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? 

If yes, list latest revision and attach a copy. Note that changes beyond the scope of the 

previously published NP RM will require a new notice. Contact the Directorate focal point 

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 of the issues 

from one commenter together. If changes 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 the following: 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 of time 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 of this 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. If an operator isn't aware of a 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 itself is difficult enough to understand ... Why would the FAA allow itself to be 

forced into mirroring a less than well thought out form of regulatory 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!!! 

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It 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 if operators 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 it justified? It is seen as redundant. 

Do we agree? No 

If YES, we agree because Insert just ification Make the following changes to the AD: List any 

changes to the AD 

If PARTIALLY AGREE, we agree with Inse rt text because Insert justification We disagree with 

Insert tc\t because Insert justirication Make the following changes to the AD: List any 

changes to the AD 

If NO, we don 't agree because FAA procedures require that we issue an AD to revise or add new life 

limits. Revising the life limits of the parts included in the applicability of this 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 it justified? Click here to enter text. 

Do we agree? Yes/No 

If YES, we agree because Insert just ification Make the following changes to the AD: List any 

changes to the AD 

If PARTIALLY AGREE, we agree with Insert text because Insert justitication We disagree with 

Insert text because Insert justification Make the following changes to the AD: List any 

changes to the AD 

'-

IfNO, we don't agree because Inse rt our rationale 

For additional issues, double-click here 

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Signature Section 

Signature indicates concurrence with this action. 

Originating Office Tracking No.: 

:4 Oer IS 

ASE Printed Name: Matthew Fuller Date 

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