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Touring Motor Gliders Association (TMGA)

11th Hour FAA action on Nose Plate AD


StuOstrander

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All Grob owners,

AD 2012-10-11 issued on Grob G109 and G109B aircraft initially called for an inspection plate to be installed in the vertical stabilizer, no later than October 9th, 2012. Jim Rutherford, the designated FAA contact just called me to alert me that they are in the process of reviewing that AD and expect to reach a conclusion this Friday, October 5th on whether or not that inspection plate will be required.

Jim asked me to get the word out to as many of my fellow G109 (and B) friends to stay posted for further, late breaking developments. If you have already installed a plate, disregard this email. If you have yet to take action, hold your breath.

Since this is very much an eleventh hour situation, Jim is unable to anticipate which way the outcome will go. Much to the FAA’s credit, and specifically, Jim Rutherford and Earl Lawrence, they have jumped through hoops in just two days.

I am emailing directly to all owners for which I have email addresses. I will also post this on the TMGA web site and the Grob Yahoo Group web site in order to notify as many people as possible.

More explanation will follow.

Stu Ostrander

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All Grob owners,

AD 2012-10-11 issued on Grob G109 and G109B aircraft initially called for an inspection plate to be installed in the vertical stabilizer, no later than October 9th, 2012. Jim Rutherford, the designated FAA contact just called me to alert me that they are in the process of reviewing that AD and expect to reach a conclusion this Friday, October 5th on whether or not that inspection plate will be required.

Jim asked me to get the word out to as many of my fellow G109 (and B) friends to stay posted for further, late breaking developments. If you have already installed a plate, disregard this email. If you have yet to take action, hold your breath.

Since this is very much an eleventh hour situation, Jim is unable to anticipate which way the outcome will go. Much to the FAA’s credit, and specifically, Jim Rutherford and Earl Lawrence, they have jumped through hoops in just two days.

I am emailing directly to all owners for which I have email addresses. I will also post this on the TMGA web site and the Grob Yahoo Group web site in order to notify as many people as possible.

More explanation will follow.

Stu Ostrander

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The FAA has issued an extension to the Nose Plate AD pertaining to that portion requiring installation of an inspection port. The extension is to Jan 9, 2013. This will provide time for the FAA to communicate more with EASA (their European equivalent), and Grob. This is time that all Grob owners should use to compile data pertinent to the issue, how many inspection ports have been installed, what was observable through the port, how many cases of observed corrosion on the exposed portion of the plate, how many plates have been replaced, what was the condition of any replaced plates. The more we know, the safer will be the outcome, in terms of our aircraft structural integrity and AD initiatives.

Stu Ostrander

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The FAA has issued an extension to the Nose Plate AD pertaining to that portion requiring installation of an inspection port. The extension is to Jan 9, 2013. This will provide time for the FAA to communicate more with EASA (their European equivalent), and Grob. This is time that all Grob owners should use to compile data pertinent to the issue, how many inspection ports have been installed, what was observable through the port, how many cases of observed corrosion on the exposed portion of the plate, how many plates have been replaced, what was the condition of any replaced plates. The more we know, the safer will be the outcome, in terms of our aircraft structural integrity and AD initiatives.

Stu Ostrander

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I asked Stu Ostrander to summarize the situation for posting her in the forums and I will included in the Knowledgebase as well. Here is his summary:

About a year ago, an English mechanic, discovered a potential issue on the Grob G109 and G109B. He maintains about 30 of them and is an obvious expert on the model. He described the issue, and also wrote up the repair procedure he used when a defect was found. He submitted his findings, pictures, and written procedure to Grob.

Grob misinterpreted his data and subsequently issued a bulletin which ultimately found its way to the FAA. The FAA, working with its European counterpart and Grob, properly issued an “Airworthiness Directive” on all Grob G109’s with a compliance date of tomorrow, Oct 9th.

