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The only significant drawbacks of this proposal are economic. This results from the increased cost of certification testing, and potential for increased weight of the gearbox and lubrication system, dependant upon the design solution chosen by the applicant. But the impact to CS-29 helicopter manufacturers is considered to be negligible
Because those who wrote the paper won't have to do it. (Yeah, I saw the table at the bottom, and all I can offer is
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Regarding paragraph 2.4: would anybody care to offer up a concise version of "where does 30 minutes come from?" (as opposed to 20, or 15, or 10, etc) to bring us up to date? I realize that this has been done to death in various S-92 / Blackhawk / Puma / 225 / 332 threads and bun fights. Reestablishing that old baseline early in this discussion might be helpful. (I see that I may not get my comments in by 31 July, but that's OK, nobody listens to me anyway)
3.2.1. b. makes some points on Failure mode analysis. Like what I see there.
Regarding para 6(a)(1) .. Oh, wait, now it's a 36 minute test. Where does that number come from? (See also 6(e) (1) (iii))
Secondary indications: yeah. Keep moving forward on that thought.
Here's an idea: make the requirement 25 minutes, and substantiate that. Not sure what's so magical about 30 minutes, or 36 minutes. Pick a different number, perhaps?
4.1.2. Who is affected This NPA will affect designers and operators of large rotorcraft as well as certifying authorities. The four largest helicopter manufacturers affected by the changes proposed in this NPA are Airbus Helicopters, Bell Helicopter, Leonardo Helicopters, and Sikorsky Aircraft Corporation.
And every operator of same. (this section explored some financial issues)
4.5.3. Social impact There are no relevant social impacts for either option.
Really? If there weren't a social impact, you'd not have been tasked to come up with this.