We suggest that the cost estimates shown in the AD are significantly underestimated. We do not understand the reasons the FAA takes into account inspection hours only.
The true cost of the compliance with the AD would include, inspection, spare cost, and rework cost, when required. Note that the rework could require as high as over 200 man-hours.
We estimate that in our case alone spares would cost around $ 1,000,000.00 US. Spare quantity required to comply with the AD could be collected via industry channels and reflected in the future AD. The FAA could possible work out three scenarios to show the realistic cost impact on airlines, as follows:
1) Inspection only.
2) Inspection and replacement, including spare cost.
3) Inspection, replacement (including spare cost), and rework cost.
We realize that the cost figures are approximate, but they would be much more realistic.
Thank you.
Air Canada
This is comment on Proposed Rule
Airworthiness Directives: The Boeing Company Airplanes
View Comment
Related Comments
View AllPublic Submission Posted: 08/14/2012 ID: FAA-2012-0805-0002
Sep 24,2012 11:59 PM ET
Public Submission Posted: 09/04/2012 ID: FAA-2012-0805-0004
Sep 24,2012 11:59 PM ET
Public Submission Posted: 09/17/2012 ID: FAA-2012-0805-0005
Sep 24,2012 11:59 PM ET
Public Submission Posted: 09/25/2012 ID: FAA-2012-0805-0006
Sep 24,2012 11:59 PM ET
Public Submission Posted: 09/25/2012 ID: FAA-2012-0805-0007
Sep 24,2012 11:59 PM ET