All Nippon Airways (ANA)

Document ID: FAA-2012-0102-0005
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: April 05 2012, at 12:00 AM Eastern Daylight Time
Date Posted: April 9 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: February 27 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: April 12 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 80fea38e
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This is comment on Proposed Rule

Airworthiness Directives: Various Transport Category Airplanes

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All Nippon Airways (ANA) has reviewed NPRM 2012-NM-004-AD and would like to comment on the proposed AD. <Reference> /A/ AD 2011-04-09 1/ The proposed AD paragraph (k) states that within 24 months after the effective date of this AD, install a supplemental oxygen system. However design approval holders have not released service information at this time. Considering the lead time of the required parts and preparation for the modification, the compliance time should be determined after the service information is released. This AD affects all fleets and impact for operators is huge, so it will be necessary at least 36 months for appropriate maintenance planning after the service information is released by the design approval holders. 2/ The proposed AD paragraph (k) states that operators can select between two methods, with chemical oxygen generators or without chemical oxygen generators. At this time, ANA receives newly delivered airplanes with chemical oxygen generators and removes them at receiving it. It is due to the difference between type certification and what ref/A/ AD requires. After the effective date of this AD, please make it clear what configuration will be selected on production airplanes.