Airworthiness Directives; Embraer S.A. (Type Certificate Previously Held by Yaborã Indústria Aeronáutica S.A.; Embraer S.A.) Airplanes
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Issuing agencies
Abstract
The FAA proposes to adopt a new airworthiness directive (AD) for all Embraer S.A. Model ERJ 190-100 STD, -100 LR, -100 IGW, -200 STD, -200 LR, and -200 IGW airplanes. This proposed AD was prompted by a determination that new or more restrictive airworthiness limitations are necessary and a determination by the design approval holder (DAH) that some structural elements are subject to widespread fatigue damage (WFD). This proposed AD would require revising the existing maintenance or inspection program, as applicable, to incorporate new or more restrictive airworthiness limitations, and for certain airplanes would require a structural modification of the wing lower skin panels, as specified in an Ag[ecirc]ncia Nacional de Avia[ccedil][atilde]o Civil (ANAC) AD, which is proposed for incorporation by reference (IBR). The FAA is proposing this AD to address the unsafe condition on these products.
Full Text
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<title>Federal Register, Volume 88 Issue 158 (Thursday, August 17, 2023)</title>
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[Federal Register Volume 88, Number 158 (Thursday, August 17, 2023)]
[Proposed Rules]
[Pages 55956-55959]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2023-16898]
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DEPARTMENT OF TRANSPORTATION
Federal Aviation Administration
14 CFR Part 39
[Docket No. FAA-2023-1635; Project Identifier MCAI-2022-01579-T]
RIN 2120-AA64
Airworthiness Directives; Embraer S.A. (Type Certificate
Previously Held by Yabor[atilde] Ind[uacute]stria Aeron[aacute]utica
S.A.; Embraer S.A.) Airplanes
AGENCY: Federal Aviation Administration (FAA), DOT.
ACTION: Notice of proposed rulemaking (NPRM).
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SUMMARY: The FAA proposes to adopt a new airworthiness directive (AD)
for all Embraer S.A. Model ERJ 190-100 STD, -100 LR, -100 IGW, -200
STD, -200 LR, and -200 IGW airplanes. This proposed AD was prompted by
a determination that new or more restrictive airworthiness limitations
are necessary and a determination by the design approval holder (DAH)
that some structural elements are subject to widespread fatigue damage
(WFD). This proposed AD would require revising the existing maintenance
or inspection program, as applicable, to incorporate new or more
restrictive airworthiness limitations, and for certain airplanes would
require a structural modification of the wing lower skin panels, as
specified in an Ag[ecirc]ncia Nacional de Avia[ccedil][atilde]o Civil
(ANAC) AD, which is proposed for incorporation by reference (IBR). The
FAA is proposing this AD to address the unsafe condition on these
products.
DATES: The FAA must receive comments on this proposed AD by October 2,
2023.
ADDRESSES: You may send comments, using the procedures found in 14 CFR
11.43 and 11.45, by any of the following methods:
<bullet> Federal eRulemaking Portal: Go to <a href="http://regulations.gov">regulations.gov</a>. Follow
the instructions for submitting comments.
<bullet> Fax: 202-493-2251.
<bullet> Mail: U.S. Department of Transportation, Docket
Operations, M-30, West Building Ground Floor, Room W12-140, 1200 New
Jersey Avenue SE, Washington, DC 20590.
<bullet> Hand Delivery: Deliver to Mail address above between 9
a.m. and 5 p.m., Monday through Friday, except Federal holidays.
AD Docket: You may examine the AD docket at <a href="http://regulations.gov">regulations.gov</a> under
Docket No. FAA-2023-1635; or in person at Docket Operations between 9
a.m. and 5 p.m., Monday through Friday, except Federal holidays. The AD
docket contains this NPRM, the mandatory continuing airworthiness
information (MCAI), any comments received, and other information. The
street address for Docket Operations is listed above.
