Richard Rupslauskas

Reference Docket No. FAA-2009-1229 Bombardier Model CL-600-2B19 Nose landing gear and nose landing gear door selector valves 1) As an air carrier with an approved record keeping system, it is unnecessary to inspect the aircraft to determine if an affect valve is installed. Records research is sufficient to locate valves requiring inspection. 2) The Tactair SB referred to in Bombardier SB 601R-32-104 provides an instruction to ink stamp the SB number on the valve. This action does not provide an added level of safety. This would only lead to confusion and a meaningless issue of non compliance should the marking ever become eradicated. As an air carrier with an approved record keeping system, it is unnecessary to mark the valve. 3) This problem with the valves was first recognized by Bombardier SB 601R-32-090. SB 601R-32-104 was issued superseding 601R-32-090 to expand the effectivity of the campaign. The Airworthiness Directive should allow for taking compliance on those valves through the use of SB 601R-32-090. 4) This problem first came to our attention in 2003 through SB 601R-32-090. It affected 645 units. SB 601R-32-104 issued in March 2009 expanded the effectivity to include 2126 units. We have been working this issue and have a substantial number of valves complied with, but since this issue has been around for almost 7 years without any regulatory influence, the short compliance time of 1600 hrs / 18 months cannot be justified. A longer compliance window should be given considering the number of units affected and an insufficient amount of spares available to ensure compliance within the time provided by a directive.