BOMBARDIER COMMERCIAL AIRCRAFT 

13100 HENRI-FABRE BLVD. 

MIRABEL, QUÉBEC CANADA J7N 3C6 

TEL. 514-855-5000 

FAX. 514-855-7401 

www.bombardier.com 

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Mirabel, November 10th, 2014 

AW-CRJ/14/752 

Mr. Gaetano Scortino, Manager NYACO 

New York Aircraft Certification Office 

Federal Aviation Administration 

1600 Stewart Avenue 

Westbury, New York 

U.S.A 11590 

Attention: Mr. Serge Napoleon, Project Manager 

Mr. Victor Wicklund, Transport Standards Staff, Transport Airplane Directorate 

Mr. John Piccola, Acting Manager, Transport Standards Staff, Transport Airplane Directorate

Subject: Bombardier Regional Jet CL-600-2E25 (CRJ1000) – Additional Information Related 

to Request to FAA for 36-month Extension to Time-Limited Exemption 10175. 

References: 1. Bombardier “Airworthiness - CRJ 1000” eRoom Certification Action Item 3678: 

https://ecs8.aero.bombardier.net/eRoom/Certification/AirworthinessCRJ1000Sustaining/0_3e1fe. 

2. Bombardier letter AW-CRJ/12/746, dated 2012-11-13, titled “CL-600-2E25 (CRJ1000) 

Revised Exemption Request Against 14CFR 25.981(a)(3)”. 

3. FAA Letter, Docket 2010-0287-0014, dated “2013-04-12”. 

4. FAA Letter, Docket 2010-0287-0015, dated “2013-12-06”. 

Dear Sirs, 

In addition to the initial Bombardier request for a 36-month extension to the FAA Time-Limited 

Exemption 10175 (extension from 2012-12-17 to 2015-12-17) [Reference 2] and in response to your 

letters [Reference 3 & 4], Bombardier offers the following: 

In the first letter, dated April 2013, the FAA explained that: 

1. FAA Position:

The FAA explains that “Provision number 4 of exemption no. 10175 anticipated the current 

situation where Bombardier did not demonstrate compliance within the 24-month period. 

Provision 4 states. “If Bombardier is unable to demonstrate compliance ... within 24 months after 

type certification of the airplane, the FAA will not issue further airworthiness certificates until 

Bombardier shows that the conditions are met.””

Bombardier Position: 

Bombardier respectfully requests that the FAA re-evaluate the above provision in light of the 

renewed “Public Interest” argument presented in point 3 below, as well as the practical 

difficulties Bombardier has encountered while attempting to establish compliance against 

14CFR25.981(a)(3) for the current metallic Water Drain Valve (WDV) and housing, which will be 
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presented in point 2 below. 

2. FAA Position: 

The FAA explains that “Considering that Bombardier successfully completed the majority of the 

tests in March 2012 with only one aspect or the design requiring reassessment and possible 

redesign and retest, it is not clear based on material provided by Bombardier why Bombardier is 

not able to complete this activity within 6 to 12-months of the current exemption schedule.” The 

FAA therefore requests that Bombardier “[...] provide the results of our finalized preliminary 

concepts and an expedited schedule, rather than a "worst case scenario" schedule”. According 

to the FAA, “The expedited schedule should include expedited test article construction, 

expedited testing and documentation, and expedited completion of design and implementation.”

Bombardier Position: 

Bombardier strongly believes we have planned for an expedited schedule which has so far 

included expedited test article construction and expedited testing. However, Bombardier has 

had to add additional testing to the schedule due to failures from previous tests. 

Bombardier will provide by December 19th, 2014, a separate confidential presentation to the 

FAA, highlighting the current progress and results of the testing, the practical issues that 

Bombardier has faced, and the plan/schedule for the next steps. 

3. FAA Position: 

The FAA explains that “Bombardier’s request for extension of the 24-month period states that 

no CRJ1000 airplanes are operated in the U.S. and that no deliveries to U.S. operators are 

forecast”, and suggested that “The public interest in the U.S. suggested by Bombardier is 

largely based on the assumption that new production airplanes will be operated by U.S . 

operators.” The FAA therefore asked Bombardier to “Please reassess the public interest such 

an extension to the exemption would provide in the U.S. in consideration of the expedited 

schedule, requested above, and the impact on forecast operations of CRJ1000 airplanes in the 

U.S.”

Bombardier Position:

Due to the current FAA position to “not issue further airworthiness certificates until Bombardier 

shows that the conditions are met” as described in point 1 above, Bombardier maintains that the 

argument that “no CRJ1000 airplanes are operated in the U.S. and that no deliveries to U.S. 

operators are forecast” should not be interpreted by the FAA as a lack of a “Public Interest” 

argument, because the FAA has effectively prohibited CRJ certification in the U.S. as of 2012-

12-17 which as a consequence has denied any future CRJ1000 sales/deliveries in the U.S (i.e. 

the chicken and the egg argument). 

Bombardier confirms that many US operators have shown interest in procuring CRJ1000s for 

their fleets, and Bombardier respectfully requests that the FAA consider such interest as part of 

the “Public Interest” argument. Bombardier is in advanced negotiations with 1 US operators who 

has a firm willingness to procure CRJ1000(s) if compliance to 14CFR25.981(a)(3) is 

demonstrated by Bombardier or the subject exemption extension is granted by the FAA. This 

operator cites competitive advantages in terms of operating the CRJ1000 when compared to the 

existing CRJ products in their fleet as a strong economic motivator for the acquisition, and 

Bombardier therefore claims that any economic benefits related to the introduction of the 
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CRJ1000 in the U.S. would ultimately serve the U.S. public interest through increased access to 

air transportation and lower fares. 

Bombardier is willing to provide additional information to the FAA about which U.S. operator has 

shown interest in the CRJ1000, to strengthen the “Public Interest” argument, if such information 

is treated confidentially. 

Bombardier hopes that the above will allow the FAA to continue to consider the petition for extension to 

the existing Exemption. 

Should you have any questions, please do not hesitate to contact Hagop Kazarian, Bombardier 

Airworthiness Section Chief for CRJ Programs, at (514) 855-5001 ext. 29334, or by email at 

hagop.kazarian@aero.bombardier.com. 

 Yours very truly, 

(For) John Kotnjek 

Manager, Airworthiness 

Bombardier Aerospace 

JK/hk