James W. Bender

These comments are being submitted on the behalf of Comair, Inc. Service Bulletin 601R-27-150 dated Jul 12/2007 has a compliance statement found on page 3 of 44. This statement for Part C reads as follows: For actuators P/N 852D100-19/-21, 853D100-19/-20, and 854D100-19/-20, with more than 2000 flight hours since new or since repair where it can be shown that the inboard pinion shaft seals P/N 853SC177-1/-2 were replaced, Bombardier Aerospace recommends that Part C of this service bulletin be done within 24 months of the release date on this service bulletin, unless otherwise directed by the airworthiness authority of the operator. Based on Bombardier recommended compliance schedule listed in the SB, actuator with less than 2000 flight hours since new or since repaired as of the effective date of the SB, July 12, 2007, would not require the inspections of Part C. We are requesting the FAA consider a similar compliance statement in the final rule. Additionally, Comair has had and will have many actuators removed for Maintenance Requirement Manual, Certification Maintenance Requirements Task No C27-50-111-10, Functional Check of the Inboard Flap Actuator Torque Limiter. The note associated with this task states ?Replace the following components: 1. Pinion Seals, 2. Retaining ring, 3. Needle bearings.? Actuators removed to comply with this CMR task should not also require Part C of the referenced SB. The CMR task is an example of a event when the Pinion seals must to be replaced. A more general statement which would also include the outboard actuators would be, replacement of the inboard pinion shaft seals P/N 853SC177-1/-2 should be considered an equal method of compliance to Part C of the SB. Based on the above information, Comair is requesting the Final rule associated with NPRM 2007-NM-197-AD Paragraph (f)(3) contain a statement qualifying under what conditions flap actuators must comply with Part C of the SB. New actuator and those recently repaired should be exempt from the Part C low temperature torque check test. We are also requesting the Final rule contain a statement in the AMOC section to allow ?AMOCs approved previously according to AD 2007-17-07, are approved as AMOCs for the corresponding provisions of this AD.?