David L. Rude

Docket No. FAA?2007?0177 Comment#1 This AD is possibly redundant and absolutely not needed. 61 years ago a similar AD, (47-16-03), was issued to adrress cracks in this fitting. The unfortunate event that you reference appears to be the result ignoring the 61 year old AD in addition to poor maintenance and inadequate personnel as verified by your description in your own discussion, quoted below, and a quick read of some existing FAA advisory circulars. "The fitting was corroded approximately 70 percent through the fracture surface. The airplane?s fabric was wrapped around the lugs of the wing strut attach fitting with the ends of the fabric stuffed into the fitting itself. The fabric plugged the drain hole on the bottom of the fitting and prevented water from draining out the front and back ends of the fitting. The fabric also did not allow for easy visual inspection of the exterior and interior of the fitting. In addition to fabric, the drain hole was blocked by other foreign debris as well." Clearly poor maintenance, lack of consideration of AD-47-16-03 as well as AC43.13-1B paragraph 6-50a, 6-50h and 6-70 a standard inspection and procedure manual for older aircraft which say the following 6-50. GUIDELINES: ALL AIRCRAFT. Corrosion prevention depends on a comprehensive prevention and control plan, implemented from the start of operation of an aircraft, which includes: a. Adequately-trained personnel in (1) recognition of corrosion-inducing conditions; (2) corrosion identification techniques; (3) corrosion detection, cleaning, and treating; and (4) lubrication and preservation of aircraft structure and components. b. Inspection for corrosion on a scheduled basis h. Keeping drain holes and passages open and functional. Sealants, leveling compounds, miscellaneous debris, or corrosion inhibitors should not block drain paths. 6-70 WATER ENTRAPMENT AREAS. Inspect area around edge of drain holes for corrosion and ensure that drain holes are not blocked by debris. There are nearly 2000 Taylorcraft airplanes flying safely and successfully because they are maintained by mechanics and owners that follow the accepted and required procedures. This one event while very unfortunate would not have been prevented by yet one more unnoticed procedure. Additionally it is my understanding that this particular aircraft was not a normal category aircraft and possibly had not been operating subject to the normal rules- hearsay I know. I have also seen the pictures of this fitting that failed and its condition was inexcusable. Using it as a standard to author an AD is completely unreasonable. Comment #2 The AD as written requires that the Taylorcraft Factory approve the repairs if repairs are required as quoted below; (3) If you find cracking or material loss due to corrosion during any of the inspections required in paragraph (e)(1) or (e)(2) of this AD, before further flight, do the following: (i) Contact Taylorcraft Aviation, LLC at 2124 North Central Avenue, Brownsville, Texas 78521; telephone: 956?986?0700 to obtain an FAA-approved repair scheme or replacement procedure; and (ii) Repair following the FAA- approved repair scheme or eplace the left and/or right wing lift strut attach fitting (s), P/N A?A11, following the replacement procedure. This company is in or out of business at an given time and cannot be relied on for this information on long term basis and possibly not even at this moment. Also I have repaired these fitting and have done so by the authority field approvals. It is a simple and straightforward repair or replacement of the fitting. The procedures for repair or replacement should be written into the AD at this time. This will reduce FAA costs in the long run as well as assure us that they are documented and available to all for perpetuity Dave Rude