In regards to this proposed rule making several factors must be weighed.
The first factor is of course Safety, so lets examine the safety aspect for a moment. The United States military has operated (until recent years) a fleet of over 1800 of this model aircraft, and has since the 1950's without EVER having a failure of a main rotor tension strap while at the same time operating these aircraft with a time life replacement of 2400 hours and no calendar replacement.
The one aircraft cited in this proposed rulemaking (the 212 which crashed offshore) has never been proven to have this failure, it was just suspected as the cause.
This company has never had a failure of any kind regarding tension straps and feel that this proposed rule making is not Justified in any way. When they are installed by the book they are protected from the elements in an air tight chamber within the main rotor hub.
If you wish to propose a rule change, may I suggest that it be to do away with the 24 month replacement time entirely and allow these items to be operated for 2400 hours with a 1200 hour mid-life inspection.
Let us cease in our attempts to correct a problem which does not exist.
Gary Baldwin
This is comment on Rule
Airworthiness Directives: Arrow Falcon Exporters, Inc. (previously Utah State University); California Department of Forestry; Firefly Aviation Helicopter Services, et al.
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