Kyle Boatright

The poposed AD on the Aeronca Sedan appears to be overly aggressive and premature. These aircraft have been flying for 60 years and there are no documented wing failures. In the public realm, I am aware of reports of one example of a Sedan with bad spar caps, and whether that was a manufacturing defect or a result of how the aircraft was treated over the years (saltwater exposure, etc), I do not know. My understanding is that an interested party has submitted information claiming spar cap corrosion on 34 sets of spar caps, yet that information will be unavailable until after the comment period closes for this proposed rule. Without that information, it is impossible to effectively determine whether this AD is necessary. Routine spar inspections in accordance with what would be normal during an annual inspection should turn up any significant corrosion issues, leading to further inspection. However, unless evidence of corrosion is seen, I submit that (pending the release of information already requested via FOIA), there is no reason to implement the proposed rule at this time and without adequate time to review the information driving this proposed rule and develop appropriate methods to address any problems identified. With all of this in mind, it would be appropriate to wait until the information regarding the "34 sets of replacement spar caps" is available for public review before implementing any new rule regarding the Aeronca Sedan's. Once the data is available, a period of 60-120 days would allow the review of the data and development of an appropriate method of resolving any issue that might arise.