Docket No: FAA-2014-0903 

### D These comments are in Directorate ID: 2013-SW-043-AD response to an SNPRM Originating Office Tracking No.: Next Step: 

### 181 FRAN 

### D SNPRM 

### D No Comments/Only Supportive Comments Received- 

## If this box is checked , no signatures are required. No 

### Has the referenced service information been revised since the NPRM was issued? Ifyes, list latest revision and attach a copy. Note that changes beyondthe scope of the previouslypublishedNP RMwill require a new notice. Contact the Directorate focalpoint for guidance. 

### Latest Rc\'ision. Instructions: Summarize all comments by issue (not by commenter) and provide your recommended resolution of each issue. All comments relating to the same issue should be discussed together. Do not list all ofthe issues from one commenter together. Ifchanges to the AD are required based on the comments received, explain why and describe in detail what change(s) you recommend. Reference FAA-IR-M-8040.1C Chapter 9. ISSUE 1: 

### Select one of thefollowing: other 

## If

other, explain: Commenter(s): Nicholas Pohl, Chuck Horgan, Greg Winkle What change to the AD action is requested? This AD is not necessary. As an operator we are required to follow the MSM Chapter 04 Airworthiness Limitations oftime change items. When a life limit is reduced by a Revision to the MSM it is automatically recognized in order to be compliant with the MSM Ch. 04- 00-00, 2-3 . I feel the issuance ofthis AD would be redundant and unnecessary, as it would essentially accomplish nothing. To whom it may concern: Please refrain from issuing this AD in its entirety. It is incomprehensible to our organization and our governing body as to why an AD would be issued instructing operators to follow the guide lines already published in an FAA approved publication. (The Airbus EC 135 MSN chapter 4). Where will the FAA draw the line??? Should an AD be issued to ensure operators perform 100 hr inspections? Ifthis AD is required why not mention all parts with life limits that are new or have changed? I crewed the first EC 135 in the USA and all ofthe manuals combined were about 12 inches thick.... New airworthiness standards were nearly a daily occurrence... No AD's were issued then. TBO's and life limits change all the time in this industry. To issue an AD because there is a change is.....well

.... ridiculous. Ifan operator isn't aware ofa change or ignores a change to chapter four he should be dealt with on a case by case basis. Please do not punish all US EC135 operators for whoever predicated this..... . action. I understand that the FAA has an agreement with EASA and at minimum something must be published.. .. This in itselfis difficult enough to understand.. . Why would the FAA allow itselfto be forced into mirroring a less than well thought out form ofregulatory information?? To whom ever it may be that is reacting or responding to this... . Please do your best to initiate some good old American common sense!!! 

### Page 1 of3It doesn't make sense to me that an AD is being issues for an aircraft manual revision. As an operator we are required to use the most current manual revision. The revision status is required to be check at a specific time (i.e.: prior to preforming maintenance). It's ridiculous to me that an AD is being issued to notify operators that a manual has been revised, which in this case, is the MSM (The EC135 Chapter 4 is approved by the FAA). In my opinion ifoperators fail to use the most current data, which we are required to use, then the operators should be dealt with on a case by case basis by their local FAA. Why is the change requested or how is itjustified? It is seen as redundant. Do we agree? No If

### YES, we agree because Insertjustification Make the following changes to the AD: List any changes to the AD If

### PARTIALLY AGREE, we agree with Insert text because Insertjustification We disagree with Insert tc\t because Insert justirication Make the following changes to the AD: List any changes to the AD IfNO, we don 't agree because FAA procedures require that we issue an AD to revise or add new life limits. Revising the life limits ofthe parts included in the applicability ofthis AD will prevent flying with parts that have exceeded their life limits which could result in an unsafe condition. 

### ISSUE 2: Select one of the following: Choose one. 

## If

other, explain: Click here to enter text. Commenter(s): Click here to enter text. What change to the AD action is requested? Click here to enter text. Why is the change requested or how is itjustified? Click here to enter text. Do we agree? Yes/No If

### YES, we agree because Insertjustification Make the following changes to the AD: List any changes to the AD If

### PARTIALLY AGREE, we agree with Insert text because Insertjustitication We disagree with Insert text because Insertjustification Make the following changes to the AD: List any changes to the AD '- IfNO, we don't agree because Insert our rationale

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### Page 2 of3Signature Section Signature indicates concurrence with this action. Originating Office Tracking No.: 

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# Oer IS ASE Printed Name: Matthew Fuller Date



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