Bad News from the FAA regarding Landing Gear Actuator (Gear Set)

[Matthew P]

Just wanted to provide an update as I received a reply from the FAA regarding the FOIA request I made to get the metallurgy report for the landing gear actuator gears.

The FAA stated that the type holder will not provide the information and that the FAA has no means of requiring them to do so, nor does the FAA have a means of requiring the type hold to provide replacement parts in order comply with ADs or SBs, even if the type holder has the capability to produce the parts, which they do.

 

The FAA also stated that the landing gear actuator gears are considered Category Type 1 parts (Critical) and therefore, are not eligible to be produced under the Vintage Aircraft Replacement and Modification Article (VARMA) program, otherwise known as Owner Produced Parts (OPP) and therefore we are dead in the water.

So, UNLESS the Mooney CEO follows through, we are screwed and I'm not very hopeful as he hasn't responded to my last inquiry as to where they are at with the effort to license the parts out in order to get them manufactured.

Makes you wonder as to the actual financials of Mooney, (if they can't front $20K to have gearsets made, knowing they will get their monies back, plus markup, or license the part out knowing that they will still make money without the initial investment risk,) whether the individuals making the decisions ever took a business 101 course....they say they are in a money crunch, yet have means to make something more than they are currently, yet they don't.

Oh well, sorry guys, I tried....will be interesting to see how my aircraft will be affected come annual in February, all I know is that Mooney has the ability to rectify our situations but actively chooses NOT to do anything about it.

Edited 21 hours ago by Matthew P

[Echo]

Thank you for all your effort and clear communication Matthew.  Pretty rotten situation to be in for Mooney owners.

[PT20J]

It seems that Mooney has entered into arrangements with the owner of LASAR to get Eaton no back springs made. I know that at least one MSC offered to front the money to get this done but was turned down. It seems Mooney was concerned about another company fronting the money. But the LASAR deal does’t require LASAR to front the money as they are collecting deposits to apparently cover the manufacturing cost and then selling them with a markup. 

This is a win for LASAR, Mooney and owners because it gets parts made, albeit expensively. So, perhaps it might be fruitful to contact Brett Stokes and see if he is interested in a similar arrangement for the gears.

[Matthew P]

5 minutes ago, PT20J said:

It seems that Mooney has entered into arrangements with the owner of LASAR to get Eaton no back springs made. I know that at least one MSC offered to front the money to get this done but was turned down. It seems Mooney was concerned about another company fronting the money. But the LASAR deal does’t require LASAR to front the money as they are collecting deposits to apparently cover the manufacturing cost and then selling them with a markup. 

This is a win for LASAR, Mooney and owners because it gets parts made, albeit expensively. So, perhaps it might be fruitful to contact Brett Stokes and see if he is interested in a similar arrangement for the gears.

I've found out, when contacting the 17 MSCs that they aren't interested in discussing the issues with me because they have all heard it before when dealing directly with Mooney leadership, Mooney knows the issues yet REFUSES to do anything about it....might be better for Mooney to just go defunct, get someone to take over the Type Certificate hoping that they have the wear withal to address the issues. I just wish I knew the Chinese Company that is licensed to manufacture Mooney in China, I'd reach out to them.... 

[Ragsf15e]

8 minutes ago, Matthew P said:

I've found out, when contacting the 17 MSCs that they aren't interested in discussing the issues with me because they have all heard it before when dealing directly with Mooney leadership, Mooney knows the issues yet REFUSES to do anything about it....might be better for Mooney to just go defunct, get someone to take over the Type Certificate hoping that they have the wear withal to address the issues. I just wish I knew the Chinese Company that is licensed to manufacture Mooney in China, I'd reach out to them.... 

Thanks very much for your time and effort.

Couple thoughts… if Mooney did go under, it doesn’t necessarily mean the parts license is released.

These parts don’t fail often (at least the 40/1 gears), so we might have some time.

I really think it could be done just like Lasar has done the ducts recently.  The parts are likely more expensive, but owners and MSCs might want a set on the shelf, so we might be able to order enough to satisfy Mooney.  I would think Lasar could use the same approach as they just did?

