Page 

### 1 of6



### Docket No: FAA

- 201 3

- 0159

Directorate ID: 201 2

- SW

- 010

- AD

Originating Office Tracking No.: 

### D i s p o s ition Comments



## 0 These comm e n t s are in

response to an SNPRM



### Next Step: 

## f8J FRAN 

## 0 SNPRM



## 0 No Comment s

/ Only Supportive Comments Received



## - If this box is checked, no signarures are

required.

Has the referenced ser v ice information been revised since the NPRM was issued? If yes,

list latest r e vision and attach a copy. Note that changes beyond the scope of the previously

published N

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

I nstructions: Summarize all comments b y i ssue (not by commenter) and provide your recommended resolution of

each issue. All comments relatin g to the same i s s ue s hould be discussed together. Do not list all of the i ssues

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.

I SSUE 

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



## If othe r

, explain:

Commenter(s): (9) Steve Grossman, Mark Dalton, Startade Heli GmbH 

### & Co KG., Mark

Dalto n

, T hom a

s Britt, Marc Desprets, Edd i e Hurle y

, James Willia m s, George Meyer

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

inspections of tail rotor blad e s for all effected models.

Why i s the change requested or h ow is it j u stifi e d? The r e is insuffi c i e n t data to justify the termination of

t h e requi r

ement for repetative inspections and to r eplace the main r o

t or blades with n

ew blades that do not

require the AD i n spe c

tion. Inspections i f done correctly w i ll ensure continued operational safety.

Do we agree? No



### 1 f 

### YE S

, we agree beca u se Make the following changes to the AD:

I f 

### PARTIALLY AGRE E

, we agree with

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

I f N O

, we don't agree because blade debonds continue to occur in service. T h e c a u se of the d eb o nd

was determined t o be erosion on unpainted blade tip bond lines which a llows the bond to weaken a nd

the skin to pull up. This s ituatio n is sufficient to warrant an AD for inspection d u e to the catestrophic

cons e quenc e s if the blade becomes delaminated. Airwo11hiness cannot be e n sured l ong

- term by

reliance on contin ued repetative i n spections. In one i n s tance bla d e debond has l ea d to a fatality, and

so it is in the interest of safety to accelerate the r etirement of the bla d es from 12 years from bla d e

manufacture to an earlier date.Page 

### 2 of6

ISSUE 2: Select one of the following: applicability



## If other. expl a in:

Commenter(s): 

### (6) B r

ant Paul Swigat t

, Greg Morriso n

, R obett DiGiovann i

, Sta t trade H e li GmbH 

### & Co

KG

. , Mark D alto n

, Miarage Helicopters Inc

. ,

What change to the AD action i s 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 mod e l s w h i c h are not

equipped with h ydra u lic assisted contr o ls or r e q uire R H C to perform testing of the new blades with the

non

- hydra u l ic R44 Astro helicopter so that the new rotor blades can be installed on the R44 Astro wi t h out

also having to convett the hel i co p ters to hydraulic as s i ste d con t r ols.

Why i s the change requested or how is it justified? The n ew rotor blad e s c a n n ot be installed on the R44

As t r a models u n l es s the helicopter i s converted to h ydraulic assisted contr o l s. Th i s i s because the new

rotor blades have n ot been tested and certified for the R 44 As t r o modes which are not equipped with

hydraulic as s i s te d controls. T h e r equirement to r e place t h e main rotor blades with the new rotor b l ades

for these helicopte r s also then requires th o se h e licopters to be converted to hydraulic assisted contro l s

w h i ch is an additional expense.

C u rrently th i s conversi o n can o n l y be performed at the Robinson factory. Robinson then reserves the r i g ht

to upgrade any component on the helico p ter to their latest revision even though there i s no AD or SB

stating the Robi n s o n required change. Th i s Robinson requirement r e su l ts in a d d i tion a l cost increase.

Commenters state that the i n st a llation of replacem e nt main rotor blades for the R44 Astro models

therefore also entails a costly conversi o n to hydraulic assisted contr o l s w h i c h are not n ecessary for safe

flight. Commenters also state that this red u ces the resale value of the non

- hydr a ul i c equipped

h elicopter s

.

