WestJet

Document ID: FAA-2012-0998-0003
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: September 27 2012, at 12:00 AM Eastern Daylight Time
Date Posted: September 27 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 24 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: November 8 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 8112b8f2
View Document:

This is comment on Proposed Rule

Airworthiness Directives: The Boeing Company Airplanes

View Comment

With respect to paragraph 2.(c).(2) the verbiage currently states: • For aircraft that have been previously modified, altered, or repaired in the areas addressed by these inspections, the operator may not be able to accomplish the inspections described in the revisions. In this situation, to comply with 14 CFR 91.403(c), the operator must request approval for an alternative method of compliance according to paragraph (j) of this AD. The use of the words “may not be able to” implies that if an inspection to a modified, altered or repaired area can be accomplished then an AMOC is not required. Other instances where an AMOC should not be required would be for: 1. Boeing repairs that have Damage Tolerant Assessments (DTA) and/or 2. STC's that have their own FAA approved AWL Structural Inspections WestJet requests that paragraph 2.(c).(2) be modified to include a statement that exempts items 1 and 2 above from requiring an AMOC.