Japan Airlines

Dear Sirs JAL would like to propose the followings. 1. The NPRM states that AMM 28-22-00 and Boeing Task Card 4-28-007-05 are the approved method to comply with the AD. But both AMM 28-22-00 and Boeing Task Card 4-28-007-05 include two tasks. One is "Engine Fuel Suction Feed Test", and the other is "Engine Fuel Feed Lines/Couplings Vacuum Test". Two tasks are equivalent procedures and each one of them would satisfy the operational check requirement of this AD. Operators can make a selection from the two tasks. JAL requests the FAA to consider clarifying if the operator can choose one of the two tasks to comply with the AD. 2. The AMM 28-22-00 and Boeing Task Card 4-28-007-05 contain two tasks. To avoid misunderstanding of requirement, JAL requests the FAA to specify the exact AMM Task Number and Paragraph as examples for AD comliance. 3. Essentially, JAL believes this requirement should not be adressed as AD but CMR(Certification Maintenance Requirement) task. Regards, Takeo Asano Japan Airlines