D o we agree? No



### I f YES, we agree because Make the following changes to t h e A D :

I fP A RTIALL Y AGRE E

, we agree with because

We disagree with bec a u se 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 re p e ta t ive

inspections are r

elied upon to e nsure their continued airworthiness. T he FAA cannot require RHC to

perform testing of the new blades with the non

- hydraulic R 44 Astra helicopter so that the new ro t or

blades can be installed on the R44 Astro without a l so having to convert the helicop t e r s to hydraulic

assisted contr o l s. 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 ser v i ce.

T h e main rotor blades for the non

- hydraulic equipped R44 As t r o helicopters are calend a r life limi t e d

to 12 yea r s

, a n d will no lo n g e r be produ c ed. Due to the de c i sio n of the manufacturer to discontinue

p r odu c tion of the o l

d design r

otor blades a nd to not pursue FAA approval of i nstallation of the new

blades on the non

- hydraulic R44 Astra, the owners of the helicop t ers w i ll need to in s tall hydraulic

assisted flight controls after 12 years regardless of the AD actions. The decision to disc o n tinue r otor

blades designed for t h e non

- hydraulic equipped helicopters is a busin e ss decision by RHC. The FAA

cannot compel the manuf a c t urer to prod u ce r

eplacem e nt parts.

The FAA acknowledes that the expense and down

- time to accomplish the rotor blade replacement i s

great e r for t h e R44 hel i copt e r s that are not equipped with hydraulic assist e d controls (Astro mode l s).

The AD accel e r a tes the retirement of t h e blades by up to 6 ye a r s for some hel i copters, and bet w een si x

years and no impact for the rest of the affec t ed heli c opter s

. 

### It i s t h e FAA's in t ent to accelera t

e the

retirement of blades subject to the repeatative inspection requirements. The absence of hydraul i c

controls d oes n ot change the rotor blade safety issue. While safety of the blades by c o ntinued

inspection i s possible in t h e s hort

- ter m

, co n tinued reports of blade delaminations and an acci d ent

### Page 3 of6

have shown t h at in in the l o n g term th e inspections are e ither incor r ec t l y perfonn ed or ev e n t ual l y

i g n ore d by s o m e operato r s. T h e refor e

, i t i s in the in t

e r est o f safety to r

e t ire the main rotor bla d es that

are s useptib l e to d e laminat i o n before their life limit. Five ye a r s from the date of t h e AD to retirement

of the blade was chose n to a l l ow the ma n u facture of a suffi c i ent s u p p l y of blad e s, and to g i v e

s ufficient advanced w a

rni n g so that operators can plan for the early r e t irement.

ISSUE 3 : Select o

n e of t h e follo w ing: 

### Costs

!f ather, explain:



### Commenter(s): (4) Robert DiGi ov a nn i

, John Robert Sie r ra 

### Jr

. , Mark D alton, Th o m a s Britt

What c han g

e to the A D ac t i on i s r

e q u e s t ed? No ch a n ge i s requested. Th e com me n t e r s state that the

p r oposed r eq u i rement to re p l ace main rotor blades will profit Robinson H elicopter and they should pay

f o r a ll o r a portion of t h e cost of the AD actions.

Why i s the change r

e que s t e d o r h ow is it j u s ti tied? Robi n s o n i s c ha n g i n g blade styles

D o we agree? No

If Y E S

, we agr e

e because Make t he following ch a n ges to the AD:

l fPAR T IALL Y AGRE E

, we agree with

Ma k e the following c ha n ges to t h e AD: beca u se We d i sa g r ee w i t h bec a u se

I f N O

, 

### we don't agree because t h e ac t i ons in the A D are based on a known safety issu e

, a n d the

r e p l ac e ment of the m ai n rotor b l ade s with an improved d e s i g n i s in the i n t e r e s t of safety. T h e FAA has

d e t e rmi n e d that the co s

ts a sso c i ate d with th e a c tio n s of th i s AD are r easona ble given t h e saf

e ty i s s u e.

IS S UE 4 : Select one of the followin g : 

### Costs



## If o t h e r

, expla i n:



### Commenter(s): (I) 

### Marc Desprets

What c han g

e to the AD action i s r

e q ueste d ? Require blade r e p lacem e nt at 2 2 00 hou r ov e rhaul or 12 yea r s

i n s t ea d of 5 year c o mpl i an c e tim e

.

