### CESSNA TWIN ICING **AD ---** **INITIAL REGULATORY FLEXIBILITY**  **ANALYSIS**

Daniel Leach 08 - 0 8 - 2012 **Introduction and Purpose of This Analysis** The Regulatory

Flexibility

Act of 1980 (Public Law 96 - 354) (RFA) establishes “as a principle of regulatory

issuance that agencies shall endeavor, consistent with the objectives of the rule and of applicable statutes, to fit regulatory and informational requirements to the scale of the businesses, organizations, and governmental jurisdictions subject to regulation. ” To achieve this principle, the RFA requires agencies to solicit and consider flexible regulatory proposals and to explain the rationale for their actions to assure that such proposals are seriously considered .” The RFA covers a wide -range of small entities, including small businesses, not- for-profit organizations, and small governmental jurisdictions. Agencies must perform a review to determine whether a rule will have a significant economic impact on a substantial number of small entities. If the agency determines that it will, the agency

must prepare an initial regulatory flexibility

analys is (IRFA) as described in the RFA. Section 603(a) of the RFA requires that each initial regulatory flexibility

analysis contain: (1 ) a description of the reasons action by the agenc y is being considered; (2 ) a succinct statement of the objectives of, and legal basis for, the proposed rule; (3 ) a description of and, where feasible, an estimate of the number of small entities to which the proposed rule will apply; (4 ) a description of the projected reporting, recordkeeping and other compliance requirements of the proposed rule, including an estimate of the classes of small entities which will be subject to the requirement and the type of professional skills necessary for preparation of the report o r record; and (5 ) to the extent practicable, an identification of all relevant Federal rules which may duplicate, overlap or conflict with the proposed rule. (6 ) Each IRF

A shall also contain a description of any significant alternatives to the proposed rule which accomplish the stated objectives of applicable statues and which minimize any significant economic impact of the proposed rule on small entities.

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**1. A Description of the Reasons A** **ction by t he Agency Is Being C**  **onsidered** F or the airplanes listed in Cessna Aircraft Company (Cessna) Service Bulletin MEB97 -4 , the actions required b y this proposed rule will prohibit flight into known icing conditions . An investigation of the airplanes affected by the proposed rule showed 52 icing-related incidents and ac cidents over the last 30 years resulting in 36 fatalities . The non- fatal accidents have usually resulted in injuries and substantial aircraft damage. Although many of these airplanes are equipped with optional deicing boots and other deicing (or icing prevention) e quipment , the manufacturer never intended that they should be flown into known icing. 1 

### However, the original certification basis for these airplanes did not incorporate Amendment 7 (May 3, 1962) of CAR 3, requiring manufacturers to provide a placard specif ying the types of operations and meteorological conditions (e.g. icing conditions) to which the operation of the aircraft is limited by the equipment installed (CAR 3 § 3.772). As a result, with operational deicing equipment these airplanes may

be qualifie d to fly

into known light or moderate icing condition under 14 CFR § 135.227(c)(1) 2 

### and may even be allowed to fly

into known icing conditions under 14 CFR Part 91.9. 3 

### In1973 new Part 23 certification rules became effective. Some of the later production o f the affected Cessna models added new and improved equipment in order to recertify under the new requirements. However, production under previous ty pe certificates continued as late as 1976. **2. Objectives of, and Legal Basis for, the**  **Proposed Rule**  The proposed rule would require owners or operators to install a placard prohibiting flight into known icing conditions . With the limited deicing equipment of the affected airplanes , flight into known icing conditions could result in unusual flight characteristics leading to loss of control with consequent accidents . The proposed rule would also require owners or operators to install a second placard that increases published speed on approach by 17 mph (15 knots) in case

1 For example, one of the Model 310 manuals notes: “Since wing and horizontal stabilizer deicer boots alone do not provide adequate protection for the entire aircraft, known icing conditions should be avoided w henever possible.” 2 § 135.227(c) allows flying into known icing conditions if “ (1) The aircraft has functioning deicing or anti - icing equipment protecting each rotor blade, propeller, windshield, wing, stabilizing or control surface, and each airspeed, altimeter, rate of climb, or flight attitude instrument system; ...” 3 § 91.9 states that “no person may operate a civil aircraft without complying with the operating limitations specified in the approved Airplane or Rotorcraft Flight Manual, marking s, and placards....”

