Airworthiness Directive 2025-02-11 Rudder Replacement

[Steve Pierce]

Well as of midnight tonight despite the efforts of a lot of people here at ShortWingPipers.org, AOPA, EAA and the Short Wing Piper Club the FAA decided to issue an Airworthiness Directive against all of our aircraft's rudders. I can tell you that no one is happy about it but it is what it is. You can read the entire document here.
https://public-inspection.federalregister.gov/2025-02528.pdf

Here is the compliance schedule:

Category I Airplanes:
Airplanes having both
a rudder post mounted beacon light and a
150 or greater horsepower (hp) engine
installed.
Compliance Time:
Within 2 years after the effective date of
this AD.

Category II Airplanes: Airplanes having
either a rudder post mounted beacon light or
a 150 or greater hp engine installed.
Compliance Time:
Within 3 years after the effective date of
this AD.

Category III Airplanes: All airplanes not in Category I or Category II that do not have a rudder
post mounted beacon light and have an engine less than 150 hp and greater than 100 hp installed.
Compliance Time:
Within 5 years after the effective date of
this AD.

Category IV Airplanes: All airplanes not in Category I, II, or III that do not have a rudder post
mounted beacon light and have an engine of 100 hp or below installed.
Compliance Time:
Within 10 years after the effective date of
this AD.

A little insight into the availability, Univair has a few in stock as does Dakota Cub, I did not check with Alaska Gear Company. The issue is that the vendor that made the tail nav light bracket for Univair suddenly announced they would no longer make the brackets. I had a call from Jim Dyer the president of Univair a few months ago about this issue. As of our conversation today a new vendor has been procured and they are expecting a batch of brackets at the end of this month. The issue is that not only does Univair use these brackets but the other two manufacturers, Dakota Cub and Alaska Gear Company also use brackets they obtain from Univair. I guess the good thing is that the compliance time has been spread out so there is hopefully not a mad rush on rudders.

From Piper Service Bulletin SB 1379B

The affected aircraft will fall into one of the following categories:
• For aircraft with an airworthiness certificate issued prior to June 3rd, 1974, these aircraft were delivered from the factory with a rudder post made from 1025 steel. If a complete service history exists and it can be confirmed that the original rudder is still installed, proceed to Part II.
• For aircraft with an airworthiness certificate issued on or after June 3rd, 1974, these aircraft were delivered from the factory equipped with a rudder post made from either 1025 steel or 4130N steel. At owner/operator discretion, proceed to Part I. Otherwise, proceed to Part II.
• Aircraft equipped with a rudder of unknown or incomplete service history may have a rudder post made from either 1025 steel or 4130N steel. For these aircraft, the type of steel alloy used in the manufacture of the rudder post cannot be determined by visual inspection. At owner/operator discretion, proceed to Part I. Otherwise, proceed to Part II.

Also, all PMA'd rudders have been made from 4130 so if your rudder has been replaced with a new one it should be 4130.

 

[PA-16]

I think I have the original Rudder for my Clipper and there is no light on the tail post but I do have 108 horse 235c1, I will read the pdf tononight when I get off work.
what is the problem, their is no corrosion in my rudder
was recovered in 1984

 

[Frank Green]

Ok so maybe there is a little window for a AMOC. I will be having a conversation with a young lady safety inspector at my FSDO who happens to own a Tri. See if maybe a doubler tube is acceptable. That would be the simplest option. Also do we have to use a PMA rudder? How about just replacing the tube in our present rudder? Their only concern is the material in the center tube. Why not just replace that. I had to replace a section of the 3/8 tube at the bottom when I recovered it 10 years ago. I replaced many sections of tubing in the fuselage not the whole thing. What's the difference? This really sucks. At least I have 3 years to figure it out.

