Dan Calugar

I am an owner operator of an Eclipse 500 jet. Previous to owning the Eclipse 500 flew a piston aircraft and the normal operation ceiling was 12,000 feet. One of the most significant safety advantages of the Eclipse jet is that at FL370 it is almost always possible to fly above or around weather systems. At FL300 in many cases that would not be possible, and therefore a blanket FL300 limitation would increase weather related flight risks to Eclipse 500 pilots and passengers. Pratt & Whitney has determined that there is no threat to safety if the Eclipse 500 is flown at FL370 for no longer than 85 minutes. It is the specific recommendation of the Pratt & Whitney that the AD restricting the flight envelope of the Eclipse 500 be modified to limit operation at FL370 for a period of 85 minutes. 95% of the flights I fly in the Eclipse 500 are for distances of 500 NM or less. Since the Eclipse cruises at from 350 to 370 knots, I would never fly more than 85 minutes at FL370 on substantially all of my flights. I respectfully request that the FAA modify the flight envelope limit of the Eclipse 500 to permit flight at FL370 for a period of up to 85 minutes, consistent with the recommendation of the engine manufacturer. If the FAA feels that such a rule is impractical because it might be difficult to enforce, then as an alternative, I request that the FAA permit flight at FL370 for a period of up to 85 minutes on flight plans that are for 600 MN or less. I believe this rule would give Eclipse pilots the weather avoidance safety of flying at FL370 on the vast majority of flights flown by Eclipse pilots, and at the same time it would be easy to verify compliance.