Airbus

FAA-2011-1167 After review of your NPRM to mandate AIRBUS SB A320-25-1649, we would like to make the following comments: EASA AD applicability is listed all aircraft that have been certified with the capability to be fitted with Air Cruisers / Aerazur Part Number (P/N) D31865-109, P/N D31865-110, P/N D31865-209 or P/N D31865-210 Off-wing Escape Slides (OWS). An unsafe condition has been identified only with these OWS. It is to say that some aircraft that were delivered with AIRBUS modification 30088 and currently in service could be fitted with one of the 4 above OWS at time of the FAA AD effective date. As such AIRBUS request FAA to update the applicability to be in line with the EASA AD. It explains why A318 models have been added in the applicability despite none of these A318 models were delivered with an affected OWS. We would like to remind FAA that AIRBUS SB applicability is based on aircraft configuration at time of production delivery. As such, paragraph (h) becomes applicable to all A320/A319/A318 aircraft models as listed. Paragraph (h) is more restrictive than EASA AD equivalent paragraphs (3) and (4). AIRBUS configuration management has been updated to not authorizing reversion to previous OWS standard, whereas exchange of OWS with same PNs is still authorized. This possibility has been offered to prevent any unscheduled OWS replacement (inadvertent deployment) during the AD compliance time to limit AOG situation in case of lack of spare parts. Based on the above, thank you to reconsider the AD accordingly.