I have a piper cub and have been working on them for 25 years. I have never encountered an issue with the toggle type switches . They are guarded and would be nearly impossible to turn both of them off except deliberately. The large rotary switch I could see accidentally turning off. I do not think the guarded toggle switches should be affected. If they were then they should be permitted on the dash panel versus a key switch which may have an AD against it anyhow. Bendix key switches are subject to failure and the original toggles are reliable. Keep it simple. I would prefer no AD action. It is impossible to legislate the pilot out of the cockpit. The design has been in place for sixty years. It works.
Shawn Shoultys
This is comment on Proposed Rule
Airworthiness Directives: Piper Aircraft, Inc. Airplanes
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