Its a stark example of a bureaucrat gone wild and refusing to admit an error. Also, the cost to do the ASW 15 inspection is listed separately from the cost to repair - 1 hour of labor at $85/hour. It took longer to pull the glider out than to find the cracks. Now, what to do with my 15?

Mike