Comment from Air Line Pilots Association, Int'l

See attached ALPA file(s) for Docket #FAA-2022-1583

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2022-1583-0005

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Comment from United Airlines

United Airlines submits the comment contained within the attachment.

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2022-1581-0006

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Comment from Quantum AI

See attached file(s)

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2021-0419-0033

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Comment from Daniel Cope

Please see attached

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2022-1463-0059

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Comment from Aviation Rulemaking Advisory Committee Helicopter ACS Working Group

Please see the comments that I have uploaded. It is too large for this space.

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2022-1463-0058

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Comment from Anonymous

The AD is written because of a part that was built of two dissimilar metals was not being maintained properly resulting in galvanic corrosion. Had the exposed ends of this part been kept painted and sealed there would have been no corrosion. I have attached a photo of one that has been in service for 55 years. Corrosion can and does happen at many places on aircraft but we normally utilize inspections to find and correct These bad corrosion examples should have been caught earlier during annual inspections. We should use service alerts and bulletins to alert inspectors of potential problem areas not ADs that affect thousands of aircraft and cause some completely airworthy airplanes to be grounded or go through needlessly and risky disassembly and inspection.

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2023-0024-0015

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Comment from Anonymous

The following a technical analysis of what I consider to be a significant error in the Mooney M20-345A service bulletin that appears to be the sole basis for this AD 2023-02-04. I have an advanced degree in Chemical Engineering with extensive industrial experience in dealing with corrosion and electrochemistry. The following was taken from my previous post on a Mooney Space discussion of this AD:
I have not been able to find the referenced section X1 in the M20F service manual. It appears to have been left out and I have confirmed that with another person who says it was left out of his also. The Mooney SB-345A step 2.3 sounds like they are telling us to chemically “strip corrosion sensitive” part? This appears to be ignoring the later guidance in M20J Service and Maintenance Manual section 20-00-02 on Corrosion Detection and Prevention. (They are looking for microscopic cracks which must be a new standard for condemning counter weights.) From my knowledge of corrosion and as indicated in the M20J manual you should not get solvents into cracks and locations where they are hard to either neutralize or wash out. Using a stripping solvent with a chlorinated hydrocarbon component has damaged a number of aircraft in the past too. They don’t say that directly but I have seen this and have a background dealing with this type of corrosion.
In any case these hybrid corrosion sensitive weights were likely manufactured with microscopic seam cracks between the steel tube and the lead. You can see this area in my previous posting of photos of two hybrid weights that had been in service for 55 years. I was asking if anybody knew why one was still in perfect shape and one was totally destroyed to see if anybody understood the mechanisms at work here. Nobody answered so here is what I think based on my background. The round seam on the side is a microscopic crack that if not adequately sealed will allow water and contaminates and paint stripper in when exposed to that. The liquids essentially become electrolytes allowing a galvanic cell and the resulting corrosion. The key here is you can have dissimilar metals in contact but if you eliminate the electrolyte there will be no corrosion. You can see in the photo the good weight has had paint and a sealant covering the crack between the steel and the lead. The airplane also has been well maintained and kept in a good dry environment. It has not been tied down near the ocean which can be an extreme hazard for galvanic corrosion over time. I believe the hybrid weights are a risky design, that obviously fail much easier if not properly maintained. But I think the hybrid weights can last indefinitely if the side seams are kept sealed. I know this thinking is contrary to some who think all hybrid weights are a ticking time bomb. But I don’t think they have an adequate understanding on the mechanisms at play here. Bottom line, in my opinion if the factory is calling for a chemical strip of the corrosion sensitive weights, that would be a mistake which is likely to cause new galvanic corrosion. Haven’t we normally just scraped select locations with a knife probing for corrosion? That would be adequate in my mind plus negate the need for removing and balancing the elevator.

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2023-0024-0010

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Comment from Anonymous

This rule proposal is an appropriate step in the correct direction but it is not enough to ensure safety and mitigate risk in the airspace surrounding Nashville, TN. Nashville Airport needs to be upgraded to a Class B.

Per FAA Order 7400.2N Chapter 15 Section 2 (https://www.faa.gov/air_traffic/publications/atpubs/pham_html/chap15_section_2.html) Nashville already meets and vastly exceeds the parameters to be considered for Class B. Specifically 15-2-1b2 states, "The airport being considered has a total airport operations count of more than 220,000 operations and will exceed 300,000 operations (of which 240,000 operations must be air carrier and air taxi) when the itinerant traffic count from (a) and (b) below are added, and at least 5 million passengers enplaned annually."

Additionally, Nashville is currently one of 3 airports that exceeds 250,000 tower operations annually which is not a Class B primary airport or adjacent to a Class B complex. BNA in CY2022 had more tower operations than DAL, SAN, BWI, TPA, MEM, HOU, STL, CVG, MSY, PIT, CLE, and MCI all of which are Class B airports. BNA had more than twice the operations of the latter 4 airports (MSY, PIT, CLE, MCI). Reference: attached Class B - ASPM OpsNet PDF.

Additionally, in CY2021 Nashville ranked #27 in passenger enplanements with over 7.5M and is only one of 2 airports in the top 30 (Austin, TX at #30) that is a stand alone Class C. Reference Enplanements CY2021.

Additionally, Nashville in terms of operational counts is the 6th busiest combined TRACON and Tower facility behind MIA, CLT, PHL, TPA, and AUS and ranks within bottom half of all FAA Core 30 and OPM 45 airports, of which lists Nashville is on neither. Reference: Total Tower - OpsNet and Total Terminal - OpsNet PDFs.

Additionally, Metro Nashville Airport Authority (MNAA) is undergoing massive airport renovations which include the addition of 14 additional gates that will be in service by Fall 2023 with 5 more additional gates planned to be in service before 2026 and more gates (number TBD) to be added by 2028. This addition will push air carrier capacity drastically as it serves as a more than 25% increase. Reference: https://bnavisionnashville.com/

Frankly, the taxpaying citizens that pilot, board, connect, or disembark from a flight at BNA or one of the surrounding airports are being done a disservice by the inaction of the FAA to make Nashville, TN an appropriate airspace class. The airspace should be appropriate to the type of operations that take place and that can not be realized as long as BNA is some iteration of a Class C.

Comment Date:2023-01-30T05:00:00Z

Comment On Document ID:FAA-2022-1678-0002

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