Thanks for the pointer to the docket, it's an interesting read.
However, I don't see its relevance to BA 038.
According to the AAIB's reports ...
Originally Posted by AAIB S3-2008
[...] the aircraft fuel boost
pumps were serviceable and operated correctly during
the flight.
So, no suction feed.
If some sort of condition was present on flight BA038 that restricted fuel flow even with the boost pumps operating, why would the FAA propose rulemaking specifically for the case of suction feed?
Bernd