Paul Armstrong

The US Army has accumulated approximately 1.75 million accident incident free flight hours since 1959 (51 years) utilizing the Bendix 204-012-122-1, 204-012-122-5 and 204-012-112-5&7 TT-Straps. These part number TT-Straps are no longer in production and are not available. The Lord TT-Strap Part number 204-310-101-101 is the only strap available and has been for a considerable time now. Although the Bell 212 accident that occurred in the Gulf of Mexico had the Bendix TT-Straps installed there is no historical evidence (Hard Cards) available to indicate exactly how many hours or months/years were on the straps at the time of failure. The Proposed AD does not address the fact that the Bell 212 and certain models of the Bell 205 have a much higher maximum torque value 56 PSI (1290 SHP to the Main gear box)as versus 50 PSI (1100 SHP to the Main gear box) which places much greater stress on the TT-Straps than in the UH1 series helicopters @ 50 PSI. The old, no longer available, Bendix straps were incased in a protective coating of urethane using Caytur 21 as a curing accelerator resulting in corrosion (see NPRM2010-0427 comments section). The Lord TT-Straps use a MOCA curing agent that does not pose a corrosion problem. The introduction of the new Lord 204-310-101-101 TT-Straps should have put an end to this AD way back in 2002 as not applicable by part number. There is NO EVIDENCE that the new Lord straps are, will, or may corrode under any condition if properly installed and maintained. There is a gross understatement in the governments estimation of the cost of this AD as well. Using a Bell service center quote on parts, and an FAA Repair Station for the labor estimate the actual cost per aircraft is: 1. 204-310-101-101 @ 7000.00 ea. 14,000.00 2. S32979-341G99 @ 119.00 ea. 238.00 3. 204-011-171-3 @ 190.00 760.00 4. 42FLW820X @ 17.10 68.40 5. 140-007-33528-3 @ 28.00 112.00 6. AN960-816 @ .25 2.00 7. M83248-240 @ 4.50 9.00 8. M83248-237 @ 6.50 26.00 TOTAL for Parts 15215.40$ Labor @ 90.00 per hour 30 hours= 2700.00$ Track and balance rotor system= 1890.00$ Total cost of AD per aircraft= 19805.00$ The number of US registered helicopters effected by this AD is closer to 585 @19805.00 ea = $11, 585,925.00 (where did the FAA come up with 25 straps?). There is absolutely no justification for this AD. Its basis is absurd has no scientific backing, and appears on face value to be based on unreliable/false data. The comment period for this AD must be extended until November 2010 so that non-destructive testing (NDT), operators, and repair stations have ample time to have input on this AD.