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of an inadvertent encounter with icing. M any of the Cessna accidents were the result of high sink speeds , which may

have been related to icing, resulting in hard landing s . Failure to mandate an increased published speed may result in continuing occurrences of this unusual flight characteristic with consequent accidents. Title 49 of the U.S. Code specifies the FAA’s authority to issue rules on aviation safety. Subtitle I, section 106, describes the authority of the FAA Administrator. Subtitle VII, Aviation Programs, describes in more detail the scope of the FAA’s authority. We are issuing this rulemaking under the authority described in subtitle VII, part A, subpart III, section 44701, “General requirements.” Under that section, Congress charges the FAA with promoting safe flight of civil aircraft in air commerce by prescribing regulations for practices, methods, and procedures the Administrator finds necessary for safety in air commerce. This regulation is within the scope of that authority because it addresses an unsafe condition that is likely to exist or develop on the airplanes identified in this AD. 

### 3. **A Description of and an Estimate of the Number of Small Entities to**  **which the Proposed**  **Rule Will**  **Apply** The airplanes affected b y the AD are the 4 206 U.S. -registered Cessna twin- engine airplanes with certain serial numbers among Models 310, 320, 340, 401, 402, 411, 414, and 421 specified in Cessna Service Bulletin MEB97 -4. 4 

### To obtain information on small entities affected by the AD, we emailed a questionnaire directly to seven firms with the larg est number of airplanes listed in Cessna Service Bulletin MEB97 -4 and received responses from six of these firms

—the Small Sample. Separately, the Aircraft Owners and Pilots Association (AOPA) conducted an online survey and received 198 responses from owners with affected airplanes. This sample was reduced to 104 entities

—the Large Sample --by

eliminating 94 responses from individuals who used their airplanes for personal use only. Employ ment size in the Small Sample ranges from 6 to 48, with a median of 16 .75. For the Large Sample 84 out of 104 respondents reported employ ment size, ranging from 1 to 1000, with a median of 6. Since, as noted, personal use appears to account for about half of the airplanes

4 http://www.faa.gov/licenses_certificates/aircraft_certification/aircraft_registry/releasable_aircraft_downlo ad/ . February 24, 2012.

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listed in Cessna Service Bulletin MEB97 -4, we estimate the number of entity airplanes affected by the AD to be half of 1608, or 804 . 5 

### As to ty pe of operations, the Large Sample indicates only if the owner’s airplane(s) are for “Corporate” or “Charter” use. All of the firms in the Small Sample engage in Part 135 operations of one kind or another

—on demand air charter, cargo and/or passenger, or scheduled freight. The Small Business Administration (SBA) classifies Part 135 operations into NAICS industries 481111, Scheduled Passenger Air Transportation; 481112, Scheduled Freight Air Transportation, 481211, Nonscheduled Passenger Air Transportation; and 481212, Nonscheduled Freight Air Transportation. For all of these industries, the SBA maximum small business size is 1,500 employees. All of the entities in both s amples are well below 1,500 employees. Accordingly, we conclude that the proposed rule would affect a substantial number of small entities. **4. Reporting, Record Keeping, and Other Compliance Requirements**  **of the Proposed Rule** Small entities will incur no new reporting and record-keeping requirements as a result of this rule. An Initial Regulatory

Flexibility

Analysis was not undertaken for the NPRM (76 FR 32105), June 3, 2011, as the FAA initially determined that the cost of the proposed rule was minimal, being just the cost of placard installation. However, as a result of comments to the NPRM docket, it became apparent to the FAA that there may be significant additional costs for the subset of the affected airplanes with optional deicing equipment. Several commenters to the NPRM docket argue that affected airplanes with deicing equipment can be safely operated in light or moderate icing conditions. They

further argue that to be prohibited from doing so would severely restrict their operations and impose si gnificant costs. As a result of these comments, we surveyed Cessna Twin operators and independently estimated the cost imposed on operators by the mandated prohibition on flight into known icing. We approximated this cost by estimating the cost to operators of substituting airplanes certified for flight into known icing for their current airplanes. In response to a request from the FAA, Cessna undertook a sample survey and estimated that 38.23% of the airplanes listed in Cessna Service Bulletin MEB97 -4 were equipped with deicing boots. Most of these airplanes also have deicing

5 This figure is an underestimate to the extent that airplanes for business use are more likely to have deicing equipment than airplanes for personal use.

