Posted for Charlie Kohler <charliekohler@yahoo.com>:

 Bryan,
 By "beef" I meant substance or meat of the complaint.  I maintain that in
compliance with 8130.2F we do have authority "as given by the administrator"
 in our operating limitations to counter the restriction in 91.319c.
   I understand your confusion with the phase1 and phase 2 wording. It just
came up in my renewal seminar --the current thinking is that phase 2 may not
be issued and that the airplane would have a phase 1 renewed annually.  Then
if it were issued phase 2 the phase 1 would be expired and be destroyed.
 Charlie K.