2006-CE-71-AD

Comment on [Docket No. FAA-2006-26400; Directorate Identifier 2006-CE-71-AD; Amendment 39-14948; AD 2006-25-08] RIN 2120-AA64 The airworthiness directive is somewhat unclear on whether it is the installation procedure or the Kelly Aerospace manufactured parts that are defective. Rather, the applicability section applies to aircraft equipped with a certain supplemental type certificate which is somewhat different from aircraft equipped with the parts themselves. Kelly Aerospace holds PMA on the items designed approved under STC SA02260CH designated as part numbers NCK-04-004 and NCK-04-005. Since the items are approved under FAR 21.303 they may be installed independently of the STC. We believe these part numbers should be included in the regulatory action and the applicability language modified to ensure that all affected aircraft with defective installations will be covered by the AD. We note the FAA contacted various type clubs and aircraft operators for relevant information prior to the issuance of this requirement. We suggest and request that MARPA also be contacted when proposed actions would affect or involve PMA items. MARPA maintains significant data and information resources that may be of value to the FAA in formulating requirements and we are always ready to assist by providing whatever information we might possess. Jack Buster AD Committee Modification and Replacement Parts Association (MARPA)