FedEx Express

General - FedEx Express concurs with the intent of this NPRM with the noted exceptions. Economic Impact - FedEx operates 49 A310-200 series aircraft and 17 A310-300 series aircraft. The economic impact to FedEx would be that FedEx would have to schedule the inspection twice as often for the A310-200 series aircraft as the current AD 98-16-11 three, and half times more often for the A310-300 Series aircraft. The inspections would have to occur outside of scheduled heavy maintenance checks. The OEM does not provide any alternate inspection method that would extend the inspection interval to meet a heavy check threshold. The cost per inspection cycles has increased from $240 to $720 per aircraft for the A310-300 aircraft ($12,240 for 17 aircraft) and $240 to $480 per aircraft for the A310-200 aircraft ($23,520 for 49 aircraft). Total FedEx cost increase is $35,760. Operation Impact - The reduction of the repetitive inspection threshold affects FedEx by pushing the inspection significantly outside FedEx’s heavy maintenance check interval. The inspection would have to be accomplished either on a special visit, or at a B Check facility. Either location would have to have the boroscope inspection and repair capabilities since the inspection is not visual and the repair would be very extensive. If damage is found the time to repair the fitting would considerably extend the out of service time. Request for Change - Provide a paragraph to keep the current inspection method and interval if the aircraft has not reached the design service goal, provide a paragraph to terminate inspections if the pylon sideload fitting is replaced with improved manufacturing techniques, and provide AMOC repair approval authority to EASA or it is delegated agent. Summary - There will be an economic and operation impact to FedEx by reducing the inspection interval with no alternative to change inspection method to reach a heavy maintenance check threshold.