Air Wisconsin Airlines Corporation

1. Again, this is an AD that should be against a specific part as it applies to the part and not the aircraft. The affected parts in the NPRM including all references did not change nor did the actions. Only the paragraph in the AD listing the aircraft changed. The S/B, 601R-24-113A, does not list all the A/C that AD 2009-06-17 currently applies (all). The FAA has said before in AD 2008-01-04 that the part on the shelf proposes no safety concerns; true. Perhaps it would be more accurate to modify your statement and apply the AD to the part by saying something to the effect of: Applicability: ADG Part Number - 604-90800-1 (761339C), 604-90800-17 (761339D), or 604-90800-19 (761339E) ADGs having Serial Numbers - 0101 through 0132, 0134 through 0167, 0169 through 0358, 0360 through 0438, 0440 through 0456, 0458 through 0467, 0469, 0471 through 0590, 0592 through 0597, 0599 through 0745, 0747 through 1005, or 1400 through 1439 When installed on any Bombardier Model CL-600-2B19 (Regional Jet Series 100 & 440) airplanes; certificated in any category. 2. This proposed AD is frivolous as the perceived “unsafe condition” has already been mitigated through paragraphs (c), Applicability (all), paragraphs (f)(1) and (f)(2) of the existing AD which address every aircraft identified as Bombardier Model CL-600-2B19 (Regional Jet Series 100 & 440) airplanes; certificated in any category or ever to be certified (subsequent). We are requesting this NPRM be rescinded for the following reasons: a) The perceived unsafe condition has been mitigated through existing AD 2009-06-17. b) All referenced technical data is exactly the same as referenced in AD 2009-06-17 (paragraph (i). c) The aircraft S/B referred to in paragraphs (f)(1)(i), (f)(1)(ii), (f)(1)(ii)(B), (f)(3), (g)(1)(i), (g)(1)(ii), (g)(1)(ii)(B), (g)(2), and (h)(3)(i) do not indicate or reference the proposed aircraft change and therefore does not apply to these A/C. (Refer to FAA’s response to comments for “request to revise applicability” in AD 2009-06-17.) d) Paragraph (f)(2) of existing AD 2009-06-17 and paragraph “B.” of Canadian Airworthiness Directive CF-2008-09, prohibits the installation of ADGs identified in Table 1 of the AD to be “…installed on any airplane, unless the identification plate of the ADG is identified with the symbol ''24-2.''.”