ABX Air

COMMENTS TO DOCKET NO. FAA-2011-0382 FROM ABX AIR Paragraph (j)(12) of the proposed AD requires SB 767-341-0114 R1 accomplishment prior to or concurrently with SB 767-31-0267 for Model 767-200, -300, and -300F airplanes identified in SB 767-31-0114 R1. SB 767-31-0114 R1 requires installation of OPS Version 2 for the 603 airplanes listed in the SB’s effectivity. SB 767-31-0114 R1 also requires installation of OPC software for only 57 airplanes of those 603 airplanes listed. ABX Air operates airplanes that are included in SB 767-341-0114 R1’s effectivity, but are not in the 57 airplane subset. ABX Air airplanes do not have prior accomplishment of SB 767-341-0114 R1. Therefore, according to the proposed rule, ABX Air would be required to install OPS Version 2 concurrently with installing OPS Version 7 in accordance with SB 767-31-0267. Currently, the ABX Air fleet has OPS Version 5 installed. If ABX elects to install OPS Version 7, then compliance with paragraph (i) and (j) of the proposed AD must be met. Requiring the installation of OPS Version 2 onto airplanes that currently have OPS Version 5 installed and then immediately installing OPS Version 7 is a burdensome process that provides no safety benefit. ABX contends that previous or concurrent installation of OPS Version 2 is not a prerequisite of installing OPS Version 7 and does not need to be included as a prior or concurrent requirement. ABX recommends paragraph (j)(12) of the proposed AD be reworded to only require OPC software upgrade for the 57 airplanes (none are 767-200 series airplanes). For example: (12) For Model 767-300 and 767-300F airplanes as identified in the table in paragraph 3.D of SB 767-31-0114, Revision 1, dated June 8, 2000: Install EICAS OPC software, as applicable, in accordance with Boeing SB 767-31-0114, Revision 1, dated June 8, 2000.