Ben Favrholdt EAA #40295

4415 Pacific Coast Highway #309

Torrance, California 90505

August 16, 1979

Mr. Paul H. Poberezny

9711 W. Forest Park Drive

Hales Corners, Wisconsin

53130

Dear Paul,

I have been a member of EAA for many years, and I have never felt the need to write to you, because I have been in full agreement with the policies and goals of the EAA, and I feel that the EAA is doing an excellent job of representing its members and Sport Aviation.

My reason for writing to you now, is that a recent AD issued by the FAA contains a paragraph, that if it should become a precedent, could be very damaging to General and Sport Aviation in the future.

Airworthiness Directive 79-11-05, dated May 29, 1979 (attached), deals with inspection of the tall assembly and aileron attach points on the Mooney Mite. Paragraph (1) requires removal of the fabric on the horizontal and vertical stabilizers in order to inspect the wood and glue joints. This in itself seems to be a sledge hammer approach, when small inspection holes and the use of a borescope and probes could very well be used to determine if fabric removal is necessary.

The shocking part of the AD however. is that this inspection is required every 36 months. This means remove the fabric on the tail surfaces every three years. 

If this AD reflects the FAA's view of wood-fabric aircraft, then it would seem only a matter of time before we see similar AD's applied to Beech Staggerwings, Bellancas and numerous other aircraft using this type of construction.

The AD was issued on the East Coast, where moisture and high humidity is very prevalent. There are several Mooney Mite owners here in the dry Southwest who have trophy winning airplanes that have always been hangared. With the new glues and dacron fabrics available these days, it is indeed difficult to understand why the FAA would single out the approximately eighty Mooney Mites flying and require that an expensive paint job be destroyed every three years.

On behalf of my fellow Mooney Mite owners and myself, I appeal to you Paul, to discuss this with the FAA and attempt to get an amendment to this AD that will permit some latitude in getting the inspection job done without removing the fabric, unless the local inspector deems it necessary.

The Mooney Mite is fuel efficient, quiet and a good neighbor. It is also gradually becoming extinct. The weak voice of eighty Mooney Mite owners against the giant FAA is no match. We can be arbitrarily dismissed and no one will notice. However, the message is clear. Today the PM requires the fabric on the Mite tail be removed every three years. Who will be next?

Sincerely,

(signed) Ben Favrholdt

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Experimental Aircraft Association

P.O. Box 229

Hales Corners, Wisconsin 53130

September 4, 1979

Mr. Ben Favrholdt

4415 Pacific Coast Highway #309

Torrance, California 90505

Dear Ben,

Thank you for your letter of August 16th relative to the Mooney situation.

I will contact Charlie Schuck in Washington to see why this AD came out. I know from earlier experiences on Mooneys, since we have one here in the local area, where some years back there were wing spar problems. I personally looked at the disassembled aircraft and wing spar and saw that the laminations were completely separated. I will see what I can find out.

Don't feel too bad, I had to spend $6,000 to put a strap on my Twin Beech and that was also quite a controversy. 

My best to you.

Sincerely,

(signed)

Paul H. Poberezny

President

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Ben Favrholdt

4415 Pacific Coast Highway #309

Torrance, California 90505

September 4, 1979

Mr. I. Mankuta

Airframe Section, AEA-212

Engineering and Manufacturing Branch

Federal Building, J.F.K. International Airport

Jamaica, New York 11430

Dear Sir,

This letter is in regard to Airworthiness Directive 79-11-05, dated May 29, 1979 which applies to the Mooney Mite.

I would like some clarification of paragraphs (1) and (7). Paragraph (1) requires removal of all fabric on the vertical and horizontal stabilizers. My aircraft, M18LA, serial 127, was completely rebuilt in 1968 by the late Bill Hackbarth of Santa Paula, California. Mr. Hackbarth was an expert craftsman in wood aircraft construction, Among his many credentials was the replica mail-plane which he built, then flew it from Santa Paula to Washington D.C., where it is now on display at the Smithsonian Air and Space Museum.