Several of us were unhappy with the recommendation (based on Grob’s faulty information) which seemed to gloss over common sense. Last Monday, several critical bits of information were uncovered which compelled me to call the head of the FAA department that had issued the AD. Not only was he very congenial, he was also quite enthusiastic to correct a potential error and promised me he would get an individual assigned to work with me. One day later, I was contacted by the assigned technical guy. By Friday, an amendment to the original AD was issued giving us an incremental 3 months to develop a more correct approach to the concern.

There is still a concern about the outcome of this issue because the FAA must once again, in lieu of any other input, rely on Grob and EASA (European equivalent of the FAA). US owner participation is essential at this time to preclude Grob getting the solution totally wrong for us. It would be a travesty if Grob and EASA were to blandly recommend replacement of all nose plates instead of correctly correlating no corrosion on the exposed portion to no action required.

Attached is the letter from the FAA.

FAA_Approval_G109_Time_Extension.pdf

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I asked Stu Ostrander to summarize the situation for posting her in the forums and I will included in the Knowledgebase as well. Here is his summary:

About a year ago, an English mechanic, discovered a potential issue on the Grob G109 and G109B. He maintains about 30 of them and is an obvious expert on the model. He described the issue, and also wrote up the repair procedure he used when a defect was found. He submitted his findings, pictures, and written procedure to Grob.

Grob misinterpreted his data and subsequently issued a bulletin which ultimately found its way to the FAA. The FAA, working with its European counterpart and Grob, properly issued an “Airworthiness Directive” on all Grob G109’s with a compliance date of tomorrow, Oct 9th.

Several of us were unhappy with the recommendation (based on Grob’s faulty information) which seemed to gloss over common sense. Last Monday, several critical bits of information were uncovered which compelled me to call the head of the FAA department that had issued the AD. Not only was he very congenial, he was also quite enthusiastic to correct a potential error and promised me he would get an individual assigned to work with me. One day later, I was contacted by the assigned technical guy. By Friday, an amendment to the original AD was issued giving us an incremental 3 months to develop a more correct approach to the concern.

There is still a concern about the outcome of this issue because the FAA must once again, in lieu of any other input, rely on Grob and EASA (European equivalent of the FAA). US owner participation is essential at this time to preclude Grob getting the solution totally wrong for us. It would be a travesty if Grob and EASA were to blandly recommend replacement of all nose plates instead of correctly correlating no corrosion on the exposed portion to no action required.

Attached is the letter from the FAA.

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  • 3 weeks later...

I am providing this brief summary to Jim Rutherford, the designated FAA contact on the Nose Plate AD and the owners for whom I have email addresses. This will also be posted on the TMGA web site.

http://www.touringmotorgliders.org/forum

The FAA database lists (31) Grob G109 and (28) Grob G109B aircraft. An attempt was made to contact (57) of the (59) owners either through email or letters mailed to the listed address.

(22) or 37% of the G109 and (9) G109B owners responded to a query of their status in respect to the Nose Plate AD.

Eight people have ordered and/or installed Inspection Port kits and two owners already had factory ports.

(17) owners reported they have inspected the exposed portion of the plate and (16) of those found no corrosion. (1) owner, whose plane is kept within visual distance to the ocean, found slight corrosion on the exposed portion and had the plate replaced. There was no corrosion on the portion below the horizontal bulkhead and which was encased in fiberglass. Five owners have not yet inspected the plate.

G109 owners report there is a very slight band of plate below the horizontal bulkhead which is visible through an inspection port, either the stipulated port or a borescope hole.

G109B owners report the plate is totally encased in fiberglass below the horizontal bulkhead and visual inspection is impossible.

Stu Ostrander

SN 6229

N80217

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I am providing this brief summary to Jim Rutherford, the designated FAA contact on the Nose Plate AD and the owners for whom I have email addresses. This will also be posted on the TMGA web site.

http://www.touringmotorgliders.org/forum

The FAA database lists (31) Grob G109 and (28) Grob G109B aircraft. An attempt was made to contact (57) of the (59) owners either through email or letters mailed to the listed address.

(22) or 37% of the G109 and (9) G109B owners responded to a query of their status in respect to the Nose Plate AD.

Eight people have ordered and/or installed Inspection Port kits and two owners already had factory ports.

