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DEPARTMENT OF 

l'\MSPORT/ff!ON 

• a n OPERATIONS 

:iU y t I 21 A ^0 2 

VIA Email 

Our Ref: TD/E/2331/MET 

Yr Ref: 

Docket Np. FAA-2010-0857 

Directorate Identifier: 2010-NM-156-AD 

25 October 2010 

AAPA 

ASSOCIATION OF ASIA PACIFIC AIRLINES 

Association of Asia Pacific Airlines 

{Re9.Ne.SB7) 

9/F Kompleks Antarabangsa 

Jalan Sultan Ismail 

50250 Kuala Lumpur 

Malaysia 

Tel +603 2145 5600 

Fax +603 2 US 2500 

www.aapairlines.org 

US Department of Transportation, 

Docket Operations, 

M-30, 

West Building Ground Floor. 

Room W12-140, 

1200 New Jersey Avenue, 

SE. Washington 

DC 20590 

Dear sir. 

Subject: Request for extension for comments for FAA NPRM Proposed Airworthiness 

Directive ^AD^ : Koito Industries. Ltd.. Seats and Seating Systems Approved 

Under Technical Standard Order (TSO) TSO-C39b. TSO-C39c. or TSO-C127a 

The Association of Asia Pacific Airlines (AAPA) appreciates this opportunity to submit 

initial comments on the Federal Aviation Administration Docket Number FAA-2010-0857, 

concerning the proposed AD on Koito seats and seating systems. 

The AAPA is the principal trade and service organization for the leading scheduled 

international air carriers in the Asia Pacific region^ AAPA members traffic represents 

more than 17% of the global passenger traffic and more than 30% of the global freight 

traffic, 

^ Royal Brunei Airlines, EVA Airways, China Airlines, Cathay Pacific Airways, Garuda Indonesia, 

Japan Airlines, Dragonalr. Korean Air, Malaysia Airlines, All Nippon Airways, Aslana Airlines, 

Philippine Airlines, Singapore Airlines, Thai Airways International, Vietnam Airlines. 
27-10-10:08:30 ; ; # 2/ 

AAPA 

ASSOCIATION OF ASIA PACIFIC AIRLINES 

First, and foremost, AAPA would like indicate it appreciates this opportunity to comment 

on the proposed AD. but more importantly for the unique opportunity to engage with the 

FAA and EASA at the recent dialogue session on the AD in Singapore. 

As noted by the FAA and EASA representatives in attendance at the recent FAA-EASA 

AD briefing on Koito seats in Singapore on 21 October 2010 the Japanese Civil 

Airworthiness Bureau (JCAB) provided a briefing outlining JCAB efforts and progress with 

its investigation into problems relating to aircraft seats manufactured by Koito seats. 

From the presentation, it was evident to all that new information and evidence on the 

Koito seat problem was now available, which could impact the EASA and FAA proposed 

ADs. From the meeting discussion it is clear that there is a need, in the near term, for the 

authorities concerned with the support of Boeing and Airbus to meet and review the new 

evidence and determine the implications to the proposed AD. 

Consequently, taking the aforementioned situation into account the AAPA would therefore 

like to request for an extension of the period comment by 90 days in order to provide time 

for the parties concerned to better understand the new JCAB data. 

On a point of clarification and with reference to the recent FAA- EASA AD briefing on 

Koito seats in Cologne on 14 October we understand that It has been agreed to carry out 

a follow-up briefing session due to the comments raised. We would like therefore to 

understand if a similar follow-up briefing session will be offered to the carriers from the 

ASPAC region. 

To conclude, the AAPA would like to reiterate its appreciation to the FAA and EASA for 

holding the briefing session in Singapore. We trust you will give due consideration to our 

request for an extension to provide comments. In the event that you require any 

clarification or further comment we are willing and prepared to respond. 

Yours faithfully, 

Martin Eran-Tasker 

Technical General 

Association of Asia Pacific Airiines