I sent the EAA regulatory rep a letter about this issue, and quoted the most relevant comments forom this discussion. Here was the EAA/FAA response:
I apologize for this canned response but I need to take advantage of this method of communication to keep up with the many calls and emails I have received on this issue. First, thank you for taking the time to respond to the notice and for providing your thought; it is appreciated. EAA and Warbirds of America (WOA) have been actively working this issue, with the primary help of Rick Seigfried WOA Board member and a NTSB designated "party to an investigation" of the recent T-6 accident. In addition, we have been in constant contact with the various FAA offices that are working this issue.
Currently, after review of the information that we have, EAA and EAA WOA concur with the need to inspect the entire fleet for cracks in the lower wing attach angles and, therefore, agree that there is a need for an airworthiness directive to be issued against the subject aircraft.
EAA and WOA are still reviewing the considerable input we are receiving from owners and maintenance professionals regarding the issue outlined in the ACS dated May 25, 2005. So far we have the following proposed suggestions for the FAA:
· The initial AD should NOT be repetitive.
o All owners/operators should be required to perform a dye penetrant inspection.
o Upon completion of the inspection the results, serial number, model number, total time of the airframe and the average hours flown for the last 5 years should be reported back to the FAA.
· A modified version of the South African inspection should be used, not the identical version.
o Under development by Rick Seigfried and others.
· Florescent dye penetrant should not be required but should be allowed as an alternate to non-florescent.
· Alodine should be listed as an appropriate alternative to paint for corrosion protection following the dye penetrant inspection.
· The AD should allow for the flight of the aircraft in the normal category for up to 10 hours to allow for movement of the aircraft to the home base and/or maintenance facility without the need for a ferry permit.
· The AD should not require the inspection if previously conducted within the preceding 12 calendar months and if less than 200 hours have been accumulated since the last inspection.
· The AD should call for annual removal of the wing joint bolting angle cover and the visual inspection for cracks and corrosion of the wing joint bolting angle.
EAA and WOA are particularly concerned that the agency may require repetitive inspections without sufficient data to support the establishment of the required inspection intervals. EAA and WOA are asking the FAA to wait until the initial inspection of the fleet has occurred and the data, along with service life of the fleet, can be accumulated and evaluated by the agency and the industry. Once that information has been evaluated a determination as to the duration of a repetitive inspection can be appropriately determined.
In addition EAA and WOA are concerned with the larger issue of mock air-combat and aerobatic training activities in aircraft. We have a concern that this particular failure, and other similar ones, are a result of aircraft seeing higher and more repetitive stresses than they were designed for. We assert that the real issue is the need to address these high stress operations of aircraft as opposed to implementing new inspection procedures on an entire fleet of aircraft. We acknowledged that we must address the current issue at hand but stress that we are willing and able to address what we believe is the real and long- term solution; the establishment for standards for the use of aircraft in mock air-combat and or other high stress aerobatic operations.
Please continue to send in your comments and let us know your thoughts about our initial position on this issue. Copies of the Airworthiness Concern sheet and the South African procedure are linked to the stories on both EAA and WOA web sites; reference
www.eaa.org and
http://www.warbirds-eaa.org/.
EXPERIMENTAL AIRCRAFT ASSOCIATION (E.A.A.)
Earl Lawrence
Vice President Industry and Regulatory Affairs
I don't totally agree with it, but I think the technical people in the EAA know a lot than me