Re: AD #111 on Brantly blades Docket# FAA-2012-1013 Directorate identifier 2011-SW-020-AD Document#2012-25444

Dear Sir(s), I am enclosing a letterthat was sent to Kyle Hardiman, then president of Brantly Helicopters, Inc., when the service lettercame outon Service Bulletin #111 in May of2011. There isn't any logical reason to include the Brantly 248-101 or Brantly 248-202 blades in this AD. The Brantly 248-404 Blades are the problem, notthe 101 or 202 series of blades. The only reason a 101 or 202 blade gets cracks is the lack of maintenance, bad inboard bearings, bad dampners or rotor system out of phase. All Brantly blades are tabbed on the last 18" ofthe blade to get cyclic pressures correct orto cure a climbing ordiving blade using a tool to slightly bend thetrailing edge ofthe blade skin. This has been the common practice for SO years. The companies that dothe Eddy Currenttesting do not believe that itcan be done successfully, because ofthe closeness ofthe rivets in the blade spar area. Some**su~gest** that itwould be destructive testing, meaning itwould destroy the blade itself. The 101 and 202 blades have been good blades for over SO years. Why kill somethingthat has been working fine? Since Brantly movedto China in December 2009, we have had no factory support on any parts. There are only a few 248-202 used blades that are available that are airworthy atthistime. The AD would put all Brantly owners outof business to have an aircraftthat can't comply with this AD, have no support from the factory in China, and new blades that don't exist anywhere. As I said before, there's no logical reason to include the Brantly 248-101 or 248-202 blades in this AD. The problem is the 248-404 blades. Ifthe FAA wants to put out an AD on the 248-404 blades, they have my blessing and support. Thank you,

# ~ '1/JJI/, _,

# 1~/6--:J-CJ/5 Gary

# Goldsb~ P.S. Ifyou need any more information, feel free to contact me at: Gary Goldsberry 1181 W. State Road 42 Mooresville, IN 46158 317-996-2487 or Cell317-691-9987 gsgold@ccrtc.com

# ....

Kyle Hardman, President Brantly International, Inc.

Re: Service Bulletin #111 I have to strongly disagree with Service Bulletin #111. I have been a Brantly ownerfor 35 years. I have sold 26 Brantly s in the past 35 years. I have 6 Brantly B2B's and one 305 Brantly all in flying condition and airworthy. I purchased a large inventoryof Brantly parts, when Ifound outthe company as moving to China in 2009. 

### I'm also a Flight Instructor CFI in helicopters. I'm not sure where you orwhoever wrotethe Service Letter are gettingyour information. I don't know ofany blade delaminations in the 101 or202 blades. There have been several in the factory404 blades. Cracks inthe 101 or202 rotor blades are caused by bad inboard bearings, bad dampners orthe old aluminum style dampner brackets. Notthe blades. We maintain 6- 7 other Brantly B2Bs in the Midwest and there haven't been any problems with blade delamination. I have in my possession Brantly B2B N9023Z SN 2021 that had 2 separate times when the blades delaminated, first on 8-20-2002. Brantly had furnished 3 used 404 blades, total time on aircraft and blades was 200.0. On 12-30-2003 the 404 blades were replaced by 404 blades with 324.6 hours totaltime aircraft, again furnished by Brantly Helicopter, Inc. I have all the serial numbers and log book entries. This was before I bought the ship. I feel thatyou orwhoever put outthis service bulletin is eithervery misinformed or are trying to sell the Brantly fleet all new rotor blades. This is the same approach that Brantlytook on the tail rotor drive shaft. The only onesthatwere defective were the ones from Brantly 1991 era and forward thatwere made wrong, butthe AD made everyone comply. Thatwasn'tfair, nor is this service letter# 111.
1would greatly appreciate a reply, before this becomes an AD. Brantlys are agreat helicopter and have a very good safety record. Mycustomers and I don'twantto comply with a service letterorAD that does not apply tothe 101 or202 blades. Ifyou wantto putout a service letterorAD on 404 blades, you nave my blessing. They are the problem. Ifyou need any more information, feel free to contact me. Gary Goldsberry Mooresville, Indiana 317-996-2487 or cell317-691-9987 gsgold@ccrtc.com