Southwest Airlines

Southwest Airlines has two comments to make on NPRM 2010-0856: 1. Boeing issued Alert Service Bulletin 737-22A1224, dated May 18, 2012, that requires installation of FCC Software 2274-COL-AC1-07. Our latest Boeing 737-800 deliveries have FCC Software 2274-COL-AC1-07 installed per PRR 38275-175S. Southwest Airlines has begun to install this version of the FCC Software into all of our aircraft, per Boeing Alert Service Bulletin 737-22A1224. Southwest Airlines requests that Boeing Alert Service Bulletin 737-22A1224 be added to the proposed AD to allow the operator the option to install FCC Software 2274-COL-AC1-07. Service Bulletin 737-22A1224 has already received an Alternative Method of Compliance (AMOC) Approval for AD 2005-07-20. Reference FAA Letter 130S-12-214, dated July 6, 2012. 2. Paragraph (h)(1) of the NPRM states that the software installed must be “fully interchangeable” with the software listed in table 2 of Boeing SB 737-22A1211. Section 2. C. 2. Note (b) of SB 737-22A1211 states: “Do not install previous versions of this software after installation of the new software part number.” This note is also present in SB 737-22A1224. This statement could cause a conflict with upgrading FCC Software beyond the requirements of Boeing Alert Service Bulletin 737-22A1211 as instructed by paragraph (h) of the NPRM. Southwest Airlines requests that the term “fully interchangeable” be removed from Paragraph (h)(1) and the following statement be added to (h)(1) and (h)(2): “subsequent software versions that have been approved by the Boeing Commercial Airplanes Organization Designation Authorization (ODA) after April 13, 2010.”