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Comment:Ladies and Gentlemen ...
As a practicing Airframe and Powerplant Mechanic with Inspection Authorization, I have been privileged to inspect a fair number of the aircraft proposed by this action.
You are correct; failure of this component is going to make the airplane in flight "unairworthy in the extreme."
However, I believe that there are alternative methods for inspection that will improve the inspection process, give us far more information than a single hole cut in the wing, and reduce the cost on the owner/taxpayer.
Most of us performing inspections in the field where the item to be inspected is difficult or impossible to see directly have been able to use a number of products that allow us to do the inspection by electronic means. That is, a video sensor at the end of a long maneuverable tube can get into areas that mirrors and other devices just can't see. The common name for this device is "borescope", but modern technology has gone so far past the borescope technology of the 1970s that "borescope" is like comparing a dial telephone to a cellphone. Let's call this device an "inspectoscope".
I also agree that this is a difficult location to inspect, either by mirrors (almost impossible) or borescope (marginally possible by a highly trained person) using currently available inspection openings.
I propose that you modify the Airworthiness Directive to the cutting of two (perhaps three for redundancy) small holes in each inspection area of the wing that an inspectoscope probe can fit into and can see the critical areas which will identify the filiform corrosion that this fitting is subject to. After inspection, the holes may be covered up with spring loaded hole covers (industry term - "botchbuttons"). that can be removed at each inspection and easily reinstalled.
If you adopt this proposed procedure I **URGE** you not to specify that we use the "Acme Model 1234AA-X" inspectoscope as most of us who do this sort of inspection on a regular basis have inspectoscopes that we have found perfectly usable and have, for lack of a better term, become great friends with them and have learned their strengths and weaknesses. You have placed a great faith in our abilities to use the tools necessary to do the job at hand and we have not failed you yet.
Thank you for your time
Jim Weir
2261417 A&P IA