Comment from AerCap

Hello, This comment is for NPRM Docket No. FAA-2026-4651, Project Identifier AD-2025-01669-E (GEnx-1B & -2B Main Fuel Pumps). AerCap wish to know if a Main Fuel Pump that has Never had any Maintenance/Repair/Overhaul work performed on it by Woodward, and is currently in Revenue Service will be affected by this AD when the engine it is installed on goes for it’s Next Shop Visit. Confusion arises, about whether a Pump in this situation is affected, for 2 reasons: 1. Use of the word 'Service' in Aviation Maintenance can have 2 different meanings. Service could mean 'Maintenance' performed on a used Pump by Woodward, OR Service could refer to 'Revenue Service' which simply means the pump has been installed on a flying Aircraft. If the NPRM, and Woodward SB, were clearer about what is meant by 'Service' it would be helpful. 2. Woodward SB 82933-73-0006, and Information presented by GE to Airlines/Lessors, indicates the cause of the unsafe condition is prior Maintenance, performed by Woodward, on Pumps that have returned from Revenue Service (Torque not measured on thrust bearing screws during Pump Repair & Screws not torqued using calibrated wrench during Re-assembly). It makes no mention of any unsafe condition affecting Pumps that have never had any Maintenance performed on them by Woodward. Paragraph h. Required Action states that any Main Fuel Pump that does not meet the definition of a part eligible for installation criteria of paragraph g.(2) must be removed at Next Shop Visit. Paragraph g.(2)(ii) is the source of confusion; does ‘no prior Service History’ mean Maintenance by Woodward, or Revenue Service/Flight? Essentially the Unsafe Condition is described as being caused by Maintenance, not the Manufacturing/New Production Process. So AerCap don’t see why Pumps with no Woodward Maintenance History would be affected. Thank you