Material Incorporated by Reference:
<bullet> For material that is proposed for IBR in this NPRM,
contact National Civil Aviation Agency (ANAC), Aeronautical Products
Certification Branch (GGCP), Rua Dr. Orlando Feirabend Filho, 230--
Centro Empresarial Aquarius--Torre B--Andares 14 a 18, Parque
Residencial Aquarius, CEP 12.246-190--S[atilde]o Jos[eacute] dos
Campos--SP, Brazil; telephone 55 (12) 3203-6600; email:
<a href="/cdn-cgi/l/email-protection#b5c5d4d6f589d495ddc7d0d388" http: anac.gov">anac.gov</a>.br">pac@<a href="http://anac.gov">anac.gov</a>.br</a>; website: <a href="http://anac.gov">anac.gov</a>.br/en. You may find this material on
the ANAC website: <a href="http://sistemas.anac.gov">sistemas.anac.gov</a>.br/certificacao/DA/DAE.asp. It is
also available at <a href="http://regulations.gov">regulations.gov</a> under Docket No. FAA-2023-1635.
<bullet> You may view this service information at the FAA,
Airworthiness Products Section, Operational Safety Branch, 2200 South
216th Street, Des Moines, WA. For information on the availability of
this material at the FAA, call 206-231-3195.
FOR FURTHER INFORMATION CONTACT: Joshua Bragg, Aviation Safety
Engineer, FAA, 1600 Stewart Avenue, Suite 410, Westbury, NY 11590;
telephone 817-222-5366; email <a href="/cdn-cgi/l/email-protection#610b0e120914004f0a4f0313000606210700004f060e17"><span class="__cf_email__" data-cfemail="1b717468736e7a35703579697a7c7c5b7d7a7a357c746d">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION:
Comments Invited
The FAA invites you to send any written relevant data, views, or
arguments about this proposal. Send your comments to an address listed
under ADDRESSES. Include ``Docket No. FAA-2023-1635; Project Identifier
MCAI-2022-01579-T'' at the beginning of your comments. The most helpful
comments reference a specific portion of the proposal, explain the
reason for any recommended change, and include supporting data. The FAA
will consider all comments received by the closing date and may amend
this proposal because of those comments.
Except for Confidential Business Information (CBI) as described in
the following paragraph, and other information as described in 14 CFR
11.35, the FAA will post all comments received, without change, to
<a href="http://regulations.gov">regulations.gov</a>, including any personal information you provide. The
agency will also post a report summarizing each substantive verbal
contact received about this NPRM.
Confidential Business Information
CBI is commercial or financial information that is both customarily
and actually treated as private by its owner. Under the Freedom of
Information Act (FOIA) (5 U.S.C. 552), CBI is exempt from public
disclosure. If your comments responsive to this NPRM contain commercial
or financial information that is customarily treated as private, that
you actually treat as private, and that is relevant or responsive to
this NPRM, it is important that you clearly designate the submitted
comments as CBI. Please mark each page of your submission containing
CBI as ``PROPIN.'' The FAA will treat such marked submissions as
confidential under the FOIA, and they will not be placed in the public
docket of this NPRM. Submissions containing CBI should be sent to
Joshua Bragg, Aviation Safety Engineer, FAA, 1600 Stewart Avenue, Suite
410, Westbury, NY 11590; telephone 216-316-6418; email
<a href="/cdn-cgi/l/email-protection#600a0f130815014e0b4e0212010707200601014e070f16"><span class="__cf_email__" data-cfemail="513b3e223924307f3a7f3323303636113730307f363e27">[email protected]</span></a>. Any commentary that the FAA receives which is
not specifically designated as
[[Page 55957]]
CBI will be placed in the public docket for this rulemaking.
Background
ANAC, which is the aviation authority for Brazil, has issued ANAC
AD 2022-12-01, effective December 14, 2022 (ANAC AD 2022-12-01) (also
referred to as the MCAI), to correct an unsafe condition for all
Embraer S.A. Model ERJ 190-100 STD, -100 LR, -100 IGW, -200 STD, -200
LR, and -200 IGW airplanes. Model ERJ 190-100 SR airplanes are not
certificated by the FAA and are not included on the U.S. type
certificate data sheet; this proposed AD therefore does not include
those airplanes in the applicability. The MCAI states that new or more
restrictive airworthiness limitations have been developed to address
structural fatigue. Additionally, an evaluation by the DAH indicated
that some structural elements, particularly the wing lower skin
stringers, are subject to WFD. A modification is needed before the wing
lower skin panel reaches its structural modification point (SMP), and
inspections are needed to preclude WFD. ANAC AD 2022-12-01 specifies
that it requires a modification of the wing lower skin panels that
terminates the repetitive inspections required by ANAC AD 2019-06-01
(which corresponds to FAA AD 2020-04-16, Amendment 39-19853 (85 FR
18435, dated April 2, 2020) (AD 2020-04-16). Accomplishment of the
proposed modification specified in this proposed AD would therefore
terminate the repetitive inspections required by paragraph (g) of AD
2020-04-16, for the airplanes identified in paragraph (a)(2) of ANAC AD
2022-12-01 only.
