Airbus SAS

Document ID: FAA-2009-1212-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 30 2010, at 12:00 AM Eastern Daylight Time
Date Posted: August 31 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: August 4 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: August 30 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80b3e744
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Airbus would like to post the following comments wrt FAA docket ref 2009-1212-005 and would be appreciative of due consideration: The proposed amendment at paragraph 2(f) [Revise the Airworthiness Limitations Section of the Instructions for Continued Airworthiness] and 2(g) [New Requirements of this AD, Actions and Compliance] contains the wording Quote: Unless already done, within 90 days of the effective date of this AD: Revise the ALS of the Instructions for Continued Airworthiness by incorporating Airbus A330 ALS Part 3-CMR..... Unquote It is felt that the above particular wording could, for certain Operators/Users, be misleading and subsequently lead to problems of demonstrating compliance to their local AA. In accordance with Title 14 CFR 25.1529 and CFR25 Appendix H, the responsibility to produce and update the ICA, such as “to incorporate the ALS”, lies with the aircraft Type Certificate Holder (TCH) [in this case Airbus]. To comply with Part 21.50/EASA IR 21A.61, these ICA must be made available by the TCH to each known owner or Operator of the aircraft. The responsibilities of the Operator are to incorporate the latest applicable contents of revisions of the ALS (or any other part of the ICA, as published by the TCH), into his Approved Maintenance Programme (AMP). This is to show compliance with 14 CFR 121.367 and 369 (or EASA Part MA302). The proposed wording of §(g) could mislead the Operator/User or his AA into believing that he is obliged to carry out a parallel action with respect to his received ICA (eg his AMM etc) in addition to updating his AMP. This may be seen as in conflict with the Operators’ requirements defined by Title 14 CFR 121.367 & 369, which governs emplacement and content of a Maintenance Programme.

Related Comments

   
Total: 2
Airbus SAS
Public Submission    Posted: 08/25/2010     ID: FAA-2009-1212-0007

Aug 30,2010 11:59 PM ET
Airbus SAS
Public Submission    Posted: 08/31/2010     ID: FAA-2009-1212-0008

Aug 30,2010 11:59 PM ET