Comment from UNITED AIRLINES
UNITED AIRLINESSupportBusiness
Summary: United Airlines is requesting a technical clarification and wording update to the Airworthiness Directive (AD) regarding MMEL restrictions. They argue that the current language "for all airplanes" is overbroad and should be changed to "for affected airplanes" to align with the specific aircraft groups defined in the referenced EASA AD.
‘‘Docket No. FAA–2026–3871; Project Identifier MCAI–2026–00247–T’’
Subject: ATA 53 – Fuselage – Forward Fuselage Skin Panels – Inspection
References:
(a)Docket No. FAA–2026–3871; Project Identifier MCAI–2026–00247–T; Amendment 39–23327; AD 2026–09–06
(b)EASA AD 2026-0030R1
(c)AOT A53N020-25R01
Dear FAA Team:
United Airlines (UAL) has received Ref. (a) FAA AD 2026-09-06. UAL has reviewed the AD and has the following comment:
1.In the “Summary” and “Material Incorporated by Reference Under 1 CFR Part 51” sections of the AD, it is mentioned that:
“This AD also requires, for all airplanes, dispatch restriction from using certain master minimum equipment list (MMEL) items, a prohibition to use certain structural repair manual (SRM) tasks.”
Per Ref. (b) EASA AD 2026-0030R1, paragraph (6) the MMEL restriction is limited to aircraft that fall under groups 1 and 2. Per the EASA AD group definition, only aircraft listed in Appendix 2 of Ref. (c) AOT 53N020-25 are included in this restriction.
UAL would like to request FAA to update the wording in the AD in relation to the MMEL restrictions from “for all airplanes” to “for affected airplanes”.
UAL appreciates FAA’s attention to this comment.
For further questions regarding this subject matter, please feel free to contact at 316-821-4170.
Thank you,
Muhammad Tahir.
United Airlines
Senior Engineer – Fleet Engineering – Structures Group