Japan Airlines

Japan Airlines (JAL) would like to send following comments to new proposed rule. In paragraph (k) of proposed rule, terminating modification in accordance with Boeing Alert Service Bulletin 747-53A2499 Rev.1 (SB) is specified. However, following requirements are provided IN 01 and IN 02 of SB, - Skin waviness requirement for airplanes with RVSM operation. (IN 01 paragraph 1) - Typo-error correction for SSID inspection option. (IN01 paragraph 3) - Usage of new revision drawings for modification. (IN02 paragraph 3) Without these requirements, operators can't accomplish correct inspection and modification. Therefore, operators must request AMOCs for every inspection and modification. To reduce unnecessary burden of both operator and manufacture, JAL would like to request FAA mandates new rule after new revision of SB is issued.