Yves Cousineau

While I applaud the intent to harmonize with CS-E (former JAR-E) here are some comments and potential consequences: a. Proposed 33.17(e) of this NPRM 08-01 could require an ELOS (or exemption) to any non-fluid carrying control component that is not fire resistant but that has been shown by test or analysis not to cause an hazardous conditions when damaged by fire (such as graceful and sane engine shutdown). [N.B. Engine Control System used to be defined in the original CS E-15(e)] b. It is also noted that the shut-off means in 33.17(c) would not apply to the engine shut-down or fuel shut-off means envisioned by 33.75(g)(2) as adopted by Amdt 33-24 (and corresponding sections 23/25/27 and 29.1189). c. Further, revisions to the current AC 33.17-1 would be required. The example in section 2.(d)(i) of AMC to CS-E 130 and other parts of this AMC should be declared acceptable by the FAA. d. This NPRM has other subtle differences from CS-E in the area of mounts (CS- E 130(h) is absent) and small piston engine oil sump. Thank for your consideration. Yves Cousineau ing.