The FAA is proposing this AD to address cracking in principle
structural elements. The unsafe condition, if not addressed, could
result in reduced structural integrity of the airplane. See the MCAI
for additional background information.
You may examine the MCAI in the AD docket at <a href="http://regulations.gov">regulations.gov</a> under
Docket No. FAA-2023-1635.
Related Service Information Under 1 CFR Part 51
ANAC AD 2022-12-01 describes new or more restrictive airworthiness
limitations for airplane structures. For certain airplanes, ANAC AD
2022-12-01 specifies procedures for the incorporation of a certain
structural modification (i.e., reinforcement of left-hand (LH) and
right-hand (RH) wing lower skin panels). This material is reasonably
available because the interested parties have access to it through
their normal course of business or by the means identified in ADDRESSES
section.
FAA's Determination
This product has been approved by the aviation authority of another
country and is approved for operation in the United States. Pursuant to
the FAA's bilateral agreement with the State of Design Authority, it
has notified the FAA of the unsafe condition described in the MCAI
described above. The FAA is issuing this NPRM after determining that
the unsafe condition described previously is likely to exist or develop
in other products of the same type design.
Proposed AD Requirements in This NPRM
This proposed AD would require revising the existing maintenance or
inspection program, as applicable, to incorporate new or more
restrictive airworthiness limitations, which are specified in ANAC AD
2022-12-01 described previously, as incorporated by reference. Any
differences with ANAC AD 2022-12-01 are identified as exceptions in the
regulatory text of this proposed AD. This proposed AD would also
require a structural modification of the wing lower skin panels.
This proposed AD would require revisions to certain operator
maintenance documents to include new actions (e.g., inspections) and
Critical Design Configuration Control Limitations (CDCCLs). Compliance
with these actions and CDCCLs is required by 14 CFR 91.403(c). For
airplanes that have been previously modified, altered, or repaired in
the areas addressed by this proposed AD, the operator may not be able
to accomplish the actions described in the revisions. In this
situation, to comply with 14 CFR 91.403(c), the operator must request
approval for an alternative method of compliance (AMOC) according to
paragraph (k)(1) of this proposed AD.
Explanation of Required Compliance Information
In the FAA's ongoing efforts to improve the efficiency of the AD
process, the FAA developed a process to use some civil aviation
authority (CAA) ADs as the primary source of information for compliance
with requirements for corresponding FAA ADs. The FAA has been
coordinating this process with manufacturers and CAAs. As a result, the
FAA proposes to incorporate ANAC AD 2022-12-01 by reference in the FAA
final rule. This proposed AD would, therefore, require compliance with
ANAC AD 2022-12-01 in its entirety through that incorporation, except
for any differences identified as exceptions in the regulatory text of
this proposed AD. Service information required by ANAC AD 2022-12-01
for compliance will be available at <a href="http://regulations.gov">regulations.gov</a> under Docket No.
FAA-2023-1635 after the FAA final rule is published.
Airworthiness Limitation ADs Using the New Process
The FAA's process of incorporating by reference MCAI ADs as the
primary source of information for compliance with corresponding FAA ADs
has been limited to certain MCAI ADs (primarily those with service
bulletins as the primary source of information for accomplishing the
actions required by the FAA AD). However, the FAA is now expanding the
process to include MCAI ADs that require a change to airworthiness
limitation documents, such as airworthiness limitation sections.
For these ADs that incorporate by reference an MCAI AD that changes
airworthiness limitations, the FAA requirements are unchanged.
Operators must revise the existing maintenance or inspection program,
as applicable, to incorporate the information specified in the new
airworthiness limitation document. The airworthiness limitations must
be followed according to 14 CFR 91.403(c) and 91.409(e).
