Theresa Solis

Retrofit of a supplemental oxygen system that meets the requirements of the various FARs called out in paragraph (k) of the NPRM will require significant time and resources to gain the required FAA approvals for a major design change. Multiple design iterations will probably be needed and could slow the approval process. SWA has twelve different lavatory systems and each would require testing and approval. Should SWA decide to utilize a COG type system, AMOCs will be required for each design which would extend the timeline. Since there is no approved data for alternate systems, and design approval holders are not required to come up with solutions, each operator is responsible for design and development of the systems needed for their aircraft. The 24 month time constraint puts an undue financial burden on the operator to produce a system, receive the required approvals, have the necessary parts manufactured, and install these new systems into our fleet within the 24 month time constraint. Taking into consideration that there are no approved systems available at this time, the likelihood of approvals and manufacturing taking 12 to 24 months or more, and the size of our fleet, SWA requests 60 months to accomplish the AD.