Shawn Abbott

Document ID: FAA-2011-0588-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: July 18 2011, at 12:00 AM Eastern Daylight Time
Date Posted: July 19 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: June 17 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: August 16 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80ec5ae3
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I own and operate RH44 S/N 0660, C-GHWI. It has 463 hours since field overhaul at 2194hr on June 25th, 2008. My experience suggests I will enjoy continued cost effective and reliable service from the aircraft until June 25th, 2020. My AME has advised that a field overhaul is no longer available and a factory rebuild will be required at that time due to the modifications required under SL-37 to support new blades. I called the factory today and they have advised me that at today's prices, I should budget $300,000 for this rebuild. It is unclear that this would be economically rational relative to market value of low time new machines, making it likely that the machine will be de-certified and sold for parts at that time. I am deeply troubled by the following language from the AD: "We are considering a subsequent AD to terminate the inspection requirement by mandating the replacement of these rotor blades." My concern and comment arise from the implication that the FAA may mandate the replacement of all C016-5 blades, because there are no alternative blades available for my ship. Installation of a newer series of blades requires the factory rebuild. A mandate to replace -5 blades at this time would destroy 9 years of future flying value, or 1,740 hours service. I want to be certain that any evaluation of the economic impact of declaring -5 blades unairworthy acknowledges the fact that some number of machines will be effectively de-certified. As your above statement says, "the actions taken in AD 2007-26-12 have been shown to detect and to prevent the debond problem". In my particular case -- operating from CYBW where none of the causal factors associated with blade debonding exist -- reliance on continued inspections is most certainly an adequate and appropriate long term solution. Mandating replacement of -5 blades would have the unintended consequence of immediately grounding and placing an entire class of safe machines beyond economical repair.

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