TCAS Change 7.1: ACSS Change 7.1 TCAS computers incorporate the changes required by the proposed AD along with the Change 7.1 software requirements. To minimize TCAS software revisions, UPS is currently accomplishing STC’s in preparation of upgrading TCAS computers directly to Change 7.1. This will prevent one software change to the proposed AD configuration and then another software change to accommodate EASA. EASA NPA-2010-03 proposes that TCAS software Change 7.1 must be installed retrofit by December 1, 2015 for aircraft operating in European airspace. Since UPS would not have all aircraft modified to TCAS Change 7.1 prior to the effective date of the AD, UPS will be in an AD “affected” status for some aircraft. At this point, the only way to show compliance to the proposed AD is to receive an AMOC for the TCAS Change 7.1 computers. UPS proposes that TCAS software Change 7.1 computers be approved in the AD as a Means of Compliance for the proposed AD. These ACSS TCAS computer part numbers are: P/N 7517900-10020 (TCAS 2000) and P/N 9003500-10905 (TCAS 3000). UPS feels that if the AD addresses a known configuration (potentially by several operators), this would prevent many operators from having to submit for an AMOC’s when they upgrade to TCAS Change 7.1.
Compliance Time: Regardless of UPS updating to TCAS Change 7.1, UPS request that the original timeline proposed (48 months) be re-implemented. Whether updating to TCAS Change 7.1 or to the proposed AD configuration, any operator will have to update all fleet STC’s to authorize the newly identified part number. The time required for revisions to STC’s and affected manuals should be considered in the timeline for implementation. UPS estimates a minimum of 48 months would be required to accomplish multiple STC’s (provided ACO could accommodate the schedule), incorporate the Instructions for Continued Airworthiness (ICA) in manuals and maintenance programs, and incorporate changes in C-Check schedule.
United Parcel Service
This is comment on Proposed Rule
Airworthiness Directives: Aviation Communication and Surveillance Systems Traffic Alert and Collision Avoidance System Units
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