Comment from Milan Pavlovic

We would appreciate your guidance and clarifications regarding the following questions: 1. Tracking of South Asia Takeoffs/Departures The AD applicability is based on HPT Stage 1 blades having accumulated more than 1,100 South Asia takeoffs, while the Service Bulletin repeatedly refers to HPT Stage 1 blades accumulating South Asia departures. Could the FAA clarify whether compliance tracking is intended to follow: the ESN, the HPT module assembly, the HPT Stage 1 blade set, or individual HPT Stage 1 blades? 2. Engine Transfers Between Geographic Regions The AD was issued due to the increased deterioration observed in engines operating in the South Asia region. If an engine has already accumulated more than 1,100 South Asia takeoffs and is subsequently transferred to an operator outside the South Asia region, should the repetitive inspection requirements continue to apply for the remainder of the installed blade set life? 3. Engines Introduced Into South Asia Operations If an engine previously operated outside the South Asia region is transferred to an operator within the South Asia region, is applicability determined solely by the historical accumulation of South Asia takeoffs/departures associated with the installed hardware, or are there additional considerations? 4. Blade Replacement and Applicability If the entire HPT Stage 1 blade set is replaced following removal criteria specified by the AD: Does the South Asia takeoff/departure accumulation reset for the replacement blade set? Does the engine remain subject to the repetitive inspection program based on prior engine operating history? Is applicability intended to follow the replacement blade set or the engine itself? 5. Partial Blade Replacement If only a portion of the HPT Stage 1 blade set is replaced during maintenance: How should South Asia takeoff/departure accumulation be tracked? How should applicability be determined for mixed blade populations? 6. Record keeping requirements The SB provides guidance when blade departure history is unknown, but we could not identify specific guidance regarding acceptable compliance records. Could the FAA clarify which records are considered acceptable for substantiating accumulated South Asia takeoffs/departures, particularly following engine transfers, lease transitions, or operator changes? 7. Future Terminating Action The AD describes itself as an interim action and indicates that a terminating action may be developed in the future. Can the FAA provide any additional information regarding whether a future blade redesign, hardware modification, or configuration change is anticipated to serve as terminating action for the repetitive inspection requirements? Thank you for your time and consideration. Any clarification you can provide would be greatly appreciated, as it will help ensure a consistent interpretation and implementation of the AD throughout the operator community.