Airbus

Dear, Please find below AIRBUS comments: Docket No. FAA-2012-1039; Directorate Identifier 2011-NM-275-AD 1. Further to the ALS PART 2 Rev 01 approval (attached copy), please be informed that EASA prepares issuance of a new AD mandating the new ALS Revision and superseding previous AD 2010-0071R1. The new AD is expected to supersede also the EASA AD 2011-0231 since the new ALI tasks 531129-02-2 and 531129-02-3 has been introduced into the ALS (pages 31, 32 of pdf. file). The repetitive inspection introduced by the two ALI tasks replace the one time inspection (ISB 53-1245) mandated by EASA AD 2011-0231. ISB 53-1245 Rev 02 has been issued to add MSNs in the effectively to allow inspection as per anticipation of the ALI tasks. However, EASA AD 2011-0231 amendment to add more MSN in the applicability was not considered at that time, since the ALI tasks of ALS Part 2 Rev 01 approval would cover all. Thank you to review the above and the Variation approved by EASA to align the compliance time between AD requirement and ALI requirement for the transition period until the AD 2011-0231 is superseded. Based on the above, we request FAA to re consider the compliance time of the AD, to avoid inconsistency on the timescale for operators following already repetitive inspection as per ALI tasks approved by FAA AMOC ANM-116-12-338 for FAA AD 2011-14-06. Thank you. Best Regards, Konstantinos SIDERIS Single Aisle Aircraft Continued Airworthiness Engineer Product Integrity Division - EIAS AIRBUS Phone: +33 (0) 5 61 93 11 24 Fax: +33 (0) 5 61 93 44 51 Mailto: konstantinos.sideris@airbus.com