Virgin Atlantic Airways would like to make the following comments regarding NPRM 2012-NM-166-AD.
1) The compliance time is not clear because SB 747-24A2360 R1 states a recommended compliance of 14 months from the R1 date (2nd May 2012) however NPRM paragraph (h) (2) states "this AD requires compliance within the specified compliance time after the effective date of this AD".
2) NPRM paragraph (i) is not clear. The current wording can be interpreted as if it applies to the entire aircraft and not just those clamps that are required to be replaced as per SB 747-24A2360 R1. Also the clamp size should not be specified in the AD because if an operator needs to install a different size clamp, then it would require an AMOC to comply with the AD.
Virgin Atlantic Airways
This is comment on Proposed Rule
Airworthiness Directives: The Boeing Company Airplanes
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