 

[PA-16]

That's quite a bit of reading I did skim over something about alternate compliance method and not needing to replace the rudder

 

[Jim]

The AD mentions;

Comment summary: Many commenters, including individuals, AOPA, EAA, The Short Wing Piper Club, and VAA, requested an option to inspect the rudder post or perform strength testing on the rudder post on a regular basis instead of replacing the entire rudder. The commenters stated that corrosion is a contributor to the rudder failure, therefore, requiring inspections or performing strength tests would be a more logical and more cost-effective means to ensure the strength of the rudder post is adequate for flight. FAA response: The FAA disagrees. It would be impractical to repetitively inspect the rudder for cracks, corrosion, and other damage. The operators could inspect the inside of the rudder post tube with a borescope; however, they would not be able to inspect the outer surface of the tube without removing the fabric. An inspection interval that adequately monitors the rudder post condition may be too costly because it will require frequent removal of the covering. Furthermore, many of the existing 1025 carbon steel rudders have been in service for over 70 years, have endured multiple corrosion removal processes, and have been painted or powder coated several times, making accurate inspections more challenging. In addition, a load test as an inspection to determine airworthiness is problematic because the load test could further damage the rudder and contribute to an accident. It would be very difficult to determine an acceptable load test that would in all cases determine a suspect rudder and not unknowingly damage a rudder. Strength testing the rudder post up to approximately yield stress is also problematic. If the strength of the rudder has been degraded over the years due to corrosion and fatigue, a test load could cause permanent, but unnoticed, damage to the rudder and could be the cause of a rudder failure in a subsequent flight.

If an owner/operator would like to implement an inspection program on its airplane to monitor the strength of the rudder in lieu of replacement, the FAA will consider the proposal upon submission of an AMOC request following the procedures in paragraph (h) of this AD.

(h) Alternative Methods of Compliance (AMOCs)(1) The Manager, West Certification Branch, FAA, has the authority to approve AMOCs for this AD, if requested using the procedures found in 14 CFR 39.19. In accordance with 14 CFR 39.19, send your request to your principal inspector or local Flight Standards District Office, as appropriate. If sending information directly to the manager of the West Certification Branch, send it to the attention of the person identified in paragraph (i)(1) of this AD. Information may be emailed to: AMOC@faa.gov.

 

[walt.buskey]

Thanks for the update, Steve.

 

[TylerR]

Thank all of you guys that have put a lot of hard work into fighting this

 

[dgapilot]

My AMOC request already went in!

 

[gundriver]

The AD mentions;

Comment summary: Many commenters, including individuals, AOPA, EAA, The Short Wing Piper Club, and VAA, requested an option to inspect the rudder post or perform strength testing on the rudder post on a regular basis instead of replacing the entire rudder. The commenters stated that corrosion is a contributor to the rudder failure, therefore, requiring inspections or performing strength tests would be a more logical and more cost-effective means to ensure the strength of the rudder post is adequate for flight. FAA response: The FAA disagrees. It would be impractical to repetitively inspect the rudder for cracks, corrosion, and other damage. The operators could inspect the inside of the rudder post tube with a borescope; however, they would not be able to inspect the outer surface of the tube without removing the fabric. An inspection interval that adequately monitors the rudder post condition may be too costly because it will require frequent removal of the covering. Furthermore, many of the existing 1025 carbon steel rudders have been in service for over 70 years, have endured multiple corrosion removal processes, and have been painted or powder coated several times, making accurate inspections more challenging. In addition, a load test as an inspection to determine airworthiness is problematic because the load test could further damage the rudder and contribute to an accident. It would be very difficult to determine an acceptable load test that would in all cases determine a suspect rudder and not unknowingly damage a rudder. Strength testing the rudder post up to approximately yield stress is also problematic. If the strength of the rudder has been degraded over the years due to corrosion and fatigue, a test load could cause permanent, but unnoticed, damage to the rudder and could be the cause of a rudder failure in a subsequent flight.

If an owner/operator would like to implement an inspection program on its airplane to monitor the strength of the rudder in lieu of replacement, the FAA will consider the proposal upon submission of an AMOC request following the procedures in paragraph (h) of this AD.

(h) Alternative Methods of Compliance (AMOCs)(1) The Manager, West Certification Branch, FAA, has the authority to approve AMOCs for this AD, if requested using the procedures found in 14 CFR 39.19. In accordance with 14 CFR 39.19, send your request to your principal inspector or local Flight Standards District Office, as appropriate. If sending information directly to the manager of the West Certification Branch, send it to the attention of the person identified in paragraph (i)(1) of this AD. Information may be emailed to: AMOC@faa.gov.

