UPS Airlines

UPS Airlines comments on NPRM: 2011-NM-179-AD (Docket # FAA-2012-0264): Dear Sir / Madam, In response to your proposal to adopt a new airworthiness directive (AD) for all A300-600 series aircraft: When this AD becomes effective, UPS prefers to accomplish the AD at our heavy maintenance facility during “C” check visits. The line maintenance environment is not conducive for this work due to the required aircraft ground time, labor, and other resources which are available in our major maintenance facility. Our current maintenance program is based on a 30 months ”C” check interval. In order to accommodate this modification at “C” check in our major maintenance facility, we will need an additional 10 months to allow for planning and preparations such as: development of engineering orders, prototyping, obtaining necessary management and finance approvals, parts acquisition, parts lead time, etc. In summary, UPS Airlines is requesting FAA to extent the compliance period of the proposed AD (NPRM # 2011-NM-179-AD) from the stated 30 months to 40 months.