The proposed AD require to perform the inspection and subsequent doublers installation "when the airplane reaches a total of 3,600 hours time-in-service or within the next 30 days after the effective date of the AD, whichever occurs later" (Action and compliance, f1).
The inspection and doublers installation may be performed also before. The best solution, to reduce impact on operator, is to perform inspection and installation during a D inspection (at 3000 hours time-in-service).
We suggest to replace "when the airplane reaches a total of 3,600 hours time-in-service or within the next 30 days after the effective date of the AD, whichever occurs later" with "before the airplane reaches a total of 3,600 hours time-in-service or within the next 30 days after the effective date of the AD, whichever occurs later"
Piaggio Aero Industries
This is comment on Rule
Airworthiness Directives: PIAGGIO AERO INDUSTRIES S.p.A Model PIAGGIO P-180 Airplanes
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Public Submission Posted: 01/06/2010 ID: FAA-2009-1116-0003
Jan 14,2010 11:59 PM ET