Airbus Model A330, A340-200, and A340-300 Series Airplanes

March 3, 2005 Docket Management Facility, U.S. Department of Transportation, Attention: Docket No. FAA-2005-20221, Directorate Identifier 2004-NM-173-AD 400 Seventh Street SW., Nassif Building, Room PL¿401, Washington, DC 20590. Subject: A330 & A340 Elevator Assembly Skin Panels - Proposed Rule Ladies/Gentlemen: The FAA proposes to adopt a new airworthiness directive (AD) for all Airbus Model A330, A340-200, and A340-300 airplanes. This proposed AD would require inspecting to determine the part number and serial number of the left- and right-hand elevator assemblies, performing related investigative and corrective actions if necessary, and re-protecting the elevator assembly. 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: ¿Visual Inspection: This maybe unnecessary where operators have A330 aircraft manufactured and delivered in July 2003, after Airbus had changed the production processes to prevent moisture ingression and the resulting disbond and delamination. Operators could ensure continuing compliance with the intent of the proposed rule by setting up controls to force inspection of (a.) all incoming spare elevator assemblies, and (b.) any elevators on future aircraft purchased from other operators. This will provide a level of safety equivalent to that in the proposed rule. Your serious consideration of these observations and comments would be greatly appreciated. Sincerely, Robert Peel Director of Quality Air Transport Association