March 3, 2014 

Department of Transportation 

Docket Operations 

M-30 

West Building Ground Floor 

Room W12-140 

1200 New Jersey Avenue SE 

Washington, DC 20590 

Re: Docket No. F AA-20 13-1027 

Federal Aviation Administration: 

James Milner, Lucindia Monday, and Andrea Tice are honored to exercise our 

right to comment in support of the ndw airworthiness directive for Boeing Company 

Model 737-600, -700, -700C, -800, -900, and -900ER series airplanes. See 78 Fed. Reg.· 

239. We are citizens of the United States concerned with the potential explosion of 

certain Boeing airplanes due to installation of incorrect wire support clamps. Although 

we have missed the deadline of January 27, 2014, for public comment, the gravity of the 

potential harm compels us to submit this comment nevertheless. 

I Policy & Authority 

A fundamental policy underlying the Federal Aviation Act is "preventing 

deterioration in established safety procedures, recognizing the clear intent ... ofCongress 

to further the highest degree of safety in air transportation and air commerce, and to 

maintain the safety vigilance that has evolved in air transportation and air commerce and 

has come to be expected by the traveling and shipping public." 1 The Federal Aviation 

Administration (FAA) is an administration in the Department of Transportation? The 

FAA Administrator has various duties and powers, one of them being to promulgate 

1 49 U.S.C.A. 4010l(a)(3). 2 49 U.S.C.A. 106(a). 

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regulations.3 Chapter 5 of Title 5 governs the issuance of these regulations, including the 

notice and comment requirements as outlined in section 553 of that same chapter and 

title.4 

11 Airworthiness Directives 

According to the Federal Aviation Regulations, airworthiness signifies the aircraft 

conforms to its type design and is in condition for safe operation. 5 By regulation, one 

cannot operate a civil aircraft unless it is in an airworthy condition.6 An airworthiness 

directive (AD) is a legally enforceable rule applying to an aircraft, aircraft engine, 

propellers, and appliances.7 The FAA issues an AD when (a) an unsafe condition exists 

in the product; and (b) the condition is likely to exist or develop in other products of the 

same type design. 8 An AD specifies inspection to be carried out, conditions and 

limitations to be complied with, and any action to be taken to resolve an unsafe 

condition. 9 If the requirements of an airworthiness directive have not been met, the 

operator of the product violates section 39.7 of Title 14 of the Code of Federal 

Regulations. 10 

Ill Proposed Airworthiness Directive for Certain Boeing Airplanes 

A. Potential Harm to Public 

With the policies and powers of the FAA in mind, we support the FAA amending 

14 CFR part 3 9 to include a new AD relating to Boeing Company airplanes. 11 The harm 

3 49 U.S.C.A. 40113(a); 49 U.S.C.A. 106(g); 49 U.S.C.A. 106(f)(2)(A)(iii); 49 U.S.C.A. 106(f)(3)(A). 4 49 U.S.C.A. I 06(f)(3)(A). 

5 14 C.F.R. § 3.5. 6 14 C.F.R. § 91.7. 7 14 C.F.R. § 39.3. 8 14 C.F.R. § 39.5. 9 14 C.F.R. § 39.3. 10 14 C.F.R. § 39.7. 11 The Boeing Company: Docket No. FAA-2013-1027; Directorate Identifier 2013-NM-AD. 

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contemplated by this new airworthiness directive is the potential explosion of certain 

Boeing Company airplanes. The apprehension stems from a "report" to the FAA of 

installation of incorrect wire support clamps within the left and right Environmental 

Control Systems (ECS) bay area during the course of producing airplanes. 

ECS is a flammable leakage zone. Using incorrect wire support clamps-ones 

not fully cushioned-could permit contact with exposed metal on the clamp. This could 

cause a short circuit and electrical arcing as a result. Electrical arcing is the discharging 

of a luminous current between two electrodes or other points. Arcing would serve as 

ignition source for flammable fuel vapors. A fuel tank explosion could ensue. The two 

elements for the FAA in issuing an AD are satisfied in that a reported unsafe conditionincorrect wiring clamps with the attendant threat of explosion-belongs to a class of 

products, in this case, Boeing Company Model 737-600,-700, -700C, -800,-900, and900ER series airplanes. 

B. Compliance 

This proposed AD requires as of its effective date that: 

(1) within 60 months after the effective date of this AD, the operator 

performs a detailed inspection to determine if a wire support clamp having part 

number (PIN) 

(a) TA0930034-10; 

(b) TA0930034-10P; 

(c) TA0930034-10P; 

(d) TA0930034-11; or 

(e) TA0930034-12P 

and do all applicable related investigative and corrective actions before further 

flight, in accordance with the Accomplishment Instructions of Boeing Special 

Attention Service Bulletin 737-28-1312 (dated April19, 2013); and 

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(2) no person may install a wire support clamp on any airplane within the ECS 

area defined in the Accomplishment Instructions of Boeing Special Attention 

Service Bulletin 737-28-1312 (dated April19, 2013), unless the clamp has PIN 

(a) TA0930034-10; 

(b) TA0930034-10P; 

(c) TA0930034-11; or 

(d) TA0930034-12P. 

C. Costs 

The FAA estimates that this proposed new AD affects 519 airplanes in the U.S. 

Registry. A problem with 519 airplanes, where even one ofthem could explode because 

of an incorrect clamp, should not go unaddressed by government, especially where the 

costs of compliance on operators seem reasonable. The FAA estimates that the labor cost 

for inspection would be $510 pet product, i.e., 6 hours of work times $85 an hour. $510 

times 519 affected airplanes equals $264,690 as an estimated cost on U.S. operators for 

inspection. Regarding investigative and corrective actions, the FAA estimates that labor 

costs would be a total of $85 for one hour of work at $85 per hour. In addition to labor 

costs, the FAA estimates a $3 parts cost, which raises the estimated cost per product to 

$88. We hope and ask that these 519 planes not be operated until investigative and 

corrective action has taken place. 

Some of the costs on affected operators may be offset by the manufacturer's 

warranties. If not for the value of human life itself, there is an incentive for industry to 

comply so as to prevent a costly explosion. In all, adopting this proposed airworthiness 

would further the government's noble aim of "maintain[ing] the safety vigilance that has 

evolved in air transportation and air commerce and has come to be expected by the 

traveling and shipping public." We therefore support this new AD. 

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Sincerely, 

James Ilner (student) 

Mercer University School of Law 

1021 Georgia A venue 

Macon, GA 31207 

jmilner 14@lawmail.mercer.edu 

Lucindia Monday (student) 

Mercer University School of Law 

1 021 Georgia A venue 

Macon, GA 31207 

!monday 15@laW!nail.mercer.edu 

Andrea Tice (student) 

Mercer University School of Law 

1 021 Georgia A venue 

Macon, GA 31207 

atice 14@lawmail.mercer .edu 

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