Subject: Request to Delay Implementation ofNotice of Proposed Rulemaking (NPRM) 2002-NM-12-AD ~ 

### BOEING The Boeing Company P.O. Box 3707 Seanle. WA 98124.2207 

## NOV 07 

## 2002 B-H21O-02-0509
Transport Airplane Directorate, ANM-103 Airworthiness Rules Docket No. 2002-NM-12-AD Federal Aviation Administration Northwest Mountain Region 160I Lind Avenue Southwest Renton, Washington 98055-4056 Dear Ms. Opland: 

# RECEIVED NOV 

## I ~ 2002 ANM -114

References: (a) NPRM 2002-NM-12-AD

(b) Boeing Letter B-H360-02-4343, Comments Related to the Static Inverter NPRM No. 2002-NM-12-AD, dated June 28, 2002 Please forward acopy ofthis correspondence to Mr. B.V. Tran (FAA Specialist, ANM-130S). Boeing respectfully requests adelay ofthe reference a) NPRM until November 15, 2002. Comments to this NPRM have been previously provided to the FAA by reference (b) The delay inreleasing the NPRM will ensure that the latest revision ofAvionics Instruments, Inc. Service Bulletin 1-002-01-2-1000-24-24 is available. Ifyou have any questions, please contact this office or Dennis Anderson at (425) 717-2401. The information being forwarded to the FAA, byorwith this correspondence, is considered proprietary to The Boeing Company, and isprovided on aconfidential basis. Very truly yours, 

# '3 t. 

# c.,tCct.N-l

# v-lt.;)
B. C. Groenewegen Manager, Continued Airworthiness Twin Aisle Programs B-H210, M/C 02-85, (425) 717-2399 FAX: (425) 266-2699 DLA

### JUN 2 8

## 2002 B-H360-02-4343 ;UL-11-2002



# _.

# - 08: 19 FAA SEATTLE ACO The Boeing Company P,O. Sox 3707 Seattle, WA 98124-2207 

# RECEIVED 425 227 1182 P.02



# ~ &rfd-I
ROUTE

Dear Ms. Liu-Nelson: 

## JUL 02 

## 2002 ANM.100S

.. FM-SACO

Comments Related to the Static Inverter NPRM No. 2002-NM-12-AD Ms. Lirio Liu-Nelson Manager, ANM-IOOS Department ofTransportation Federal Aviation Administration Seattle Aircraft Certification Office 160I Lind Avenue SW Renton, WA 98055-4056
Subject:
Reference: Electrical Power-Static Inverter-Bridge Assembly RI70

Relocation Service Bulletin from Avionic Instruments Inc., Number 1-002-0102-1000-24-24, dated July 19, 1999 This letter provides our formal comments related to the pending AD associated ",ith the subject NPRM NO.2002-NM-12-AD. Avionic Instruments, Inc. (AI') estimates that approximately 3,200 static inverters mil require implementation ofService Bulletin 1-002-0102-1000-24-24. AI' can process approximately 100units per month. Therefore, a42-month compliance time period is requested. Under "Explanation ofRelevant Service Information". the NPRM reads as follows: "The FAA has reviewed and approved Boeing Service Letters 737-Slr24-165, 747-5L-24-058

..." etc. The FAA typically does not, ifever, approve aBoeing Service Letter, and Boeing has notbeen able to locate any such approval. However, Boeing does have record ofFAA approval ofthe Avionic Instruments Service Bulletin, 1-002-0102-1000-24-24, which isreferenced inthe Boeing Service Letters. In the "APPLICABILITY" table, the Model 737-700C ismissing, although it is included in the listing under "SUMMARY". The formatting ofthe "APPLICABILITY" table could bemisleading. The dotted lines inthe table could cause the misinterpretation that only the Boeing -5 inverter is used on the 737, only the Boeing -7 inverter is used on the 747, etc. Under "Spare Parts", the NPRJ,,!reads as follows: "(b) As ofthe effective date of this AD, no person may install. on any airplane, astatic inverter having apart number listed inthe applicability section ofthis AD, unless the static inverter has been modified in accordance with the requirements ofthis AD". This seems to contradict the requirement, under "Modification", that static inverters be modified within 18months ofthe effcctive date ofthe AD. Boeing therefore strongly recommends that the requirement under "Spare Parts" berelaxed to allow operators arcasonable length oftime, after the effective date ofthe AD, to modify their spares. Operators mil require asubstantial period oftime following the effective date ofthe AD to implement plans to cycle unmodified static inverters offtheir airplanes, into aJUL-11-2002 08:19 FRR SERTTLE RCO 425 227 1182 P.03

,..



