Michael Donahue

In reviewing this NPRM, it is written against the blade assembly. This will make this AD very difficult to track for an operator with a large fleet. Since the propeller is modular and blades can be moved around from assembly to assembly, the chance of missing an inspection becomes high. As an alternative, I suggest that the AD be written against the propeller assembly, at which time all four blades are inspected. This way, no tracking of individual blades is required and whichever four blades are in the assembly at the time of the inspection are inspected. Because the blades can move from prop to prop, a requirement to inspect all four blades at the time the propeller is assembled, "zero- ing out" the inspection, will prevent any blade in the assembly from exceeding its' inspection interval. This would be much easier to administer in the long run and make compliance easier. though I realize this is not the way the service bulletin is written.