Attached

UPS Aircraft Engineering would like to submit the following comments in response to the referenced NPRM, which is a proposal for a new Airworthiness Directive (AD) applicable to Airbus Model A300F4-622R airplanes having specified IPECO crew seats P/N 3A218-000X-01-1. Paragraph 2.(f)(1) requires 30 day repeat detailed visual inspections of the two springs of the pilot seat and co-pilot seat locking device, in accordance with Airbus Mandatory Service Bulletin A300-25A6210. UPS is currently accomplishing this inspection and supports this proposal as the means to ensure continued safe operation of the affected units until such time that the modification of the seats in accordance with IPECO SB 218-25-01 issue 2 can be accomplished. Paragraph 2.(f)(4) requires the operator to modify IPECO crew seats P/N 3A218-000X-01-1 to P/N 3A218-000X-01-2 within 6 months after the effective date of the proposed AD. Modification of the seats can be accomplished in accordance with IPECO SB 218-25-01 issue 2. UPS agrees with the modification requirement, but is concerned with the proposed timeline of paragraph 2.(f)(4), given the number of aircraft that are affected (approximately 132 per the referenced NPRM). The manufacturer of the seats and modification kits, IPECO, has quoted UPS a lead time of 120 days to supply the modification kits. Unless production estimates change upon the issuance of the AD, it is apparent that the availability of modification kits will not support the 6 month modification requirement. UPS proposes extending the incorporation timeline requirements to 30 months from AD effective date. This will enable adequate industry support of the modification, and at the same time, enable operators to utilize regularly scheduled maintenance opportunities. Continued inspections as required in paragraph 2.(f)(1) would ensure continued airworthiness of the affected aircraft. Paragraph 2.(f)(3) states that as of the effective date of the proposed AD, no unmodified seat can be installed on any airplane unless the seat has been inspected and modified in accordance with Service Bulletin (SB) A300-25A6210 (applicable to UPS aircraft). However, SB A300-25A6210 is the inspection SB and replaces springs that are found missing or damaged. There is no modification performed per this SB. The modification SB is A300-25-6214. So, the word modified should be removed from this paragraph. In summary, UPS supports the inspection intervals proposed in the referenced NPRM, but suggests a longer modification timeline, and seeks correction of paragraph 2.(f)(3) language to better reflect the work scope of SB A300-25A6210. UPS appreciates your consideration of our comments. If you have any questions, please contact Ashley Dennis at (502) 329-6020.