Rocky Mountain Jet

Rocky Mountain Jet operates its Eclipse 500 as part of an 11 Eclipse FAR 135 charter fleet. The FAA's imposition of an arbitrary ceiling of FL300 is far from trivial. The AD claims the economic impact is simply the cost of inserting the note in the AFM. That estimate is a blatant insult. One would have to be completely ignorant of aviation realities to make such a ludicrous estimate. The FL300 ceiling increases fuel burn 25%, dramatically increasing our operating costs and decreasing range by an equal amount. This all but eliminates the economic and environmental advantages we tout to our passengers. A reduction of range from 1,100nm to 800nm eliminates our non-stop range from reaching the west coast from the Denver area. We anticipate loosing $10-25,000 per month in charter revenue as a direct result of the capricious actions of an unknown few at the FAA. If the FAA really believes draconian actions (over-ruling Transport Canada, disregarding PWC, implementing the AD without normal NPRM process), then stand up and acknowledge the severe economic impact. Don't lie. Yes, safety comes first. No argument. But the burden of proof must be on the FAA to prove that the proposed interim solution by Transport Canada (the certifying organization) and PWC (the manufacturer) is insufficient. What tests has the FAA run which contradict the tests run by PWC? What evidence, if any, has the FAA found which supports over-ruling Transport Canada? Show us the data! In the absence of supporting data, the FAA should adopt the interim solution offered by Transport Canada and PWC. Limited operation at the higher altitudes until new liners can be installed is a sufficient response to this issue. Base this decision on the data, not a knee jerk reaction to take the 'least risky' course of action. Respectfully submitted, Marc Arnold Rocky Mountain Jet Leasing, LLC