Something tells me that trying to get the FAA to go along with implementing an "inspection program" would be futile...

"D. Requests Regarding Repetitive Inspections Comment summary: Many commenters, including individuals, AOPA, EAA, The Short Wing Piper Club, and VAA, requested an option to inspect the rudder post or perform strength testing on the rudder post on a regular basis instead of replacing the entire rudder. The commenters stated that corrosion is a contributor to the rudder failure, therefore, requiring inspections or performing strength tests would be a more logical and more cost-effective means to ensure the strength of the rudder post is adequate for flight.

FAA response: The FAA disagrees. It would be impractical to repetitively inspect the rudder for cracks, corrosion, and other damage. The operators could inspect the inside of the rudder post tube with a borescope; however, they would not be able to inspect the outer surface of the tube without removing the fabric. An inspection interval that adequately monitors the rudder post condition may be too costly because it will require frequent removal of the covering. Furthermore, many of the existing 1025 carbon steel rudders have been in service for over 70 years, have endured multiple corrosion removal processes, and have been painted or powder coated several times, making accurate inspections more challenging.

In addition, a load test as an inspection to determine airworthiness is problematic because the load test could further damage the rudder and contribute to an accident. It would be very difficult to determine an acceptable load test that would in all cases determine a suspect rudder and not unknowingly damage a rudder. Strength testing the rudder post up to approximately yield stress is also problematic. If the strength of the rudder has been degraded over the years due to corrosion and fatigue, a test load could cause permanent, but unnoticed, damage to the rudder and could be the cause of a rudder failure in a subsequent flight."

 

[Steve Pierce]

Something tells me that trying to get the FAA to go along with implementing an "inspection program" would be futile...

"D. Requests Regarding Repetitive Inspections Comment summary: Many commenters, including individuals, AOPA, EAA, The Short Wing Piper Club, and VAA, requested an option to inspect the rudder post or perform strength testing on the rudder post on a regular basis instead of replacing the entire rudder. The commenters stated that corrosion is a contributor to the rudder failure, therefore, requiring inspections or performing strength tests would be a more logical and more cost-effective means to ensure the strength of the rudder post is adequate for flight.

FAA response: The FAA disagrees. It would be impractical to repetitively inspect the rudder for cracks, corrosion, and other damage. The operators could inspect the inside of the rudder post tube with a borescope; however, they would not be able to inspect the outer surface of the tube without removing the fabric. An inspection interval that adequately monitors the rudder post condition may be too costly because it will require frequent removal of the covering. Furthermore, many of the existing 1025 carbon steel rudders have been in service for over 70 years, have endured multiple corrosion removal processes, and have been painted or powder coated several times, making accurate inspections more challenging.

In addition, a load test as an inspection to determine airworthiness is problematic because the load test could further damage the rudder and contribute to an accident. It would be very difficult to determine an acceptable load test that would in all cases determine a suspect rudder and not unknowingly damage a rudder. Strength testing the rudder post up to approximately yield stress is also problematic. If the strength of the rudder has been degraded over the years due to corrosion and fatigue, a test load could cause permanent, but unnoticed, damage to the rudder and could be the cause of a rudder failure in a subsequent flight."

Yea, they pretty much disagreed with any comment we had.

 

[txfirefighter628]

So the only option is to replace the rudder with a PMA replacement? No way to replace the tube or reinforce it on the stock rudder?

 

[Jim]

Hi,

I think replacing the tube will nullify the AD, but I guess wrong too often.

 

[davidpatton111]

Since I'm going to be recovering the plane in the next 2 years, and I fall into the 5 year category, I'm in no rush. I did look at the Univair Rudders. One comes with no place to install lights, the other comes with a lower rear rudder installation point for the white position light and an input for the tail beacon. I already have the belly beacon. Here is what I'm looking for (I have attempted to navigat the various threads on lights and am still confused about appropriate part numbers), so:

1. Can someone provide the company and part number for an LED white position light for the lower part of the rudder
2. Is there a company that makes a strobe light that would fit where the tail beacon goes? If so what is the company and the part number?
3. What is the company and part number that will replace my mechanical belly beacon with an LED flashing beacon?

I only have the rear white nave light, but that doesn't seem to be an option when purchasing the Univair Rudder.

