Docket No. FAA-2011-1128; Directorate Identifier 2011-CE-031-AD
Dear T.N. Baktha,
Aerodyme Corporation was granted FAA-PMA for replacement spars 44211-RE9 and 44211-RE10 earlier this year and has delivered approximately 160 new replacement spars to date. Each spar has been delivered with an FAA-approved inspection procedure and intervals as set forth in Section 8 of the FAA-approved Instructions for Continued Airworthiness, Aerodyme Doc. No. 44211-RE9-RE10-ICA, uploaded with this comment for your convenient reference.
There are differences between the inspection procedure and intervals in the proposed rule as compared to the previously-approved ICA for the PMA replacement spars.
In the interest of clarity for mechanics and inspectors, I would suggest this point be addressed by appropriate revision of the proposed rule.
In order to simplify your consideration, Aerodyme Corporation is agreeable to accepting the procedure and intervals set forth in the proposed rule Section (i) (1), thus it may suffice for the proposed rule to state as follows, or equivalent:
"In the event Aerodyme PMA spar(s) 44211-RE9 and/or 44211-RE10 have been installed, the inspection procedures and intervals set forth in this section shall apply, and shall take precedence over the previously-approved Instructions for Continued Airworthiness, Aerodyme Doc. No. 44211-RE9-RE10-ICA dated 05 May 2011."
Sincerely,
James D. Richards III
Accountable Manager
Aerodyme Corporation
Aerodyme Corporation
This is comment on Proposed Rule
Airworthiness Directives: CPAC, Inc. Airplanes
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Aerodyme Corporation
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Aerodyme Corporation
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