David Gries

In response to Notice of Proposed Rule Making (NPRM), directorate identifier 2012-NM-13-AD. The USAF Joint STARS program which operates 707-300C aircraft is concerned the proposed AD only addresses aircraft that are frequently used to haul cargo. For operators that do not haul cargo and typically only open the main cargo door for C-check inspections; the general visual inspections required every 330 cycles or 150 days seems excessive. This inspection does not fit into the current Joint STARS maintenance program and would result in aircraft downtime and additional cost. A less frequent inspection interval will eliminate unnecessary downtime and cost for operators that do not regularly use the main cargo door while meeting the intent of the inspection. The detailed inspections every 3000 cycles/24 months and the HFEC inspections every 6000 cycles/48 months fit within the current maintenance schedule and would not cause a significant impact.