Air Canada

Document ID: FAA-2012-0805-0002
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: August 13 2012, at 12:00 AM Eastern Daylight Time
Date Posted: August 14 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: August 8 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: September 24 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 810d33ff
View Document:  View as format xml

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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.

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