### DDE'NC Page 2 Ms. Lirio Liu-Nelson B-H360-02-4343
modification facility, and back into their fleet. Until this cycle ofremove, modify, and return-to-service is complete, itis likely that atanyone time the only spare static inverter(s) available to support fleet operations will be unmodified static inverter(s). Please contact this office or Keith Cebell at(425) 342-3843 ifyou have any questions. The information being forwarded to the FAA byorwith this correspondence is for the exclusive purpose ofsupport ofapplications foror amendments to Type Certificates, is considered proprietary to The Boeing Company, and isprovided on a confidential basis. The data provided should bereturned to Boeing immediately following use by the FAA, including any copies thereof which the FAA may berequired to make inthe course ofits review. Boeing does not authorize the FAA to retain anyportion ofthe materials being supplied. Very trulv yours,

.Blankinship anager, Airplane Certification Twin Aisle Deliveries & Fleet Support, B-H360 ~ail Code 02-79 Phone (425) 342-3810, FAX (425) 342-7546 

## KNC

TOTRL P.03Tho Boeing Company P.O. Box3707 Seattle, WA 98124.2207 

## JUN202006 B-1I21O-06-0392

Docket Management Facility 

## u.s. Department ofTransportation 400 Seventh Street SW Nassif Building, Room PL-40 I Washington, DC 20590 Attention: DOT Rulemaking Docket No. 2002-NM-l2-AD 

# 0- BOEING Subject: Comments onSupplemental NPRM DocketNo.2002-NM-12- AD: "Modification ofStatic Inverter ByRelocation ofResistor RI70 oftheStstic Inverter Bridge Assembly", Airplane Model 737,747-400,757,767, and 777

Boeing bas reviewed the subject NPRM and provides the enclosed comments.

Very truly yours, 

# "B.t. 

# G~~ B. C. Groenewegen 

# J Manager, Continued Airworthiness Twin Aisle Prognuns H-H2l0, M/C OA-87, (425) 266-4030 FAX: (425)342-5219

dla Enclosure; NPRM Comments 1pageComment # v,'hat does the commenter re ucst? How is the rcqut:st justified? List paragraphs thai change: describe (nollobvious) chan 'es. Enclosure to B-H21 0-06-0392 Page Iof I

Comments on NPRM Docket 

### "'0. 2002-NM-12-AD

Address imminent revisions to two of the service bulletins identified in the co ased AD. as well as ossiblc future revisions to an of the identified bulletins. Revisions are inuninent to the 747 and 777 bulletins which will add se••. eral airplanes to the Effectivity lists in the bulletins. As written, the "Applicability" am fa h in the co sed AD will not include the added a" lanes. "Applicability ,.paragraph and paragraph (a) under "Modification": Suggest changing to read .•... the applicable service bulletin specified in Table 1 of this AD or~'ubsequentrevls/on(s) 10 thatbulletin.

Comment # 2 ""hat does the Remove 747 and 777 from the applicability ofthc proposed AD. commcnter reQuest? How is the request Boeing Safety Review Board made a finding of "Not Safety" for the 747 and 777. justified? There havc bcen no failures on these models, and the inverters on thcse models arc not runnim! durin!! nonnal operations. List paragraphs that "Table J .-Applicability" l:hange: describe (nonohvious) ehanees.

6/19/2006 4:33:53 PM~ 

### BOEING The Boeing Company P,O. Box 3707 Seattle, WA 98124.2207

June 19.2006 B-H2IO-06-0390 Docket Management Facility U.S. Department ofTransportation 400 Seventh Street SW Nassif Building, Room PL-401 Washington, DC 20590 Attention: Airworthiness Rules Docket No. 2002-NM-12-AD 

## RECEIVED JUN 27 2006 ANM-114 

## •

Subject: Comments, SNPRM Docket No. 2002-NM-12-AD:

"Modification ofStatic Inverter by Relocation of Resistor R170 ofthe Static Inverter Bridge Assembly", Airplane Models 737-300/400/500, and 757 Boeing has reviewed the subject NPRM and concurs with the contents of the proposed rule. Therefore, no additional comments will be forthcoming. Very truly yours,

.K. Dial Manager, Continued Airworthiness Single Aisle Programs B-H2IO, MC 67-TC, (425) 237-9472 FAX: (425) 234-4649 Jam