Thanks again,

Drew

[Matthew P]

5 minutes ago, Ragsf15e said:

Thanks very much for your time and effort.

Couple thoughts… if Mooney did go under, it doesn’t necessarily mean the parts license is released.

These parts don’t fail often (at least the 40/1 gears), so we might have some time.

I really think it could be done just like Lasar has done the ducts recently.  The parts are likely more expensive, but owners and MSCs might want a set on the shelf, so we might be able to order enough to satisfy Mooney.  I would think Lasar could use the same approach as they just did?

Thanks again,

Drew

Understood, but if it is abandoned, then the FAA could release the Manufacturer data, or whomever purchased the Type Certificate for the M20 series, might produce parts for the aircraft.

The problem is, as you are aware, there are NO gearsets to get in the event one has the old 20:1 gearsets or an improperly maintained 40:1 gearset. there are only (3) alternatives: 1. Convert to Manual J-bar 2. Take chances buying a used actuator not knowing the condition of the gears 3. Get with Maxwell in regards to a conversion.....seeing how 2 of the 3 are $10K or more, makes the alternatives less than appealing....I know (1) individual that has a new set of the original gears still in the package, he was nice enough to lend them to me to get them measured and scanned, I'm just waiting for him to sell his Mooney in hopes that he'll sell them to me.

I would think 115-120 sets would have been enough for Mooney, the minimum required to make a run is less than that, but apparently not.

I'm still waiting to hear back from the company that acquired Dukes (Aero Fluid Products) to see if they still provide the gears sets, I did find the manufacturer of the gears (Avon Gears) they wouldn't tell me who their customers are that they make that same gear set for, assume Mooney and Cessna, I asked them to provide my information to their customers and their response back was that they don't deal with individuals and aren't interested in providing parts... I've heard that the same gears are used by cessna, but no one has provided me any information on what the part numbers or actuators are.

[KSMooniac]

I think the biggest problem with Mooney or Dukes/Aero Fluid Products or an MSC that might sell any replacement gears is that it will reset the liability clock for the vendor, and the math will NOT work out at nearly any sane or insane sales price to us for a set of gears.  Right now, most of our Mooney fleet is >>18 years old and thus off the books in terms of liability exposure, but the moment any new part gets installed, then the liability shifts to that vendor.  It really sucks, but that is likely the reality with our litigious society.

I wonder if Mooney even has drawings or other engineering data for the gears in the first place.  I expect they bought actuators to a specification that they fit in a physical volume, travel XX inches, consume XX amount of power, etc. and it was up to the actuator manufacturers to design a product to meet those requirements.  I think it would be very unusual for an airframe manufacturer to be doing detailed design of gears like that.  Similarly, accessory gears in a Lycoming are designed by Lycoming, and we would not expect Mooney to provide a replacement cam gear, would we?

Having said all that, Mooney could be proactive to design/fab/sell a replacement set of gears like they did in the past (likely just bought from the actuator vendors) but obviously they have no interest in doing that and putting a lot more planes on their liability exposure when they have no money to buy insurance or defend a future lawsuit that might arise from selling <$100k worth of gears.

I know Maxwell was noodling around with a hydraulic actuator in the last year or so... that is an intriguing idea but then we would have to add a hydraulic system to the plane too.  

If MAPA or similar were still a functioning entity, then perhaps they could sponsor a design/STC contest like the American Bonanza Society has for replacement ruddervators.

[Matthew P]

8 minutes ago, KSMooniac said:

I think the biggest problem with Mooney or Dukes/Aero Fluid Products or an MSC that might sell any replacement gears is that it will reset the liability clock for the vendor, and the math will NOT work out at nearly any sane or insane sales price to us for a set of gears.  Right now, most of our Mooney fleet is >>18 years old and thus off the books in terms of liability exposure, but the moment any new part gets installed, then the liability shifts to that vendor.  It really sucks, but that is likely the reality with our litigious society.

