This proposed rulemaking appears to rely heavily on undocumented heresay. If I'm reading the text of the proposed AD correctly, its direction is being guided largely as a result of 34 reported cases of intergranular corrosion in the upper and lower beam angles, aka spar caps.
A Freedom of Information Act (FOIA) request has been submitted, requesting further information on these 34 reported cases. If FAA is mandating substantial expense and alterations to the airplane's wings, to a substantial portion of the owners of this airplane...it makes sense to wait until FAA has had time to respond to the FOIA request, rather than force it through the system in an uncharacteristically quick and seemingly haphazard manner.
I would request a 90-day extension of this rulemaking, giving time for all parties involved to properly examine the documentation driving the proposal.
Eric Sandberg
This is comment on Rule
Airworthiness Directives: Burl A. Rogers Models 15AC and S15AC Airplanes
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