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propellers, making them eligible for flight into known icing under Part 135.227 and, in any case, these airplanes may

be eligible for flight into known icing under Part 91.9. Applying that percentage to our airplane count of 4206, we obtain an estimate of 1608 AD - affected airplanes whose operators would be affected b y the prohibition on flight into known icing. Cost of Proposed Rule per Airplane All 4206 U.S. -registered Cessna twin- engine airplanes will incur at least the minimal cost of the required placarding. As already noted above, however, the AD will also prohibit operators of an estimated 1608 of the affected airplanes from flyinginto known icing conditions. Many respondents estimate that they will incur significant costs as a result . As sample information varies widely in quality, however, we use below an independent standardized approach to estimating the cost impact of this prohibition . We approximated this cost by estimating the cost to operators of substituting airplanes certified for flight into known icing for their current airplanes . Although this may be a somewhat conservative approach, it allows us to estimate operator cost using just data on airplane value s and a straightforward method. The closest available substitute s for the affected airplanes are similar Cessna Twins certified for flight into known icing, many in the same series and a few even of the same model and year. Substitute airplanes, however, will generally be newer and more expensive than the AD affected airplanes. In Table 1 below we show the distribution by model series of the AD affected airplanes, and in Table 2 we show the distribution by model of substitute airplanes certified for flight into known i cing. In Table 1 the Mid- Production Model is the model of the median airplane in a chronological list of all the registered airplanes in the Model Series. In both tables the MidProduction Year is the year in which the median airplane was produced. Airplane Value is the base retail valuation for the median airplane from a sample of airplane valuations from the AOPA website . It is used here as a measure of the average airplane value for the model series in Table 1 and for the model in Table 2.

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**Table 1. Dis tribution by Model Seri** **es of Airplanes Affected by the Cessna**  **Twin Icing AD Model**  **Series Models**  **Pdn Years**  **No.**

**of APs**  **Mid**   ** Pdn** **Model Mid**  ****

**Pdn Year**  **AP Value** 310 310, 310A- R 1955 - 81 2377 310J 1965 $ 44,000 320 320, 320A- F 1962 - 68 302 320C 1965 $ 38,000 340 340, 340A 1972 - 76 308 340 1974 $ 123,000 401 401, 401A- B 1967 - 72 186 401A 1969 $ 71,000 402 402, 402A- B 1967 - 74 199 402B 1972 $ 74,000 411 411, 411A 1965 - 68 142 411 1965 $ 39,000 414 414 1970 - 74 214 414 1972 $ 128,000 421 421, 421A- B 1967 - 74 478 421B 1971 $ 115,000 4206 1967.2 $ 64,142

Weighted Averages Note s : The “Mid-Pdn Model” is the model of the median airplane in a chronological list of all the registered airplanes in the Model Series. The “Mi d-Pdn Year” is the year in which the median airplane was produce d . “AP Value” is the base retail valuation for the median airplane from the Airplane Owners and Operators (AOPA) website, retrieved 03 -26 - 12 to 04 - 02 - 12. 

### Tabl**e 2. Distribution by Model of**  **Substitute A** **P s**  **Certified for Flight i nto Known Icing**  **Model Pdn**  **Years No. of**  **APs Mid**  **- Pdn**  **Year AP Value**  310R 1976 - 81 274 1978 $ 110,000 340A 1976 - 84 549 1979 $ 189,000 402B 1974 - 78 105 1976 $ 90,000 402C 1977 - 85 189 1980 $ 175,000 414 1974 - 77 120 1976 $ 165,000 414A 1977 - 85 414 1979 $ 270,000 421B 1974 - 75 105 1975 $ 155,000 421C 1975 - 85 616 1978 $ 255,000

2372 1978.2 $ 202,935 Weighted Averages 

### The tables show considerable variation in airplane value by mo del ty pe. Not surprisingly, there is also considerable variation in airplane value over time as shown by the much lower weighted average value of $64,142 for the older AD airplanes (weighted average ye ar of 1967) compared to the $202,935 weighted average value for the newer substitute airplanes (weighted average ye ar of 1978) . So an operator of a 310 model series AD airplane with a low average value of $44,000 looking for a substitute airplane would likely prefer, if available, a 310R with

