FAA-2012-0731-0008

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Here is my comment on AD FAA-2012-0731-0008:

We completed this AD on our 1972 PA-32-300 last March and I'm still angry. I'm angry because the FAA, once again, grossly under estimated the cost of AD compliance.

FAA - Inspection of the horizontal stabilator control system takes 5 hours.

FAA - Replacement of stabilator control cable per set at $1,558 parts and labor.

The AD specifically instructs the mechanic to inspect the cables and it would seem that FAA believes this can be done without removal. I talked to three shops and none of them would sign off on the work unless the cables were removed and inspected. I carefully read the AD, looked at diagrams, talked to mechanics and it was clear, removal was necessary. Two of the three shops strongly suggested it would be cost effective to skip the inspection and just purchase new cables which we did.

So the reality of this AD isn't a cable inspection. It's the removal and replacement of two sets of cables which the FAA estimates the cost to be $3,116.

If the mechanics I talked to and my analysis of what needs to be done as per the AD are correct, using the FAA numbers the compliance of this AD will cost Piper owners over $105,984,508!

You should budget more closer to $3,500 to $4,000 and use a shop experienced in this repair.

FYI, our cables were stretched but had no corrosion. It's clear the previous inspection requirement, if done, was good enough but there should be something more the FAA could do to make it clear this was a serious problem in lieu of a full blown $125 million repair.

When you look at the real cost of this AD, the amount of work needed, the hard physical labor, rubber mallet hammering alone... The cable replacement was absolutely a back breaker and it makes you wonder how many cable replacements will result in subsequent problems?

On the flip side, during the AD we took the opportunity to remove, paint and reinstall the horizontal stabilator which turned out to have significantly worn bushings. The result was a much tighter trim control and a horizontal stabilator with zero flutter/slop which improved performance.