EUROCOPTER Continuing Airworthiness

EC comments on FAA's Determination The start of the roll oscillation in LOC mode at the end of an approach does not lead to an unsafe condition. Refer to Appendix 1 of attached file for more details EC comments on AD Requirements Alternate ways to safely complete an approach below 500 ft than using the LOC mode in 4-axis configuration have been extensively demonstrated in single pilot IFR operation. Eurocopter agrees to increase the LOC mode Minimum Use Height, in 4-axis configuration, from 200 ft to 500 ft over the US territory but disagrees with the EC155 interdiction of single pilot for IFR operations. Refer to Appendix 1 of attached file for more details EC comments on Costs of Compliance The FAA AD strongly underestimates the Costs of Compliance because it does not take into account the additional operator cost due to the 2nd pilot in IFR flight.