Administration, Central Region
Office of the Regional Counsel
Attention: Rules Docket 98-CE-121-AD, Room 1558
601 E. 12 th Street
Kansas City MO 64106
September 9, 1999
Re: Docket No. 98-CE-121-AD
On behalf of the membership of the Bellanca-Champion Club, I would like to submit the following in response to the above referenced Notice of Proposed Rulemaking.
It is our belief that the proposed AD is unnecessary for the following reasons:
We also take exception to the characterization of this NPRM as 'not significant' under the Cost Impact and Regulatory Impact paragraphs. As mentioned above, there is no indication of a large number of aircraft being in danger of spar failure, especially the lower-powered pre-Citabria models, yet this NPRM proposes extensive and all-inclusive inspections above and beyond that already mandated. The additional costs imposed on owners exceeds their cost of the normal annual inspection, which has already been effective in uncovering damaged or deteriorated spars as evidenced by the high ratio of ground-discovered to in-flight accidents.
Additionally, since we believe this action to be redundant and unnecessary, there will be a detrimental effect on the value of the effected aircraft with the onus of another Airworthiness Directive. This will be relative to the market value of each, and we estimate will be anywhere from 10% for the Citabria and Decathlon to as much as 25% for the older Aeronca models.
The Bellanca-Champion Club does not advocate the abandonment of safety inspections, nor taking lightly the responsibility of owners and maintenance personnel in assuring the airworthiness of their aircraft. In fact, we have alerted and continue to inform our membership as to the proper maintenance and inspection of the wood spars many years before the current Service Letters were available. This response is not intended to lessen these efforts, but redirect them from the onus of a mandatory and redundant AD to self-interested emphasis on an effective program of continued maintenance. We continue to be available to assist in this effort and provide the vehicle for information and education.
The Bellanca-Champion Club is
a group of 1,600 owners and enthusiasts dedicated to the
furtherance, preservation and maintenance of Bellanca (Cruisair,
Cruisemaster, 260, Viking) and Champion (Champion, Citabria,
Decathlon, Scout) and derivative lines of aircraft.
have wood spars.
We accomplish this with information,
publications and technical assistance. Our library of manuals and
other publications of great importance to owners is now the most
extensive collection in existence.
Within our ranks are some of the most knowledgeable and experienced owners, mechanics, and even some manufacturers. All have proven to be most eager to help others with advice and assistance; few have been inclined to support this NPRM.
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