Attached is a picture of my current rudder with only white position light

 

[gundriver]

Yea, they pretty much disagreed with any comment we had.

Since I'm going to be recovering the plane in the next 2 years, and I fall into the 5 year category, I'm in no rush. I did look at the Univair Rudders. One comes with no place to install lights, the other comes with a lower rear rudder installation point for the white position light and an input for the tail beacon. I already have the belly beacon. Here is what I'm looking for (I have attempted to navigat the various threads on lights and am still confused about appropriate part numbers), so:

1. Can someone provide the company and part number for an LED white position light for the lower part of the rudder
2. Is there a company that makes a strobe light that would fit where the tail beacon goes? If so what is the company and the part number?
3. What is the company and part number that will replace my mechanical belly beacon with an LED flashing beacon?

I only have the rear white nave light, but that doesn't seem to be an option when purchasing the Univair Rudder.

Attached is a picture of my current rudder with only white position light

I just ordered U40622-007 with the rear nav light and the beacon post at the top. I have a belly beacon too, but I figured if this isn't the right one it may be the only one.
I'm thinking these rudders will be like Bitcoin in a few weeks and I'll just sell it on the dark web for millions...

​

 

[snoskier1]

For those in need of a small amount of nitric acid .... I can be a source.

I will need to work out the shipping requirements ... and my final cost.

Mark

 

[dgapilot]

So the only option is to replace the rudder with a PMA replacement? No way to replace the tube or reinforce it on the stock rudder?

You can replace the tube with a 4130 tube. It takes some jigging as you need to weld on the hinges and the reinforcement and the bellcrank but it can be done. If you are paying someone to do it, it may be cheaper to buy a new rudder. If you have the skill set to do it, and a few hours if time it can be done. I submitted an AMOC request to put an internal sleeve in, we will see where that goes. They say there is about a 30 day turnaround time for AMOC requests.

 

[PA-16]

Found this on facebook, happened 30 years ago, pilot said happened inflight towing a banner, 180hp J-3 with no light on top of rudder.
.

 

[Steve Pierce]

I ordered some nitric acid today. Piper can't say what their rudders were made of after 1974 which I think is bunk. I will pull the steering arm out of my Super Cub rudder that was built in 1982 and verify that it is 4130. I have some other customers in the same quandary.

 

[Steve Pierce]

For those in need of a small amount of nitric acid .... I can be a source.

I will need to work out the shipping requirements ... and my final cost.

Mark

Sorry, I ordered some this first thing this morning.

 

[PA-16]

My plane was built from a basket case in 1984, is there a way to tell without uncovering it if it's the original Rudder or a PMA rudder?

 

[Smokey]

A little insight into the availability, Univair has a few in stock as does Dakota Cub, I did not check with Alaska Gear Company. The issue is that the vendor that made the tail nav light bracket for Univair suddenly announced they would no longer make the brackets. I had a call from Jim Dyer the president of Univair a few months ago about this issue. As of our conversation today a new vendor has been procured and they are expecting a batch of brackets at the end of this month. The issue is that not only does Univair use these brackets but the other two manufacturers, Dakota Cub and Alaska Gear Company also use brackets they obtain from Univair. I guess the good thing is that the compliance time has been spread out so there is hopefully not a mad rush on rudders.

Steve,

I pulled up the SWPC drawing 40622 for the Rudder assy. and was confused by the lack of normal drawing standards. No suffix number or bill of materials listing the differences. The only identifying remarks is parenthesis around the application of the -7 suffix to include the bracket you listed above. From a previous post of yours, you identified the -8 suffix rudder as being approved under PMA for the PA-20. The pricing of the -8 without the bracket and strobe mount is somewhere in the neighborhood of $300.00 less than the -7.

As I have no need for the strobe mount my question to you is. Would you see it as doable to rob the bracket from my currently installed 1025 rudder and attach it to the -8 rudder with a log book entry? Or would you redo the bracket under owner produced parts?

Todd

 

[Brian]

In my situation a ‘57 150HP and original rudder. Mine never had the heavy rotating beacon but I do have a small lightweight Strobe at the top of the ruddder. Im guessing that small strobe puts me in Category l of the AD and 2 years to comply.
What I find lacking in this AD is there is no consideration for total time in service and / or if the aircraft is currently or was ever in the past on floats! We know the two failed rudders were both on float planes and probably high total time aircraft. Both of these criteria should have been factored into the decision on compliance in addition to, age, HP, & the beacon.

