Comment from Papillon Airways Inc.
Papillon Airways Inc.OpposeBusiness
Summary: The commenter, likely a private aircraft owner or operator, argues that the proposed Airworthiness Directive is too broad because it relies on production dates rather than flight hours. They suggest that high-usage aircraft would have already undergone the necessary component changes and request that the AD be based on flight hours instead.
To Whom it may concern, upon review of this proposed AD, the date ranges are too broad and does not address high usage aircraft, my fleet would not be affected by this proposed AD as all have had multiple engines and Main gearbox changes throughout the years. I'm unclear why these types of AD or EASA are issued as aircraft built prior to 2023 have flown for many hours. I would request that instead of just a production date be indicated that it indicated hours flown. Most gearboxes and engines would be changed out by aircraft have flown more than 3500 flight hours.