(17) owners reported they have inspected the exposed portion of the plate and (16) of those found no corrosion. (1) owner, whose plane is kept within visual distance to the ocean, found slight corrosion on the exposed portion and had the plate replaced. There was no corrosion on the portion below the horizontal bulkhead and which was encased in fiberglass. Five owners have not yet inspected the plate.

G109 owners report there is a very slight band of plate below the horizontal bulkhead which is visible through an inspection port, either the stipulated port or a borescope hole.

G109B owners report the plate is totally encased in fiberglass below the horizontal bulkhead and visual inspection is impossible.

Stu Ostrander

SN 6229

N80217

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  • 3 weeks later...

There is nothing to report yet. Jim Rutherford has our information (Public Input) and is pursuing it. During our meeting, he stated several times that he could accept input but could not provide comments about status or direction.

I am in a similar situation to you, as I am near annual. And everyone will be impacted when the Global Alternative Method of Compliance providing an extension to the original due date expires on Jan 12, 2013.

I absolutely will post new information the moment I have it.

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There is nothing to report yet. Jim Rutherford has our information (Public Input) and is pursuing it. During our meeting, he stated several times that he could accept input but could not provide comments about status or direction.

I am in a similar situation to you, as I am near annual. And everyone will be impacted when the Global Alternative Method of Compliance providing an extension to the original due date expires on Jan 12, 2013.

I absolutely will post new information the moment I have it.

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  • 2 weeks later...

Here is my recent email to Jim Rutherford at the FAA regarding the Nose Plate AD. Following my letter is his brief response. He previously informed me that he could not share in-house deliberations with any of us, so his response can be expected to exclude anything really definitive. Nevertheless, I remain optimistic that logic will prevail and a more realistic result be achieved this time around.

Hi Jim,

Many of the Grob owners are looking to me for the status of the Nose Plate AD. You were specific in your comments that specifics could not be shared prior to an internal decision. However, is it possible to delineate the possible alternatives that future actions might take and assign an estimated time frame?

The Global AMOC expires in January. Several of the owners (including me) are either approaching an annual or are actually currently in Annual. Previous to the original AD being issued, there was a very brief period of public input defined with the Notice of Rulemaking document. May I submit the following, for the record, for consideration in any of your office’s deliberations?

Summary information about the Grob G109 and Grob G109B Nose Plate inspection. The information has been gleaned from US owners, Grob documents, and the originator of the concern, inspection and repair methods. It is being provided to the FAA to be considered as public input on the chance that the original AD 2012-CE-008 will be modified and reissued.

Facts:

· There are (31) G109 aircraft registered with FAA registration. (22) have provided input on this AD

· There are (28) G109B aircraft registered with FAA registration (9) have provided input on this AD

· The nose plate is totally enclosed in fiberglass below the horizontal bulkhead on some and, on others there is a slight gap between the bulkhead and the beginning of the fiberglass “wrap”. (It is believed, but not verified, that the construction detail changed between the 109 and 109B, the latter being totally enclosed.)

· The first corrosion examples were identified by Tim Dews and reported to Grob several years before Grob took action.

· Only one US owner has reported seeing any corrosion. His aircraft is hangared by, and operates near the ocean. On replacement of the plate, there was no corrosion on the portion below the horizontal bulkhead.

Assumptions:

· Grob is either unwilling or unable to research and resolve this issue adequately, and may readily assume a defensive or hostile posture in future considerations.

· If corrosion exists, it will manifest itself on the exposed portion of the Nose Plate which is readily observed above the horizontal bulkhead.

· If the bond between the fiberglass and Nose Plate is secure and continuous, the likelihood of corrosion below the horizontal bulkhead is nil.

· The presence of moisture alone is not conducive to galvanic action on the Nose Plate. Exposure to salt water is an essential element but not a guarantor of corrosive results.

Conclusions:

· Grob’s Service Bulletin was inadequately developed and failed to consider their own construction details.

· Corrosion will first be observed on the already exposed portion of the Nose Plate above the horizontal bulkhead.

