Proposed Legal Interpretation on 14 CFR Part 39

The Aerospace Industries Association (AIA) and General Aviation Manufacturers Association (GAMA) represent manufacturers of commercial and general aviation aircraft, engines, avionics and components who also provide airworthiness and maintenance services to nearly every commercial and general aviation operator in the U.S. and throughout the world. AIA/GAMA appreciate the opportunity to review Proposed Airworthiness Directive Legal Interpretation published in the Federal Register on April 14, 2011 and offer the following comments for consideration. In addition, AIA/GAMA respectfully request that the Federal Aviation Administration (FAA) extend the comment period for an additional 60-days as it is necessary in the interest of manufacturer, operator and maintenance organizations and individual aircraft owner operators and the traveling public. AIA/GAMA offer the attached comments in support of this request.