Aeropostal

Aeropostal has reviewed the NPRM, and finds applicable the following comments. 1) The text of proposed rule should clarify if requirements of CDCCL 20-13 of Boeing document MDC-92K9145 rev H are met when incorporating the changes required by the proposed rule (i.e. installation of fuses i.a.w. applicable SB). The document MDC-92K9145 rev H required by AD 2008-11-15 does not state any first or repetitive inspections for CDCCL 20-13. Aeropostal understands that with a one-time inspection, and revised standard practices, the CDCCL 20-13 requirements are met. Based on this, Aeropostal understands that during the incorporation of referenced SB, the requirements of CDCCL 20-13 required by AD 2008-11-15 are met. 2) Aeropostal noticed that last year SFAR 88 AD's are related to CDCCL (MDC-92K9145). Some required incorporation of systems related to the applicable CDCCL. But, for these new requirements, the FAA adopted a new AD, instead of revise the AD 2008-11-15. Aeropostal would like to know why these AD's (that are related to AD 2008-11-15) are not adopted as a revision of AD 2008-11-15. For example, the requiremet of fuses (to be installed per this proposed AD) are incorporated by rev J of MDC-92K9145. Should not be more appropiated the adoption of revision J of referenced document in AD 2008-11-15 instead of issue a new AD? Among other things, this would provide operators to control more appropiately their implementation documents (as Engineering Orders), rather than issue several documents with different unlerated references. Thank you.