Elliot Defalco

I am commenting on AD 2011–07–13 regarding inspection of the elevator spar on Commander AC-11. The AD as issued directs us to remove both elevators and associated hardware. It also directs us to remove both outer ribs to inspect the rear of the outer attachment fitting. As this is an inspection and report AD it seem excessive and counterproductive to the expedient gathering of information. A flexible bore scope can be introduced at the trailing edge and get a very clear view of the entire spar surface and bolt area. There are no doublers to hide a crack or evidence of such. Drilling out rivets and reinstalling if the spar is found good before a terminating AD is issued raises the question of are we going to be required to do this over again, and facing the possibility of a damaged skin or rib which may not be available? I propose we are allowed to use a borscope and/or dye penetrate inspection of the assembly on the AC. If cracks or issues are found, then go further. This will also expedite the gathering of a larger sample of aircraft.