I read through a lot of the comments on this proposed AD.
https://www.regulations.gov/docket/FAA-2023-1893/comments
You can Comment here. Deadline is Tuesday 2-20-2024
https://www.regulations.gov/document/FAA-2023-1893-0165/comment
Afterwards I submitted my comment:
I am an A&P/IA who has specialized in the maintenance, repair and restoration of tube and fabric Piper aircraft for almost 30 years. Having worked with the FAA, ACO and the Small Aircraft Directorate on issues effecting Aging Aircraft in the past I have to say that I have been very disappointed in the communication with the type clubs on this rudder issue. When you eat, sleep and breath these aircraft and spend lots of time insuring that they are flown, maintained and restored in the safest possible condition you hope you would be contacted when these type of issues come up as I personally have in the past. Some of these previous correspondences have resulted in SAIB, AD revisions and others were just general knowledge. It proved to me personally that this was not “us against them”. Nothing to do with this issue has made me feel that way.
Piper built in excess of 50k airplanes with this rudder. I have read the ACS dated 9-4-2020, NTSB AIR-22-02and the NTSB Aviation Investigation Final Reports for the aircraft listed in the preceding documents. Having maintained, repaired and rebuilt fabric covered aircraft for almost 30 years I have discovered there are lots of causes of failures. I am curious as to the history of the aircraft involved, modifications, history of repairs, etc. Way more questions than answers in the data provided.
Since this issue came up almost 4 years ago I have investigated several ways to both verify the integrity of the rudder and to reinforce it. A simple fixture can be fabricated to fit over the top of the rudder to attach a fish scale to or even a torque wrench to allow a pull test to a minimum standard. Also I have installed a 3/4”x.035” wall 4130 steel tube into several rudders to verify that it is both doable and to check the tightness of fit. It is doable and tight. Could even be held to the outside tube via Cherry rivets.
I would be curious to know the load on the rudder on any given model. Is a J3 with a 65 hp engine even close to the load put on the rudder of a PA12 with 180 hp, on floats with no ventral fin? Again, more questions than answers.
This proposed AD will take years to comply with given the availability of rudders and experienced personnel to do the cover work. I would hope that the FAA takes all things into account and realizes that 2 or 3 incidence in a fleet of at least 30,000 aircraft is a probability of .0001 to .000066.