Robert DiGiovanni

Document ID: FAA-2013-0159-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: March 18 2013, at 12:00 AM Eastern Daylight Time
Date Posted: March 19 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: February 25 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: April 26 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-849q-dr64
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I have a concern over the validity of this AD revision. It begs the question. Is this the Robinson business model? Did Robinson knowingly sell the blades in question with this AD revision in mind? These type of blade AD terminations seem to be a continuing mode of operation. Considerations: • Has there been an issue with the blades since the inspection signoff? • How many fleet accumulated hours on the current blades? • How many fleet accumulated hours are on the new set of “safer” blades? • Are the customers now the test pilots for the new blades? • Robinson has also discontinued the manufacturing of the trim motor systems forcing the modification regardless of the blade condition. Another business decision or safety concern? • For R22 and R44 owners which require only blade changes then the replacement blade cost should be pro-rated based on the lost value due to the AD. • For R44 Astro owners, that will be required to convert to hydraulics, Robinson should not only pro-rate the blades but also share in the cost of the retrofit. Currently this conversion can only be performed at the Robinson factory. Robinson then reserves the right to upgrade any component on the helicopter to their latest revision even though there is no AD or SB stating the Robinson required change. • Please do not make your findings based on the recommendation of a company who stands to make millions of dollars.

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Apr 26,2013 11:59 PM ET