Comment from UPS

Docket No. FAA-2026-4651; Project Identifier AD-2025-01669-E Hello FAA Team, UPS Airline believes that clarification is needed. In paragraph 2.(g)(2)(ii), parts eligible for installation are defined as "a new part with no prior service history." This can be interpreted to mean only new pumps that have never been operated on-wing. However, upon examining GEnx SB 73-0110 R01, it appears that the affected main fuel pumps were improperly measured or reassembled during a repair visit, meaning that any main fuel pump that had not yet been to a repair visit would not be affected. This is alluded to in the original Woodward service bulleting in section 1.C. By defining eligible parts as parts "with no prior service history," it implies that no part that has been flown in service is eligible for installation. If this is not the intention, it is our recommendation that the wording in paragraph (g)(2)(ii) is changed to say, "A main fuel pump that has a part number identified in table 1 to paragraph (c) of this AD that is a new part with no prior repair history." UPS Airline also believes that there is another discrepancy in the definition of parts eligible for installation. In paragraph 2.(g)(2)(iii), parts eligible for installation are defined as having been "overhauled and confirmed to have all thrust bearing screws replaced in accordance with any revision of GE Service Bulletins GEnx-1B SB73-0117 or GEnx-2B SB73-0110." UPS Airline notes that GEnx SB 73-0110 R01 does not require overhaul of the main fuel pumps. The Service Bulletin instead refers to Service Bulletin 82933-73-0006, in which the replacement of the screws is recommended independently of the accomplished workscope. As a result, repaired units should fulfill the requirements of the AD as long as the screw replacement has been accomplished in accordance with the Service Bulletins. It is our recommendation that paragraph 2.(g)(2)(iii) should instead say, "A main fuel pump that has a part number identified in table 1 to paragraph (c) of this AD that has been repaired and confirmed to have all thrust bearing screws replaced in accordance with any revision of GE Service Bulletins GEnx-1B SB73-0117 or GEnx-2B SB73-0110." Thank you, Harper Hall Powerplant Engineer UPS Airline