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FAA Docket for October 10, 2007
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Freedom Air - Comments Concerning Door Compliance
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Aviation Services, Ltd. d/b/a Freedom Air
October 5, 2007
Comments Concerning Door Compliance
Freedom Air installed its door in compliance with the applicable FARs. The door meets the standards established by 14 CFR 25.795. 121.313(k) clearly requires a means to monitor from the flight deck side of the door the area outside the flight deck door to identify persons requesting entry to the cockpit and to detect suspicious behavior and potential threats from the cabin. Additionally FAR 121.582 and 584 require procedures for communication between the cabin crew and the cockpit. The NPRM indicates that the existing cockpiticabin interphone system is adequate for the aural notification requirements.
The NPRM was published August 15, 2007 with a 60 day compliant period. There was some comment regarding the shorting of the compliance date, but the FAA reviewed and determined that every door manufactured in compliance with FAR 25.795 contained a peep hole which could be used to comply with the FAR212.313(k). Therefore compliance by airlines would be a relative minor. Such is not the case. Our door was manufactured in compliance with FAR 25.795 and does not have a peep hole. Compliance will be a major problem.
Compliance with FAR 121.582 and 121.584 will be complied with by not opening the door block out to block in. The intercom system is available for use. This is a practical method of compliance due to the shortness of the routes.
By: Freedom Air, Joaquin Flores, 671-472-8009, freedom@ite.net