Comment from Bombardier

BombardierSupportBusiness
Summary: Bombardier, Inc. provides technical updates regarding the incorporation of revisions and references in the proposed Airworthiness Directive. They also request that specific service information be excluded from public online posting due to its status as Confidential Business Information, while remaining available to interested parties through their customer portal.
1. In regards to the REFERENCES: Paragraph (h): Note that the TRs references have been incorporated since. Suggested wording: TR_XX or subsequent revisions dated post June 28, 2024. AFM RSs dated May 6, 2024 were incorporated into the AFMs via TRs or Full revs on June 2024. TCCA AD was issued on Nov 2024. FAA NPRM for AD on review July 2026. As a few months have passed since, Flight Manuals have changed, TRs have been already incorporated into Full Revs. The TCCA AD contains wording regarding "later revisions approved...", recent FAA ADs didn't contain that statement which caused confusion, also the need for AMOCs in some cases. I will send via email to FAA a file that clarifies where incorporated. 2. DISCLAIMER: Bombardier considers the following service information listed in the AD NPRM as Confidential Business Information (CBI)/PROPIN: (See AFM Table for details) While Bombardier doesn't disagree that the listed service information be incorporated by reference, we request that they be excluded from public posting of the PDF versions on the regulations.gov online docket. A paper copy may be incorporated by reference in the Library of Congress version. We believe there is sufficient grounds to exclude public posting of the PDF versions because, as already stated in the AD NPRM, the listed service information is reasonably available because the interested parties have access to it through their normal course of business or by the means identified in the ADDRESSES section. In particular, interested parties can sign up to Bombardier online customer portal (https://my.bombardier.com/) and obtain access to the listed service information, and therefore the FAA might want to amend paragraph (n)(5) to clarify this.

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