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FAA Central Region Office Of The Regional Counsel Attention: Rules Docket No. 2001-Ce-45-AD 901 Locust Kansas City, Missouri 64106 Dear Sir, I have reviewed the NPRM regarding the proposed AD requiring implementation of the proposed Univar Service Bulletin 31. First, Univar has not actually issued any Service Bulletin on the subject and the proposed draft copy circulated has not been FAA approved which put the owner in the position of having to make a structural modification with no "Approved Data" to work from. This is at best a "Catch 22". The draft Service Bulletin does not have sufficient data for anyone to manufacture the simple parts to be in compliance with the Bulletin or some other approved data. It would seem that Univar with the help of the FAA are planning to have a sole source for compliance so that they may charge anything they wish for the kit regardless of the value of the parts included. This is not in compliance with the FAA rules and should not be moved forward. Second, the Ercoupe community has debated this issue at some length and the proposal of Mr. John Wright to inspect with the wings removed is a very effective plan to get the required area inspected with no further structural modification to the airframe. I also agree with others who have correctly commented that the prim issue is inspecting for "Intergranular Corrosion". As this is by definition a condition caused during the manufacture of the part and the parts in question are for the most part now over 50 years old it would make good sense that if we do not see any evidence of "Intergranular Corrosion" during the first inspection we will likely never see any. I would think that based on this a wing pull and full center section inspection every five years would be more than acceptable to assure that we still have safe and corrosion free center sections. For background, I own two Ercoupes and am an A&P mechanic. Thank you for your consideration of the above. Sincerely, Vern J. Hendershott, Jr. 9140 Hwy 47 Carlton, OR 97111 ================================================================== TO UNSUBSCRIBE go to: http://ercoupers.com/lists.htm
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