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Disposition Comments

Docket No: FAA-2011-1170 These comments are in

Directorate ID: 2010-NM-264-AD response to an SNPRM

Originating Office Tracking No.: 2010-0175

Next Step: FRAN SNPRM

 No Comments/Only Supportive Comments Received – If this box is checked, no signatures are 

required.

 Has the referenced service information been revised since the NPRM was issued? If yes,

list latest revision and attach a copy. Note that changes beyond the scope of the previously 

published NPRM will require a new notice. Contact the Directorate focal point for guidance.

Instructions: Summarize all comments by issue (not by commenter) and provide your recommended resolution of 

each issue. All comments relating to the same issue should be discussed together. Do not list all of the issues 

from one commenter together. If changes to the AD are required based on the comments received, explain why and 

describe in detail what change(s) you recommend. Reference FAA-IR-M-8040.1C Chapter 9.

ISSUE 1: Select one of the following: costs

If other, explain: 

Commenter(s): FedEx and UPS

What change to the AD action is requested? Revise the cost estimate

Why is the change requested or how is it justified? NPRM did not include all the costs associated 

with this modification. 

Do we agree? Yes

If YES, we agree because we did not include parts from Intertechnique/Zodiac Aerospace Make the 

following changes to the AD: Price depends upon the configurations but prices are in average of 

$39,000 per aircraft.

If PARTIALLY AGREE, we agree with because We disagree with because 

Make the following changes to the AD: 

If NO, we don’t agree because 

ISSUE 2: Select one of the following: compliance time

If other, explain: 

Commenter(s): UPS and FedEx

What change to the AD action is requested? Both operators requested more time.

Why is the change requested or how is it justified? To allow for accomplishment of the work to be 

performed at a scheduled heavy maintenance event The proposed timeframe to accomplish the 

AIRBUS MANDATORY SB would force UPS to SPECIAL VISIT for a MAJORITY of the 

aircraft directed for accomplishment by the AD. The FAA previously released MD-11 AD 
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number MD11-28A132 to install in-line fuses for the fuelfloat switches that completes a similar 

task as the A300 fuel level sensors. The MD-11 AD was released to correct the same scenario of 

a potential short circuit entering the tanks via the float switch wiring harnesses. The MD-11 AD 

was given a 5 year compliance requirement and we believe that the same level of safety is 

achieved with a 5 year compliance on the A300 fleet. This condition does not justify such a 

restrictive timeframe which will lead to special aircraft maintenance visits and undue hardship on 

the operation of the airline

Do we agree? No

If YES, we agree because Make the following changes to the AD: 

If PARTIALLY AGREE, we agree with because We disagree with because 

Make the following changes to the AD:

If NO, we don’t agree because insufficient information provided to justify an extenstion of the 

compliance time (Use standard response for extension of compliance time).

For additional issues, double-click here
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Signature Section

Signature indicates concurrence with this action.

Originating Office Tracking No.: 2010-0175

ASE Printed Name: Date

Branch Manager Date