  In series of papers Fomin introduced and discussed the so-called robust
phases in a system with frozen orientational disorder (with application to
superfluid 3He in aerogel). We show that his consideration is based on the
erroneous overestimation of the fluctuation energy which comes from the
interaction of the Goldstone modes with the frozen disorder. This interaction
leads to the Imry-Ma effect, which destroys the orientational order, but is
unable to destroy the local structure of the A-phase. There is no ground for
the robust phases.
