Airbus

Docket No. FAA-2012-0427; Directorate Identifier 2011-NM-202-AD We would like to request FAA to reconsider paragraph (h) of the NPRM taking into account the paragraphs (2) and (3) of the MCAI EASA AD 2011-0176. More specifically: (1): NPRM paragraph (h) refers to method for repair that is approved by EASA or its delegated agent. We consider that any Airbus Repair Approval Sheet (RAS) issued and approved under the authority of Design Organisation Approval No. EASA.21J.031 is acceptable. Thank you to reconsider paragraph (h) of this NPRM providing resolution on the AD wording interpretation of what constitutes approval “by EASA” or “under EASA DOA”. (2): The NPRM does not consider the repair as terminating action to the inspections. Thank you to reconsider paragraph (h) to take into account paragraph (3) of EASA AD 2011-0176 where the approved repair is considered terminating action unless specified otherwise.