FedEx Express

Per our discussions with Sue Lucier, FedEx has found several issues with the NPRM that needs to be addressed: 1. AD 2007-11-08 per SB 727-28A0132 accomplishes a detailed inspection of the fuel boost pumps and an engine fuel suction feed operational test thereafter. The operational test in SB 727-28A0132 is performed per the 727 AMM. The test called out in SB 727-28-80 seems to be equivalent to the test called out in the 727 AMM. FedEx believes that the NPRM accomplishes the same test that is being accomplished per AD 2007-11-08. AD 2007-11-08 repeats the detailed inspection and engine fuel suction feed operational test at intervals not to exceed 15,000 flight cycles, whereas the NPRM repeats the interval not to exceed 7,000 flight hours or 36 months. The operational test would be repeated twice within that time period. 2. Has Boeing reviewed and identified any CDCCL items in SB 727-28-80? 3. SB 727-28-80 on Page 24 step G performs a functional test per the 727 AMM. No functional test exists in the current 727 AMM. 4. If the auxiliary fuel tanks have been totally removed and/or deactivated, is the current action per the NPRM applicable to the auxiliary fuel tanks?