David Jiang

Here, the FAA in this NPRM has in fact created a simply chart of the added estimated costs to Boeing for each inspection cycle regarding the APUs, which amount to an additional $31,900. The FAA does not clearly state how it calculated that this new AD would only cost Boeing $31,900 per inspection cycle. I would like very much that the FAA would disclose exactly how they calculated that the labor costs of inspecting and replacing the clamp and grommet would only take 6 hours and $510 (at $85 per hour). Also, the FAA estimated that the parts cost only amount to $70 per plane. Further, although Boeing right now only has 55 airplanes affected by this proposed AD, Boeing might build more planes in this 747-400 series, meaning there would be additional costs per inspection cycle. I suspect that the FAA’s estimated inspection cycle of $31,900 is on the lower end of the spectrum because most repairs and replacements to airplanes are costly and timely both in parts and labor; and this is not including the financial loss for Boeing’s planes to be grounded. Therefore, to be fair to Boeing, I propose that this NPRM to be stayed until more independent research can be performed to assess the true financial costs of this new AD to Boeing. For instance, I hope that the FAA and Boeing can come to a mutual understanding and decide on a handful of independent entities to research more on the costs of the inspections, repairs, and replacements. After more thorough research is done, the FAA will then have a better ability to weigh the costs and benefits of their new AD. This is important because if many independent thirty party entities find out that the financial costs of these minor repairs to Boeing’s planes outweigh other concerns, perhaps this NPRM will be scrapped entirely, saving Boeing and the public much unnecessary headache.