### Re: FAA AD NPRM- TCCAAD CF2001-42/ASB 407-11-95 (Top Skin and Upper 

### UH Longeron) ']

Hi Luc
. Sharon Y Miles to: 

### Murphy, Luc ASW-111 , Regulations & Policy Group Cc: Jim Grigg



### I believe all the documents (Bell ASB, TCCA, and FAA) are in agreement. 04/22/2014 10:31 AM



### Perthe NPRM required actions (e)(3) replacing the longeron assembly with longeron assembly, P/N 206-031-314-237B, and installing three external strap doublers constitutes terminating action for this AD. It is understood that the AD inspections no longer apply
. and the inspections, if any, would be perthe maintenance manual. Perthe requirements of (e)(4), ifthere is no crack in the upper skin and there is no crack, corrosion, or other damage in the longeron assembly, you may install three external strap doublers in accordance with part Ill ofthe ASB. This option extends the recurring 50 hours TIS to 150 hours TIS
. This is the same as ASB 407-11-95,which also states in two separate notes that to benefit the replacement ofthe 50 hour intervals to 150 hour intervals, by installing the strap doublers, the longeron and top skin must be free ofdefects and shall not carry any type of repair. Perthe NPRM requirements of (e)(1 )(ii)(A), ifthere is a crack, before further flight, replace the longeron with specific longeron p/n or repair the longeron
. Ifthe longeron is repaired and the strap doublers are installed , the inspections remain at 50 hour intervals based on the ASB note (not eligible for 150 hour interval due to repairs) and NPRM requirements of (e)(1 )(C)
. Ifthe longeron is replaced and strap doublers are installed , this action constitutes terminating action(e)(3). Per NPRM requirements of (e)(2) that allows you to delay longeron inspection 10 hours if no skin damage detected- ifthere is a crack in the longeron, NPRM (e)(2)(i) specifies that you may replace with specific longeron part number and install strap doublers or repair the longeron and install strap doublers. Ifthe longeron is replaced and strap doublers are installed, this action constitutes terminating action(e)(3). If repaired, the 50 hour interval continues because if repaired, it is not eligible for expanding the interval to 150 hours due to repairs according to the ASB
. Ifyou have any questions or need additional information, please let me know
. Best regards.
Regulations and Policy Group Rotorcraft Standards Staff 817-222-5122 (office) 817-222-5961 (FAX)We value your feedback. Click here to tell us how we are doing "Murphy, Luc" Hi Sharon, I have posted the following comment... From: To: "Murphy, Luc" <lmurphy@bh.com> ASW-111 , Regulations & Policy Group Sharon Y Miles/ASW/FAA@FAA, 03/04/2014 12:38:24 PM

Cc: Date: "Deer, Michael" <mdeer@bh
.com>, "Gajewski, Bogdan" <bogdan
.gajewski@tc
.gc.ca> 03/04/2014 12:38 PM Subject: FAA AD NPRM- TCCA AD CF2001-42 I ASB 407-11-95 (Top Skin and Upper UH Longeron) Hi Sharon, I have posted the following comment on regulations.gov regarding the subject NPRM : [Docket No
. FAA-2014-0070; Directorate Identifier 2011-SW-062-AD] RIN 2120-AA64 Airworthiness Directives; Bell HelicopterTextron Canada Helicopters You were cited as the contact person in the NRPM 

### ******** The proposed AD is more restrictive than the TCCA Airworthiness Directive orthe Bell ASB without providing a rationale for the lower inspection intervals. As currently worded, the NPRM imposes the following inspection intervals: 1. If no strap doublers or new Iongeron is installed, the inspection interval is 50 hrs. 2. Ifthe strap doublers (but not the new longeron) are installed, the inspection interval remains at 50 hrs. 3
. Ifthe strap doublers and the new longeron are installed (terminating action), the inspection interval is 150 hrs
. The TCCA AD and Bell ASB impose the following inspection intervals: 1
. If no strap doublers or new longeron is installed, the inspection interval is 50 hrs. (NPRM agrees with TCCA AD and ASB) 2
. Ifthe strap doublers (but not the new longeron) are installed, the inspection interval is increase to 150hrs
. 3. Ifthe strap doublers and the new longeron are installed (terminating action), the inspection interval returns to the normal chapter 5 requirement of 300 hrs
. In all cases, it is assumed that there is no crack in the upper skin orthe Iongeron. Other aspects ofthe NRPM are acceptable
. The lower inspection intervals will impose an additional burden to operators without any additional safety benefits
. 

### *********Best regards Luc Murphy, ing., PMP Airworthiness Office Bell Helicopter Textron Canada lmurphy@bh.com (450) 971-6500 ext. 6783 Confidentiality Notice This message is intended only for the use ofthe individual to whom or the entity to which it is addressed and may contain information which is confidential and privileged
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.

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