Nicolas Jaccard

First comments: General / Affectivity: Last year in May the FAA send us the text below: Yes you are correct. Since you have Configuration 3 installed on your Aircraft, your AFS is in compliance with SFAR88 requirements. No further action is required for your Aircraft. What as changed on our A/C from Last year? Nothing and we still have the same configuration and the same STC configuration -3 installed. We where compliance with SFAR 88 last year and not this year? Second comments: Compliance: The impact of the proposed compliance time would be disproportionate to the risk. The capacity is insufficient within the available facilities to accomplish the retrofit in 45 days after the effectively of the AD. Much risk analyse has been done for these other AD’s with similar risk that support 3 to 5 year of compliance time. ( AD 2005-23-16, AD 2007-02-14, AD2008-06-03). ( same as Boeing comments) A compliance date if effective to our A/C must be established by a risk analyse would allow for the modification during a scheduled maintenance visit without compromise safety. And you have also commented that: Is not a ``significant regulatory action'' under Executive Order 12866, and Is not a ``significant rule'' under the DOT Regulatory Policies and Procedures (44 FR 11034, February 26, 1979). Third comments: Cost: You estimate that this proposed AD would cost $31,250 per product. And the quotation from the manufacturer is around 600’000 USD and only for kit and labor. You also need to add that the A/C will be out of services fro 4 weeks minimum and need to be ferry to the modification centre. The real total cost per Airplane will exceed 1.2M USD.