Shoreline Aviation, Inc.

This A.D. should apply to the clamp rather than the airplane model. These clamps have had the same failure in other airplanes that has prompted the previous two AD's referenced in this NPRM. If the AD had applied to the clamp rather than the airplane at the time those other AD's were written then this one would not be necessary and the accident that prompted this AD might have never happened because Lycoming would not have been able to install these clamps on the engine when it was new. Also, your cost analysis is incorrect for the PA46-350P since that airplane model has two of these clamps installed - your cost analysis only shows one per airplane.