Steve Donohue

Dear Sir, Inresponses to the proposal, I submit the following: An aircraft records review to determine the valve part number installed and the condition (service bulletin and revision level or line installation) under which it was installed should be allowed versus the GVI of each installation in PART I, (f)(1). ExpressJet has purged almost all of the -3 valves from our fleet (less than 10 remain) mostly under SB145-30-0044R2 and can document the status of the remaining positions such that GVI of all locations would be redundant and a waste of resources. I believe there is an error in the proposal regarding revision levels of SB 145-30- 0044 in that PART V, (f)(5)(i) and (ii) both allow for rev 3 of the bulletin. I believe that PART V (f)(5)(ii) should address valves installed per SB145-30-0044R1 and earlier. While I don?t have access to the earlier versions of this SB, rev 2 and 3 in addition to replacing the valve, inspected the inlet deice line for blockage while I believe the original issue and rev 1 did not. This may effect other areas in the proposal. While PART V, (f)(5)(i) is very clear that it terminates the actions of the AD, paragraph (ii) is less convincing. It addresses the installation of the -4 valve installed under SB145-30-0044 (R3, maybe R1?, See preceding paragraph of this comment) but it should also address any -4 valve that may have been installed as a line replacement, i.e. not as a result of any SB. Further, once the inspection required by this section is satisfied no further action should be required by the AD. At this point, a -4 valve is installed and the inlet line has been inspected which is equal to the status of PART V, (f)(5)(i). Allowance should be made in the final rule such that any position that can determined (by GVI or records review) to be a -4 valve installed under SB145-30- 0044R2 or 3 or, a -4 valve exist where the deice inlet line inspection has previously accomplished (since the -4 valve?s installation date) IAW SB145-30- 0049R1 or R0, OR AMMII task 30-21-05-200-801-A00, OR AMMII task 30-21-05- 200-802-A00, that no further action is required by the AD. These scenarios all equate to the status of PART V, (f)(5)(i). It follows that any position meeting these requirements should qualify under the exception to the MEL rule at PART VI, (f)(6). PART III, (f)(3) and PART IV, (f)(4) would be impossible or very difficult to document to meet FAR121.380 (a)(2)(i). I submit that any installation would already involve serviceable parts under existing regulations. Adding this check to the final rule would create an undue burden on operators for no practical gain. The resources to find the record of any pre-installation inspection would have be traced from the stock issue or the installation non-routine, or at any waypoint in between which could span several calendar days for an aircraft in check. Tracking the pre- install inspection isn?t practical. Sincerely, Steve Donohue Director, Technical Services ExpressJet Inc