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Docket No: FAA-2013-0159

Directorate ID: 2012-SW-010-AD

Originating Office Tracking No.:

Disposition Comments

0These comments are in

response to an SNPRM

Next Step: f8J FRAN 0SNPRM

0 No Comments/Only Supportive Comments Received -Ifthis box is checked, no signarures are 

required.

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 NPRM will require a new notice. Contact the Directorate focal point for guidance.

Instructions: Summarize all comments by issue (not by commenter) and provide your recommended resolution of 

each issue. All comments relatin g 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-8040.1 C Chapter 9.

ISSUE 1: Select one of the following: allow repetitve inspections

If other, explain:

Commenter(s): (9) Steve Grossman, Mark Dalton, Startade Heli GmbH& Co KG., Mark

Dalton,Thomas Britt, Marc Desprets, Eddie Hurley,James Williams, George Meyer

What change to the AD action is requested? Withdraw this NPRM and allow continued repetative 

inspections of tail rotor blades for all effected models.

Why is the change requested or how is it justified? There is insufficient data to justify the termination of 

the requirement for repetative inspections and to replace the main rotor blades with new blades that do not 

require the AD inspection. Inspections ifdone correctly will ensure continued operational safety.

Do we agree? No

1f YES,we agree because Make the following changes to the AD:

If PARTIALLY AGREE, we agree with

Make the following changes to the AD:

because We disagree with because

I f NO, we don't agree because blade debonds continue to occur in service. The cause of the debond 

was determined to be erosion on unpainted blade tip bond lines which allows the bond to weaken and 

the skin to pull up. This situation is sufficient to warrant an AD for inspection due to the catestrophic 

consequences if the blade becomes delaminated. Airwo11hiness cannot be ensured long-term by 

reliance on contin ued repetative inspections. In one instance blade debond has lead to a fatality, and 

so it is in the interest of safety to accelerate the retirement of the blades from 12 years from blade 

manufacture to an earlier date.
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ISSUE 2: Select one of the following: applicability

If other. explain:

Commenter(s): (6) Brant Paul Swigatt,Greg Morrison, Robett DiGiovanni, Stattrade Heli GmbH & Co

KG., Mark Dalton, Miarage Helicopters Inc.,

What change to the AD action is requested? Remove the requirement for replacement of the main rotor 

blades with new blades that do not require the AD inspection for the R44 Astra models which are not 

equipped with hydraulic assisted controls or require RHC to perform testing of the new blades with the 

non-hydraulic R44 Astro helicopter so that the new rotor blades can be installed on the R44 Astro without 

also having to convett the helicopters to hydraulic assisted controls.

Why is the change requested or how is it justified? The new rotor blades cannot be installed on the R44

Astra models unless the helicopter is converted to hydraulic assisted controls. This is because the new 

rotor blades have not been tested and certified for the R44 Astro modes which are not equipped with 

hydraulic assisted controls. The requirement to replace the main rotor blades with the new rotor blades 

for these helicopters also then requires those helicopters to be converted to hydraulic assisted controls 

which is an additional expense.

Currently this conversion can only be performed at the Robinson factory. Robinson then reserves the right 

to upgrade any component on the helicopter to their latest revision even though there is no AD or SB 

stating the Robinson required change. This Robinson requirement resul ts in additional cost increase. 

Commenters state that the installation of replacement main rotor blades for the R44 Astro models

therefore also entails a costly conversion to hydraulic assisted controls which are not necessary for safe 

flight. Commenters also state that this reduces the resale value of the non -hydraulic equipped 

helicopters.

Do we agree? No

If YES, we agree because Make the following changes to the AD:

IfPARTIALLY AGREE, we agree with because

We disagree with because Make the following changes to the AD:

If NO, we don't agree because the R44 Astra is subject to the same unsafe condition if repetative 

inspections are relied upon to ensure their continued airworthiness. The FAA cannot require RHC to 

perform testing of the new blades with the non-hydraulic R44 Astra helicopter so that the new rotor 

blades can be installed on the R44 Astro without also having to convert the helicoptersto hydraulic 

assisted controls. The FAA has no basis to require the manufacturer to obtain FAA approval for a 

design that is does not want to propose or to support in service.

The main rotor blades for the non-hydraulic equipped R44 Astro helicopters are calendar life limited 

to 12 years,and will no longer be produced. Due to the decision of the manufacturer to discontinue 

production of the old design rotor blades and to not pursue FAA approval of installation of the new 

blades on the non-hydraulic R44 Astra, the owners of the helicopters will need to install hydraulic

assisted flight controls after 12 years regardless of the AD actions. The decision to discontinue rotor 

blades designed for the non-hydraulic equipped helicopters is a business decision by RHC. The FAA 

cannot compel the manufacturer to produce replacement parts.

The FAA acknowledes that the expense and down-time to accomplish the rotor blade replacement is 

greater for the R44 helicoptersthat are not equipped with hydraulic assisted controls (Astro models). 