Recommendation:

· A new AD be issued that dictates an annual visual inspection of the aluminum Nose Plate for corrosion, and the integrity of the fiberglass bond to the horizontal bulkhead.

Thanks for your time,

Stu

Hi Stu,

Thank you very much for the input and for putting together the summary. This information is helpful especially if a decision were to be made to take "unilateral action". See FAA Order 8040.5, Paragraph 3.d.(2).(B)., on page 3, for more info on that topic. The investigation in conjunction with Grob and EASA is continuing. I do understand that the deadline is coming up and we are working to get something out to the operators as soon as we can. I appreciate your patience.

Best Regards,

Jim Rutherford

Aerospace Engineer, Project Support Branch, ACE-112

Small Airplane Directorate, Kansas City, MO

Federal Aviation Administration

Office: 816-329-4165

Email: jim.rutherford@faa.gov

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Here is my recent email to Jim Rutherford at the FAA regarding the Nose Plate AD. Following my letter is his brief response. He previously informed me that he could not share in-house deliberations with any of us, so his response can be expected to exclude anything really definitive. Nevertheless, I remain optimistic that logic will prevail and a more realistic result be achieved this time around.

Hi Jim,

Many of the Grob owners are looking to me for the status of the Nose Plate AD. You were specific in your comments that specifics could not be shared prior to an internal decision. However, is it possible to delineate the possible alternatives that future actions might take and assign an estimated time frame?

The Global AMOC expires in January. Several of the owners (including me) are either approaching an annual or are actually currently in Annual. Previous to the original AD being issued, there was a very brief period of public input defined with the Notice of Rulemaking document. May I submit the following, for the record, for consideration in any of your office’s deliberations?

Summary information about the Grob G109 and Grob G109B Nose Plate inspection. The information has been gleaned from US owners, Grob documents, and the originator of the concern, inspection and repair methods. It is being provided to the FAA to be considered as public input on the chance that the original AD 2012-CE-008 will be modified and reissued.

Facts:

· There are (31) G109 aircraft registered with FAA registration. (22) have provided input on this AD

· There are (28) G109B aircraft registered with FAA registration (9) have provided input on this AD

· The nose plate is totally enclosed in fiberglass below the horizontal bulkhead on some and, on others there is a slight gap between the bulkhead and the beginning of the fiberglass “wrap”. (It is believed, but not verified, that the construction detail changed between the 109 and 109B, the latter being totally enclosed.)

· The first corrosion examples were identified by Tim Dews and reported to Grob several years before Grob took action.

· Only one US owner has reported seeing any corrosion. His aircraft is hangared by, and operates near the ocean. On replacement of the plate, there was no corrosion on the portion below the horizontal bulkhead.

Assumptions:

· Grob is either unwilling or unable to research and resolve this issue adequately, and may readily assume a defensive or hostile posture in future considerations.

· If corrosion exists, it will manifest itself on the exposed portion of the Nose Plate which is readily observed above the horizontal bulkhead.

· If the bond between the fiberglass and Nose Plate is secure and continuous, the likelihood of corrosion below the horizontal bulkhead is nil.

· The presence of moisture alone is not conducive to galvanic action on the Nose Plate. Exposure to salt water is an essential element but not a guarantor of corrosive results.

Conclusions:

· Grob’s Service Bulletin was inadequately developed and failed to consider their own construction details.

· Corrosion will first be observed on the already exposed portion of the Nose Plate above the horizontal bulkhead.

Recommendation:

· A new AD be issued that dictates an annual visual inspection of the aluminum Nose Plate for corrosion, and the integrity of the fiberglass bond to the horizontal bulkhead.

Thanks for your time,

Stu

Hi Stu,

Thank you very much for the input and for putting together the summary. This information is helpful especially if a decision were to be made to take "unilateral action". See FAA Order 8040.5, Paragraph 3.d.(2).(B)., on page 3, for more info on that topic. The investigation in conjunction with Grob and EASA is continuing. I do understand that the deadline is coming up and we are working to get something out to the operators as soon as we can. I appreciate your patience.

