Pilauts Aircraft Ltd.

Pilatus requests that the latest revision of the AMM 01975 be quoted in the AD. "Pilatus PC–6 B2–H2/B2–H4 Maintenance Manual, document No. 01975, Revision No. 17, dated December 31, 2012". This will prevent applications for an AMOC shortly after AD release. The ALS section remained unchanged in this revision of the AMM. The AMM update was released after the MCAI was submitted. The EASA AD 2012-0268 correctly quotes the AMM at revision 16, because the AD was released before the AMM update. The ALS document 02334 at revision 3 dated July 31, 2012 is correct. Pilatus also finds the specified compliance time rather complicated and not as intended in the ALS and therefore requests the FAA to rather use the compliance time and grace period as specified in the EASA AD 2012-0268 eg. "For aeroplanes which have a Flap Actuator installed, except part numbers 978.73.14.101 and 978.73.14.103, which, on the effective date of this AD, has already accumulated or exceeded 3500 flight hours or 7 years since new or since last overhaul, within 6 month or 350 flight hours, whichever occurs first after the effective date of this AD, but not later than 8,5 years since new or since last overhaul, replace the Flap Actuator with a serviceable part in accordance with approved maintenance instructions." Should the above proposal not be acceptable to the FAA, Pilatus proposes that a flight hour limitation also be added to Par. 2.(f)(3)(iii). Pilatus argues that should an operator have more than 8 years but less than 8.5 years actuator service with no flight hour limitation, the operator with extreme operating hours may exceed the allowed 3500fh + 350fh grace period.