Steve R. Reed

Docket No. FAA-2008-1079; Directorate Identifier 2008-NM-116-AD FCU components undergo a functional check during unscheduled shop visits and it is so noted on the shop work order for that component. The CMM requirements have been revised to include an internal visual inspection of these units as part of the SFAR88 requirements. Because of this revision, there is some question for older units regarding their compliance to this proposed rule. Also, because of the quantity of components requiring their initial functional checks, the lack of available exchange or loaner units from Parker, and the shop turn time that is averaging about 14 days, many aircraft will become AOG at the end of the grace period (90 days after December 16, 2008). My suggestion would be to allow for airlines to take credit for units that have previously had the original functional check performed (grandfathered) and develop a bridging program that will not be such a huge economic impact to airlines with a large fleet. I believe that a following statement similar to the following, added to the amended AD with regards to the FCU & VFCU, would not compromise safety and would avoid a significant negative economic impact on carriers with large fleets of EMB-145 aircraft: “For units that have had a shop functional check without the internal visual inspection, prior to December 16, 2008, a grace period of 180 days after the December 16, 2006 is allowed. After the 180 day grace period, task 28-41-01-720- 001-A00 (28-41-04-720-001-A00 for the VFCU) must have been performed within prior to the 10,000FH threshold or within the 10,000FH repeat interval”