### Disposition Comments
Docket No: FAA-2014-0498 Directorate ID: 2013-SW-052-AD Originating Office Tracking No.: 

### 0 These comments are in response to an SNPRM



### Next Step: 1:81 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 previouslypublishedNP RMwill require a new notice. Contact the Directorate focalpoint for guidance. 

### Latest Revision

. 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 the following: compliance time 

### If

other, explain: Commenter(s): Airbus Helicopters, Inc. via Mike May What change to the AD action is requested? You are penalizing the operators that operate in a non-salt laden atmosphere to a 300 hour check when the EASB allows for a 660 hour check in these conditions. The EASB allows for the inspection 10% tolerance, recurring inspection at 330 hours salt laden environment and 660 hours non-salt laden environment. Why is the change requested or how is itjustified? You are taking away the tolerance from the operator, this could faciliate planning issues with tools and personal
Do we agree? Yes If

### YES, we agree because Upon further consideration safety is not compromised by recognizing the reduced exposure to a corrosive environment afforded aircraft that operate in non-salt laden environments as defined in the EASB. Further, changing the recurring inspection interval to 330 from 300 hours, for salt laden environments and allowing 660 hour intervals for aircraft in non-salt laden environment, aligns with normal scheduled maintenance cycles with no reduction in safety. Make the following changes to the AD: Change AD paragraph §39.13(f) Required Actions to read: Before the next practice autorotation or on or before the next 100 hours time-in-service (TIS) , whichever occurs first, and thereafter at inte rvals not to exceed 330 hour TIS , for aircraft that operate or have operat ed since the previous compliance inspection in salt laden conditions OR at intervals not to exceed 660 hours TIS for aircraft which do not operate and have never operated since the previous compliance inspection in salt laden conditions [Salt laden conditions persist when an aircraft is ship-based, based less than 0

.5 miles from salt water or performs a flight over salt water at low altitude ( below 1 OOOft)] , inspect the wiring, perform a compliance inspection by following the Accomplishment Instructions , paragraph 3.B Operational Procedure ofEurocopter Emergency Alert Service Bulletin (EASB) No

. 05. 00 .61 , Revision 2, da ted August 13 , 2013 , for Model AS350B3 helicopters or EASB No. 05A009 , Revision 2, dated August 13 , 201 3, for Model EC130B4 helicopters, as appropriate for your model helicopter.



### Page 

### 1 of4IfPARTIALLY AGREE, we agree with Insert text because Insertjustification 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

ISSUE 2: Select one of the following: compliance time If other, explain: Click here to enter text. Commenter(s): Mike Shannon What change to the AD action is requested? The failures have been attributed to operations in a corrosive environment. The inspection intervals in the Manufacturers Service Bulletin are different due to operating conditions. Aircraft operated in a non-corrosive environment should only have to perform the inspection at 660 hours as per the service bulletin instead ofthe 300 hour requirement as per the proposed Airworthiness Directive

. The proposed Airworthiness Directive does not allow for the inspection interval tolerance of I0% as per the Manufacturers Service Bulletin. Any inspection requirement interval should include this tolerance to allow for maintenance planning. Why is the change requested or how is itjustified? The inspection interval should be 330 hours for aircraft operated in a salt laden or corrosive environment and 660 hours for aircraft operated in a noncorrosive or non-salt laden environment. This would allow the inspection to be performed at the same interval as the other existing Manufacturers inspection intervals. Do we agree? Yes If YES, we agree because Upon further consideration safety is not compromised by recognizing the reduced exposure to a corrosive environment afforded aircraft that operate in non-salt laden environments as defined in the EASB. Further, changing the recurring inspection interval to 330 from 300 hours , for salt laden environments and allowing 660 hour intervals for aircraft in non-salt laden environment, aligns with normal scheduled maintenance cycles with no reduction in safety. Make the following changes to the AD : Change AD paragraph §39.13(f) Required Actions to read: Before the next practice autorotation or on or before the next 100 hours time-in-service (TIS) , whichever occurs first, and thereafter at intervals not to exceed 330 hour TIS, for aircraft that operate or have operated since the previous compliance inspection in salt laden conditions OR at intervals not to exceed 660 hours TIS for aircraft which do not operate and have never operated since the previous compliance inspection in salt laden conditions [Salt laden conditions persist when an aircraft is ship-based, based less than 0.5 miles from salt water or performs a flight over salt water at low altitude (below lOOOft)], inspect the wiring, perform a compliance inspection by following the Accomplishment Instructions, paragraph 3.B Operational Procedure ofEurocopter Emergency Alert Service Bulletin (EASB) No. 05.00

.61 , Revision 2, dated August 13 , 2013 , for Model AS350B3 helicopters or EASB No. 05A009 , Revi sion 2, dated August 13 , 2013 , for Model EC 13 OB4 helicopters , as appropriate for your model helicopter. IfPARTIALLY AGREE, we agree with Insert text because Insertjustification 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

ISSUE 3: Select one of the following: Service Info If other , ex pl a in: Click here to enter text. Page 2 of 4

### Commenter(s): Tim Shannon What change to the AD action is requested? The proposed Airworthiness Directive requires compliance with paragraph 3

.B.l thru 3.B.6 but the replacement requirement in paragraph 3.B.2 is only required ifthe aircraft fails the inspection requirements ofparagraph 3 .B.l. Why is the change requested or how is itjustified? The Airworthiness Directive should not require compliance with paragraph 3

.B.2 unless it fails the inspection requirement.
Do we agree? Yes If YES, we agree because The replacement requirement in paragraph 3.B.2 is only required ifthe aircraft fails the inspection requiremd nts of. paragraph 3.B.l Make the following changes to the AD: Inspection instructions will point to paragraph 3

.B Operational Procedure, so as to bypass step 3 .B.2 ifno failure is found in step 3 .B.l. See text for the Required Action paragraph changed to the AD in the previous two comment responses. IfPARTIALLY AGREE, we agree with Insert text because Insertjustification We disagree with Insert text because lnsertjustificationMake 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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. Originating Office Tracking No.:

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