Why is t h e ch a n ge requested or h o w i s it justified? R H C started the produc t i o n of new MR blades about

3 years ago, and the 5

- ye a r re p l acem e n t period would requi r e some owners to replace the MR blades l o ng

before reachi n g the 1 2

- ye a r i n spec t i o n. Th e financial cost of c o mplian c e in this NPR does not ta k e in t o

ac c o unt the fact that RHC w i ll on l y install MR B l a d e s w ith t h e full potential of 2200 Hr s I 

### 12 yea r s

duri n g a RHC fac t

ory overhaul. This mea n s that M R bla d es with 3 years Time In Service wil l be replaced

again during this factory ov e r h aul.

Do we a g r e e? No

If YE S

, we agree because Make the f o l l o w i n g c h anges to t he AD:

I f PARTIALLY AGRE E

, we agree with

Ma k e the following c h a n ges to the AD: because We disagree w ith because

### Page 4 of6

If N O

, we don't agree because the actions in the AD are based on a known safety iss u e, a nd the

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

cann o t be en s ured l on g

- term by r e l iance on continued repetative i n s pectio n s. T h i s has been s h own in

s e rvice by conti n u ed r e ports of blade delaminatio n s and a fatal accident. Therefore, it is in the interest of

s a fety to r e tire the m ain rotor blades that a r e s useptibl e to delamination before their li f e limit. F ive years

from the date of

t h e AD to reti r

e ment ofth e blade w a s c hosen to a l l ow th e manufacture of a sufficient

s upply of blades, and to give suffi c ient advanced warni n g so that o p e r ators can p l a n f

or the ea r l y

r et ireme n t. The FAA acknowledges that in some situations the cost to the operator m a y be in ex cess of

t he cost of the repl a ceme n t bla d e s

. T h e FAA has d etermi n ed that t h e costs asso c iated w ith the act i o ns of

this AD a r

e reasonab l e g iven t h e s a fety i s s u e.

ISSUE 5: S e lect o n

e of the following: Ot h er



## if other, e x

plain: lt i s a comment that bare metal c a n be seen on a r eas of t h e h e licopte r a nd that the OEM

provides poor corr o s ion protection o n the h e licopter.

C o m m e n t

e r (s): (!) P aulo Lima

What cha n ge to the AD action i s requested? N o ne

Why i s the c hange r

e q uested o r how is it justified? M etal to metal conta c t is the cause of the corr o s i on

that occu r s on the main rotor blades which is part of th i s AD action.

D o we agree? No

If YE S

, we agree because Make the following ch a nges to the AD:

lfPARTIALLY AGRE E

, we agree with

Make the f

o l l o w ing cha ng e

s t o the AD: beca u se We disagree with because

IfN O

, we d o n 't ag r

ee because t h e presence o r lack of p r e s ence of metal to metal c o nt a ct may be a

mechan i s m that i s causing the corro s ion in the rotor blade tip cap to sk i n in t e rface but t h i s is accounted

f o r in the i n s pect i o n s in this A D

. Metal to m e t al contact has n ot been shown t o be a mechanism for s kin

debond in the area of s kin t o sp a r debond that has b e e n found in the fleet that th i s AD i s att e mpti n g to

correct.

ISSUE : Se l e c

t o n e of t h e f o ll o wing:



## if other. ex

p lain:

C o mmen t er (s) :

What change to the AD action i s requeste d ?

Why is t h e change r

e q uested or h ow is it j u s tified?

Do we agree?

If YE S

, we agree because Make the f o llowi n g ch a ng e s to the AD:

l fPARTIALL Y AGRE E

, we a g ree with

Make th e f

o l l owing c hanges t o the AD: beca u se We disag r ee with because

If NO, we don't ag r

ee becausePage 5 

### of6

ISSUE : Select one of the following:



## Jf other. ex p lain:

C o m m enter (s) :

What cha n ge to t h e AD action i s requeste d ?

Why is the ch a n g

e requested or how is it justified?

Do we ag r

ee?

I f 

### YE S

, we a g ree because Make the following changes to the A D:

If 

### PARTIALLY AGREE, we agree with

Make the follow i n g c hanges to the AD:

I f 

### N O

, we don't agree bec a u s e



### For addition a l iss u es, double

- click h e r e beca u se W e disag r ee w ith becau s

e

### Page 6 of6 Signature Section

Signature indicates concurrence w i t h this action.

Or i g inating Office T r acking No.:

Branch Manager Da t e