Douglas A. Lesh

The following are problems that I see with this AD 1. It would appear that 18 failures are far over the limit to initiate an AD of this nature. The owners should have been notified as early as after three failures. This is not acceptable that up to 18 airplanes were allowed to possibly crash before notifying the owners. 2. The act of determining if the nut is loose takes no tools and is entirely within the capabilities of a licensed pilot. A pilot, by virtue of doing a preflight, is determining equivalent levels of airworthiness on other parts of the aircraft every flight. This portion of the check should be allowed to be completed and signed off by an owner/operator/pilot, much as other items, like oil changes, and other maintenance allowed to be accomplished by owner/operators. 3. The timing of this inspection with oil changes, while sounding like a good idea, is a poor choice. There is absolutely no correlation between the two. An immediate inspection is a must for such a dangerous condition. If testing proved that this loosening could occur in less than standard inspection intervals of 100 hours or Annual inspection, then perhaps a 50 hour inspection interval may be needed but lets use data to choose instead of a typical oil change interval. The reason the oil change idea does not work is that some operators change their oil at 25 hours (those without filters), or 50 hours or one of their own choosing. Personally we change ours at approximately 33 hours of flight time. We, as owner/operators also do our own oil changes. This AD now mandates that we locate a mechanic every time we change oil just so this AD can be signed off. Again a reason the owner/operator should be able to do the initial loose plug inspection. No argument, that once a loose nut is found, it would require an A&P to evaluate and fix if possible and no ferry flights should be allowed. Some aircraft probably have little or no access to this nut unless the cowling is removed, fortunately others, such as the one I own, I can access every preflight. 4. Since this unit has been in use for many years, there is a known fix. That should be provided as terminating action for this AD. Since this nut is safety wired, then it is obvious that not very much loosening is possible unless the wire is broken. If that is all the loosening that it takes to create an unsafe condition then this deserves more of a fix than lets just watch it and see what happens. Flying is expensive enough; we don't need unnecessary recurring inspections if fixes are available or need an A&P to determine if a nut is loose. Respectfully Douglas Lesh Part owner of a 1979 Piper Lance II