Comment from United Parcel Service (UPS)
United Parcel Service (UPS)SupportBusiness
Summary: UPS Airlines requests specific modifications to the compliance methods for the Airworthiness Directives regarding Pratt and Whitney Division Engines. They propose allowing a 15-year calendar-time compliance interval for low-utilization operators and seeking a method to determine replacement timeframes for sensors with unknown history.
UPS Airlines requests that approved methods of compliance include replacement of Pb sensors with new sensors (in accordance with the CMM or other approved procedures) and accomplishment of Hamilton Sundstrand/UTAS/Collins Service Bulletin EEC131-73-62.
UPS Airlines requests the modification of the calendar-time compliance option for low-utilization operators (less than 1,200 cycles per year), such as cargo and freight operators. UPS proposes a 15-year compliance interval rather than the 10-year interval specified in paragraph h(2). No change to the flight-hours requirement is requested for low-utilization operators.
UPS Airlines also requests that Pb sensors with unknown flight hours or unknown calendar time since new or since repair be allowed to use the highest accumulated flight hours or the oldest repair date of any Pb sensor in the fleet for determining the applicable replacement compliance timeframe.