Embraer

Dear Sir: Please find below Embraer comments to NPRM Docket No. FAA-2008-0271. Embraer recommends setting the applicability to those airplanes that have incorporated original revision of Service Bulletin 145-00-0032, as well as revisions 1, 2 and 3. Operators that have incorporated revision 4 or subsequent revisions of SB145-00-0032 should not be affected by this AD since information regarding updated Airworthiness Limitations Requirements is included on the Service Bulletin. Regarding Note 2, under paragraph (f)(1), Embraer recommends changing the wording to not include the term “identical to that in TR 10-5”, as this would mandate the TR 10-5 for aircrafts that have applied SB145-00-0032, even after the MRB have been re-revised, and would require operators to request AMOCs for every next revision, or even worse prevent operator from implementing more restrictive time intervals that might be updated on future revisions. Instead we recommend accepting MRB-145/1150 Revision 11, which is already published, or subsequent MRB revisions as an alternative method of compliance. MRB-145/1150 Revison 11 already includes information from TR 10-5. Embraer recommends including information regarding maintenance plan intervals bridging, available at paragraph A2.3.2.1 of Appendix 2 of MRB-145/1150, as an acceptable method to bridge these new intervals into operators' maintenance plan. Sincerely, _________________________________ Daniel Pascoal Gonçalves Continued Airworthiness Engineer Certification Office Embraer - São José dos Campos Phone: +55-12-3927-1371 daniel.pascoal@embraer.com.br