AOPA has filed comments on the NPRM, but only on two of the sections. Spokesman Chris Dancy said it's AOPA's view that helicopter rotor and tail-rotor damage must still fit the definition of "substantial damage" before it's reportable as an accident, so it wasn't concerned about that section. AOPA did object to the section on electronic flight displays as being "too vague." AOPA also noted the FAA already collects data on ACAS warnings so it would be redundant for the NTSB to require them. The NPRM was originally issued on Dec. 16 and the comment period was set to expire on Feb. 25. However, HAI requested an extension and the comment period now expires on March 11. Part of the information available to HAI members is a summary of the impact of the proposed rule on helicopter operators by Roy Fox, chief of flight safety for Bell Helicopter Textron. Fox insists the new regulations will do little to advance safety but will seriously harm both operators and helicopter manufacturers because of an "inflated" accident rate.