FEDEX

The following comments/recommendations related to NPRM 2009-NM-074-AD are submitted for your consideration: FedEx concurs with the AD requirements and should be able to comply within the compliance time. However, estimated costs of the proposed AD will need correction. Boeing SB MD11-28A140, page 10, section B. Concurrent Requirements states that SB MD11-28-102 must be done before or at the same time as SB MD11-28A140. SB MD11-28-102 constitutes terminating action for AD 99-25-14 and it takes 28.8 hrs for group 1 (12 airplanes) and 40.4 hours for group 2 (1 airplane). Considering all US – registered airplanes are in group 1 (9EA). This will cost $20,736 in labor and due to FOC parts, zero dollars for parts. SB MD11-28A140, page 11, section G. Manpower states that it takes 18.5 hrs for group 1 (12 airplanes) and 24.5 hours for group 2 (1 airplane). Considering all US – registered airplanes are in group 1 (9EA). This will cost $13,320 for labor and $11,232 for parts. The proposed AD will cost approximately $34,056 in labor and $11,232 in parts with a total cost of $45,288. Therefore, estimated cost for the proposed AD should be: Rework (required by AD 99-25-14) $20,736 and Modification (new proposed action) $24,552 resulting with a total fleet cost (US – registered airplanes) $45,288. Based on SBs data and figures provided above, FedEx kindly request the FAA to revise estimated costs of the proposed AD.