Devlin Talkington

Document ID: FAA-2010-0427-0010
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: June 08 2010, at 12:00 AM Eastern Daylight Time
Date Posted: June 10 2010, at 12:00 AM Eastern Standard Time
Comment Start Date: April 22 2010, at 12:00 AM Eastern Standard Time
Comment Due Date: June 21 2010, at 11:59 PM Eastern Standard Time
Tracking Number: 80afe71e
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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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According to the US Military maintenance manual TM55-1520-210-23-1 the retirement life utilized by the Army and all other public entities is 2400 hours. As stated in this NPRM the same process causing corrosion is not utilized on the P/N 204-310-101-101 straps. So where is the reasoning? The estimated financial impact contained in the NPRM is grossly inaccurate. The real number fleet wide is closer to $10,893,224.00 not including ferry flights to maintenance or other incidental expenses such as seals, orings nuts and bolts. The Bell published list price is $7267.00 ea. which is somewhat higher than the $6250.00 used in tis NPRM. What prompted this AD? Has there been any documented failures on the 204-310-101-101 strap assembly? If so please disclose them? It is in my opinion the 24 month life limit imposed on the Bell 204, 205, 212 and now the UH-1 series has no basis. If there is a true basis please let the public know what it is.