Elvio Marinelli

Dear Sirs, With regard of the reference NPRM I would like to submit two comments to your consideration. The paragraph (f) states that the inspections and corrective actions must be performed in accordance with the service information listed in Table 1. The service bulletins listed there are all dated on August 9, 2007. This date corresponds, for example, to the revision 01 of SB A340-27-4151. Due to the emergency nature of the EASA AD and the short compliance time mandated by it, several aircraft have been inspected as per original issue of the service bulletins. The changes introduced with revision 01 of SB are minor. Therefore, we believe that aircraft inspected in accordance with the original issue of the SB are in compliance with the AD. We think that the FAA should reflect this fact in the AD by means of a note. The paragraph (f) (1) (i), (ii), (iii), (iv) and (f) (2) states that all applicable corrective actions must be performed before further flight. We are not sure about what the term applicable defines in this case. Are the applicable corrective actions those described in the Airbus SB with its compliance time or are the corrective actions defined in the Airbus SB without considering the compliance time defined there? To be more precise, the Airbus SB and the associated vendor SB allow to leave installed on the A/C DDS and IPGB damaged to a certain extent, deferring its replacement, in line with this the EASA AD requires application of the corrective actions within the compliance time defined in the Airbus SB. That is why we believe that the text of the FAA AD should be changed to be in line with the EASA AD avoiding any misunderstanding. With best regards, Elvio Damian Marinelli