Scott T. Rollen

FedEx Express has conducted a review of our fleet and stock and determined that we have a total of 19 10-14 Spool Shafts with the subject suspect part numbers in our system. Of these, only 3 could not immediately be confirmed as having previously complied with S/B 72-A1122. Additionally, FedEx has confirmed with our primary Engine overhaul vendor that the ECI being mandated in the proposed rule is already part of our routine maintenance program and any findings should be subject to S/B warranty terms. Therefore, the proposed rule is not expected to have any adverse effect on FedEx either operationally or financially. FedEx finds, therefore, that we have no concerns with the content of the AD as currently proposed by this NPRM. One minor note, however, is that it appears that the estimated total cost to U.S. operators as stated in the NPRM ($594,500) is the cost of a single spool replacement rather than the accumulated total of the proposed action if the estimate of 10 affected units is accurate (though this may be moot due to warranty considerations).