Rolls-Royce plc

The way in which "engine shop visit" is defined in the proposed FAA AD could potentially result in the LPT discs being inspected earlier than intended by the associated Rolls-Royce NMSB and the corresponding EASA AD. This will require US operators to take action where the rest of the world's airlines would not need to. The specification of level 3 >refurbishment< and level 4 >overhaul< was used as the basis for determining when the inspections were necessary and the assessments and evaluations were based on this. The use of "Separation of Major Flanges" even when for transportation only is exempt, will cause the inspections to be mandated at a level 2 >check and repair< shop visit which was not the intention of the Rolls-Royce NMSB or the EASA AD. It is requested that the definition of "engine shop visit" be re-worded to reflect the intent of the original instructions and so prevent unnecessary inspections and the associated disruption.