Airbus Model A330-223, -321, -322, and -323 Airplanes

Subject: A330 Lower Aft Pylon Fairing Firewall ¿ Proposed Rule Response Ladies/Gentlemen: FAA proposes to adopt a new airworthiness directive (AD) for all Airbus Model A330-223, -321, -322, and -323 airplanes. This proposed AD would require repetitive inspections of the firewall of the lower aft pylon fairing (LAPF), and corrective actions 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: ¿Referenced Service Bulletin: Both referenced service bulletins are at revision level 1 and the new revision levels should be reflected in the final rule. ¿Flight Hour v Flight Cycles: The final rule should state 4,600 flight hours instead of 4,600 flight cycles to provide agreement with the originating OEMs Service Bulletins. ¿Crack Length: Additional cracks found during inspections should be allowed as long as the total combined crack length of all cracks in a single firewall does not exceed 1.2 inches. ¿Accomplishment Deadlines: Initial accomplishment deadline should be 600 hours rather than 500 hours for a LAPF that has accumulated greater than 3,000 hours in order to align with the A-Check schedule. ¿Repeat Inspections: Repeat intervals for inspection should be amended as the time frame would permit the subject inspections and required follow-on action to be accomplished during a routine A-Check. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association