**DOCKET SUBMISSION Docket No. FAA-2007-27495**

In consultation with Eurocopter, it is the position of American
Eurocopter LLC that this proposed Airworthiness Directive (AD) for
Eurocopter France Model AS350B, BA, B1, B2, B3, C, D, and D1; EC130B4;
and AS355E, F, F1, F2, and N Helicopters is overly broad and is
unnecessarily and incorrectly directed toward the above-mentioned
aircraft. The problem to be addressed is not a Eurocopter
Type-Certificated aircraft problem. It is a specific issue with an
after-market Geneva Center Console STC installation. Additionally,
American Eurocopter finds the proposed incorporation of the unattributed
illustration, extracted from the Geneva Center Console Installation
Instructions, completely inappropriate for Eurocopter Type-Certificated
aircraft which do not have the Geneva Center Console STC installed.
Furthermore, Eurocopter has contacted EASA to coordinate the submission
of an additional objection to this NPRM on these same grounds and,
perhaps, others.

The two accidents mentioned in the text of the proposed AD were caused,
by reduced clearances between the collective lock knob and the
collective lock strip on the Geneva Aviation STC'd Center Console
installed in each of these aircraft. The correctly installed collective
lock on the Type-Certificated aircraft with a standard Eurocopter center
console has never been involved as the cause of an accident.

The NTSB's Probable Cause finding for the first accident, NTSB \#
LAX04LA254, states, in part, that "The collective down lock engagement
was due to a combination of the reduced clearance between the lock plate
and the collective WITH THIS AVIONICS PANEL DESIGN \[*GENEVA CENTER
CONSOLE*\]...."

The NTSB's Probable Cause finding for the second accident, NTSB \#
LAX05LA020, states, in part, that "The collective down lock engagement
was due to a combination of the reduced clearance between the lock plate
and the collective WITH THIS AVIONICS PANEL DESIGN \[*GENEVA CENTER
CONSOLE*\]...."

In December, 2004, the FAA Rotorcraft Directorate issued a SPECIAL
AIRWORTHINESS INFORMATION BULLETIN (SAIB) No. SW-05-20, to address the
reduced clearance between the lock plate and collective in aircraft with
the Geneva Center Console installed. Eurocopter then issued a Telex
Information T.F.S. No.00000215 dated February 17, 2005, on the subject
"ROTOR FLIGHT CONTROLS, Risk of Inadvertent Collective Pitch Lever
Locking in the Low Pitch Position on Helicopters fitted with Consoles
defined under Supplemental Type Certificate 'STC'."

Subsequently, Eurocopter issued an AS350 Service Bulletin, No. 67.00.21,
dated June 21, 2006, which introduced a re-designed collective lock
strip with a rigid tang spring, hinged at its lower end. The application
of this Service Bulletin was left to the operator's discretion.

To date, there has been no recurrence of inadvertent collective down
lock engagement in the AS350 fleet.

If the proposed AD is to be issued at this point, its application should
be limited to the Eurocopter model aircraft which are fitted with a
Geneva Center Console under the applicable STC. This was the approach
taken by the FAA in issuing SAIB No. SW-05-20, and in issuing an AD
relating to another Geneva STC'd application affecting Eurocopter
aircraft, AD No. 2006-11-17. We firmly believe this is the correct
approach.

Joseph A. Syslo

Senior Manager -- Aviation Safety

American Eurocopter LLC

2701 Forum Drive

Grand Prairie, Texas, 75052