Japan Airlines

Document ID: FAA-2009-0607-0011
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 26 2009, at 02:28 PM Eastern Daylight Time
Date Posted: August 26 2009, at 12:00 AM Eastern Standard Time
Comment Start Date: July 13 2009, at 12:00 AM Eastern Standard Time
Comment Due Date: August 27 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 80a129b5
View Document:

This is comment on Rule

Airworthiness Directives: Boeing Model 747 100B SUD, 747 200B, 747 300, 747 400, and 747 400D Series Airplanes

View Comment

JAL would like to comment for Docket No. FAA-2009-0607; Directorate Identifier 2009-NM-024-AD References: /A/ SB 747-53A2507, dated April 21, 2005 /B/ SB 747-53A2559, dated January 8, 2009 /C/ AD 2007-23-18 Description: 1. In paragraph (m), proposed AD requires modification for all affected airplanes within compliance time. However, JAL would like to continue the repetitive inspection per Ref/C/ AD for some affected aircrafts without the modification per paragraph (m) of proposed AD because of the following reasons: - Based on kit costs ($346000 per airplane), manhours (approx. 4000) and no warranty remedies, projected JAL Fleet cost will become very heavy burden. - By taking JAL's fleet plan (especially for retirement of 747-400D airplanes) into account, JAL would like to continue the repetitive inspection without the modification for some affected airplanes until retirement. Therefore, JAL would like to request to allow the current repetitive inspection per ref/A/ as an option to ref/B/ modification so that operators can continue the repetitive inspection per Ref/C/ AD as an option. 2. There are many typo erros in Ref /B/ SB about airplane effectivity (especially BCF airplanes are not reflected properly), general note, accomplishment instruction, etc. They should be revised piror to issuance of AD. Best Regards, Satoshi Ishibe Airframe Section, Engineering Dept. Japan Airlines International E-Mail: satoshi.ishibe@jal.com