I wonder if Mooney even has drawings or other engineering data for the gears in the first place.  I expect they bought actuators to a specification that they fit in a physical volume, travel XX inches, consume XX amount of power, etc. and it was up to the actuator manufacturers to design a product to meet those requirements.  I think it would be very unusual for an airframe manufacturer to be doing detailed design of gears like that.  Similarly, accessory gears in a Lycoming are designed by Lycoming, and we would not expect Mooney to provide a replacement cam gear, would we?

Having said all that, Mooney could be proactive to design/fab/sell a replacement set of gears like they did in the past (likely just bought from the actuator vendors) but obviously they have no interest in doing that and putting a lot more planes on their liability exposure when they have no money to buy insurance or defend a future lawsuit that might arise from selling <$100k worth of gears.

I know Maxwell was noodling around with a hydraulic actuator in the last year or so... that is an intriguing idea but then we would have to add a hydraulic system to the plane too.  

If MAPA or similar were still a functioning entity, then perhaps they could sponsor a design/STC contest like the American Bonanza Society has for replacement ruddervators.

Mooney doens't seem to have those concerns or problems making parts for other manufacturers, which is what I understand is keeping them afloat...Still begs the question, if they aren't willing to do it, why not license it out?

[PT20J]

2 hours ago, Matthew P said:

I've found out, when contacting the 17 MSCs that they aren't interested in discussing the issues with me because they have all heard it before when dealing directly with Mooney leadership, Mooney knows the issues yet REFUSES to do anything about it....might be better for Mooney to just go defunct, get someone to take over the Type Certificate hoping that they have the wear withal to address the issues. I just wish I knew the Chinese Company that is licensed to manufacture Mooney in China, I'd reach out to them.... 

My point was that things may have changed because LASAR has cut at least two recent deals with Mooney to supply parts made by 3rd parties that Mooney can’t or won’t have made on its own.

[N201MKTurbo]

We are not dead in the water. Someone could make them under PMA.

[KSMooniac]

2 hours ago, Matthew P said:

Mooney doens't seem to have those concerns or problems making parts for other manufacturers, which is what I understand is keeping them afloat...Still begs the question, if they aren't willing to do it, why not license it out?

If Mooney is making parts for others now, their customer would likely be the primary liability target.  I presume Mooney's certified QA/QC system (part of their Production Certificate) shows compliance with all engineering and manufacturing requirements levied by their customer, so presumably the liability would lie with their customer.  (I'm assuming they're making parts for aircraft here.)  Mooney would only be liable if they delivered defective parts, lied on paperwork/inspections/etc. versus a "faulty design" that is usually alleged by ambulance chasers.

[EricJ]

1 hour ago, N201MKTurbo said:

We are not dead in the water. Someone could make them under PMA.

Or via AC 23-27, e.g., with a DER or whatever.   It's always possible, it just may be more expensive than just having one made.

I'm thinking it might be more practical, more economical, and more servicable, to find an actuator assembly from another, newer, application and fit that.   Finding something that fits reasonably well dimensionally and provides sufficient force is probably not outside a reasonable realm of possibility.   If one is found that meets a TSO somewhere, even better.   Flap actuators from larger airplanes are often very similar.

 

[MikeOH]

20 minutes ago, EricJ said:

Or via AC 23-27, e.g., with a DER or whatever.   It's always possible, it just may be more expensive than just having one made.

I'm thinking it might be more practical, more economical, and more servicable, to find an actuator assembly from another, newer, application and fit that.   Finding something that fits reasonably well dimensionally and provides sufficient force is probably not outside a reasonable realm of possibility.   If one is found that meets a TSO somewhere, even better.   Flap actuators from larger airplanes are often very similar.

 

@EricJ

Adapting such an actuator would require a DER, TSO or not,  correct?

