Pratt & Whitney JT8D Series Turbo Fan Engines

February 18, 2005 Docket Management Facility, U.S. Department of Transportation, Attention: Docket No. FAA-2004-19929, Directorate Identifier 2004-NE-15-AD, 400 Seventh Street SW., Nassif Building, Room PL¿401, Washington, DC 20590. Subject: P&W JT8D Critical Life-Limited Rotating Parts - Proposed Rule Ladies/Gentlemen: FAA proposes to adopt a new airworthiness directive (AD) for Pratt & Whitney (PW) JT8D-1, -1A, -1B, -7, -7A, -7B, -9, -9A, -11, -15, -15A, -17, -17A, -17R, -17AR, -209, -217, -217A, -217C, and -219 turbofan engines. This proposed AD would require removing affected rotating parts overhauled by a certain repair vendor, and inspecting or replacing the parts as applicable. 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: ¿Cadmar Aerospace: This NPRM should include all parts that were incorrectly processed by Cadmar Aerospace, Inc. ¿Shop Visit: The definition of a shop visit should be consistent with ADs that have been issued in the past. ¿Compressor Hub: Consider removing from NPRM as: oLack of known cracking or corrosion issues. oNot life limited, therefore, lack of serial number availability oSimilar material as 13th stage disk that is not included in the NPRM ¿Pratt & Whitney Service Bulletin A6442: All parts listed in the NPRM should be able to be inspected per Pratt & Whitney Service Bulletin A6442 and returned to service. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association Attachments