The proposed AD requirement of every 12 months or every 100 hours is unacceptable. The 100 hour requirement should be only for aircraft used for rental or hire (i.e. aircraft which currently require a 100 hour inspection). For non-commercial aircraft, an inspection at annual will suffice. Otherwise the AD as proposed would add almost an additional dollar per flight hour in compliance cost, which would cumulatively incur a heavy burden on private owner operators, who are very well aware of the current AD and inspect their seat rails frequently. I, personally, inspect my seat tracks and locks as part of every preflight. I use my 172 to travel as a consultant, and can little afford an additional dollar per hour based on a 100 hour inspection interval. An annual inspection is quite often enough, and an insert for the aircraft POH could be required to educate operators as to the needed inspections.
Ken Anderson
This is comment on Rule
Airworthiness Directives: Cessna Aircraft Co. Models 150, 152, 170, 172, 175, 177, 180, 182, 185, 188, 190, 195, 206, 207, 210, T303, 336, and 337 Airplanes
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