Actions and Compliance paragraph (f)(3) proposes that landing gear radius rods with casings manufactured from bar stock (as described by the quoted part number and mod strike-off) must be installed when the aircraft has accumulated 8,000 total landings, or within 100 landings, whichever is the later. This proposal differs from the manufacturer's service bulletin recommendations and the EASA AD requirements.
Whilst BAE Systems understands the FAA policy on aging commuter class aircraft, we submit that retention of this statement within the AD would significantly affect the operation of these aircraft type by US operators.
All aircraft on the US register have achieved more than 8000 landings, and therefore owners would be required to replace the radius rods within 100 hours TIS of the AD's effective date. We have been advised by the equipment manufacturer that spares provisioning will be unable to support a replacement programme within these timescales leading to extended groundings of the aircraft fleet.
BAE Systems submit that the repeat inspection requirements are sufficient to allow radius rod replacement in a longer timescale without adversely affecting safe operation of the aircraft, and propose that an alternative form of words should be used that would require radius rod replacement (using the quoted improved standard) at the next overhaul that occurs after 12 months following the effective date of the AD.