DHL Aviation Americas, Inc.

As an operator of 7 freighter B727s our comments as follows: Since the issuance of AD 96-06-05 we have modified 1 aircraft (both sides) and 1 aircraft (one side), the modifications have been accomplished based on results/findings of the repetitive inspections as required by the AD. Based on the afore mentioned that would make a total of three findings since the effective date of AD 96-06-05. We feel that the current AD provides an acceptable level of safety and does not need to be revised. Should the above comments not be considered: We respectfully request that the modification/terminating action of 18 months after the effective date of the proposed AD be extended to 36 months in order to prevent any conflicts with heavy maintenance scheduling per our approved maintenance program and to prevent any delays that may arise from the manufacturer in providing the necessary parts and/or kits required to modify the aircraft. We respectfully request that repetitive inspection interval of 1,600 flight hours of the proposed AD be extended to 2,400 flight hours in order to match intervals with heavy maintenance scheduling as per our approved maintenance program. We concur in that no stop drilling be allowed if any findings are evident.