United Airlines

Docket No. FAA-2011-1417 FAA Identifier 2011-NM-159-AD This NPRM requires a general visual inspection of the housing assembly of the packboard release mechanism to determine if its surface treatment has been sealed; and if unsealed, before further flight, replace the housing assembly with a new or serviceable housing assembly, in accordance with the accomplishment instructions of Boeing Special Attention Service Bulletin 777-25-0507. United Airlines has reviewed the subject NPRM and find that the forthcoming AD is applicable to 74 aircraft. We offer the following comments for potential revision of this proposed ruling: -We do not object to the 42-months compliance time given. -We request the AD to be worded such that it allows operators to simply inspect for the accomplishment of Air Cruisers Service Bulletin 777 107-25-30. This can be done by verifying the stencil of the "Inspected and/or Mod per S.B. 777 107-25-30" on the girt or upper lacing cover. If this service bulletin is not done on a unit, the operator must accomplish it or replace the slide with a post-SB unit before further flight. -We request the AD to permit operators demonstrate compliance by means of a technical records review for the accomplishment of Air Cruisers SB 777 107-25-30. -We also request the AD to allow credit for accomplishment of previous Service Bulletin revisions. Please note that AirCruisers SB 777 107-25-30 is now in revision 1 as of 11/11/2011. The original issue of this service bulletin has been accomplished on some of our units. United Airlines believes that a revision per the comments given will enhance the specific requirements without affecting the mandate’s intent. Thank you for giving us the opportunity to comment on this NPRM.