Lyle Schumacher

Document ID: FAA-2010-0436-0006
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: June 04 2010, at 12:00 AM Eastern Daylight Time
Date Posted: June 4 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: May 10 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: June 24 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80afb7b4
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This is comment on Rule

Airworthiness Directives: Bombardier, Inc. Model CL 600 2B19 (Regional Jet Series 100 and 440) Airplanes

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Regarding: Docket No, FAA 2010-0436 Directorate Identifier 2009-NM-230- AD Notice of proposed rule making. In reference to paragraph “Cost of compliance” We disagree with the estimate of 21 work hours as stated in the NPRM and the cost of $1,785 per product to comply with the basic requirement of this A.D. To be in full compliance with this A.D. the costs are as follows. Paragraph “Actions” (g) (3) DCU modification actual cost is $600.00 per unit with two DCU units at a minimum are installed total cost $1,200.00. (g) (4) installation of low heat detection system IAW Bombardier Service Bulletin 601R-30-031, materials cost for the installation kit is $3,300.00. Labor to install Bombardier Service Bulletin is 300 man-hours at an average labor rate of $85 dollars equals $25,500.00. The actual cost is $30,000.00 per product affected not $1,785.00 as stated in the NPRM. Regards Lyle Schumacher Lead Aircraft Technician Limited Brands 4387 International gateway Columbus, Ohio 43219 (614) 415-1849 Phone (614) 239-7041 Fax