The FAA's fatigue and damage tolerance policy should cover all older aircraft, according to the Aircraft Owners and Pilots Association (AOPA). The organization was responding to an FAA draft advisory circular (AC) on fatigue and damage tolerance issued to the industry for comment (see ASW, May 9). The new AC would set guidelines for allowing aircraft to continue flying with known structural cracks, if the cracks are not in the primary structure and the airframe can still withstand the ultimate design load.

"The FAA left out the majority of older general aviation (GA) aircraft from this guidance document," said Luis Gutierrez, AOPA's director of regulation and certification policy. "As drafted, it only applies to Part 23-certificated aircraft, but most aircraft flying today were certificated under the old CAR 3 standards."

He argues that the CAR 3 standards should be included. As AOPA said in its comments to the FAA, "The FAA has previously applied this policy to CAR 3 airplanes."

Of concern to AOPA is the elimination of analysis and test options for flying with known cracks. "The FAA's 1996 policy memorandum allows for various combinations of analysis and test," the AOPA submission to the docket says. "The removal of those options would eliminate viable alternative methods to substantiate the ability to sustain ultimate load with known cracks."