Pilatus Aircraft, LTD.

RE: Comments to Docket No. FAA-2007-0116 / Directorate Identifier 2007-CE- 082-AD (Pilatus PC-12) To whom it may concern, On behalf of Pilatus Aircraft Ltd., we would like to make the following comments on the proposed AD Docket No. FAA-2007-0116; Directorate Identifier 2007-CE- 082-AD: (1) At the issue date of SB 32-020 (basis for this NPRM) Pilatus had sufficient replacement parts (bolts) to cover the affected aircraft. (2) However, Pilatus had to learn that operators replaced also a lot of bolts that were not affected. We received replaced bolts that had the marking of the non affected suppliers, thus customer replaced non affected parts. (3) As consequence, Pilatus does now not have sufficient parts to cover the affected aircraft anymore, considering only the replacement parts defined in SB 32- 020. (4) Leadtimes for the production of sufficient replacement parts P/N 532.10.12.218 and 532.10.12.219 are too long, but alternatively Pilatus could procure ?good? P/N 532.10.12.202 as alternate for P/N 532.10.12.218 and ?good? P/N 532.10.12.205 as alternate for P/N 532.10.12.219. These alternate P/N are purchased from a supplier which was and is not affected by the SB 32-020. These parts have permanent marked supplier code "VLG" engraved. (5) Based on the current situation, Pilatus has decided to upissue SB 32-020 to allow the alternate P/N from the specific supplier "VLG". (6) Furthermore Pilatus wants to stress the fact, that only bolts with the marking "AT" are affected. Therefore we have introduced a comment in the reading under 1.C(1) Problem: "If the bolt is not marked or has a mark other than AT (for example VLG), the bolt is not affected". (7) To account for customer that have already accomplished with the initial issue of the SB, we have introduced a comment in the reading under 1.C(3) Solution: "Unless already accomplished at initial issue of this Service Bulletin, ?" (8) The changes can be seen in enclosed SB 32-020 Rev. 1, November 22/07, which has already been approved by the Pilatus DOA system. (9) Pilatus likes to propose to the FAA to consider the initial issue and the Revision 1 of the SB as the basis for the proposed AD. The changes introduced are minimal and should not affect the comments. Yours sincerely, L E de la Iglesia y Gotarredona. Luis Enrique de la Iglesia y Gotarredona Certification Coordinator ________________________________________ Pilatus Aircraft Ltd. P.O. Box 992, 6371 Stans, Switzerland Phone: +41 41 619 69 01 Fax: +41 41 619 64 52 mailto: ldelaiglesia@pilatus-aircraft.com www.pilatus-aircraft.com