Narrative:

The small aircraft had complied with emergency airworthiness directive (ead) 91-07-08 of 3/X/91. I had been informed during a phone call to AOPA of the revision in the ead (91-07-08-R1) to allow IFR IMC flight, as long as no forecast of known icing, thunderstorms or moderate or greater turbulence. I had not received the actual amendment to the ead. The briefing called for thunderstorms east of the planned route. There was also forecast turbulence in mid-route area (sc and GA) below 10000' (below planned en route altitude). I departed VFR and climbed VFR to 16500'. While en route I saw buildups and deviated VFR over northeast nc. With higher clouds ahead, still in nc, I converted to an IFR plan and climbed to FL200 (ZDC). Passing some buildups to my right (west), I began to see returns on stormscope to the west. Was now advised by ATC of a new SIGMET which called for thunderstorms in area in which I was flying. I was easily able to remain visibility (daytime) and continue flight with deviations. Hourly reports now indicated a thunderstorm at ssi, and stormscope indicated south of sav wide coverage along the route of flight. I landed at sav in VFR conditions at :30 pm. After dinner I personally walked to the radar shack twice at about xa:30 and xb:30 pm. As expected, thunderstorms passed overhead from west to east. By xx:30 pm, none were noted on radar along the route to jax. The waycross, GA radar was OTS, and I could not obtain actual radar conditions south of jax to vrb. There were reports (sa) of thunderstorms in orlando and daytona. These were expected to die out. I departed at xx pm local time, on an IFR plan in VMC to FL180. There were not returns on my stormscope along route of flight (only many mi east out over the ocean). No thunderstorms were reported along route of flight, and there was no forecast or reported turbulence. Rain was expected and encountered from jax to titusville. I was IMC intermittently while in rain. No turbulence was encountered. I landed at vrb after X am in VFR conditions. Did I break any regulations? I don't know. The ead revision states: 'this ad revision changes paragraph (a)(1) of the ad from, 'flight into instrument flight rule (IFR) meteorological conditions is prohibited,' to, 'flight into known or forecast ice, thunderstorms, moderate or severe turbulence is prohibited.' the FAA has determined that this change maintains the same level of aircraft safety and allows for improved usage and operation of the fleet.' does this mean flight into known or forecast ice is prohibited, flight into known or forecast thunderstorms is prohibited, and flight into known or forecast moderate or severe turbulence is prohibited? Or does it mean flight into known or forecast ice is prohibited, flight into thunderstorms is prohibited and flight into moderate or severe turbulence is prohibited? As the FAA has determined either the old or new (a)(1) 'maintain the safe level of aircraft safety,' it would appear as long as the flight remains in VMC, flight can be made, even if ice, thunderstorms or turbulence are either forecast or known. Obviously, the pilot must avoid these hazards. However, but remaining in VMC, thunderstorms and icing can be avoided visually. The aircraft is also less likely to be seriously upset in turbulence when outside visibility cues are available in VMC. I have since heard through others that 2 district offices of the FAA (atlanta and kansas city) each have their own interpretation of the ead. One seems to match my interpretation in the previous paragraph. If the FAA cannot write an ad that is understandable to their own district offices, how can they expect pilots to comply? As a result of the new ead, my aircraft now has 2 placards. One required by the ead revision says, in part, 'flight into known or forecast icing...is prohibited.' the second, which was factory installed and remains in the cockpit, states, in part,' this aircraft is approved for...icing flight...'

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Original NASA ASRS Text

Title: REPORTER ASKS QUESTION ABOUT AN EMERGENCY AIRWORTHINESS DIRECTIVE.

