All Nippon Airways Co., Ltd.

Docket No. FAA-2012-1221; Directorate Identifier 2012-NM-151-AD Boeing Special Attention Service Bulletin 777-54-0028, dated May 25, 2012, specifies to contact Boeing for repair and do the repair within 25 flight cycles or 10 days, whichever occurs first at Condition 2B and contact Boeing for repair and do the repair before further flight at Condition 2C. NPRM Docket No. FAA-2012-1221 paragraph (h) (2) describes that repair in accordance with a method approved by the Manager, Seattle Aircraft Certification Office (ACO), FAA where Boeing Special Attention Service Bulletin 777-54-0028, dated May 25, 2012, specifies to contact Boeing for repair. In the case of Condition 2B or Condition 2C, we would like to get the approved repair methods and do the repair as soon as possible to minimize the down time of the aircraft. It takes only 4 or 5 days for 25 flight cycles for our airplane. We have only 4 or 5 days to get the approval for the repair to return our airplane into service in the shortest after repair in the case of Condition 2B. In the case of Condition 2C, we need to get the approval more quickly. Otherwise our airplane cannot fly for a long time. However it takes time to get the approval for the repair methods from ACO FAA. So, we would like FAA to delegate the approval for a repair method to the Boeing Commercial Airplanes Organization Designation Authorization (ODA).