Mike Atkins

This NPRM is for the Grob model G115E only, and is derived from the EASA AD 2013-0017, also on the G115E only. The G115E and G115EG are both type certificated by the EASA under type certificate EASA.A.364. The G115 series aircraft are USA type certificated under Type Certificate A57EU. However, while there is a listing of the G115EG on A57EU, there is no mention of the G115E on this TCDS. NPRM 2013-CE-006-AD lists an applicability serial number range of 82086/E through 82184/E. Per EASA Type Certificate EASA.A.364, the serial number suffix "/E" denotes a model G115E only, while any new production G115EG will show a "/EG" serial number extension. Judging from the above serial numbers, I must presume that the FAA is not treating the USA certificated G115EG as a subset of a G115E "series." Therefore it would appear that NPRM 2013-CE-006-AD is preliminary to establishing an AD on a Non-USA Certificated aircraft, which would be a violation of the FAA's own rules. Since there are no G115E aircraft shown as registered in the USA, and there is no USA FAA certification of this model, there seems to be no logical reason for converting this NPRM to a new AD.