NPRM proposing to update the AC 43.13 2A -

Hi all,
I got this from a Bonanza website.
This could have a great impact on general aviation maintenance.
Please read it and comment if you have valued input.
Dave
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http://a257.g.akamaitech.net/7/257/2...4/04-12987.htm

Finally! a commonsense proposal from someone who obviously has been in
the field, using tools and supporting aircraft owners.

Thanks, Mr. O¹Brien, for the suggestion that simple modifications to
small aircraft be made easier to accomplish.

You suggest that the relaxed rule be limited to aircraft with no more
than 200 hp and 4 seats, making it inapplicable to the Bonanzas and
Barons that I have flown for forty-five years.

I suggest that your proposal be made MORE INCLUSIVE so as to apply to
all non-pressurized piston aircraft of MGTOW of 6,000-8,000 pounds or
less (dropping the 4-seat and 200-hp restrictions).

I also think that age of the aircraft should not matter. For example, a
recent Bonanza or Baron may have a system that represents good thinking
and good design and perhaps more recent technology, but it may well be
utterly uneconomical for Beechcraft to undertake the expense of
providing an approved kit to retrofit each earlier variant of the line.
In that case, a slightly modified field-designed variant of the system -
which would surely use mostly Beech or otherwise-approved parts - would
be a reasonable and economical solution.

My shops have long been frustrated by unreasonable ³NO² answers when we
have tried to retrofit a salvaged and perfectly serviceable Baron C-55
oxygen system but with new-technology pulse-delivery regulators into a
nearly-identical B-55 Baron, for example. The entire proposal we
submitted would have been to the highest of engineering standards. My
highly-modified Baron is a BETTER and SAFER aircraft BECAUSE OF
additions and minor modifications we have made to its systems.

But I still carry a portable bottle of oxygen that can come loose and
fly around the cabin in turbulence, when I¹d far prefer a fixed system
that used the thinking behind two similar systems (Beech fixtures. Pulse
delivery)...and for which I am perfectly willing to submit a reasonable
design proposal, based on similar Baron installations.

The new recombinant batteries are simple same-size swap-outs for the old
wet-cells. Requiring a full STC for such a modification is absurd. Your
sensible proposal make such improvements easier.

(I can personally offer a half-dozen more example of similar situations *
some of which were ultimately approved after a long approval process -
if you need these).

As the FAA is supposed to encourage and advocate for all aviation, your
proposal is a magnificent contribution which I support and I hope you
will expand.

Most cordially,
-- Fred W. Scott, Jr.