Rolls-Royce plc

Rolls-Royce, plc via Chris Leat Airworthiness Engineer has reviewed AD 2011-13-01 and would like to offer the following comments: Comment #1- Regarding Reason section (d): Although this section quotes the EASA AD, the wording appears to be slightly misleading in the context of future repairs. As stated in the AD, FRS 5887 did not originally require the rivets adjacent to the repair to be replaced, however the FRS has subsequently been re-issued to include replacing all the affected rivets. Comment #2 – Informational: Section (f) (1) - All engines identified as having this type of failure have already been reworked to RR ASB RB.211-78-AG084. Comment #3 – Regarding Elapsed Time: Section (f) (2) The number of accumulated cycles to accomplish the rework to this type of repair should be reduced from 2225 to 1100 to account for the time that has elapsed since the EASA AD was issued. If the compliance time is not adjusted, then US operators will be complying with an extended compliance time that was not originally intended by the EASA AD.