James Zangger

A quote from the proposed AD: "the unsafe condition described previously is likely to exist or develop on other products of the same type design." I question the word likely and would replace it with possible. While recognizing the need to keep our aging aircraft safe it is also general knowledge that the accident aircraft had been stored outdoors, on floats, in a salt air environment far exceeding ten years. The owner IA possibly did not use normal and accepted maintenance practices that would have revealed the presence of corrosion. I don't believe a single accident warrants an AD but the service bulletin would be justified. An aircraft's storage history would have a significant impact on the need for this inspection on a frequent basis. It would be my recommendation that the interval between inspections is extended to rebuild or recovering intervals. Again, this single incident does not indicate a trend with these aircraft. Steel tube and fabric construction is a time honored method of construction that has generated a long history of success. Normal maintenance practices have been sufficient in the past to indicate the need for tubing replacement. A land based aircraft would not be subjected to the same concerns that a float plane is, due to the attitude at rest and the areas that water would normally collect. Please realize the economic impact this AD along with the previous strut AD have created to owners of an otherwise economical aircraft. It is an aircraft with a long history of having only three AD's for 50 to 60 years and now two have been issued within months. The inspection intervals suggested in this AD may be appropriate for float equipped aircraft, but I believe a differentiation should be made with land based aircraft given significantly longer intervals between inspections. Thank you