The previous format of the airworthiness limitation ADs included a
paragraph that specified that no alternative actions (e.g.,
inspections), intervals, or CDCCLs may be used unless the actions,
intervals, and CDCCLs are approved as an AMOC in accordance with the
procedures specified in the AMOC paragraph under ``Additional AD
Provisions.'' This new format includes a ``New Provisions for
Alternative Actions, Intervals, and CDCCLs'' paragraph that does not
specifically refer to AMOCs, but operators may still request an AMOC to
use an alternative action, interval, or CDCCL.
Costs of Compliance
The FAA estimates that this AD, if adopted as proposed, would
affect 33 airplanes of U.S. registry. The FAA estimates the following
costs to comply with this proposed AD:
The FAA has determined that revising the existing maintenance or
inspection program takes an average of 90 work-hours per operator,
although the agency recognizes that this number may vary from operator
to operator. Since operators incorporate maintenance or inspection
program changes for their affected fleet(s), the FAA has
[[Page 55958]]
determined that a per-operator estimate is more accurate than a per-
airplane estimate.
The FAA estimates the total cost per operator for the new revision
to the existing maintenance or inspection program to be $7,650 (90
work-hours x $85 per work-hour).
Estimated Costs for Required Actions
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Cost per
Labor cost Parts cost product Cost on U.S. operators
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Up to 569 work-hours x $85 per hour = Up to $280,825............ $329,190 Up to $10,863,270.
$48,365.
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Authority for This Rulemaking
Title 49 of the United States Code specifies the FAA's authority to
issue rules on aviation safety. Subtitle I, section 106, describes the
authority of the FAA Administrator. Subtitle VII: Aviation Programs,
describes in more detail the scope of the Agency's authority.
The FAA is issuing this rulemaking under the authority described in
Subtitle VII, Part A, Subpart III, Section 44701: General requirements.
Under that section, Congress charges the FAA with promoting safe flight
of civil aircraft in air commerce by prescribing regulations for
practices, methods, and procedures the Administrator finds necessary
for safety in air commerce. This regulation is within the scope of that
authority because it addresses an unsafe condition that is likely to
exist or develop on products identified in this rulemaking action.
Regulatory Findings
The FAA determined that this proposed AD would not have federalism
implications under Executive Order 13132. This proposed AD would not
have a substantial direct effect on the States, on the relationship
between the national Government and the States, or on the distribution
of power and responsibilities among the various levels of government.
For the reasons discussed above, I certify this proposed
regulation:
(1) Is not a ``significant regulatory action'' under Executive
Order 12866,
(2) Would not affect intrastate aviation in Alaska, and
(3) Would not have a significant economic impact, positive or
negative, on a substantial number of small entities under the criteria
of the Regulatory Flexibility Act.
List of Subjects in 14 CFR Part 39
Air transportation, Aircraft, Aviation safety, Incorporation by
reference, Safety.
The Proposed Amendment
Accordingly, under the authority delegated to me by the
Administrator, the FAA proposes to amend 14 CFR part 39 as follows:
PART 39--AIRWORTHINESS DIRECTIVES
0
1. The authority citation for part 39 continues to read as follows:
Authority: 49 U.S.C. 106(g), 40113, 44701.
Sec. 39.13 [Amended]
0
2. The FAA amends Sec. 39.13 by adding the following new airworthiness
directive:
Embraer S.A. (Type Certificate Previously Held by Yabor[atilde]
Ind[uacute]stria Aeron[aacute]utica S.A.; Embraer S.A.): Docket No.
FAA-2023-1635; Project Identifier MCAI-2022-01579-T.
(a) Comments Due Date
The FAA must receive comments on this airworthiness directive
(AD) by October 2, 2023.
(b) Affected ADs
This AD affects AD 2020-04-16, Amendment 39-19853 (85 FR 18435,
April 2, 2020) (AD 2020-04-16).
(c) Applicability
This AD applies to all Embraer S.A. (Type Certificate previously
held by Yabor[atilde] Ind[uacute]stria Aeron[aacute]utica S.A.;
Embraer S.A.) Model ERJ 190-100 STD, -100 LR, -100 IGW, -200 STD, -
200 LR, and -200 IGW airplanes, certificated in any category.
(d) Subject
Air Transport Association (ATA) of America Code: 57, Wings.
