June 7, 2011
Mr. Ali Bahrami
Manager, Transport Airplane Directorate,
Aircraft Certification Service
C/O: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor
Room W12-140
1200 New Jersey
Avenue, S.E.
Washington, DC 20590
Subject: Docket No. FAA-2011-0384; Directorate identifier
2010-NM-058-AD
Dear Mr. Bahrami,
Southwest Airlines would like to submit the following comments for
NPRM Docket No. FAA-2011-0384 which proposes an AD to prevent
failure of the seat attachment structure and possible injury to passengers
during an emergency landing. Southwest Airlines has an interest in
this NPRM because we recently acquired 46 of the aircraft affected by this
proposed rule.
Southwest Airlines interpretation of the proposed rule is that it
is to prevent an unsafe condition that only exists when Recaro 3510A351-()-()
series seats are installed where the aft leg attachment fitting spans the STA
521.45 seat track split. It is Southwest Airline’s intention to retrofit
the above mentioned 46 aircraft and replace the Recaro seats with new B/E
Aerospace seats to match the previously certified and compliant Southwest
Airlines current configuration.
Southwest Airlines feels the NPRM should be withdrawn since the
Boeing SBs listed in the NPRM have already been accomplished and the unsafe
condition no longer exists. Furthermore, the airframes listed will be
retrofitted to a configuration that makes the AD irrelevant and will be
accomplished before the proposed AD deadline.
If the NPRM is not withdrawn, Southwest Airlines is requesting the
applicability of the AD to apply only to aircraft operating with Recaro seats
installed in a specific configuration. If the aircraft does not have
Recaro seats and is not installed with the foot at STA 521.45 then the unsafe
condition does not exist and the AD should not apply.
Sincerely,
Amy
Oonk
Director
– Engineering
(214)
792-2733
Cc:
Ross MacArthur - Manager – Systems Engineering
Geoffrey
Buschur – Engineer – Interiors