FR 2025-02221

General Summary

This document presents a proposal from the Federal Aviation Administration (FAA) concerning airworthiness directives for specific models of helicopters manufactured by Leonardo S.p.a. The models affected include the A109E, A109S, and AW109SP. The initiative arises from reports of incorrect installations of motor cables and bonding braids associated with the engine fire extinguisher systems. These deficiencies could potentially compromise the engine fire extinguishing capabilities, resulting in loss of control over the helicopter during a fire incident. The FAA intends to rectify these issues by mandating inspections and corrective actions, guided by a related European Union Aviation Safety Agency (EASA) directive. Public comments are sought on this proposal until March 24, 2025, after which it may be amended based on the feedback received.

Significant Issues or Concerns

The document leaves several areas open to interpretation or lacks specificity, which could lead to confusion among stakeholders:

• Ambiguity in Exceptions: The text mentions "any differences identified as exceptions" without detailing what these exceptions entail. This could lead to varying interpretations among operators and maintainers.

• Undefined Terms: Terms such as "the ASB" are used without prior explanation, thus potentially causing confusion for those not intimately familiar with the terminology.

• Cost Considerations: While the document provides a basic estimate of compliance costs, it does not delve into additional expenses that might be incurred beyond the basic corrective measures such as re-installation.

• Compliance Penalties: There is no mention of potential consequences or penalties for failing to comply with the directives, which could be important for stakeholders to understand the severity of non-compliance.

• Access to Materials: The document assumes that stakeholders have normal access to the necessary materials but does not provide alternative access methods for entities that might lack such resources.

• AMOC Process Details: The description of the process for approving Alternative Methods of Compliance (AMOCs) is quite brief, lacking details about the timeline or the criteria for approval. This may lead to uncertainty for those seeking alternative compliance methods.

Impact on the Public Broadly

This proposed rule represents an effort to enhance aviation safety, which broadly benefits the public by aiming to prevent potential accidents. The focus is on ensuring that the helicopter components related to fire suppression systems are correctly installed and function as intended during emergencies. Such measures are crucial for preventing in-flight crises that could affect not just aircrew but also passengers and those in areas where helicopters operate.

Impact on Specific Stakeholders

• Helicopter Operators and Owners: These stakeholders will face direct impacts due to this proposal. They would need to allocate time and resources to inspect the specified systems on their aircraft and undertake any necessary corrective actions. While improved safety should be seen as a positive outcome, there is a cost associated with these inspections and repairs that operators must bear.

• Maintenance Organizations: Maintenance facilities could see increased business due to the required inspections and corrections. However, they might also encounter challenges if the required materials are not easily accessible or if they need to familiarize themselves with new compliance concepts.

• Small Business Impact: There is a regulatory assertion that the proposed AD will not significantly impact small entities, yet the rationale is not made clear. This could concern smaller operators who might be disproportionately affected by compliance costs.

In summary, while the proposed directives are crucial for ensuring safety, they bring about several considerations that must be addressed to minimize uncertainty and ensure smooth implementation for all affected parties.

The Federal Aviation Administration (FAA) has proposed a regulation that involves financial implications for operators of certain Leonardo S.p.a. helicopter models. This proposed rule aims to inspect and, if necessary, correct the installation of motor cables and bonding braids connected to engine fire extinguishers. The financial considerations surrounding this proposal are critical for stakeholders to understand, as they directly impact compliance costs.

Cost Estimates and Financial Impact

According to the document, the FAA estimates labor rates at $85 per work-hour. This flat rate serves as the basis for calculating the financial cost of meeting the proposed inspections and any necessary corrective actions. Specifically, inspecting the engine fire extinguisher bottle electrical connections is expected to require 1 work-hour, translating to an estimated cost of $85 per helicopter. When scaled across the entire U.S. fleet, which consists of 101 helicopters, the total estimated cost for compliance is $8,585.

In scenarios where the installation of the motor cables and bonding braids needs to be corrected, the document anticipates that disconnecting and reinstalling these components would again take up to 1 work-hour per helicopter, adding another potential $85 of expense per helicopter.

Relating Financial References to Identified Issues

The financial estimates contained in the document do not account for any potential costs beyond the basic inspection and adjustment of the cables. This raises a significant issue, as stakeholders may face additional, unanticipated expenses, depending on the complexity of rectifying improperly installed systems. The absence of a detailed breakdown of these further potential costs constitutes a gap in the financial information provided.

Additionally, while the document mentions that the proposal will not significantly impact small entities, it does not provide a detailed explanation or criteria for this determination. For smaller operators or those less familiar with compliance processes, understanding the total impact, including potential hidden costs, is crucial.

The regulatory text also mentions "exceptions" and "Alternative Methods of Compliance (AMOCs)" without specifying any financial ramifications these might entail. Such ambiguity could lead to uncertainty about the financial resources necessary to achieve compliance, particularly if operators pursue alternative methods that differ from those outlined in the proposed rule.

Conclusion

In summary, the financial elements of this proposal center on the labor costs associated with inspecting and potentially correcting the installation of components in the helicopters. Although basic cost estimates are provided, the document lacks a comprehensive explanation of additional costs and financial impacts beyond those tied directly to the inspection and correction phase. Operators, especially smaller entities, might find themselves uncertain about the real financial burden of compliance due to these gaps, underscoring the need for a clearer and more detailed financial analysis within such proposals.