Best Regards,

Jim Rutherford

Aerospace Engineer, Project Support Branch, ACE-112

Small Airplane Directorate, Kansas City, MO

Federal Aviation Administration

Office: 816-329-4165

Email: jim.rutherford@faa.gov

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  • 1 month later...

The FAA, Grob, and EASA (FAA’s European counterpart) have been in extensive communication on the Grob G109/G109B Elevator Nose Plate AD. Their conclusions are:

· it is possible to have corrosion present even when not visible on the exposed portion of the Nose Plate.

· timeliness is of the essence in inspecting the Nose Plate

· the original AD 2012-109-11 is applicable

At this point, we owners have the following options:

1 – comply with the original AD

2 – request an AMOC (Alternative Method of Compliance)

Several of us have begun work on, and intend to submit, an AMOC to drill a ½ or ¾ inch diameter hole and use a an “inspection camera” to inspect the Nose Plate below the horizontal bulkhead. The smaller hole will be located within the area of the originally specified 110 mm (4.33”) hole.

The edges of the proposed hole will be completed as defined for the larger hole.

We will propose to seal the inspection hole, in between inspections, with wing seal tape in the same manner currently used on many high performance, glass sailplanes.

Robert Mudd, Composite Aircraft Repair, our authorized US Grob repair facility, has volunteered to assist us in developing the AMOC, and even an appropriately sized materials kit.

One of the key elements in the process is obtaining the required materials. Although the resin and flocking materials are readily available from numerous suppliers, the typical quantities far exceed our requirements. Robert is going to explore developing a kit comprised of the very small volumes we might require, reducing cost and complexity. With proper instructions, it should be possible to accomplish the requirements using any IA willing to do the work.

The intent is to complete this AMOC within a week. In the meantime, one of our fellow owners intends to submit an AMOC requesting an extension to the current AD due date of Jan 9, 2013. Hopefully all of this can all be accomplished within a time frame eliminating, or minimizing, any downtime.

I have found many camera options are available. There are units for as little as $25 that will plug into a computer (USB port), providing viewing and picture recording. For an example video:

Again, I will keep everyone posted on the developments.

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The FAA, Grob, and EASA (FAA’s European counterpart) have been in extensive communication on the Grob G109/G109B Elevator Nose Plate AD. Their conclusions are:

· it is possible to have corrosion present even when not visible on the exposed portion of the Nose Plate.

· timeliness is of the essence in inspecting the Nose Plate

· the original AD 2012-109-11 is applicable

At this point, we owners have the following options:

1 – comply with the original AD

2 – request an AMOC (Alternative Method of Compliance)

Several of us have begun work on, and intend to submit, an AMOC to drill a ½ or ¾ inch diameter hole and use a an “inspection camera” to inspect the Nose Plate below the horizontal bulkhead. The smaller hole will be located within the area of the originally specified 110 mm (4.33”) hole.

The edges of the proposed hole will be completed as defined for the larger hole.

We will propose to seal the inspection hole, in between inspections, with wing seal tape in the same manner currently used on many high performance, glass sailplanes.

Robert Mudd, Composite Aircraft Repair, our authorized US Grob repair facility, has volunteered to assist us in developing the AMOC, and even an appropriately sized materials kit.

One of the key elements in the process is obtaining the required materials. Although the resin and flocking materials are readily available from numerous suppliers, the typical quantities far exceed our requirements. Robert is going to explore developing a kit comprised of the very small volumes we might require, reducing cost and complexity. With proper instructions, it should be possible to accomplish the requirements using any IA willing to do the work.

The intent is to complete this AMOC within a week. In the meantime, one of our fellow owners intends to submit an AMOC requesting an extension to the current AD due date of Jan 9, 2013. Hopefully all of this can all be accomplished within a time frame eliminating, or minimizing, any downtime.

I have found many camera options are available. There are units for as little as $25 that will plug into a computer (USB port), providing viewing and picture recording. For an example video:

Again, I will keep everyone posted on the developments.

