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 

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

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 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: 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 it justified? 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 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 1 OOOft)], inspect the wiring, perform a compliance inspection by 

following the Accomplishment Instructions, paragraph 3.B Operational Procedure of Eurocopter 

Emergency Alert Service Bulletin (EASB) No. 05.00.61 , Revision 2, dated August 13, 2013, for 

Model AS350B3 helicopters or EASB No. 05A009, Revision 2, dated August 13, 2013, for Model 

EC130B4 helicopters, as appropriate for your model helicopter. 

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

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

changes to the AD 

If NO, 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 of the 300 hour requirement as per the proposed 

Airworthiness Directive. The proposed Airworthiness Directive does not allow for the inspection interval 

tolerance of I 0% 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 it justified? 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 of Eurocopter 

Emergency Alert Service Bulletin (EASB) No. 05.00.61, Revision 2, dated August 13, 2013, for 

Model AS350B3 helicopters or EASB No. 05A009, Revision 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 Insert justification We disagree with 

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

changes to the AD 

If NO, we don't agree because 

ISSUE 3: Select one of the following: Service Info 

If other, explain: Click here to enter text. 

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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 if the 

aircraft fails the inspection requirements of paragraph 3 .B.l. 

Why is the change requested or how is it justified? 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 requiremdnts 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 if no 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 Insert justification We disagree with 

Insert text because lnsertjustificationMake the following changes to the AD: List any changes to the 

AD 

If NO, we don't agree because Insert our rationale 

For additional issues, double-click here 

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Signature Section 

Signature indicates concurrence with this action. 

Originating Office Tracking No.: 

ASE Printed Name: Date 

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