ALL Nippon Airways

Description: ANA has 5 B747-400 airplanes(RTXXX) which the maximum take-off weight is 899600lbs, and 11 B747-400D(Domestic) airplanes(RUXXX) which the maximum take-off weight is 599600lbs. If the AD changes the repetitive flap carriage overhaul interval and the general visual inspection interval from the flight hour basis to the flight cycles basis, and add the repetitive flap carriage general visual inspection(GVI) interval(400 cycles), ANA's B747-400D airplanes which normally operate on Japan domestic routes (Daily Usage : 5-6 flight cycles) are greatly affected by this AD. So, JAL’s B747-400D airplanes must be greatly affected too. The repetitive flap carriage overhaul must be done every 2 or 3C check(3-4.5 years) and the GVI must be done every 2 months, thus requiring a lot of man power and costs. ANA has never found sever damage on the carriage spindle and aft link on wing and in their shop on B747 and B747-400 airplanes. ANA believe that the loads on the spindles happen during takeoff and landing for B747-400D airplanes must be smaller than it for B747-400 airplanes because the takeoff and landing weight of B747-400D airplane is smaller than B747-400 airplanes. ANA strongly requested Boeing to develop the different repetitive flap carriage overhaul and the GVI intervals for B747-400D airplanes by analyzing our B747- 400D airplanes' flight data which Boeing needed We also requested Boeing new interval criteria, overhaul interval : 15000cycles, GVI interval : 1 year or C check. ANA and JAL strongly request FAA to add new flap carriage overhaul and GVI intervals for B747-400D airplanes in accordance with the results of Boeing analysis to new AD or at least as the AMOC.