Kevin LaRue

NPRM Requirement: Paragraph (h)(2) of the NPRM states, “Operator must obtain an approved damage tolerance evaluation for any repair installed to comply with Section 121.1109(c)(2) or 129.109(c)(2) of the Code of Federal Regulations (14 CFR 121.1109(c)(2) or 129.109(c)(2)).” SWA Questions/Comments: This is a direct contradiction of the following statement given in the Front Matter of the NPRM under the heading “Differences Between the Supplemental NPRM and the Service Information”. This section contains the following language: “Table 10 if paragraph 1.E., “Compliance,” of Boeing Special Attention Service Bulletin 737-53-1287, Revision 1, dated November 15, 2010; and Part 8 of the Accomplishment Instructions of Boeing Special Attention Service Bulletin 737-53-1287, Revision 1, dated November 15, 2010; specify post-repair/modification inspections at the number 3 VHF antenna location, which may be used in support of compliance section 121.1109(c)(2) or 129.109(c)(2) of the Federal Regulations (14 CFR 121.1109(c)(2) or 129.109(c)(2)), but this supplemental NPRM does not propose to require those post-repair/modification inspections.” SWA would like to highlight the disparity between this statement and paragraph (h)(2) of the NPRM. SWA Proposed Solutions: Delete the requirement given in paragraph (h)(2) of the NPRM. The requirement to have a damage tolerance assessment is already mandated by 14 CFR 121.1109. It is not necessary for this to be also mandated by this proposed AD.