Comair, Inc.

Please see the two attached files. These comments are submitted on behalf of Comair, Inc. Comair believes Paragraph (g) should also include part numbers 49263-1 and 49263-3. We have been in contact with Goodrich regarding these part numbers and their response supports what we surmised from their Component Maintenance Manual (CMM), these part numbers are a higher assembly part number consisting of a piston axle with a metering pin assembly installed. The CMM for Part Number 49000, section 32-11-05, Figure 3, pages 1070 – 1072, Items -1630 and -1630A have the following nomenclature, “Piston/Axle/Metering Pin Assy (Pre SB 32-45)”. There have been several instances where Comair has sent Goodrich Landing Gear Services a Piston/Axle part number 49203-3 for repair. While at Goodrich, a metering pin was installed and when it was returned the Authorized Release Certificate, Form One only contains part number 49263-1. The Form One does not list the part number for the Piston/Axle and Metering Pin, just the higher assembly part number. When received back into stock, the receiving process changes the part number from 49203-3 to 49263-1. Consequently, when it is installed on an airplane it shows the 49263-1 installed and as the NPRM is written, would not apply by part number. While performing research for this NPRM, another US Operator of CL-600-2C10 and CL-600-2D24 airplanes was contacted and they missed this part number, 49263-x, in their initial analysis for this NPRM. They have ten 49263-x currently installed. If part numbers 49203-3 and 49203-5 exhibit an unsafe condition, then part numbers 49263-1 and 49263-3 should be considered to have the same fretting concern, and the same unsafe condition.