(e) Unsafe Condition
This AD was prompted by a determination that new or more
restrictive airworthiness limitations are necessary and a
determination by the design approval holder (DAH) that some
structural elements are subject to widespread fatigue damage (WFD).
The FAA is issuing this AD to address cracking in principle
structural elements. The unsafe condition, if not addressed, could
result in reduced structural integrity of the airplane.
(f) Compliance
Comply with this AD within the compliance times specified,
unless already done.
(g) Requirements
Except as specified in paragraph (h) of this AD: Comply with all
required actions and compliance times specified in, and in
accordance with, Ag[ecirc]ncia Nacional de Avia[ccedil][atilde]o
Civil (ANAC) AD 2022-12-01, effective December 14, 2022 (ANAC AD
2022-12-01).
(h) Exceptions to ANAC AD 2022-12-01
(1) Where ANAC AD 2022-12-01 refers to its effective date, this
AD requires using the effective date of this AD.
(2) The initial compliance time for doing the tasks specified in
paragraph (b)(3) of ANAC AD 2022-12-01 is at the applicable
``threshold or interval'' as incorporated by the requirements of
paragraph (b)(3) of ANAC AD 2022-12-01, or within 30 days after the
effective date of this AD, whichever occurs later. Where the service
information referenced in ANAC AD 2022-12-01 does not specify a
threshold, this AD requires using the applicable flight cycles (FC),
flight hours (FH), or months (MO) identified as the interval as the
threshold. The applicable FC, FH, and MO in the ``T: Threshold I:
Interval'' column of the service information referenced in ANAC AD
2022-12-01 are as specified in paragraph (h)(2)(i) or (ii) of this
AD:
(i) For any task with an applicability that includes ``POST-MOD
SB,'' use the specified number of FC, FH or MO since accomplishment
of the applicable service bulletin.
(ii) For any task with an applicability that does not include
``POST-MOD SB,'' use total FC, total FH, or MO since issuance of the
original airworthiness certificate or original export certificate of
airworthiness, as applicable.
(3) Table 01 and paragraph (c)(2) of ANAC AD 2022-12-01 specify
a grace period. However, for this AD the grace period is as
identified in Table 01 of ANAC AD 2022-12-01, except replace the
text ``within the next 3,000 FC'' with ``within 3,000 FC after the
effective date of this AD;'' and replace the text ``within the next
4,000 FH'' with ``within 4,000 FH after the effective date of this
AD.''
(4) Where ANAC AD 2022-12-01 Table 01 specifies a compliance
time based on the accomplishment of certain service information,
replace the text ``the accomplishment of the Embraer SB No. 190-57-
005, Revision 01, dated October 27, 2006,'' with ``the
accomplishment of Embraer SB 190-57-0005.''
(5) This AD does not adopt the provisions specified in paragraph
(e)(1) of ANAC AD 2022-12-01.
[[Page 55959]]
(i) Provisions for Alternative Actions, Intervals, and Critical Design
Configuration Control Limitations (CDCCLs)
After the existing maintenance or inspection program has been
revised as required by paragraph (g) of this AD, no alternative
actions (e.g., inspections), intervals, and CDCCLs are allowed
unless they are approved as specified in the provisions of paragraph
(f) of ANAC AD 2022-12-01.
(j) Terminating Action for AD 2020-04-16
Accomplishing the actions required by this AD terminates the
repetitive inspection requirements of paragraph (g) of AD 2020-04-
16, for the airplanes identified in paragraph (a)(2) of ANAC AD
2022-12-01 only.
(k) Additional AD Provisions
The following provisions also apply to this AD:
(1) Alternative Methods of Compliance (AMOCs): The Manager,
International Validation Branch, FAA, has the authority to approve
AMOCs for this AD, if requested using the procedures found in 14 CFR
39.19. In accordance with 14 CFR 39.19, send your request to your
principal inspector or responsible Flight Standards Office, as
appropriate. If sending information directly to the International
Validation Branch, send it to the attention of the person identified
in paragraph (l) of this AD. Information may be emailed to: <a href="/cdn-cgi/l/email-protection#b28b9ff3e4e19ff3fbe09f8581829ff3fffdf1f2d4d3d39cd5ddc4"><span class="__cf_email__" data-cfemail="635a4e2235304e222a314e5450534e222e2c20230502024d040c15">[email protected]</span></a>. Before using any approved AMOC, notify your
appropriate principal inspector, or lacking a principal inspector,
the manager of the responsible Flight Standards Office.
