Wermlandsflyg Operations AB

Our company is specialized in aerial surveys and for this purpose our aircraft are modified with camera hatches and latest generation survey and navigation equipment. The availability of these aircraft is of critical importance to our client, which is a government agency. There is no way to substitute these aircraft during the photo-season, which lasts until the end of September. We have scheduled the inspections and modifications required to comply with SB241 to be performed in October 2013. The AD states 60 days’ compliance time for airplanes with more than 7500 hours which in our opinion is too restrictive and will have a large impact on our operation. From our point of view, the airplane will not crack because of time expressed in a very limited amount of calendar days, rather than flight hours. We therefore, for the following reasons, mean that the original time for compliance, as specified in Twin Commander SB241 should be used 1. Supply of SB241 kits. 2. Availability of adequate personnel. 3. We have already inspected parts that are accessible without airframe dismantling without any apparent damage at all. If you do not agree with the above, we mean, that the AD should at least be split in two parts, provision for a part 1 initial inspection and a part 2, modification. For example: Part 1, inspection – no damage found, modify within 6 months. Part 1, inspection – damage found, modify/repair before flight. Part 2, modification.