Dustin Radford

The change to compliance times (Par "e") which eliminates the 1000 hour minimum and requires part 91 aircraft to comply at each 100 hours adds an unnecessary burden to this AD for Part 91 operators. The additional requirement to remove the seat for the inspection makes it impossible to do this inspection quickly even if the inspecting mechanic is familiar with the aircraft and able to determine its airworthiness without removing the seat. The specific changes regarding inspection of the tang areas (Par "e7") are informative, but unnecessary, as any deformation should be noted during routine inspection and rejected under current rules. For example: I regularly maintain aircraft operated under Part 91 which have equipment installed which makes the complete removal of the seats very difficult. However, as a conscientious mechanic, I visually inspect the affected area each 100 hours and, like all other parts of the aircraft which I maintain, keep a mental record of any anomalies or areas requiring closer or even more frequent inspection. Overall, these changes are, in my opinion, adding unnecessary burdens to conscientious maintenance personnel, and will do nothing to eliminate the sloppy or unprincipled maintenance which it can be assumed has led to the accidents cited as the reason for these changes.