Larry Nelson

Both AD 2007-17-07 and this NPRM in paragraphs (f)(3) Part III and (g)(1) do not meet the requirements of FAR 39.3 and FAR 39.5 9a) and (b). FAR 39.3 states "...rules that apply to the following products: aircraft, aircraft engines, propellers, and appliances." With that said, paragraphs (f)(3) Part III Training for Flight crewmembers, Operational Control/Dispatch and (g)(1) Flight crewmember simulator training has nothing to do with the aircraft. FAR 39.5 (a) states "An unsafe condition exists in the product; and" (b) The condition is likely to exist or develop in other products of the same type design." The perceived unsafe condition, although part of the aircraft, actually applies to specific parts, i.e. 1. (4) Part IV, Flap flex shafts, 2. (g)(2) Flap flex shafts,3. (g)(3) Flap actuators. How does maintenance provide compliance documentation for Operations/Dispatch and Flight crewmembers' training compliance? FAR 39.11 "Airworthiness directives specify inspections you must carry out, conditions and limitations you must comply with, and any actions you must take to resolve an unsafe condition." As stated above, FAR 39.5, this requirement would be met until one or more parts are changed. Since this is written against the aircraft and do not include the specific parts the AD, NPRM and SB addresses and would therefore be difficult to manage.