Paul Edwin Agaliotis

Document ID: FAA-2011-0318-0020
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: June 29 2011, at 12:00 AM Eastern Daylight Time
Date Posted: June 29 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: April 29 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: July 3 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80eb6242
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This is comment on Rule

Airworthiness Directives: Burl A. Rogers Models 15AC and S15AC Airplanes

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Having been involved with the 15AC maintenance for 30 years I feel qualified to comment on this NPRM. The Sedan has achieved an exceptional service record utilizing the inspection procedures outlined in Part 43 app.d. There does not appear to be any documentation to the contrary. The defects found in the subject wing had unknown hours and usage. To subject the fleet of 15AC's to this intrusive procedure based on these findings is not in the best interest of safety. Far more problems can be created than solved. The installation of the inspection plates is problematic for me. The 15AC is a single strut wing much like the 100 Series Cessna. They differ in that the Cessna has a means to adjust the wash of the wing utilizing an eccentric at the read spar attach. The Sedan has no such feature relying on the skin to sustain any wing wash angle built into it. Cutting holes into the skin would require structural reinforcement and a load carrying inspection plate. Please review the analysis as this might be the subject of a MSAP. I would urge you to reconsider the issuance of this AD. Paul Agaliotis AP 560258266 IA