[Schllc]

Years ago I bought this really high end Italian oscillating belt sander. It worked really well for a few years and then the oscillating part stopped working. 
I took the machine apart and found this helical worm gear made of bronze. I hunted for the company only to find out they had gone out of business years ago and if I couldn’t get the gear the machine was scrap. Well, a new machine of this size and quality was over 20k so I started looking…

I ended up finding a shop in Columbia (the country) that would to produce the part for $75. I ordered three of them and zip tied them into the machine near the gears… I’ve used one more set of them and apparently this was a part designed to wear to spare the more expensive parts. 
sorry for the tangent but my ocd required me to complete the story…

point being, I’m not going to retire any machine I own for some part that I know I can figure out a way to replace. 
I understand there are some things on the plane like a turbo housing, or a crank that are far too complex and critical to produce yourself, but the FAA treats too many things as critical, that just are not so on our little planes. 
Good machinists all pride themselves on being able to do complicated things, and they are extremely knowledgeable about metal and its properties, those gears are not that hard to manufacture, and I’m willing to bet if you knocked on enough machine shop doors you would find somebody willing to make them.

[EricJ]

25 minutes ago, MikeOH said:

@EricJ

Adapting such an actuator would require a DER, TSO or not,  correct?

Depends on who you talk to, and probably the circumstances around a specific part, but there are various ACs that give guidance in that area.    For example, AC 23-27 p7c(4) sez a previous field approval can be used as the basis for field approval on a particular aircraft, and any missing data may be filled in by a DER.   Other guidance describes using a DER to develop data for an installation.   A TSO helps, since the part is already known to conform to data that may be relevant, or potentialy even sufficient.

So it only takes one case of a field approval to provide approved data for subsequent installations.    The data would not have to be generated every time.   VARMA can even use data from previous field approvals, so that's another avenue.
 

8 minutes ago, Schllc said:

Years ago I bought this really high end Italian oscillating belt sander. It worked really well for a few years and then the oscillating part stopped working. 
I took the machine apart and found this helical worm gear made of bronze. I hunted for the company only to find out they had gone out of business years ago and if I couldn’t get the gear the machine was scrap. Well, a new machine of this size and quality was over 20k so I started looking…

I ended up finding a shop in Columbia (the country) that would to produce the part for $75. I ordered three of them and zip tied them into the machine near the gears… I’ve used one more set of them and apparently this was a part designed to wear to spare the more expensive parts. 
sorry for the tangent but my ocd required me to complete the story…

point being, I’m not going to retire any machine I own for some part that I know I can figure out a way to replace. 
While I understand there are some things on the plane like a turbo housing, or a crank that are far too complex and critical to produce yourself, but the FAA treats too many things as critical, that just are not so on our little planes. 
Good machinists all pride themselves on being able to do complicated things, and they are extremely knowledgeable about metal and its properties, those gears are not that hard to manufacture, and I’m willing to bet if you knocked on enough machine shop doors you would find somebody willing to make them.

Yup.   There's always a way.   Go to a fly-in or airshow with a lot of vintage airplanes and many of them are examples of people just finding ways to get it done.

Sometimes it just takes established "common practice" however it got there.   My fave example is how MMO has been commonly used to cure many ills in engines on certificated airplanes for many decades (since before WWII!), despite it not being ever approved anywhere for any of them, but it is cited as "common practice" and sometimes "best practice" since it's been done effectively for so long by so many people.   

[KSMooniac]

12 minutes ago, Schllc said:

Good machinists all pride themselves on being able to do complicated things, and they are extremely knowledgeable about metal and its properties, those gears are not that hard to manufacture, and I’m willing to bet if you knocked on enough machine shop doors you would find somebody willing to make them.

I agree, and I'm sure I would find the motivation if my fantastic J were grounded for lack of these gears.  The difference between our machines and your belt sander gears is the end use...  If you get asked what they're for, you better have a plausible answer/application that is something far different than "airplane" or you're likely to get ushered out the door.  

My first job in the industry was an internship at Cirrus Design, back before there were SR-20s (or -22s).  My work neighbor had to source flap actuators for a POC aircraft and routinely got hung-up on when making inquiries to various industrial supply companies/manufacturers.  Even when trying to purchase off-the-shelf.  He later tried to buy some "toilet seat actuators" but I don't think that ultimately helped. 

[Ragsf15e]

1 hour ago, EricJ said:

Or via AC 23-27, e.g., with a DER or whatever.   It's always possible, it just may be more expensive than just having one made.