I have been flying my Mooney Mite since 1969 with confidence and absolutely no problems whatsoever. It has always been hangared in the dry Southern California climate. Preliminary inspection of the tail assembly through inspection holes, show no trace of dry rot or glue separation. My question regarding paragraph (1) of the AD is; Would it satisfy the AD if the decision to remove all fabric from the tail assembly be put at the discretion of the local Inspector. If necessary, additional small inspection holes could be provided near the critical areas, to facilitate thorough inspection.

Paragraph (7) states that upon submission of substantiating data, the inspection time may be adjusted. I would like some information about what kind of data would be required, and what inspection interval could be granted.

I agree with the AD in several respects. I think that after flying the Mite for ten years, the tail should be removed in order to inspect the bulkhead and attach points. For my own safety, I would also want to have the attach bolts replaced with new ones. I do, however feel, that some allowance should be made for a plane that has never been parked outside in the rain and has never been flown in the rain, compared with a plane that is parked outside in a high humidity part of the country.

My airplane has won several trophies, including second place at the Jimmy Doolittle fly-in in Long Beach In 1972. To remove all the fabric on the tail every three years, may require re-painting the entire aircraft each time,

If no allowances can be made for the requirements in paragraph (1), would it be possible to extend the inspection interval to six or eight years, with the stipulation that the aircraft must be hangared during the entire period. 

Sincerely

(signed) Ben Favrholdt

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Experimental Aircraft Association

P.O. Box 229

Hales Corners, Wisconsin 53130

September 26, 1979

Mr. Ben Favrholdt

4415 Pacific Coast Highway #309

Torrance, California 90505

Dear Ben,

I am enclosing a copy of a letter I've received from Charlie Schuck relative to the AD on the Mooney 18. 

As Charlie states, they will be in contact with you on this matter.

My very best to you.

Sincerely,

(signed)

Paul H. Poberezny

President

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Department of Transportation

Federal Aviation Administration

Washington. D.C. 20591

September 13, 1979

Mr. Paul H. Poberezny, President

Experimental Aircraft Association

P. O. Box 229

Hales Corners, Wisconsin 53130

Dear Paul,

This is in reference to Ben Favrholdt's letter and the AD on his Mooney-18.

I talked to our Engineering Office in New York. which initiated the AD and they were very cooperative. They will write to Ben and advise him of alternatives he has, and will copy you on the reply. They will also advise you of the background on the need for the AD. This appeared to be the best approach and keeps the principals in the loop. I understand Ben's concern, but also recognize Engineering's responsibility in this case.

I trust all will work out satisfactorily.

Sincerely,

(signed) Charles Schuck

FAA/EAA Liaison

General Aviation and Commercial Division

Office of Flight Operations

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Department of Transportation

Federal Aviation Administration

Washington. D.C. 20591

Eastern Region

Federal Building

John F. Kennedy International Airport

Jamaica, New York 11430

October 15, 1979

Clarification of Paragraphs (1) and (7) of AD 79-11-05, Mooney Model M-18LA, S/N 127; ref., your ltr. dated 9/4/79

FROM:    Chief, Engineering and. Manufacturing Branch, AEA-210

TO:      Mr. Ben Favrholdt

         4415 Pacific Coast Highway #309

         Torrance, California 90505

This is in reply to your subject letter, which requested clarification of Paragraphs (1} and (7) in AD 79-11-05.

Upon review of your letter, we have the following comments:

1. Although you state that your aircraft was completely restored in 1968, and that the aircraft has been hangared in a dry climate, we consider these reasons insufficient evidence that the basic wood structure and glue joints are in satisfactory condition as of this date, since there is a possibility that wood rot and deterioration could have formed over the eleven year period.

2. As a guide for installation of inspection covers, we are enclosing a Mooney Mark 20 Service Bulletin M-20-170A. With reference to the addition of small inspection holes in the critical areas of the tail assembly, we suggest that this modification be coordinated with your local FAA Flight Standards District Office (WE-FSDO-65), located at 2815 East Spring Street, Long Beach, California 90806, Telephone No. (213} 426-7134.

