DeCrane Aerospace/PATS Aircraft, LLC

Please accept this letter as the PATS Aircraft, LLC (herein PATS), comments to the subject NPRM. PATS is in agreement to the presentation of the NPRM, however PATS would like to provide recommendations to clarify a few areas within. PATS has received numerous questions from operators concerned about their aircraft which have already been converted to Configuration 3 and have the SFAR 88 Alternative Methods of Compliance (AMOC) Service Bulletins (SBs) ST00936-D-28-SB-001 and ST00936NY-D-28-SB-021 installed in compliance to AD2008-22-01. The operator’s interpretations are that this NPRM affects their aircraft when in fact if the operators have complied with AD 2008-22-01 using PATS AMOC SB’s this NPRM for proposed AD is not affective.