JetBlue Airways

JetBlue Airways requests the FAA to consider a change to the compliance time for inspection and replacement of the MLG Side Stay Support Fitting bushing, as mandated in NPRM 2012-NM-016-AD paragraph (g) and (h), to match the compliance time in SB 190-57-0036 R02 paragraphs E(1),E(2) and E(3), based on the following: According to Embraer SB 190-57-0036 R02, paragraphs C(1) and C(3), The reason for replacement of the MLG Side Stay Support Fitting bushing with an improved bushing and retaining spacers is to ensure that the MLG Side Stay Support Fitting remains properly lubricated. The Embraer SB 190-57-0036 R02 compliance time, paragraphs E(1), E(2) and E(3) is based on the MLG Side Stay Fitting lubrication difficulty. The MLG Side Stay Support fitting is lubricated per AMM 32-00-03-600-801-A/300 every 600 FC. If the MLG Side Stay Support Fitting bushing lubrication is normal with no difficulties, there should be no technical reason to defer the replacement of the MLG Side Stay Support Fitting to an interval not to exceed 1200 flight Cycles after the effective date of the AD. However, If the MLG Side Stay Support Fitting cannot be properly lubricated, then it is prudent to inspect the MLG Side Stay Support Fitting bushing for migration and replace the MLG Side Stay Busing per 2012-NM-016-AD paragraph (g), (g)(1), (g)(2) and paragraph (h) respectively. Further, JetBlue Airways agrees with the requirements to inspect the MLG Side Stay Support and perform all additional inspections and corrective action as detailed in Embraer SB 190-32-0043 R02 at the compliance time stated in 20120NM-016-AD paragraphs (i), (i)(1), (i)(2) and (i)(3), and has no further comments