3. In accordance with Paragraph (7) of the AD, it will be necessary that you provide this office with additional supporting evidence such as signed documents pertaining to current periodic inspections, log book records of flight hours, major repairs and service difficulties and any other incidentals confirming that the present condition of the aircraft's structure is in a state of airworthiness equivalent to that which would have resulted by implementation of the AD.

4. We consider the repetitive inspection interval of six or eight years, as you suggest for hangared aircraft, too relaxatory. Based on engineering judgment and accounts of service difficulties in the field, we feel that a repetitive inspection interval of 36 months is more reasonable from a precautionary viewpoint to detect wood deterioration in the aircraft structure.

By a copy of this letter we are suggesting that the FAA Flight Standards District Office (WE-FSDO-65) inspect your aircraft for airworthiness of structure, review your substantiating information, and submit their recommendation to this office concerning an extension of inspection time. Upon receipt of their recommendation, we will further review your request for an extension.

(signed) Kenneth M. Lauterstein 

for RAYMOND J. BOROWSKI

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October 25, 1979

AEA-212

Airworthiness Directive 79-11-05, Mooney M-18 Series, ref., your ltr. dated September 4, 1979, Washington AFO-803 ltr. dtd. September 13, 1979

Chief Engineering and Manufacturing Branch, AEA-210

Mr. Paul H. Poberezny, President

Experimental Aircraft Association

11311 W. Forest Home Avenue

Franklin, Wisconsin 53130

This refers to your subject letter and Mr. Favrholdt's letter submitted to us by our Mr. Schuck of the General Aviation Division, Flight Standards Service, AFO-803, Washington, D.C., requesting information pertaining to AD 79-11-05.

The problem areas relating to this AD were brought to our attention as the result of a fatal accident involving Mooney Mite M-18LA, S/N 123, which occurred in Wilson, Texas, on October 29, 1978. Inspection of the aircraft revealed a large percentage of wood rot in the fin rear spar and the wing rear spar at the rib attachment points.

Inspection of other aircraft of this model, and discussion with the type certificate holder, and others closely associated with the design, production and operation of the Mooney Mite, revealed that wood deterioration has long been a foremost factor in its continued airworthiness. As you may be aware, AD 59-22-03 was initially issued to correct this unsafe condition and vividly serves as testimony to the need for the continued periodic inspection. Furthermore, it has become evident that a number of aircraft owners may not be aware of the extent of wood deterioration existing in certain areas of the aircraft structure which cannot readily be inspected without removing the fabric covering, even though the exterior appearance of the aircraft portrays an excellent condition.

Enclosed for your information are letters from the Mooney Mite Owners Association Bulletin, Volume IX, Number II, Quarterly Issue, April - June 1974, and Volume IX, Numbers III and IV, Half Yearly Issue, July - December, 1974, pertaining to wood rot and a General Aviation News Article "Wooden Wings, a Little Damp Will Do You In", dated January, 1977, on wood deterioration. The possibility of wood rot, deterioration, delamination and separation of glue joints demands that a thorough inspection be made to detect these defects, before they progress to the point of failure. With regard to Mr. Ben Favrholdt's letter relating to the use of small inspection holes on the horizontal and vertical stabilizers and the borescope for inspection purposes, we would consider this an equivalent method of inspection, provided these areas to be inspected, noted in paragraphs (1), (2) and (3) of AD 79-11-05, could be actually seen. [the bold print is ours]

As you may be aware, there are no inspection covers on the fabric of the horizontal and vertical stabilizers of Mooney Model 18 series aircraft as there are on Mooney M-20 series aircraft.

In the interest of safety, we believe that the enforcement of AD 79-11-05 and AD 79-18-07 are justified.

(Original signed by Kenneth M. Lauterstein)

for Raymond J. Borowski

Enclosures (3)

Cc: AFO-803 Mr. C. Schuck/Mr. Ben Favrholdt,

4415 Pacific Coast Highway #309,

Torrance, California 90505