Tim Morgan

This policy has a serious adverse effect upon the competitiveness of aviation companies who specialize in aircraft modifications. TTF, and our competitors, are already experiencing STC project delays due to nonresponsive FAA certification support, and it makes us unable to secure projects from airline and MRO customers. We are a growing $25 million/year company currently employing over 120 people. We have many constructive ideas to benefit the airline industry. This policy will cause TTF to lose projects, lay off people, share trade secrets with other ODAs, and may ultimately be instrumental in our going out of business. TTF applied for ODA over two years ago, only to be told by the FAA ACO they would not process our application. TTF currently has 19 active STC projects. TTF's demand for STC certifications to support our customers continues to grow. We cannot meet any demand if the FAA refuses to delegate ODA authorizations. The FAA exacerbates the backlog of certification projects by inappropriately evaluating those that fall under the 40 hour rule, and by often reviewing and evaluating data (at the ACOs) already approved by FAA DERs. TTF wants to anticipate market demands and make the certification process more efficient for the FAA, our customers and the industry as a whole. This will not do that. This policy will not accomplish its goal of increasing safety. It will dramatically increase costs to the airlines and correspondingly decrease modification work. Airlines will stop looking for incremental safety, convenience and operational efficiencies (witness voluntary use of Crew Rest Modules)because the profitability and associated risks will no longer fit the required ROI timeframe of any viable airline business model. We, along with many of our competitors, would be ecstatic if the FAA would adopt an EASA-type method of billing for STCs on a first come, first serve basis. Please properly staff the FAA and utilize ODA as it was conceived.