On January 3, the FAA issued an Airworthiness Directive that goes into effect on January 18 — zero notice, without the customary public comment period.
It attempts to address a safety issue concerning Robinson helicopter blades — one that is already amply covered by Robinson service bulletins, service letters, and safety alerts — but does so in a terribly ham-fisted way. There are two serious problems.
First, it requires the pilot to make an entry in the maintenance logbook before each flight, stating that a visual inspection was conducted. This is bad policy not only because these entries will flood the logbooks with useless entries, but also because everyone in the aviation universe recommends that maintenance logbooks not be kept in the aircraft.
In the event of an accident, they may be the only insight into how the aircraft was maintained, which exact parts were present, when they were installed, and so on. To require their presence for this meaningless preflight signature runs contrary to all prior wisdom, especially since any competent pilot is already doing a pre-flight blade inspection.
Second, it screws student pilots by explicitly prohibiting them from making these inspections, effectively preventing them from legally flying solo.
Yes, they could arrange for another pilot to inspect the blades prior to departure (a pilot who, frankly, may have even less experience with helicopters than the student). But that doesn’t help if the student needs to stop for fuel on a long cross-country. Or wants to make the prudent decision to shut down and take a break at his destination. Both actions are now prohibited.
Whether or not you fly helicopters or fly at all, if you understand why this is important I urge you to submit a comment to the FAA. Even if you’re a foreign pilot this may end up affecting you, as other countries typically look to FAA Airworthiness Directives for guidance.
Reversing nonsense like this is all about the volume of outcry.
My comment is below, although it’s not showing on regulations.gov yet.
If this AD merely mandated a one-time maintenance inspection plus the visual inspections that pilots should already do, that would be one thing. Then it would be merely redundant, instead of an active hindrance.
To require documentation for each flight is both unreasonable and counterproductive. It requires that maintenance logs remain in the aircraft and therefore subject to loss or damage in an accident, contrary to all standard practice. This additional paperwork does nothing to increase safety, and may well reduce it, as it clutters logbooks with useless signatures and obscures truly relevant updates.
Furthermore, the impact on renters and student pilots is unacceptable. The status of renters as opposed to owner/operators in the AD is undefined, and the inability for students to fly solo is explicit.
There is useful precedent in SFAR 73: once a student pilot has received ground training and meets experience requirements, he is permitted to operate solo. Avoiding the dangerous flight conditions outlined in SFAR 73 requires far more care and responsibility than a simple pre-flight blade inspection — yet under this AD, a student is prohibited from doing so.
This AD places a significant burden on helicopter owners and operators without any additional safety benefit. It was issued on extremely short notice without a public comment period, even though these issues have been known to Robinson and the FAA for more than a year.
This AD should be withdrawn immediately, before it begins to disrupt operations on January 18. If the FAA feels so strongly that the existing procedures or a mandatory update to the POH are insufficient, then it would be proper to introduce a rethought AD with the customary notice and public comment process.