Airbus Model A318, A319, A320 and A321 Series Airplanes

Subject: A318/A319/A320/A321 Spoiler Servo Control - Proposed Rule Ladies/Gentlemen: The FAA proposes to adopt a new airworthiness directive (AD) for all Airbus Model A318, A319, A320, and A321 series airplanes. This proposed AD would require an inspection of the spoiler servo control for certain part numbers 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: ¿Applicability: Applicability statement does not limit aircraft effectivity. This introduces unnecessary maintenance activity. oNPRM paragraph (j) prohibits installation of an affected spoiler servo control on any airplane. Consequently, the applicability statement could be altered to limit the effectivity to those aircraft affected by SB A320-27-1158 or A320-27-1159, provided documentation reflects that no spoiler servo control has been changed on post SB aircraft before the AD effective date. oFor those operators with an accurate line replaceable component record system, the NPRM applicability statement introduces unnecessary maintenance activity. ¿Service Bulletin: NPRM should be revised to reflect the latest referenced Service Bulletin Revisions. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association