Air Spray Ltd.

Docket number FAA-2012-0393 Directorate Identifier 2012-CE-025-AD We have a fleet of 8 Commander 690 model aircraft affected by this AD. We have accomplished Service Bulletin 241 on 2 of the 8. Our company is primarily involved in aerial fire suppression and uses these aircraft as lead aircraft for the air tankers. We have 2 aircraft in the fleet that have total airframe time between 7500 and 9999 hours this requires the completion of SB 241 in 60 days from the effective date (by 29 July 2013). This time restriction does not allow us to meet our contractual obligation to various government agencies. We have inspected all aircraft visually to the extent allowed without structural dismantling and do not have any visible cracks on the remaining 6 aircraft. The restrictive time of compliance will have a significant financial impact on our company as the aircraft are equipped with specialized avionics and equipment and cannot be substituted. This will result in a default on our contracts and also pose a threat to public safety as these aircraft are directly involve with wild fire control. The shortened time of compliance will also impact the return to service of aircraft as the supply SB 241 kits will not be able to keep up with the demand.