Boeing Model 737-600, -700, -700C, -800, and -900 Series Airplanes

Subject: B737 Main Landing Gear Wheel Well Electrical Connectors ¿ Proposed Rule Response Ladies/Gentlemen: FAA proposes to adopt a new airworthiness directive (AD) for all Boeing 737-600, -700, -700C, -800, and -900 series airplanes. The existing AD currently requires either determining exposure to runway deicing fluids containing potassium formate, or performing repetitive inspections of certain electrical connectors in the wheel well of the main landing gear (MLG) for corrosion, and follow-on actions. This proposed AD would add a new inspection requirement and related corrective actions. 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: ¿Previous AMOCs:: There should be no technical or operational reason that existing AMOCs cannot be applied to this new AD. ¿Definition of "Exposure": It would be very helpful if the FAA would provide a written definition of what constitutes "exposure". ¿Technical Objection in Principle: These inspection are an imprudent practice, since routinely opening cannon-plug connectors on so many aircraft without any symptoms of problems could create a risk of pushing back connector pins, of bending pins, and of leaving a less secure seal that could allow the ingress of moisture in future. ¿Terminating Action: Need manufacturers and the FAA to more aggressively address a terminating action to this repetitive inspection. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association

Subject: B737 Main Landing Gear Wheel Well Electrical Connectors ¿ Proposed Rule Additional Response Ladies/Gentlemen: FAA proposes to adopt a new airworthiness directive (AD) for all Boeing 737-600, -700, -700C, -800, and -900 series airplanes. The existing AD currently requires either determining exposure to runway deicing fluids containing potassium formate, or performing repetitive inspections of certain electrical connectors in the wheel well of the main landing gear (MLG) for corrosion, and follow-on actions. This proposed AD would add a new inspection requirement and related corrective actions. ATA appreciates the opportunity to provide additional comment son 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: ¿Repetitive Inspections:: Similar rules in the past have seen inspection frequencies extended. Operators would like to see a similar extension for this rule. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association Attachments