Airbus Model A319, A320, and A321 Series Airplanes

March 2, 2005 Docket Management Facility, U.S. Department of Transportation, Attention: Docket No. FAA-2005-20166, Directorate Identifier 2004-NM-175-AD, 400 Seventh Street SW., Nassif Building, Room PL¿401, Washington, DC 20590. Subject: A319/A320/A321 Cargo Ventilation Extraction Duct - Proposed Rule Ladies/Gentlemen: The FAA proposes to adopt a new airworthiness directive (AD) that would require replacing the cargo ventilation extraction duct at frame 65 with a new duct, and relocating the temperature sensor in the aft cargo compartment. 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: ¿Incorporation Timeframe: Incorporation to be mandated at next Heavy Maintenance Visit, or S-Check rather than a 24-month calendar incorporation window. This change would reduce the economic impact to operators, who would be forced to take aircraft out of revenue service in order to meet the 24-month window. ¿Service Bulletin: Mandate latest revision of the referenced SB and this will prevent the need to request an Alternative Method of Compliance. In addition both referenced SB modifications should be mandated from the same FAA Airworthiness Directive. ¿Man-hours: The NPRM has reduced the original Airbus OEM estimates by approximately one-third. Airbus typically underestimates, rather than over-estimates manpower requirements for repair and modification bulletins and therefore the FAA should consider Airbus¿ average estimates as the correct basis. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association