Karl Zeiset

Document ID: FAA-2009-0218-0003
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: March 27 2009, at 01:10 PM Eastern Daylight Time
Date Posted: March 27 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: March 10 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: May 11 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80931c9e
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This is comment on Rule

Airworthiness Directives: Piper Aircraft, Inc. PA 23, PA 31, and PA 42 Series Airplanes

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This Proposed AD is insufficient for the following reasons. 1. NTSB issued Safety Recommedation A-78-004......Problems still occured 2. Piper issued Service Bulletin 604A in 1979.... 9 Latch related incidents have occured since then.......Still no real solution 3. Piper issued Service Bulletin 1174 in 2007......6 Fatalities have occured since then.......Still no real solution 4. What makes you think SB 1194A and this AD will make a difference? It still gives no redundancy. These latches need to address the following issues 1. The latch mechanism is only 1 clevis pin away from complete failure 2. The tabs on Handle Bracket (P/N 28467-003) are easily bent 3. Once the forward tube assembly spring (P/N 83302-023) breaks, the latch becomes spring loaded to the open position. 4. The baggage door becomes locked into the full open position with no hope of a pilot being able to close it in flight. After the PA 31-350 fatal accident off Kodiak Island (1-05-2008) a secondary latch was designed to solve this problem. It works great and is installed under STC #SA02331AK. Albert Einstein once said "Insanity is doing the same thing over and over again and expecting different results." This proposed AD is insane! Karl D Zeiset Director of Maintenance Iliamna Air Taxi Iliamna, Alaska