 

[snellbob]

So the FAA’s answer is to just put a new PMA’d 4130 rudder on your airplane. I just noticed in one of the ads for new 4130 rudders that one vendor sells that they are powder coated. I am NOT a fan of any kind of powder coat on tube and fabric aircraft. Powder coat, steel, and water. What could possibly go wrong!

 

[Steve Pierce]

Steve,

I pulled up the SWPC drawing 40622 for the Rudder assy. and was confused by the lack of normal drawing standards. No suffix number or bill of materials listing the differences. The only identifying remarks is parenthesis around the application of the -7 suffix to include the bracket you listed above. From a previous post of yours, you identified the -8 suffix rudder as being approved under PMA for the PA-20. The pricing of the -8 without the bracket and strobe mount is somewhere in the neighborhood of $300.00 less than the -7.

As I have no need for the strobe mount my question to you is. Would you see it as doable to rob the bracket from my currently installed 1025 rudder and attach it to the -8 rudder with a log book entry? Or would you redo the bracket under owner produced parts?

Todd

I would do whatever is easiest.

 

[buttercupairplane]

Since I'm going to be recovering the plane in the next 2 years, and I fall into the 5 year category, I'm in no rush. I did look at the Univair Rudders. One comes with no place to install lights, the other comes with a lower rear rudder installation point for the white position light and an input for the tail beacon. I already have the belly beacon. Here is what I'm looking for (I have attempted to navigat the various threads on lights and am still confused about appropriate part numbers), so:

1. Can someone provide the company and part number for an LED white position light for the lower part of the rudder
2. Is there a company that makes a strobe light that would fit where the tail beacon goes? If so what is the company and the part number?
3. What is the company and part number that will replace my mechanical belly beacon with an LED flashing beacon?

I only have the rear white nave light, but that doesn't seem to be an option when purchasing the Univair Rudder.

Attached is a picture of my current rudder with only white position light

Univair has that rudder option available for the white nav light and not rotating beacon at the top although it has a short post at the top. https://www.univair.com/piper/piper...dL3DQxrCuPucsToSbMj_iLeEMboS-fY7Ka35YwNc_ESY8 I have a tail beacon in mine and if you need the original tail light with an LED bulb, I'll make you a great deal. I ordered a new rudder for my plane yesterday to be ahead of the game and since I have a shorter timeframe to comply than most. It's already an 8 week lead time and this will grow fast according the guy at Univair who sounded totally overwhelmed.

 

[davidpatton111]

You have the white tail light and it is LED? Just the bulb or entire assembly? And what the heck am I supposed to do with that post? It looks like it’s all Univair offers. Will a small strob fit on there? Or can it be cut off and covered? It would be nice if I could fit a stobe up there. Assume the post has a hole in it for wires?

Assuming this will open the flood gates and others will make variations of it. The Alaska one looks good but only for PA-18 from what the site says.

 

[Steve Pierce]

This is what I bought. https://consolidated-chemical.com/product/nitric-acid-70-acs-grade-corrosive-acid/

 

[Steve Pierce]

Here is a better drawing than what is on the Short Wing Piper Club CD.

 

[McDaver63]

FYI, I contacted Alaska Gear Company about their PA-18 rudder for $800. They said it is currently approved for the PA-18 but they are working with the FAA to get it approved for the PA-20 & 22. I have also contacted Dakota Cub as well who makes a PA-18 rudder. Hopefully more options for a replacement will become available.

 

[Scott M]

How smart can they be if they think the aircraft can be returned to service in 8 hrs @ 85 dollars an hour ?

 

[Steve Pierce]

Same part number, install it and be done with it. If it bothers someone refer to AC23-27 Substitution of Parts on Vintage Aircraft.

 

[Flyjeep]

Would it be possible to set something up at oshkosh or sun n fun or fill in the blank location to set something up to have a group cover their rudders under the supervision of a qualified individual that can sign off on it when completed? I know final coat of paint might be an issue but it could cut the cost.