This proposed AD is misplaced and poorly thought-out. I have flown with the spot-welded v-band clamps for many years and thousands of hours without any failure or problem. The problem you are trying to solve with the proposed AD is human. The bands are not torqued or placed correctly by some mechanics, and then fail. The same thing will happen with the proposed riveted replacement clamps. If they are not installed correctly they too, will fail.
Also, there are two or more clamps per engine on many aircraft. The current list price for one clamp is just shy of $750.00, making your economic impact calculations very incorrect.
This proposed AD should not be adopted.
Gerald Blank
This is comment on Rule
Airworthiness Directives: Piper Aircraft, Inc. Models PA-32R-301T and PA-46-350P Airplanes
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