I'm thinking it might be more practical, more economical, and more servicable, to find an actuator assembly from another, newer, application and fit that.   Finding something that fits reasonably well dimensionally and provides sufficient force is probably not outside a reasonable realm of possibility.   If one is found that meets a TSO somewhere, even better.   Flap actuators from larger airplanes are often very similar.

 

I think it’s possible (and been done) to put in a newer model Eaton actuator.  I think the mod was around $10k.  That’s a starting point.  Not as much pma, DER, etc required to put on a newer approved part.

[McMooney]

20 minutes ago, Schllc said:

Years ago I bought this really high end Italian oscillating belt sander. It worked really well for a few years and then the oscillating part stopped working. 
I took the machine apart and found this helical worm gear made of bronze. I hunted for the company only to find out they had gone out of business years ago and if I couldn’t get the gear the machine was scrap. Well, a new machine of this size and quality was over 20k so I started looking…

I ended up finding a shop in Columbia (the country) that would to produce the part for $75. I ordered three of them and zip tied them into the machine near the gears… I’ve used one more set of them and apparently this was a part designed to wear to spare the more expensive parts. 
sorry for the tangent but my ocd required me to complete the story…

point being, I’m not going to retire any machine I own for some part that I know I can figure out a way to replace. 
While I understand there are some things on the plane like a turbo housing, or a crank that are far too complex and critical to produce yourself, but the FAA treats too many things as critical, that just are not so on our little planes. 
Good machinists all pride themselves on being able to do complicated things, and they are extremely knowledgeable about metal and its properties, those gears are not that hard to manufacture, and I’m willing to bet if you knocked on enough machine shop doors you would find somebody willing to make them.

agree

[MikeOH]

5 minutes ago, Ragsf15e said:

I think it’s possible (and been done) to put in a newer model Eaton actuator.  I think the mod was around $10k.  That’s a starting point.  Not as much pma, DER, etc required to put on a newer approved part.

It's eventually going to come to that. Meanwhile, if mine was to be declared unairworthy tomorrow, I'd likely source a used one (at around $7,000 it seems) and take my chances.  Sucks, but it is what it is.

[skykrawler]

The are a number of OTS actuators that would probably work.  The trick is having the manual extension ability if the power to the motor or the motor fails.

[Schllc]

1 hour ago, KSMooniac said:

The difference between our machines and your belt sander gears is the end use

I don’t disagree with this.  Ironically, they never even asked me what the part they were making was for. 
That being said, most people not involved in aviation are unaware of the challenges and limitations. 

[201Steve]

I talked to LASAR about this a couple weeks ago when it was announced they’d be supplying no back springs. 
 

They said Mooney ( @Jonny ) was refusing to cooperate when it comes to the dukes gear set. No idea why. 
 

 

[MikeOH]

I've often wondered the following but never seen any data to provide answers:

1) How many gear ups have been because of failed Dukes gears?
2) How many gear failures have been due to failed Dukes motors but landed ok because of the manual extension.
3) How many gear ups have been because of failed no-back springs?

 

My SWAGs:

1) Enough that Mooney wants NOTHING to do with potential liability!
2) We'll never know
3) One or two traced to a small defective batch.  Hence, Mooney feels the real risk is pretty small.

 

 

[Fly Boomer]

8 hours ago, KSMooniac said:

I expect they bought actuators to a specification that they fit in a physical volume, travel XX inches, consume XX amount of power, etc. and it was up to the actuator manufacturers to design a product to meet those requirements.  I think it would be very unusual for an airframe manufacturer to be doing detailed design of gears like that. 

I agree.  Linear actuators are used in many machines in general, and in many airplanes for a variety of tasks.  No airplane company the size of Mooney is going to design and build linear actuators.  The ROI is not there.  Pretty sure Mooney never manufactured nuts, bolts, screws, and washers either.  They were in the airplane business.

[PT20J]

4 hours ago, 201Steve said:

They said Mooney ( @Jonny ) was refusing to cooperate when it comes to the dukes gear set. No idea why. 
 

Airworthiness Directive?