Great Lakes Airlines

Fuel Quantity AD Docket #2010-0546 This AD requires the operator, within 600 flight hours or 180 days, to determine real fuel quantity using the dripless stick measuring and comparing to fuel quantity master indicator and repeater. The operator is directed to use EMB MM revision 24 dated Mar 30, 2009. The current revision is 26 dated March 29, 2010. At revision 26 to the MRB dated January 5, 2010 Embraer introduced a task (28-25) to be accomplished every A check (400 or 500 hrs dependant upon the program) to compare fuel quantity indicated on dripless sticks to fuel quantity system using the same references as in the AD. In the revision March 29, 2010 the task card manual was revised to include task card 28-25. The AD requires all corrective actions on FQIS to be accomplished iaw EMB-120 MM revision 24. There is no terminating action for this AD, the air carrier would be required to have revision 24 available to the technicians when completing the repetitive AD action and to perform corrective action to any discrepancies discovered. Sounds like a set up for failure. The best example of a logical method of introducing a repetitive action to an AD is AD 2008-04-18. In this AD the FAA required operators to revise the limitations section of their manual to include the repetitive action. This would be a perfect opportunity to utilize that method of forcing compliance. If every operator was required to add the task 28-25 to its airworthiness limitations within 30 days, and the task accomplished at the next A check but no longer than 180 days it would accomplish the same as the current version of the AD and it would close the AD once the revision was accomplished. The FAA could ask Embraer to move task 28-25 from MRB section 3 to section 6 which is airworthiness limitations. I have attached EMB MRB Task 28-25 for your review.