United Airlines

Document ID: FAA-2013-0029-0003
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: May 31 2013, at 12:00 AM Eastern Daylight Time
Date Posted: June 3 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: April 5 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: June 4 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-85n3-jw9t
View Document:

This is comment on Proposed Rule

Airworthiness Directives: Rolls-Royce plc Turbofan Engines

View Comment

United Airlines has reviewed subject proposed AD and provides below comments. Paragraph (e)(1) and (2) require within 30 days to recalulate LLP lives. This is too short of a period for UAL fleet of 137 engines. We operate in both new profiles D and E. Can we extend the period to 90 days? Paragraphs (e) (4) and (5) will restrict fly-on of recalculated parts before the new LLP lives are published in the Time Limits Manual. It was our understanding we could fly-on until Nov 2016 as long as we did not exceed the C flight profile limits. See EASA AD 2012-0265, Remove parts per RR sb 72-AG875. In addition, can we avoid using sb dates as that requires using a AMOC to approve future sb revisions. The definition of engine shop visit needs to be changed to deblading and not breaking a flange. The current definition in paragraph (g) would require us to address at all engine shop visits. Regards, Richard R. Foster Power Plant Engineering United Airlines