My company MNG Airlines will start to operate 6 ea PW4158-3 engines soon after our purchasing of these asset last year. Our technical concerns about the subject NPRM are:
1. In the current version of the NPRM only pn:51L201, 51L201-001 and 52L401 and some of the ( effected per SN per table 9 of PW SB 72-795) 51L901 are given.
But the last operator based life limited part statusses of some of our engines were reflected as having the T1 hub pn :52L301 and 51L201-021.
So the NPRM seemed N/A to our subject parts but, after noticing this I just wanted to make a cross check and consult our local P&W field service rep concerning the effectivity. He explained me in a detailed way that the pn: 52L301 T1 Hub assembly has a T1 Hub pn:51L901 and the pn: 51L201-021 T1 Hub assembly has a T1 Hub pn:51L201-001.
So that changed the effectivity.
So why, we as MNG Airlines kindly request from you explain the effected PN's in more details so that no operator concerns the proposed AD as NA even though it is applicable to them.
2. As a newly operation starter operator for this particular engine type ( PW4158-3) our engines will lose 1382 flight cycles in total which will cause more than 1 million us dollars and some early shop visits which will seriously effect the budget plans.
So why, we kindly request a better solution concerning the financial point of view.
3. The NPRM states the compliance ( for PW4158-3 type engines) as follows: If effected part CSN is 12700 or fewer on AD effective date, remove from service efore 13700 CSN. If the CSN on AD effective date is higher than 12700 then remove from service before additional 1000 CIS or at next PPE, whichver occurs first.
So, for the 1000 additional CIS section, from our point of view inserting such a wording would be better :"Former life limits can not be exceeded in no case."
Thank you very much for your understanding and support as a reaction to our comments as MNG Airlines-Turkey.
Kind Regards,
MNG Airlines
This is comment on Proposed Rule
Airworthiness Directives: Pratt and Whitney Division Turbofan Engines
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