Aeropostal

Aeropostal would like to comment the proposed rule, to request clarification of certain topics to be considered in the final release of AD: 1) Please clarify the word "serviceable" in para. (g)(2); in the common aircraft phraseology, the word serviceable can be also associated to "removed in a serviceable condition" from another aircraft. In this case, although the manufacturing tolerances of fastener holes are so that the installation of a removed panel from one aircraft to install it in another aircraft is not always possible (considering oversize fasteners, etc), the terminology used in the proposed AD seems to permit the installation of a "removed in a serviceable condition" panel from one aircraft to be installed in an aircraft affected by a crack finding. 2) As a corrective action, the proposed rule would have to consider the replacement of the horizontal stabilizer assembly with a uncracked one. This could allow the operators to guarantee the continuous service of an in-service airplane, reducing the down-time during the repair of the affected horizontal stabilizer assy. 3) As you state, the FAA is not considering the possibility of a temporary service action designed by the TC holder. Since the inspections not always falls during a C check, they are phased out and performed during in-service short maintenance checks. The finding of a crack in an in-service revenue aircraft that is not allowed to be temporary repaired in a reasonable time could lead to a non scheduled downtime of affected aircraft. The replacement of the panel is a heavy work, including the procurement of expensive parts, that leads to extensive downtime, which could affect operations of low size operators that rely on few aircrafts on the fleet, finally affecting the quality of service provided to passengers. Thank you Sante Brucoli Aeropostal Engineering