James W. Bender

The first comment deals with the preamble section Clarification of AD Compliance Time and the corresponding Paragraph (g) of the AD. The preamble section begins with the following statement: “Due to the degree of urgency associated with the subject unsafe condition, this AD specifies a compliance time of within 7 days after the effective date of this AD to more closely coincide with the time the Canadian airworthiness directives must be accomplished.” The cold weather season (December to March inclusive in the northern hemisphere) as defined by AD 2008-01-04 is clearly outside the range of the effective date of this AD. I do not believe the “degree of urgency” is as great at the end of April as it was in the beginning of March when Transport Canada AD CF-2008-15 was issued. A short compliance time does not seem to be justifiable when the content of the subject is less likely to be used; i.e. cold weather operations. The second comment pertains to Paragraph (f), Note 2 and Paragraph (h). Paragraph (h) reads: “When information identical to that in a TR specified in paragraph (g) of this AD has been included in the general revisions of the applicable AFM, the general revisions may be inserted into the AFM, and the TR may be removed from that AFM.” Is a superseding TR considered a “general revision”? Example from Table 1, CL-600-2B19 TR RJ/149-1 was superseded by TR RJ/149-2, which was superseded by TR RJ 155-2 and TR RJ 155-2 has been superseded by TR RJ/155-3. So, is it acceptable to insert a superseding TR as long as the information is identical to that in the TR specified by the AD? A third comment is for Paragraph (g). Paragraph (g) reads, in part: “revise the applicable sections of the applicable AFM by inserting a copy of the applicable TR listed in Table 2 of this AD”. Again, this comment is limited to the CL-600-2B19. Table 2 – Temporary Revisions for the CL-600-2B19, requires inserting TR RJ155- 3 “to the-“ “Limitations and Abnormal Procedures section and Supplement 15 of the Canadair Regional Jet AFM, CSP A-012”. I am requesting this wording be changed to read: “Limitations and Abnormal Procedures section, and if applicable, to Supplement 15 of the Canadair Regional Jet AFM, CSP A-012”. Comair’s AFM do not contain Supplement 15. Comair did not purchase Option Code 0090 and does not conduct High Altitude Airport Operations. When Bombardier supplies Comair unique AFM revision TR RJ/155-3 it will not contain Supplement 15. As the second and third comments reflect, AFM-oriented ADs can be very difficult for operators of large fleets to comply with in a short timeframe and drives literally hundreds of man-hours of administrative activity to ensure the insertion of proper pages to meet the compliance deadline. When ADs requiring AFM revisions are required in the future, an effort should be made to write the AD to recognize that multiple variants of AFM Temporary Revisions exist.