Robert Brodersen

Document ID: FAA-2011-0199-0008
Document Type: Public Submission
Agency: Federal Aviation Administration
Received Date: March 14 2011, at 12:00 AM Eastern Daylight Time
Date Posted: March 14 2011, at 12:00 AM Eastern Standard Time
Comment Start Date: March 10 2011, at 12:00 AM Eastern Standard Time
Comment Due Date: April 25 2011, at 11:59 PM Eastern Standard Time
Tracking Number: 80c06f23
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This is comment on Rule

Airworthiness Directives: Eclipse Aerospace, Inc. Model EA500 Airplanes Equipped With a Pratt and Whitney Canada, Corp. PW610F-A Engine

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Please modify this AD to adopt the manufacturers recommendation of an 85 minute time limit for flight above FL300 rather than completely banning high altitude flight. The manufacturer has shown flight under this restriction to be safe, and it is quite easy for pilots to monitor time at altitude. The E500 has a built-in timer that can easily be used for this purpose. Cruise is a low workload phase of flight and timing would not be a burden on the pilot. Even though modifying the AFM is inexpensive, eliminating flight above FL300 would be a significant cost burden to operators such as myself. The fuel consumption is much higher at low altitudes and range is severely reduced as well. In addition to costs, weather tends to be more dangerous below FL300; IMC, turbulence, and possible icing. Again, please relax the FL300 limitation by providing a time at altitude allowance. Thanks -- Bob