Comment from ROBERT SMITH

5 State Helicopters, Inc. currently operates two UH-60 aircraft under separate FAA-approved type certificate data sheets (TCDS). One aircraft is a UH-60A operating under the Delta Engineering type design, while the second is a UH-60L operating under the Pickering Aviation type design. We are concerned that the proposed Airworthiness Directive appears to apply broadly across multiple UH-60 type designs without adequately addressing the differences between these FAA-approved configurations. Pursuant to 14 CFR §39.5, an Airworthiness Directive applies to a product when an unsafe condition exists in that specific product and the condition is likely to exist or develop in other products of the same type design. In this case, the FAA has not provided sufficient technical justification demonstrating how an unsafe condition identified within one type design can be automatically extended to another independently approved type design. As an operator directly affected by this action, 5 State Helicopters strongly opposes the proposed AD in its current form. We respectfully request that the FAA provide the supporting technical data and legal rationale demonstrating compliance with the requirements of 14 CFR Part 39 before proceeding with any final rulemaking action. Regulatory actions of this magnitude should be supported by clear engineering evidence and should appropriately recognize distinctions between separately approved type designs.