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an average price of $110,000 or perhaps a 402B with an average value of $90,000, The owner of a 414 model series AD airplane with an average value of $128,000 would likely prefer, if available, to stay

with the same model at an average substitute airplane price of $165,000 . The owner of a 1971 421B with a value of $115,000 would likely prefer a substitute 1974 - 1975 421B with an average price of $155,000, but might have to opt for a 421C, with a much higher average price of $255,000. And this is the case overall. Overall, airplanes in the Table 2 group substitute for the AD affected airplanes in Table 1. Accordingly, in order to continue to fly into known icing, operators will have to substitute airplanes with an average price of about $200,000 for their currently

owned airpl anes with an average value of about $64,000. We estimate the cost per airplane of the proposed rule as the 1 0 - ye ar amortized cost of substituting a Cessna Twin certified for flight into known icing for a Cessna Twin not certified for flight into known icing . We limit our cost estimate to a 10 - ye ar period in order to greatly simplify the analys is. We can measure the 10 - ye ar capital cost of an airplane (or any asset) by estimating the decline in its value over the 10 - ye ar period . S ubstitute airplanes are more expensive, have a higher capital cost, and will decline more in value than less expensive affected airplanes . The net cost of the rule per affected airplane will be the net decline in value incurred by the operator substituting the newer, more expensive, airplane for the older, less expensive affected airplane s . We approximate the decline in airplane value over time by the cro ss - sectional variation in value as estimate d by

a regression of airplane value on airplane age using our sample of 84 AOPA airplane values (see Appendix) . The sample covers the entire range of production years for each AD model and each substitute model. A double log transformation, in which the log of airplane value is regressed on the log of age, significantly improved the fit over an untransformed linear model. Dummy variables for the 320, 340, 401, 402, 411, 414, and 421 model series were included in the regression equation to control for value differences b y model series. The regression results are presented in Table 3 below:

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**Tab le 3**  **. Regression of Airplane Valu e on**  **Airplane Age Using a Double Log Model**

Coeffs Std Error t Stat Intercept 22.042 0.290 76.1 LnAge - 2.943 0.077 - 38.2 320s - 0.125 0.044 - 2.9 340s 0.381 0.043 8.8 401s 0.217 0.046 4.8 402s 0.011 0.035 0.3 411s - 0.170 0.054 - 3.2 414s 0.596 0.042 14.1 421s 0.620 0.036 17.1 R2 

### 0.981 Adj. R2 

### 0.979 Std Error 0.099 Obs 84 Note : Airplane Value is b asic retail valuation from the AOPA website. 

### The R2 

### = 0.98 shows that the double log model provides a very good fit indeed . The t- statistic of 38.2 in absolute value for the coefficient on the variable of interest, LnAge, shows the coefficient to be overwhelmingly significant. The negative value of the coefficient shows the standard negative relationship b etween age and airplane value. 6 

### Since the model is a double log

6 A plot of airplane age against airplane value using the estimated regress ion results shows that as age increases, value fall s rapidly up to about age 40 , after which the relationship quickly flattens and value falls much less rapidly as age increases.

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transformation, the coefficient measures a constant elasticity relationship between airplane age and airplane value, viz. the coefficient measures the elasticity of airplane value with respect to airplane age, or the age elasticity of airplane value. We use this feature of the double log model to estimate the 10 - year decline in airplane valuation over time. The results of that estimation are shown in Table 4 below.

## Table 4. **10 -** **Year Cost of Subs**  **tituting Icing Compliant Airplane s**  **for AD Affected Airplane s** 

**Substitute Airplanes Certified for Flight Into Known Icing Production Year**  **1978 1977**  **1976 1975**  **1974 1973**  **1972 1971**  **1970 1969**  **1968 Airplane Age**  34 35 36 37 38 39 40 41 42 43 44 **Airplane V alue**  **$202,935** $185,871 $170,677 $157,102 $144,935 $133,998 $124,140 $115,229 $107,155 $99,822 $93,145 **Change in Value** - $17,063 - $15,194 - $13,575 - $12,167 - $10,937 - $9,859 - $8,910 - $8,074 - $7,334 - $6,676 