Narrative: THE SMA HAD COMPLIED WITH EMER AIRWORTHINESS DIRECTIVE (EAD) 91-07-08 OF 3/X/91. I HAD BEEN INFORMED DURING A PHONE CALL TO AOPA OF THE REVISION IN THE EAD (91-07-08-R1) TO ALLOW IFR IMC FLT, AS LONG AS NO FORECAST OF KNOWN ICING, TSTMS OR MODERATE OR GREATER TURB. I HAD NOT RECEIVED THE ACTUAL AMENDMENT TO THE EAD. THE BRIEFING CALLED FOR TSTMS E OF THE PLANNED RTE. THERE WAS ALSO FORECAST TURB IN MID-RTE AREA (SC AND GA) BELOW 10000' (BELOW PLANNED ENRTE ALT). I DEPARTED VFR AND CLBED VFR TO 16500'. WHILE ENRTE I SAW BUILDUPS AND DEVIATED VFR OVER NE NC. WITH HIGHER CLOUDS AHEAD, STILL IN NC, I CONVERTED TO AN IFR PLAN AND CLBED TO FL200 (ZDC). PASSING SOME BUILDUPS TO MY RIGHT (W), I BEGAN TO SEE RETURNS ON STORMSCOPE TO THE W. WAS NOW ADVISED BY ATC OF A NEW SIGMET WHICH CALLED FOR TSTMS IN AREA IN WHICH I WAS FLYING. I WAS EASILY ABLE TO REMAIN VIS (DAYTIME) AND CONTINUE FLT WITH DEVIATIONS. HOURLY RPTS NOW INDICATED A TSTM AT SSI, AND STORMSCOPE INDICATED S OF SAV WIDE COVERAGE ALONG THE RTE OF FLT. I LANDED AT SAV IN VFR CONDITIONS AT :30 PM. AFTER DINNER I PERSONALLY WALKED TO THE RADAR SHACK TWICE AT ABOUT XA:30 AND XB:30 PM. AS EXPECTED, TSTMS PASSED OVERHEAD FROM W TO E. BY XX:30 PM, NONE WERE NOTED ON RADAR ALONG THE RTE TO JAX. THE WAYCROSS, GA RADAR WAS OTS, AND I COULD NOT OBTAIN ACTUAL RADAR CONDITIONS S OF JAX TO VRB. THERE WERE RPTS (SA) OF TSTMS IN ORLANDO AND DAYTONA. THESE WERE EXPECTED TO DIE OUT. I DEPARTED AT XX PM LCL TIME, ON AN IFR PLAN IN VMC TO FL180. THERE WERE NOT RETURNS ON MY STORMSCOPE ALONG RTE OF FLT (ONLY MANY MI E OUT OVER THE OCEAN). NO TSTMS WERE RPTED ALONG RTE OF FLT, AND THERE WAS NO FORECAST OR RPTED TURB. RAIN WAS EXPECTED AND ENCOUNTERED FROM JAX TO TITUSVILLE. I WAS IMC INTERMITTENTLY WHILE IN RAIN. NO TURB WAS ENCOUNTERED. I LANDED AT VRB AFTER X AM IN VFR CONDITIONS. DID I BREAK ANY REGS? I DON'T KNOW. THE EAD REVISION STATES: 'THIS AD REVISION CHANGES PARAGRAPH (A)(1) OF THE AD FROM, 'FLT INTO INSTRUMENT FLT RULE (IFR) METEOROLOGICAL CONDITIONS IS PROHIBITED,' TO, 'FLT INTO KNOWN OR FORECAST ICE, TSTMS, MODERATE OR SEVERE TURB IS PROHIBITED.' THE FAA HAS DETERMINED THAT THIS CHANGE MAINTAINS THE SAME LEVEL OF ACFT SAFETY AND ALLOWS FOR IMPROVED USAGE AND OPERATION OF THE FLEET.' DOES THIS MEAN FLT INTO KNOWN OR FORECAST ICE IS PROHIBITED, FLT INTO KNOWN OR FORECAST TSTMS IS PROHIBITED, AND FLT INTO KNOWN OR FORECAST MODERATE OR SEVERE TURB IS PROHIBITED? OR DOES IT MEAN FLT INTO KNOWN OR FORECAST ICE IS PROHIBITED, FLT INTO TSTMS IS PROHIBITED AND FLT INTO MODERATE OR SEVERE TURB IS PROHIBITED? AS THE FAA HAS DETERMINED EITHER THE OLD OR NEW (A)(1) 'MAINTAIN THE SAFE LEVEL OF ACFT SAFETY,' IT WOULD APPEAR AS LONG AS THE FLT REMAINS IN VMC, FLT CAN BE MADE, EVEN IF ICE, TSTMS OR TURB ARE EITHER FORECAST OR KNOWN. OBVIOUSLY, THE PLT MUST AVOID THESE HAZARDS. HOWEVER, BUT REMAINING IN VMC, TSTMS AND ICING CAN BE AVOIDED VISUALLY. THE ACFT IS ALSO LESS LIKELY TO BE SERIOUSLY UPSET IN TURB WHEN OUTSIDE VIS CUES ARE AVAILABLE IN VMC. I HAVE SINCE HEARD THROUGH OTHERS THAT 2 DISTRICT OFFICES OF THE FAA (ATLANTA AND KANSAS CITY) EACH HAVE THEIR OWN INTERP OF THE EAD. ONE SEEMS TO MATCH MY INTERP IN THE PREVIOUS PARAGRAPH. IF THE FAA CANNOT WRITE AN AD THAT IS UNDERSTANDABLE TO THEIR OWN DISTRICT OFFICES, HOW CAN THEY EXPECT PLTS TO COMPLY? AS A RESULT OF THE NEW EAD, MY ACFT NOW HAS 2 PLACARDS. ONE REQUIRED BY THE EAD REVISION SAYS, IN PART, 'FLT INTO KNOWN OR FORECAST ICING...IS PROHIBITED.' THE SECOND, WHICH WAS FACTORY INSTALLED AND REMAINS IN THE COCKPIT, STATES, IN PART,' THIS ACFT IS APPROVED FOR...ICING FLT...'

Data retrieved from NASA's ASRS site as of July 2007 and automatically converted to unabbreviated mixed upper/lowercase text. This report is for informational purposes with no guarantee of accuracy. See NASA's ASRS site for official report.