FedEx Express

FedEx Express has conducted a review of our fleet and stock and determined that we have no Stage 1 HPT disks with the subject suspect part numbers in our system. This proposed rule will therefore not directly affect our operation and at this time we feel that no further action on our part will be required to meet future compliance requirements if the AD is released in its current form. FedEx would, however, like to make a general comment on one aspect of the proposed rule both in general support of the industry and as a potential hedge against similar requirements in future rules. We feel that the FAA has greatly underestimated the actual cost impact that accomplishment of this AD would impose on an operator required to comply with it. The NPRM states that it is estimated that removal of the Stage 1 HPT disk would require only 1 work-hour and hence the labor cost of the proposed AD is only $80 per engine. This work estimate is only accurate if the engine is already removed and disassembled to the point of piece part exposure of the disk. As this AD would require removal of the affected disks within 30 days of issuance (as opposed to at next part exposure), in all likilihood compliance would neccessitate early removal of an engine from service and an unplanned shop visit to perform the required operation. The true cost to an airline, both in disruption to the operation and in the subsequent shop visit, would vastly exceed the given estimate of $300,080 per engine and $900,240 total.