US Airways

2007-NM-092-AD proposed to supersede AD 2005-20-03 by, amongst other new requirements, lowering the repeat inspection interval for certain structures from the previous 25,000 cycles to 6,000 cycles due to industry findings. The final rule would require new inspection within 6,000 cycles from previous inspection or 3,000 cycles from effective date of the new rule whichever is later. Since all US Airways airplanes were inspected within the threshold of AD 2005-20-03, about 70% of the airplanes will require inspection within 3,000 cycles of the new rule. The Boeing recommended regular structural inspection program for that area is every 24,000 hours. The routine US Airway inspection program, like many other operatores, is similar. Therefore, the new inspection would impact our operation by requiring additional maintenance that is not previously scheduled. AD 2005-20-03 requires both repetitive detailed and eddy current inspections of affected structures after the airplanes accumulated certain number of cycles. The inspection requires significant open up of the aircraft interior for access and is more suited for heavy maintenance environment. The industry findings that triggered the interval reduction should also prove that the inspection techniques are effective. Since, the inspection technique has proven to be effective and the new rule requires a significant reduction in the inspection interval, US Airways respectively request the FAA consider increasing the threshold grace period from 3,000 cycles to 4,500 cycles of the new rule. This would allow us and other operators to schedule more airplanes into appropriate maintenance tracks.