### AD Affected Airplanes **Prod uction Year**  **1967 1966**  **1965 1964**  **1963 1962**  **1961 1960**  **1959 1958**  **1957 Airplane Age**  45 46 47 48 49 50 51 52 53 54 55 **Airplane Value $64,142**  $60,038 $56,279 $52,828 $49,656 $46,733 $44,036 $41,544 $39,237 $37,099 $35,114 **Change in Value** - $4,104 - $3,759 - $3 ,450 - $3,173 - $2,923 - $2,697 - $2,492 - $2,307 - $2,138 - $1,985

**Net Change** $12,960 $11,091 $9,816 $8,716 $7,764 $6,936 $6,214 $5,582 $5,027 $4,538 **Present Value**  **Change $12,112**  **$9,687 $8,013**  **$6,650 $5,535**  **$4,622 $3,870**  **$3,249 $2,734**  **$2,307** 

### Total Present Value **Cost $60,277**  **Annualized Cost $8,582**  Notes: 1. Calculations may be off by one or more units owing to rounding error. 2. A 7% return on capital is recommended by the Office of Management & Budget. See OMB, Circular A- 94, “Guidelines and Discount Rates for Benefit- Cost Analysis of Federal Programs”, October, 29, 1992, p. 8 (www.whitehouse.gov/omb/circulars/index.html).

### In Table 4 we simultaneously estimate and amortize the 10 -ye ar decline in average airplane value for both the AD affected airplanes and their substitutes. For the substitute airplanes we start with the average airplane value of $202,935 from Table 2 and calculate the annual decline in value of the average airplane for ten years from the average ye ar of 1978 , or age 34 . Since the estimated coefficient of - 2.943 for Ln(Age) measures a constant elasticity relationship between airplane age and value , the one - ye ar percentage change in value = - 2.943 x the percentage change in age, so the Change in Value = Airplane Value x - 2.943 x the percentage change in age. For 1978 the calculation is then $202,935 x - 2.943 x (1/35) = - $17,063. 7 

### The estimate of Change in Value results in an average Airplane Value estimate of $185,871 for 1977. The value estimate for 1977 is then used to generate the next estimate of annual decline in value, etc. until the entire 10 years of changes are estimated. We repeat the process for the AD affected airplanes, starting with average Airplane V alue of $64,142 and average ye ar of 1967 , or age 45, from Table 1 . We then calculate the Net Change series as the difference b etween the substitute airplane Change in Value series and the affected airplane Change in Value series. Finally, we c alculate the Present Value Change series b y discounting the Net Change series b y a discount rate of 7%. 8 

### Summing this series yields our estimate per airplane of the present value cost of the proposed rule , $ 60,277 . The annualized cost can then be estimated to be $8,582 . 

### Our estimate of $60,277 per airplane may seem large in comparison to an average affected airplane value of $64,142. The per affected airplane metric is a natural one when estimating the cost of a rule to an affected airplane. In this case the perspective of the per affected airplane metric is a poor one because we are substituting a different airplane for the AD affected airplane . The $60,277 estimates the cost to the operator of flying into known icing conditions. Without this proposed rule, the operator can fly into known icing using an airplane with an average price of $64, 142. With the proposed rule , in order to do the same thing , the operator must fly a much newer and much more expensive airplane.

7 To measure the percentage, or proportionate, change in age in this calculation, we use 1/35 rather than 1/34 in order to treat the elasticity estimate as an arc elasticity, somewhat increasing the accuracy of our calculation. 8 A 7% return on capital is recommended by the Office of Management & Budget. See OMB, Circular A- 94, “Guidelines and Discount Rates for Benefit- Cost Analysis of Federal Programs”, October, 29, 1992, p. 8 (www.whitehouse.gov/omb/circulars/index.html).

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Economic Impact on Small Entities Our survey

results indicate that almost all of the respondents were the owners of just one affected airplane. Of the 54 respondents reporting business receipts, 16 reported business receipts of $400,000 or less. For these respondents the annualized cost of the proposed rule implies an annual economic impact ranging from 2.1% to 19.1 % of business receipts. We therefore conclude that this proposed rule will have a significant impact on a substantial number of firms. **5. Duplicative, Overlapping or Conflicting Fed**  **eral Rules** The FAA is unaware of any Federal rules that duplicate, overlap, or conflict with this proposed rule. **6 .**  **Significant Alternatives to the Proposed Rule** Owing to the existing unsafe conditions, however, there is no feasible significant alternative to prohibiting the affected airplanes from flying into known icing conditions. And there is no significant alternative to mandating an increase in published speed on approach.

