Columbia Helicopters, Inc.

Columbia Helicopters, Inc. (CHI) has been successfully working with the Seattle Aircraft Certification Office for over 30 years on many type certification projects including new and amended STC’s and type design changes. CHI has in place a Partnership for Safety Plan (PSP) with the FAA (Seattle ACO and MIDO) that commits to the timely support of CHI projects and CHI believes that the SOP #AIR-100-001 threatens this commitment. CHI appreciates that the FAA must prioritize certification activities with its’ primary mission of ensuring continued operational safety, however, CHI is concerned that the Aircraft Certification Service Project Sequencing SOP #AIR-100-001 imposes an unnecessary level of complexity for projects requiring less than 40 hours of FAA time. CHI and other applicants are experiencing delays in the initiation of certification projects that are subsequently deemed by the FAA to require less than 40 hours. For CHI, these delays affect the implementation of design improvements to legacy aircraft. Also, CHI is competing in a global marketplace with foreign aircraft operators that are supported by foreign civil aviation authorities that may or may not provide the same level of oversight as the FAA. CHI is also very concerned that for projects that are sequenced the option exists for a project to be given to a difference ACO rather than the geographic ACO. Projects assigned to a different geographic ACO impose a hardship on the applicant in regard to travel as well as lack of familiarity with the applicants’ product by another ACO. Also, assigning projects to a non-geographic ACO would seem to be contrary to the spirit of the PSP. Historically, the FAA has committed a dedicated rotorcraft Program Manager at the Seattle ACO, due to the number of heavy lift rotorcraft certificate holders and operators in the Northwest Mountain Region. Additional comments attached.