nprm comments template - regulations.gov

NPRM Comments Template

Comment #1

What does the commenter request?

Boeing proposes this Airworthiness Directive be considered interim action and a subsequent updated MMEL be authorized to provide modified dispatch relief.

How is the request justified?

Boeing is currently in work to provide an update (with substantiation) that allows limited relief for an inoperative open fuel shutoff valve which will mitigate the unsafe condition.

List paragraphs that change; describe (non-obvious) changes.

The entirety of the subject matter (NPRM Docket No. FAA–2020–0785)

Comment #2


Boeing requests changing the word “secured” to “failed” in reference to “failed in the open position.” This change can be found in seven locations in NPRM Docket No. FAA–2020–0785.


The MEL does not direct operators to “secure” the fuel shutoff valve open; it allows for operation (dispatch) with a valve “failed” (“inoperative”) in the open position.


SUMMARY, Discussion (first, third, and fourth paragraphs therein), Proposed AD Requirements, Paragraph (e), and Paragraph (g)

Comment #3


Boeing proposes changing paragraph (g) from: “No later than 60 days after the effective date of this AD: Operation of an airplane with any inoperative refuel valve (fueling shut-off valve) secured in the open position is prohibited.” to “No later than 60 days after the effective date of this AD: Operation of an airplane with any Reserve Tank (747 only), Main Tank, or Center Tank inoperative refuel valve (fueling shut-off valve) failed in the open position is prohibited.”


The unsafe condition does not apply when operating in accordance with the existing DDG/MMEL relief for tanks with refuel valves isolated from the main manifold that provides fuel to the wing tanks. The tanks that do not apply are the Auxiliary Tank, if installed, and the Horizontal Stabilizer Tank, if installed, on the 747; and the Body Tanks on the 767-2C.


Paragraph (g)

Enclosure to RA-20-03444

ECCN : 9E991

Comment #4


A second note to paragraph (h), “Note 2 to paragraph (h)”, should be added that states the operator must not dispatch using MMEL item 28-21-01 with any of the identified valves in the inoperative open condition.


This addresses the requirement to prevent dispatch with fueling shutoff valves in the inoperative open condition without requiring reference to a specific chapter. Dispatch to MMEL 28-21-01 “Pressure Fueling System” “inoperative” cannot include an inoperative open fueling shutoff valve or valves as part of, or while applying, that relief.


Paragraph (h)

Comment #5


The section title “(h) MMEL Items” should be titled “(h) MEL Items” and sub-paragraphs (1) through (6) should be titled with text starting with “MEL Item”


This provides clarification that the MEL(s) will be updated and is consistent with wording in previous Airworthiness Directives (e.g., AD 2018-07-04).


Paragraph (h)

Comment #6


The 747-8F and 747-8I are currently covered together in MMEL item (4), which lists the affected MMEL item number as is 28-21-01-01-01A. However, this number is only for the 747-8F. The actual 747-8I refuel valve item number is 28-21-01-02-01A and was not included in the content of paragraph (h).

How is the request justified? Coverage specifically for the 747-8I was missed.

List paragraphs that change; describe (nonobvious) changes.

Paragraph (h), MMEL item (4)


ECCN : 9E991

Comment #7 What does the commenter request? All text for “KC-46A” should be removed.

How is the request justified? The KC-46A is covered under the 767-2C for type certification purposes.



Comment #8 What does the commenter request? Remove “MMEL” items referring to the 767-2C.


An FAA-approved MMEL document does not exist for the 767-2C. The 767-2C has only a DDG. The reference MMEL items (6)(i) and (6)(ii) areonly found in the DDG and as such are not public documents. It is notappropriate to reference these MMEL items in the Airworthiness Directive.




ECCN : 9E991

nprm comments template - regulations.gov

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