Aviation Partners Boeing

Aviation Partners Boeing (APB) has reviewed the subject NPRM regarding wing upper skin panel cracking at fastener holes common to the inboard and outboard pitch load fittings on 767 airplanes. APB has identified in AP67.3-0321 Winglet Affected Area report that pylon structure and wing skins are affected by the installation of winglets. To support aircraft with the APB winglet STC ST01920SE installed, APB has confirmed through analysis (FAA approved analysis is available from the submitter upon request) that airplanes affected by this NPRM do not require additional or more frequent inspections than those described in Boeing Service Bulletin 767-57A0117, Revision 1, dated March 2, 2011 to comply with the requirements of this proposed rule. Further, the repairs described in Boeing Service Bulletin 767-57A0117, Revision 1, dated March 2, 2011 are fully applicable to airplanes with winglets installed per STC ST01920SE. Based on the above, APB requests the FAA revise the proposed rule to include aircraft that have APB Winglet STC ST01920SE installed to preclude the need for separate AMOC approvals.