The AD accelerates the retirement of the blades by up to 6 years for some helicopters, and between six

years and no impact for the rest of the affected helicopters. It is the FAA's intent to accelerate the 

retirement of blades subject to the repeatative inspection requirements. The absence of hydraulic 

controls does not change the rotor blade safety issue. While safety of the blades by continued 

inspection is possible in the short-term, continued reports of blade delaminations and an accident
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have shown that in in the long term the inspections are either incorrectly perfonned or eventually 

ignored by some operators. Therefore, i t is in the interest of safety to retire the main rotor blades that 

are suseptible to delamination before their life limit. Five years from the date of the AD to retirement 

of the blade was chosen to allow the manufacture of a sufficientsupply of blades, and to give 

sufficient advanced warning so that operators can plan forthe early retirement.

ISSUE 3: Select one of the following: Costs

!f ather, explain:

Commenter(s): (4) Robert DiGiovanni,John Robert Sierra Jr., Mark Dalton, Thomas Britt

What change to the AD action is req uested? No change is requested. The commentersstate that the 

proposed requirement to replace main rotor blades will profit Robinson Helicopter and they should pay 

for all or a portion of the cost of the AD actions.

Why is the change requested or how is it justitied? Robinson is changing blade styles

Do we agree? No

If YES, we agree because Make the following changes to the AD:

lfPARTIALLY AGREE, we agree with

Make the following changes to the AD:

because We disagree with because

If NO,we don't agree because the actions in the AD are based on a known safety issue, and the 

replacement of the main rotor blades with an improved design is in the interest of safety. The FAA has 

determined that the costs associated with the actions of this AD are reasonable given the safety issue.

ISSUE 4: Select one of the following: Costs

Ifother, explain:

Commenter(s): (I) Marc Desprets

What change to the AD action is requested? Require blade replacement at 2200 hour overhaul or 12 years 

instead of 5 year compliance time.

Why isthe change requested or how is it justified? RHCstarted the production of new MR blades about

3 years ago, and the 5-year replacement period would require some ownersto replace the MR blades long 

before reaching the 12-year inspection. The financial cost of compliance in this NPR does not take into 

account the fact that RHC will on ly install MR Blades with the full potential of 2200 HrsI 12 years 

during a RHC factory overhaul. This meansthat MR blades with 3 years Time In Service will be replaced 

again during this factory overhaul.

Do we agree? No

If YES, we agree because Make the following changes to the AD:

If PARTIALLY AGREE, we agree with

Make the following changes to the AD:

because We disagree with because
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If NO, we don't agree because the actions in the AD are based on a known safety issue, and the 

replacement of the main rotor blades with an improved design is in the interest of safety. Airworthiness 

cannot be ensured long-term by reliance on continued repetative inspections. This has been shown in 

service by continued reports of blade delaminations and a fatal accident. Therefore, it is in the interest of 

safety to retire the main rotor blades that are suseptible to delamination before their life limit. Five years 

from the date ofthe AD to retirement ofthe blade was chosen to allow the manufacture of a sufficient 

supply of blades, and to give sufficient advanced warningso that operators can plan for the early

retirement. The FAA acknowledges that in some situations the cost to the operator may be in excess of

the cost of the replacement blades. The FAA has determined that the costs associated with the actions of 

this AD are reasonable given the safety issue.

ISSUE 5: Select one of the following: Other

if other, explain: lt is a comment that bare metal can be seen on areas of the helicopter and that the OEM

provides poor corrosion protection on the helicopter. 

Commenter(s): (!) Paulo Lima

What change to the AD action isrequested? None

Why isthe change requested or how is it justified? Metal to metal contact is the cause of the corrosion 

that occurs on the main rotor blades which is part of this AD action.

Do we agree? No

If YES, we agree because Make the following changes to the AD:

lfPARTIALLY AGREE, we agree with

Make the following changes to the AD:

because We disagree with because

IfNO, we don't agree because the presence or lack of presence of metal to metal contact may be a 

mechanism that is causing the corrosion in the rotor blade tip cap to skin interface but this is accounted 

for in the inspections in this AD. Metal to metal contact has not been shown to be a mechanism for skin 

debond in the area of skin to spar debond that has been found in the fleet that this AD is attempting to 

correct.

ISSUE : Select one of the following:

if other. explain:

Commenter(s):

What change to the AD action is requested?

Why is the change requested or how is it justified? 

Do we agree?

If YES, we agree because Make the following changes to the AD:

lfPARTIALLY AGREE, we agree with

Make the following changes to the AD:

because We disagree with because

If NO, we don't agree because
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ISSUE : Select one of the following:

Jfother. explain:

Commenter(s):

What change to the AD action is requested?

Why is the change requested or how is it justified? 

Do we agree?

If YES, we agree because Make the following changes to the AD:

If PARTIALLY AGREE, we agree with

Make the following changes to the AD: 

If NO, we don't agree because

For additional issues, double-click here

because We disagree with because
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Signature Section

Signature indicates concurrence with this action. 

Originating Office Tracking No.:

Branch Manager Date