Robert A. Louviaux

Document ID: FAA-2013-0393-0009
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: June 11 2013, at 12:00 AM Eastern Daylight Time
Date Posted: June 12 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: May 14 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: June 28 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-85un-xl4j
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I am the Maintenance Manager for a FAA 145 repair station and also a Twin Commander Service Center. I waited two weeks after the effective date of this AD to see what kind of impact this AD has done to my Commander customer base affected by the release of this AD and the severely restrictive compliance times called out by it. I must say that it is substantial and overwelming to say the least. Four of my customers now have less than 30 day to comply, and a dozen less than 60 days. Our shop has the capability of doing two of these projects every 5-6 weeks, so you can see by the math that several of my customers will be parking their aircraft until I can accomodate them, possibly for months. My biggest fear is that some of my customers will have no choice but to go to other shops where the quality or experence may be lacking to the point where the repair/mod will be done incorrectly; possibly causing a safety issue, or as we have seen before on other structural ADs, reworks resulting in an AMOC. I can tell you that this will be the case since the Twin Commander service centers and other qualified shops will not be capable of handling this overwelming demand. I am requesting that you re-evaluate the severely restricting compliance times in order for the Twin Commander operators to be able to schedule their down time to a realistic compliance period as not to ground a large portion of the fleet in less than 60 days, and where quality and safety will not be an issue due to the urgency forced upon the repair facilities.

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Jun 28,2013 11:59 PM ET