Boeing Executive Flight Operations

??Docket No.FAA?2007?0163; Directorate Identifier 2007?NM?046?AD?? Boeing BBJ and BBJ2 aircraft (737-700-IGW, 737-800 with variable identifiers of YGxxx and YD4xx respectively) aircraft are delivered ?green? without an interior from Boeing to a customized VIP completion center for interior outfitting and interior completion. These aircraft modified to a custom interior specification and design that are certified by Supplemental Type Certificate. Many BBJ interior installations currently incorporate a Passenger Entertainment Switch (PES) or load shed switching in their STC configured Interior power distribution that will remove power from the interior equipment and or systems as required under FAR Part 25.1309, 1351, 1353 and 1355 for the interior certification process. Service Bulletin 737-24-1147 dated March 1, 2007 issued by Boeing and NPRM 2007-NM-046-AD does not consider the BBJ/BBJ2 (737-700-IGW, 737-800) configurations separate from the commercial airline interior configurations and does not supply enough detail as to what systems or equipment are to be isolated with the PES disconnects. We request that NPRM 2007-NM-046-AD acknowledge the BBJ/BBJ2 (737-700- IGW & 737-800) aircraft equipped with PES capability certified as part of their interior STC with either manual or automatic load shedding be exempted from the applicability of this AD. Alternatively we request that the FAA provide additional detail on what specific interior systems or equipment should have a means of being disconnected in order that operators can accurately petition and apply for an Alternate Means Of Compliance to this NPRM.