David Edwards

Document ID: FAA-2011-0588-0009
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: 80ec5be6
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This is comment on Rule

Airworthiness Directives: Robinson Helicopter Co. Model R22, R22 Alpha, R22 Beta, R22 Mariner, R44, and R44 II Helicopters

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Where did you obtain replacement cost figures from? Your estimate is totally incorrect! The cost of replacement blades for an older R44 is $80,000 to convert the machine to take the new blades. With a newer model even if Robinson provided the blades at half price the cost with spindles and labor would be $30,000+ My 3 year old Raven 1 with only 300 hours total time was found to have blade delaminating despite maintaining the blades to Robinson recommendations. The bond line has never been exposed as I have kept them well painted, and I have washed blades after every flight. I had to buy new blades and my helicopter was out of service for six weeks. This has been financially devastating from both a replacement cost and loss of revenue. Robinson needs to accept responsibilty for design defects and pay for them. This should not be an owner expense!