Airworthiness Directives: Various Helicopters

Touchdown Aviation LLC opposes the proposed Airworthiness Directive, arguing that the mandatory modifications impose excessive costs and logistical burdens on small operators without sufficient evidence of a widespread safety crisis. The commenter suggests that the FAA should instead rely on enhanced inspection regimes and optional modifications to maintain safety while preserving the economic viability of the firefighting and utility helicopter fleets.

Vertical Aviation International, a global trade association for the civil vertical aviation industry, opposes the proposed Airworthiness Directive as currently drafted. They argue that the FAA has failed to provide sufficient fleet-specific data to justify applying identical corrective actions to different aircraft types with different maintenance philosophies and retirement-life structures.

Aerocraft Inc. opposes the proposed Airworthiness Directive, arguing that it conflicts with existing FAA policies and regulations by requiring the use of proprietary, uncertified repair processes. They contend that the AD uses outdated data and could lead to the grounding of the UH-60 fleet or the installation of unapproved parts with reduced fatigue life.

Rotor Blade Repair, Inc. and 5 States Helicopters, Inc. oppose the proposed airworthiness directive, arguing that it incorrectly conflates different type certificates and improperly restricts maintenance to specific Sikorsky-authorized facilities. They request the withdrawal of the proposal, citing concerns over configuration control, regulatory non-compliance, and the potential for maintenance errors.

Firehawk Helicopters, Inc. opposes the proposed Airworthiness Directive, arguing that the FAA has not provided sufficient evidence that the unsafe condition exists in civilian aircraft with different operating profiles than military ones. The company asserts that their own fleet has not experienced the issues and that the FAA should provide a more reasoned, record-based explanation before requiring new T/R blades.

Firehawk Helicopters, Inc. opposes the proposed Airworthiness Directive, arguing that the FAA has not provided sufficient evidence that the unsafe condition exists in civilian aircraft with different operating profiles than military ones. The company asserts that their own fleet has not experienced the issues and that the FAA should provide a more reasoned, record-based explanation before requiring new T/R blades.

ACE Aeronautics, a manufacturer of UH-60A and L model rotorcraft, opposes the proposed Airworthiness Directive (AD) because it contradicts existing military maintenance data and creates an unworkable maintenance environment. They argue the AD imposes impractical inspection criteria, fails to account for specific part numbers, and unfairly forces them to rely on proprietary Sikorsky data and fees.

The United Aerial Firefighters Association (UAFA) opposes the proposed Airworthiness Directive as currently written, arguing that the 12-month compliance timeline would ground critical firefighting aircraft during peak fire seasons and impose an undue economic burden. They request that the FAA extend the compliance timeline to 24-48 months and incorporate the U.S. Army's inspection-based protocols as an approved alternative to mandatory modifications.

Billings Flying Service, LLC, a subsidiary of Quanta Services, Inc., requests that the FAA withdraw the proposed airworthiness directive in its entirety. They argue that the FAA exceeds its authority under 14 CFR § 39.5 by attempting to apply a corrective action to multiple helicopter types that do not share the "same type design."