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## Appendix**— Basic Airplane Valuations for Cessna Twin Airplanes**  **AOPA Group**  **M odel**  **Year Value**  **Model Pdn Yrs**  **Affected**

**by AD? Model/Year Ser.** 

**Nos.** 310 B - Q 310 1955 $ 29,000 1955 - 57 Yes 35000 - 35225 310 B - Q 310 1956 $ 30,000 1955 - 57 Yes 35226 - 310 B - Q 310B 1958 $ 31,000 1958 Yes 35771 - 310 B - Q 310C 1959 $ 32,000 1959 Yes 3 5772 - 39031 310 B - Q 310D 1960 $ 34,000 1960 Yes 39032 - 39299 310 B - Q 310F 1961 $ 36,000 1961 Yes 3100001 - 156 310 B - Q 310G 1962 $ 38,000 1962 Yes 310G0001 - 156 310 B - Q 310H 1963 $ 42,000 1963 Yes 310H001 - 148 310 B - Q 310J 1965 $ 44,000 1965 Yes 3 10J0001 - 200 310 B - Q 310K 1966 $ 47,000 1966 Yes 310K0001 - 245 310 B - Q 310N 1968 $ 53,000 1968 Yes 310N0001 - 198 310 B - Q 310Q 1970 $ 63,000 1970 - 74 Yes 310Q0001 - 130 310 B - Q 310Q 1972 $ 71,000 1970 - 74 Yes 310Q0401 - 545 310 B - Q 310Q 1973 $ 77,000 1970 - 74 Yes 310Q0601 - 845 310 B - Q 310Q 1974 $ 85,000 1970 - 74 Yes 310Q0901 - 1160 310 R 310R 1975 $ 95,000 1975 - 76 Yes 310R0001 - 330 310 R 310R 1976 $ 100,000 1975 - 76 Yes 310R0501 - 735 310 R 310R 1977 $ 105,000 1976 - 81 No 310R0801 - 1004 310 R 310R 1978 $ 110,000 1976 - 81 No 310R1201 - 1434 310 R 310R 1979 $ 115,000 1976 - 81 No 310R1501 - 1690 310 R 310R 1980 $ 125,000 1976 - 81 No 310R1801 - 1899 310 R 310R 1981 $ 135,000 1976 - 81 No 310R2101 - 2140 320 A- F 320 1962 $ 31,000 1962 Yes 3200001 - 110 320 A- F 320A 19 63 $ 33,000 1963 Yes 320A0001 - 047 320 A- F 320B 1964 $ 36,000 1964 Yes 320B0001 - 062 320 A- F 320C 1965 $ 38,000 1965 Yes 320C0001 - 073 320 A- F 320D 1966 $ 43,000 1966 Yes 320D0001 - 130 320 A- F 320E 1967 $ 48,000 1967 Yes 320E0001 - 110 320 A- F 320 F 1968 $ 54,000 1968 Yes 320F0001 - 045 340 A 340 1972 $ 115,000 1972 - 75 Yes 3400001 - 115 340 A 340 1973 $ 118,000 1972 - 75 Yes 3400151 - 260 340 A 340 1974 $ 123,000 1972 - 75 Yes 3400301 - 370 340 A 340 1975 $ 130,000 1972 - 75 Yes 3400501 - 555 340 A 340A 1976 $ 160,000 1976 Yes 340A0001 - 125 340 A 340A 1979 $ 189,000 1976 - 84 No 340A0601 - 801 340 A 340A 1980 $ 205,000 1976 - 84 No 340A0901 - 1045 340 A 340A 1984 $ 240,000 1976 - 84 No 340A1801 - 17

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## Appendix**— continued**  **AOPA Group**  **Model Year**  **Value Model**  **Pdn Yrs Aff** **ected**

