Boeing Model 747-400 and -400D Series Airplanes - 2007-NM-047-AD

FAA-2007-28988

October 3, 2007

Comments of Japan Airlines

We think the purpose of SB 747-24-2246 is different from the proposed AD, because 747-400 airplanes already have utility bus switches since the production.

In addition, we think, the result of this SB is opposite to the aim of the proposed AD. Because this SB will make the electrical power to some cabin lights remains when utility bus switch is turned off. This means flight crew / cabin crew cannot remove electrical power from some cabin light systems when smoke happens.

Moreover, in most cases, we airlines add/change IFE system by STC. So Boeing SB cannot cover all the IFE system. Therefore, FAA needs to review those STCs. (But we believe the STCs approved after Swiss Air MD-11 accident have been checked at the point of "Interim Policy Guidance for Certification of In-Flight Entertainment System" PS-ANM100-2000-00105.)

We believe almost all IFE systems have "MASTER POWER SW" in cabin. So cabin crew can also shut down IFE system. In other words, "MASTER POWER SW" in cabin also satisfies the aim of the proposed AD. Once SB 747-24-2246 became mandatory, a lot of airlines would need to request AMOCs. The impact to operators would be so significant.

By: JAL, Toshiba Asaba, toshihisa.asaba@jal.com