ExpressJet

March 7, 2008 Ref: Docket No. FAA-2008-0182 Directorate Identifier 2007-NM-262-AD U.S. Department of Transportation Docket Operations M-30, West Building Ground Floor, Room W12-140 1200 New Jersey Ave. SE. Washington, DC 20590 The NPRM, Paragraph 2.(f).2 ?Actions and Compliance? states that ?Before December 16, 2008, revise the ALS of the ICA to incorporate Section A2.5.2, Fuel System Limitations Items, of Appendix 2 of the MRB.? This should read ?Before December 16, 2008, revise the ALS of the ICA to incorporate Section A2.5, Fuel System Limitations Items, of Appendix 2 of the MRB.? Alternatively, it would be acceptable for this paragraph to state ?Before December 16, 2008, revise the ALS of the ICA to incorporate Section A2.5.1 and A2.5.2, Fuel System Limitations Items, of Appendix 2 of the MRB.? Paragraph A2.5.2 establishes new Tasks and Limitations previously not included in the Airworthiness Limitation Sections of the OEM's instructions for Continued Airworthiness. By including this paragraph into an operators program, we, as well as other U.S. operators, will have exceeded the Flight hours or Flight Cycles that these new task intervals will impose. Embraer made provisions to implement these new tasks and intervals and has included these provisions into Paragraph A2.5.1. Without allowing operators to use the provisions of paragraph A 2.5.1 they will be non compliant to these new requirements immediately on the inclusion of Paragraph A2.5.2 into his Maintenance program. Since it is unlikely any operator would have sufficient spares to handle the demand, this would require removing aircraft from service that have exceed the intervals established by A2.5.2. This will cause a major economic impact to operators. Furthermore, we have been advised by the manufacture of the components included in these new requirements, that they did not have the capabilities to timely accomplish the number of task that would be required to mitigate this economic impact. Embraer has also advised that they have no record of faults related to the failure mode these tasks are designed to check. Therefore, safety should not be impaired by allowing a systematic implementation of these tasks. By making one of the two suggested changes, the AD will match the full intent of the Fuel System Limitations published by Embraer which includes the implementation plan under A2.5.1. In other words, the AD should be clear to also include not only the program items but the implementation as described in Section A2.5.1 of the MRB. Regards, Steve Reed Sr. Mgr., Methods & Standards EMB-145 ISC Chairman 832-353-2624 (Office) 281-380-9238 (Mobile) steve.reed@expressjet.com