**by AD? Model/Year Ser.** 

**Nos.** 401 A/B 401 1967 $ 64,000 1967 - 68 Yes 4010001 - 401 A/B 401A 1968 $ 66,000 1967 - 68 Yes - 322 401 A/B 401A 1969 $ 71,000 1969 Yes 401A0001 - 132 401 A/B 401B 1970 $ 82,000 1970 - 72 Yes 401B0001 - 401 A/B 401B 1971 $ 84,000 1970 - 72 Yes 401B0201 - 121 401 A/B 401B 1972 $ 87,000 1970 - 72 Yes 401B0201 - 221 402 A/B 402 1967 $ 50,000 1967 - 68 Yes 4020001 - 402 A/B 402 1968 $ 53,000 1967 - 68 Yes - 322 402 A/B 402A 1969 $ 56,000 1969 Yes 402A0001 - 129 402 A/B 402B 1970 $ 69,000 1970 - 74 Yes 402B0001 - 402 A/B 402B 1971 $ 71,000 1970 - 74 Yes - 122 402 A/B 402B 1972 $ 74,000 1970 - 74 Yes 402B0201 - 249 402 A/B 402B 1973 $ 77,000 1970 - 74 Yes 402B0301 - 455 402 A/B 402B 1974 $ 81,000 1970 - 74 Yes 401B0501 - 640 402 A/B 40 2B 1975 $ 85,000 1974 - 78 No 402B0801 - 935 402 A/B 402B 1976 $ 90,000 1974 - 78 No 402B1001 - 1100 402 A/B 402B 1977 $ 95,000 1974 - 78 No 402B1201 - 250 402 A/B 402B 1978 $ 102,000 1974 - 78 No 402B1301 - 84 402 C 402C 1979 $ 165,000 1979 - 85 No 402C0001 - 125 402 C 402C 1981 $ 185,000 1979 - 85 No 402C0401 - 528 402 C 402C 1985 $ 245,000 1979 - 85 No 402C0808 - 1020 411 A 411 1965 $ 39,000 1965 - 66 Yes 4110001 - 411 A 411 1966 $ 40,000 1965 - 66 Yes - 250 411 A 411A 1967 $ 43,000 1967 - 68 Yes 4110251 - 411 A 411A 1 968 $ 45,000 1965 - 66 Yes - 300 414/ A 414 1970 $ 120,000 1970 - 74 Yes 4140001 - 099 414/ A 414 1972 $ 128,000 1970 - 74 Yes 410251 - 280 414/ A 414 1974 $ 140,000 1970 - 74 Yes 4140451 - 550 414/ A 414 1975 $ 145,000 1974 - 77 No 4140601 - 655 414/ A 414 1976 $ 165, 000 1974 - 77 No 4140801 - 855 414/ A 414A 1979 $ 270,000 1977 - 85 No 414A0201 - 340 414/ A 414A 1980 $ 290,000 1977 - 85 No 414A0401 - 535 414/ A 414A 1982 $ 330,000 1977 - 85 No 414A0801 - 858 414/ A 414A 1985 $ 370,000 1977 - 85 No 414A1007 - 212

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## Appendix**— continued**  **AOPA Group**  **Model Year**  **Value Model**  **Pdn Yrs Affected** 

**by AD? Model/Year Ser.** 

**Nos.** 421 A/B 421 1967 $ 87,000 1967 - 68 Yes 4210001 - 421 A/B 421A 1969 $ 92,000 1969 Yes 421A0001 - 158 421 A/B 421B 1970 $ 113,000 1969 - 74 Yes 421B0001 - 056 421 A/B 421B 197 1 $ 115,000 1970 - 74 Yes 421B0101 - 147 421 A/B 421B 1972 $ 118,000 1969 - 74 Yes 421B0201 - 275 421 A/B 421B 1973 $ 125,000 1969 - 74 Yes 421B0301 - 486 421 A/B 421B 1974 $ 140,000 1969 - 74 Yes 421B0501 - 665 421 A/B 421B 1975 $ 155,000 1974 - 75 No 21B0801 - 970 421 C 421C 1976 $ 220,000 1975 - 85 No 421C0001 - 171 421 C 421C 1978 $ 255,000 1975 - 85 No 421C0401 - 525 421 C 421C 1980 $ 350,000 1975 - 85 No 421C0801 - 910 421 C 421C 1982 $ 370,000 1975 - 85 No 421C1201 - 257 421 C 421C 1985 $ 430,000 1975 - 85 No 421C1801 - 807 

### Source: AOPA website . Retrieved 03 - 26 - 12 to 04 - 02 - 12.