(2) Contacting the Manufacturer: For any requirement in this AD
to obtain instructions from a manufacturer, the instructions must be
accomplished using a method approved by the Manager, International
Validation Branch, FAA; or ANAC; or ANAC's authorized Designee. If
approved by the ANAC Designee, the approval must include the
Designee's authorized signature.
(3) Required for Compliance (RC): Except as required by
paragraph (k)(2) of this AD, if any service information referenced
in ANAC AD 2022-12-01 contains steps in the Accomplishment
Instructions or figures that are labeled as RC, the instructions in
RC steps, including subparagraphs under an RC step and any figures
identified in an RC step, must be done to comply with this AD; any
steps including substeps under those steps, that are not identified
as RC are recommended. The instructions in steps, including substeps
under those steps, not identified as RC may be deviated from using
accepted methods in accordance with the operator's maintenance or
inspection program without obtaining approval of an AMOC, provided
the instructions identified as RC can be done and the airplane can
be put back in an airworthy condition. Any substitutions or changes
to instructions identified as RC require approval of an AMOC. If a
step or substep is labeled ``RC Exempt,'' then the RC requirement is
removed from that step or substep.
(l) Additional Information
For more information about this AD, contact Joshua Bragg,
Aviation Safety Engineer, FAA, 1600 Stewart Avenue, Suite 410,
Westbury, NY 11590; telephone 216-316-6418; email
<a href="/cdn-cgi/l/email-protection#0b616478637e6a25602569796a6c6c4b6d6a6a256c647d"><span class="__cf_email__" data-cfemail="c8a2a7bba0bda9e6a3e6aabaa9afaf88aea9a9e6afa7be">[email protected]</span></a>.
(m) Material Incorporated by Reference
(1) The Director of the Federal Register approved the
incorporation by reference (IBR) of the service information listed
in this paragraph under 5 U.S.C. 552(a) and 1 CFR part 51.
(2) You must use this service information as applicable to do
the actions required by this AD, unless this AD specifies otherwise.
(i) Ag[ecirc]ncia Nacional de Avia[ccedil][atilde]o Civil (ANAC)
AD 2022-12-01, effective December 14, 2022.
(ii) [Reserved]
(3) For ANAC AD 2022-12-01, contact ANAC, Aeronautical Products
Certification Branch (GGCP), Rua Dr. Orlando Feirabend Filho, 230--
Centro Empresarial Aquarius--Torre B--Andares 14 a 18, Parque
Residencial Aquarius, CEP 12.246-190--S[atilde]o Jos[eacute] dos
Campos--SP, Brazil; telephone 55 (12) 3203-6600; email:
<a href="/cdn-cgi/l/email-protection#6c1c0d0f2c500d4c041e090a51" http: anac.gov">anac.gov</a>.br">pac@<a href="http://anac.gov">anac.gov</a>.br</a>; website: <a href="http://anac.gov">anac.gov</a>.br/en/. You may find this ANAC AD
on the ANAC website: <a href="http://sistemas.anac.gov">sistemas.anac.gov</a>.br/certificacao/DA/DAE.asp.
(4) You may view this service information at the FAA,
Airworthiness Products Section, Operational Safety Branch, 2200
South 216th Street, Des Moines, WA. For information on the
availability of this material at the FAA, call 206-231-3195.
(5) You may view this service information that is incorporated
by reference at the National Archives and Records Administration
(NARA). For information on the availability of this material at
NARA, email: <a href="/cdn-cgi/l/email-protection#eb8d99c58285989b8e889f828485ab858a998ac58c849d"><span class="__cf_email__" data-cfemail="1177633f787f6261747265787e7f517f7063703f767e67">[email protected]</span></a>, or go to: <a href="http://www.archives.gov/federal-register/cfr/ibr-locations.html">www.archives.gov/federal-register/cfr/ibr-locations.html</a>.
Issued on July 19, 2023.
Victor Wicklund,
Deputy Director, Compliance & Airworthiness Division, Aircraft
Certification Service.
[FR Doc. 2023-16898 Filed 8-16-23; 8:45 am]
BILLING CODE 4910-13-P
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