Bellanca-Champion Club

Federal Aviation 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

Gentlemen:

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:

1. The number of actual damaged spars identified by the FAA are small; most have been the result of known wing-strikes (ground loops with contact, collision with structures, etc.); others are not fully identified, therefore no confirmation exists of any damage resulting from in-flight origin. This is especially so in the case of the lower-powered 7 & 11-series Aeronca aircraft; in fact no known case of damage or failure exists in the 11-series at all. Any wing-strike or other physical damage incurred by these aircraft are cause for extensive inspection outlined in item 2 below; this is an existing, de facto procedure already accepted, similar to engine tear-down after a prop strike.
   
   
2. It (NPRM) is redundant with long-established inspection requirements and procedures. All affected aircraft models are subject to mandated annual inspections and require the approval of an A&P with Inspection Authorization (IA) to be returned to service (airworthiness). To comply with the above, many references and much guidance are available to the IA;



• the FAA's AC 43.13-1B paragraph 1-29 adequately addresses the very same issues (including compression cracking) of concern in this NPRM including inspection methods and paragraph 1-28 gives a review of wood deterioration and damage;


• American Champion Aircraft Corporation has issued Service Letters 406 (Rev. A) and 417 (Rev. C) with methods specific to these aircraft models;


• Certificated (therefore deemed qualified) A&Ps with the experience and trust levels recognized by the FAA for the issuance of Inspection Authorization have been trained in the very procedures required to safely maintain these aircraft on a normal scheduled (annual) basis as well as in response to wing-strike events and owner demand (pre-purchase inspections, etc.)

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. These all 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.

Sincerely,

Robert Szego
President
Bellanca-Champion Club

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