Docket No: FAA-2016-4278 

Directorate ID: 2012-SW-022-AD 

Originating Office Tracking No.: 

Disposition Comments 

Next Step: w{RAN D SNPRM 

D These comments are in 

response to an SNPRM 

D No Comments/Only Supportive Comments Received - 1ft his box is checked, no signatures are 

required. 

\. t<:':\ l ;..,' ,-\...:....) 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 ofthe 

previous~v published NPRAt will require a nevv notice. Contact the Directorate focal point 

for guidance. Lltc>l lZ.~\ i ,j '•1 

Instructions: Summarize all conrments 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. f 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 ofthefo!lmving: withdraw the NPRM 

~lother. explain: 

Commenter(s): Ray Sullivan from ERA Helicopters LLC 

What change to the AD action is requested? "Comment for NPRM 2016-4278 Operational 

checks of# 1 and #2 hydraulic systems. I am against the addition of an AD for these 

hydraulic system checks as the checks already exist in our maintenance program. Due 

to the release of BT139-269 and EASA AD20 11-0207, we currently have a 600 

hour/12 month inspection/operational check that covers all of the items in this new 

AD. The new AD would not change any of our maintenance procedures, only require 

additional paper work for the same result. Thank you." 

Why is the change requested or how is it justified? '· 1,.._·:, l k'L. tt· ,·,1 :1 ; .. ' ,i 

Do we agree? No 

If YES, we agree because I 1, .• ·n i'.', ; ';. 1 i · Make the following changes to the AD: l l"l .rt'< 

IfPARTIALLY AGREE, we agree with !,,·· ' ,r because I,.,,,_''; ·<:ik ,.!.' We disagree with 

! ; ,," t !.-.."\' because I 1 '•~. t i " !. Make the following changes to the AD: [ i ., ! , , 

If NO, we don ' t agree because The commenter's position that he is "aga inst the addition of an AD" is 

understandable, however the FAA does not agree for the following reasons: I. EASA AD 20 I 1-0207 

is not mandatory for US operators. EASA AD 2011-0207 identified a potential latent safety concern 

for which the operational checks mandated by the AD help identify. US operators are under no 

obligation to perform any actions identified in EASA ADs. The FAA must issue an FAA AD in order 

for those actions to become mandatory. 2 . Any information in ASBs. Tech Bulletins, etc. may get 

incorporated into the appropriate maintenance manual ; however the updated maintenance manual is 

not required by helicopte'r operators. Only the maintenance manual revision that was provided when 

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they acquired the helicopter is required to be followed by helicopter operators. In order for the 

updated actions in the revised maintenance manuals to be mandatory, the FAA must mandate those 

actions through the use of an AD. 

ISSUE 2: Select one qfthefollmving: Clt''l"'.: ,1,1..:. 

![other. explain: Click lh·rc l\l cnh.'r ic.'\l. 

Commenter(s): Click h..'t\.' lll .._'ntct· k.\t. 

What change to the AD action is requested? C 'l:ck h,;r: lP ,'tll..:t· \...?.\!. 

Why is the change requested or how is it justified? Click h-..'t\.' lLl l'i1t'-'l" \...'\l. 

Do we agree? '1 '-'"' :\ u 

If YES, we agree because ! n-.;cn .i lhti t!,:;lliLll1 Make the following changes to the AD: l is\ ~\11) 

ch .. 111~2:.:s tu the ,\D 

If PARTIALLY AGREE, we agree with ln-,crt tc\.l because lnscnjll':ti!icati(-.n We disagree with 

lns ... ·n k\.l because Insert _iu:->titic<tliPI1 Make the following changes to the AD: List <m; 

c!:ms ... ·s lLl th.: \[) 

If NO, we don't agree because lth-."1'\ <•lii r,t[;(ltl,tL.: 

For additional issues, double-click here 

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Signature Section 

~ignature indicates concurrence with this action. 

Originating Office Tracking '-Jo.: 

ASE Printed Name: I Date 

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