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To all Grob G109 and G109B owners,

Since several have requested an update on the Nose Plate AD, and since there is another new AD and, yet one more after that in the pipeline, this slightly pre-mature mailing is going out.

Review:

The original AD 2012-10-11 had a due date of Oct 9th, 2012. Ron Schwenniger received FAA approval for an Alternative Method of Compliance (AMOC) which provided a 90 day extension to Jan 9th, 2013. (today!)

The FAA concluded that the original AD should remain in place.

Last week, Ron submitted another AMOC request which I believe has a very good chance of receiving FAA approval…and it is also possible we will see that very soon. A copy of Ron’s AMOC is attached.

I believe that the time and cost to implement Ron’s AMOC will be absolutely minimal and can be accomplished by your local IA. Robert Mudd, Composite Aircraft Repair, is our US Grob authorized repair facility and has the materials to complete either the original AD procedure or the proposed AMOC.

New issues:

An AD on the elevator Push/Pull tube has been issued and it is believed an AD is likely for possible cracking on the rudder pedals. Neither one of these is cause for alarm. The required inspections are relatively easy to accomplish and will likely have minimal associated costs. I attached the new AD on the Push/Pull tube also. My Grob just went in the shop this morning for an annual. I will try to keep a photo log of accessing and inspecting the Push/Pull tube to share with those wanting more detail.

Recommendations:

When it appeared likely that we might receive approval on an AMOC for the Noseplate, I called Robert Mudd, Composite Aircraft Repair, to discuss the availability of the materials. It was the first time I had talked with Robert and the conversation left me knowing that I was no longer a Grob orphan.

Robert is willing to explore the possibility of providing the very small quantities of resin, catalyst, and flocking that the AMOC will require (for a legal repair). I suggest we all support Robert whenever we can. Our aircraft do not require significant care, but it sure is nice to know there is a place (in the US) where we can get help when we need it.

Robert’s complete contact information is:

Composite Aircraft Repair

P.O. Box 2010

Moriarty, NM 87035

505-269-8234

robertmudd1u@aol.com

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To all Grob G109 and G109B owners,

Since several have requested an update on the Nose Plate AD, and since there is another new AD and, yet one more after that in the pipeline, this slightly pre-mature mailing is going out.

Review:

The original AD 2012-10-11 had a due date of Oct 9th, 2012. Ron Schwenniger received FAA approval for an Alternative Method of Compliance (AMOC) which provided a 90 day extension to Jan 9th, 2013. (today!)

The FAA concluded that the original AD should remain in place.

Last week, Ron submitted another AMOC request which I believe has a very good chance of receiving FAA approval…and it is also possible we will see that very soon. A copy of Ron’s AMOC is attached.

I believe that the time and cost to implement Ron’s AMOC will be absolutely minimal and can be accomplished by your local IA. Robert Mudd, Composite Aircraft Repair, is our US Grob authorized repair facility and has the materials to complete either the original AD procedure or the proposed AMOC.

New issues:

An AD on the elevator Push/Pull tube has been issued and it is believed an AD is likely for possible cracking on the rudder pedals. Neither one of these is cause for alarm. The required inspections are relatively easy to accomplish and will likely have minimal associated costs. I attached the new AD on the Push/Pull tube also. My Grob just went in the shop this morning for an annual. I will try to keep a photo log of accessing and inspecting the Push/Pull tube to share with those wanting more detail.

Recommendations:

When it appeared likely that we might receive approval on an AMOC for the Noseplate, I called Robert Mudd, Composite Aircraft Repair, to discuss the availability of the materials. It was the first time I had talked with Robert and the conversation left me knowing that I was no longer a Grob orphan.

Robert is willing to explore the possibility of providing the very small quantities of resin, catalyst, and flocking that the AMOC will require (for a legal repair). I suggest we all support Robert whenever we can. Our aircraft do not require significant care, but it sure is nice to know there is a place (in the US) where we can get help when we need it.

Robert’s complete contact information is:

Composite Aircraft Repair

P.O. Box 2010

Moriarty, NM 87035

505-269-8234

robertmudd1u@aol.com

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