Dan P. Johnson

Document ID: FAA-2008-0070-0005
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: February 14 2008, at 09:00 AM Eastern Standard Time
Date Posted: February 14 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: January 25 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: February 25 2008, at 11:59 PM Eastern Standard Time
Tracking Number: 803aea90
View Document:  View as format xml

View Comment

The reduction of the hourly limit may be acceptable provided there is evidence supporting it. The Proposed AD document states the ?Based on full scale fatigue tests the life limit has been extended but the TBO reduced?. I would like to see the actual test results that prove a 5 year calendar limit is warranted. Please notice that the current Chapter 4 component entry for this actuator has no calendar limitation. These actuators are overhauled in the U.S. by Derco Repair services inc. in Milwaukee WI. I contacted this Repair Station for a quote to overhaul one of these last year. I was told that at that time the average to date had been around $4500.00. I was also told that due to a proprietary agreement with Pilatus they would not accept direct requests for overhaul and only Pilatus could provide service. This is a common practice of Pilatus to control U.S. parts distribution. I understand that the FAA is not concerned with costs incurred by operators in the interest of safety. My concern is when they assist in the gouging of American operators by agreeing to an unsubstantiated calendar limit. My opinion is that the hourly TBO reduction is sufficient for Part 91 operators.

Related Comments

   
Total: 5
Scott R. Lania
Public Submission    Posted: 02/05/2008     ID: FAA-2008-0070-0003

Feb 25,2008 11:59 PM ET
Scott R. Lania
Public Submission    Posted: 02/12/2008     ID: FAA-2008-0070-0004

Feb 25,2008 11:59 PM ET
Dan P. Johnson
Public Submission    Posted: 02/14/2008     ID: FAA-2008-0070-0005

Feb 25,2008 11:59 PM ET
Luis Enrique de la Iglesia Gotarredona
Public Submission    Posted: 03/11/2008     ID: FAA-2008-0070-0007

Feb 25,2008 11:59 PM ET
Tim Kitzmann
Public Submission    Posted: 02/25/2008     ID: FAA-2008-0070-0006

Feb 25,2008 11:59 PM ET