All Nippon Airways (ANA)

ANA would like to comment on paragraph (j) and (k) of the NPRM, which instruct repair methods for “Outer Chord Crack or Cracked Frame Attachment Angles (or Clips)” and “Upper Main Sill Web Crack”, respectively. On the other hand, subject area is also inspected by AD 2010-01-01 on certain airplanes. As paragraph (o) of the NPRM states that AD 2010-01-01 is acceptable for compliance with the detailed inspection requirements of paragraph (g), (h), (l) and (m) of this NPRM, ANA believes repair method per paragraph (j) and (k) of the NPRM should also be an AMOC to AD 2010-01-01. Otherwise operators should obtain AMOC against AD 2010-01-01 when they repair subject area per paragraph (j) or (k) of this NPRM.