Boeing Model 737-100, -200, -200C, -300, -400, and -500 Series Airplanes

Filed on regulations.gov — full text not in the inline record.

Subject: B737 Classics - Intercostal Webs, Attachment Clips, and Stringer Splice Channels ¿ Proposed Rule Ladies/Gentlemen: FAA has proposed adoption of a new AD for certain Boeing 737-100, -200, -200C, -300, -400, and -500 series airplanes. This AD would require repetitive inspections of the intercostal webs, attachment clips, and stringer splice channels for cracks; and corrective action if necessary. ATA appreciates the opportunity to comment on this proposed rule. Our members generally support the intent of the rulemaking; however, additional review and clarification would be desirable on the attached comments. Specifically: ¿Can the FAA please identify in what way their analysis of the failure mechanism differs from the manufacturer's. ¿The NPRM does not address this approval for pre-existing repairs, or repairs accomplished in the interval between distribution of the NPRM and issue of the AD. ¿Allowances should be made in the final rule for previously approved repairs authorized by the Seattle ACO ¿FAA extends the repetitive inspection interval to align with operators¿ maintenance visits in order to avoid the increased man-hours for access. ¿Referenced Service Bulletin should be corrected to reflect the proper work instructions and references accurate figures for accomplishment. Your serious consideration of this observation comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association Attachments