Comair, Inc

These comments are submitted on behalf of Comair, Inc. I believe it is less confusing and more accurate to completely restate all the compliance requirements of AD 2010-22-02. The way it is written in this NPRM, a copy of AD 2010-22-02 must be on hand to fully cross reference between it and the NPRM. As an example, NPRM Paragraph (h), in part, states: Doing the removal of the hydraulic system No. 3 accumulator in paragraph (o) of this AD is an alternate method of compliance with the requirements of this paragraph. AD 2010-22-02 actually references paragraph (j) instead of (o). The content of paragraph (j) is not included in this NPRM, nor is paragraph (m). Additionally, paragraph (o) should not be considered an “alternate method of compliance” but is rather a superseding requirement. Assuming the content of paragraph (j) is included in the final rule, the proposed paragraph (h) of this NPRM can be reworded to read: (h) Within 250 flight cycles after November 4, 2010, deactivate the hydraulic system No. 3 accumulator, in accordance with Part A of the Accomplishment Instructions of Bombardier Alert Service Bulletin A601R-29-031, Revision A, dated March 26, 2009. Doing the removal of the hydraulic system No. 3 accumulator in paragraph (j) of this AD is an alternate method of compliance with the requirements of this paragraph. The actions in this paragraph apply to all accumulators in hydraulic system No. 3. Paragraph (o) of this AD is a superseding requirement to paragraph (j). Consideration should be provided for AMoC dated May 18, 2011, allowing the relocation of the No. 3 Accumulator using SB 601R-29-0 Rev B., either as a separate, optional paragraph or included in Paragraph (t)(1), AMoCs. Additionally, in general, other approved AMoCs for AD 2010-22-02 should be considered for inclusion into the final rule, assuming they are still relevant.