Ravi Bayas

Ref. 2012-NM-179-AD The NPRM, as written is inaccurate because the source document D622N001-9 dated Nov 2012 has been revised. The latest document revision is August 2012. The August 2012 version has errors. Global AMOC 140S-13-19 addresses one such error. AD, even if issued to the current August 2012 Sec. 9 MPD revision will be inaccurate. If AMOC 140S-13-19 information is included in the AD, the AD will be further complicated. As it is, the NPRM is a wordy 18 paragraphs long. More information added will make it even more complicated, thus creating a situation for chances of lapses and misinterpretation. This will create an unsafe condition, and cause another revision to the AD. It is suggested to correct the D622N001-9 document, and then issue an NPRM/AD for compliance. The resulting AD will create an accurate compliance requirement. We understand there will be a delay as Sec. 9 document is not easy to revise, but the chances of inaccurately performing safety tasks override the delay in issuing an AD.