Embraer

1) FAA AD 2008-26-06 covers wheels above 15,500 FC. This AD replaced AD 2008-19-51, which covered wheels above 6,500 FC. The most critical wheel with cracks found so far was around 12,500 FC and the cracks found on it were initiated at around 7,500 FC. The multiple cracks covered a total of 5,5 inches length (more than 120 degrees of the wheel circunference). In addition many other inspected wheels presented cracks with less than 15,500 FC. Therefore there are still critical parts not covered by AD. 2) FAA AD 2008-26-06 does not demand a reduction in the life limit of the HPT-2 wheel. 3) FAA AD 2008-26-06 does not contain re-inspections intervals for critical wheels as part of the control program. Cracks found on wheel SN MM228369 propagated for about 5,000 FC. This indicates a necessity of re-inspection since the time interval from first inspection to the life limit of the part (30,000 FC) may be higher than 5,000 FC. 4) The comments presented herein took into account the information contained on draft memorandum presented by "Draft - Policy FAA (28-01-09)".