P.O. BOX 3086 OSHKOSH, WI 54903-3086 • Tel 920.426.6522 • Fax 920.426.6560 • WWW.EAA.ORG

June 10, 2011

U.S. Department of Transportation 

Docket Operations, M-30

West Building Ground Floor, Room W12-140 

1200 New Jersey Avenue, SE. 

Washington, DC 20590.

Reference: Request for Comment Period Extension for Airworthiness Directives; Burl A. Rogers 

(Type Certificate Previously Held by William Brad Mitchell and Aeronca, Inc.)Models 15AC and 

S15AC Airplanes, Docket FAA-2011-0318.

To Whom It May Concern:

EAA (Experimental Aircraft Association) is the world leader in recreational aviation. VAA 

(Vintage Aircraft Association) is the world leader in the retention and restoration of historical 

Antique, Classic and Contemporary aircraft. With a combined international membership of 

160,000 people in more than 110 nations, EAA and VAA bring together aviation enthusiasts, 

pilots and aircraft owners who are dedicated to Sharing the Spirit of Aviation by promoting the 

continued growth of aviation, the preservation of its history and a commitment to aviation’s 

future. EAA and VAA programs, activities and events are known throughout the world for 

Preserving the heritage of aviation, Promoting access to flight, Protecting the right to fly, 

Preparing for the future of aviation, and of our Passion for aviation safety and education.

EAA and VAA are requesting an additional 60 day extension, until September 1, 2011 to the 

comment period stated in this docket.

• On April 6, 2011 EAA and VAA requested a 90 day extension to the original comment 

period deadline of May 19, 2011 in order to allow the FAA time to publish in the docket 

additional safety information regarding this proposed AD;

• On April 22, 2011, the FAA approved an extension to the comment period to July 3, 

2011. This was a 45 day extension in lieu of the requested 90 days;

• On May 18, 2011 EAA and VAA was informed by the FAA that the additional 

information regarding this proposed AD would not be released unless we submitted a 

Freedom of Information Act (FOIA) request;

• On May 24, 2011 EAA and VAA submitted the required FOIA request;

• On May 25, 2011 the FAA assigned control number 2011-6312 to the FOIA request. 

• As of June 10, 2011 FAA response to the FOIA request is still pending.

EAA and VAA are requesting the additional comment period extension to allow time for the 

FAA to process the FOIA request and provide said documents, and for EAA and VAA to 

evaluate those documents. Factored into the extension request time period is the major EAA and 
P.O. BOX 3086 OSHKOSH, WI 54903-3086 • Tel 920.426.6522 • Fax 920.426.6560 • WWW.EAA.ORG

VAA aviation event called AirVenture which will prevent our staffs from devoting sufficient 

time to the document evaluation process. 

In conclusion, EAA and VAA are requesting an additional 60 day extension to the comment 

period, until September 1, 2011 in order for the FAA FOIA process to provide the required 

evaluation documents and for EAA and VAA to conduct the required research on those 

documents after receipt.

 

Please contact H.G. Frautschy, Executive Director, Vintage Aircraft Association (VAA) for any 

questions regarding this extension and information request. 920-426-4825, 

hgfrautschy@eaa.org. 

Thank you for this opportunity to comment on this proposed AD. 

Sincerely,

Randy Hansen H.G. Frautschy

Government Relations Director Executive Director

EAA VAA