FedEx Express

09 September 2010 U.S. Department of Transportation Docket Operations M-30, West Building Ground Floor Room W12-140 1200 New Jersey Ave, SW Washington, DC 20590 Attention: Rules Docket No. FAA-2010-0801 Directorate Identifier 2010–NM–054–AD References: 1. Airbus SB A300-53-6246 rev 01 2. A300-600 ALI 53.16.04.01-1 & 53.16.22.01-1 Dear Sir or Madam, In response to Notice of Proposed Rulemaking, Directorate Identifier 2009–NM–204–AD, dated July 1, 2010, FedEx Express offers the following comments: 1. The proposed Airworthiness Directive (AD) will be effective for 65 A300-600 model airplanes operated by FedEx Express. 2. FedEx Express has determined that the modification threshold will fit within our planned scheduled maintenance checks. Therefore, there will be no impact to available lift 3. The SB A300-53-6146 Rev 1 paragraph E (Threshold table) recommends number of flight cycles (FC) for each model after which modification should be embodied. If the modification is embodied before the recommended threshold additional inspections are required per Airbus instructions. Paragraph E.2 of the service bulletin states: The NPRM paragraph (g) stipulates accomplishment before 42,500 FC and we believe following the Airbus recommendation will avoid extensive inspections similar to the ALI mandated tasks 53.16.04-01 and 53.16-22.0101. Hence, FedEx recommends a change to paragraph (g) of the NPRM to read as follows: ”Accomplish modification in accordance with the thresholds specified in service bulletin A300-53-6146 revision 01, paragraph E(2), Accomplishment Timescale” If you have any questions regarding these comments, please contact Mr. Gibby Thomas at (901) 224-4807 or via e mail at gthomas@fedex.com.