Emanuel Papandreas

The effect of this proposed rule is to increase the cost of certification for all small turbine aircraft in the U.S, while only providing marginal benefits to aircraft that are not properly designed in the first place. The problems noted with Eclipse were primarily a result of a small startup company with no corporate memory, attempting to design and develop an entirely new product in an under funded environment. The engineering issues that arose following the introduction of the Eclipse were, for the most part, the result of poor engineering that would, had the aircraft been developed by a more experienced manufacturer, been resolved in the design process. Oversight during the design process by experienced engineering design teams, management, and well by the FAA is best way to address this issue. Please do not increase the test requirements based on one manufacturer, when there have been introductions by more experienced firms that were highly successful. The end result of this proposed rule will be to reduce the competitiveness of American made aircraft. Foreign aircraft are not required to complete this testing. However, since they will be able introduce their aircraft in their home country, by the time U.S. Certification is applied for, they will have accrued sufficient flight time, that the applicant will be able to waive this test requirement. This rule addresses a problem that would not exist in a proper design and development environment and increases the cost of certification for manufacturers who are doing it correctly anyway. I urge that this NPRM be reconsidered and not implemented.