George Richard Wilhelmsen

On review of the proposed AD, it is unlikely that the addition of notes to the POH, or placards will be an effective solution to this issue. The concern here is "maximum braking," which can also be considered as "panic braking" at which point, the pilot is making an instinctive reaction to an adverse condition (e.g., exiting the end of the runway, attempting to avoid an encounter with wildlife or other aircraft). In such cases, these solutions as proposed, will neither be effective nor useful. Proposal: 1. Withdraw the existing AD. It is fatally flawed, and will not be effective. An engineered solution is warranted. 2. Require the OEM to develop an engineered solution. One viable solution would be to add anti-lock brakes to the aircraft, adapting existing automotive technology. The use of an anti-lock braking system would prevent brake lockup, and by doing so, prevent the adverse condition cited in the Airworthiness Directive. It would address maximum braking, regardless of the cause. The cost of the system change would be in the range of $2000 to $5000 - it would include the typical slotted wheels and Hall sensors, as well as changes to the brake system, but should be able to be accomplished with reasonable engineering effort. This should be able to meet the cost/benefit requirements to warrant inclusion as a backfit, since the risk of "significant structural damage" is cited in the AD. Thank you for considering this request.