SSS i Helicop-ber 

A Textron Company 

Tim J. Harrington. Jr Post Office Box 482 

Deputy General Counsel - Litigation Fort Worm, Texas 76101 

Oire«dialna.: (817)280-2543 (817)230-2011 

a-mall: thai'ring(on@belllneiicapter.ieytron.com 

I Febniarv 16. 2010 ...--{Deleted; Fetrmty 15.Ml 

Filed via DOT DMS 

U.S. Department of Transportation 

Docket Operations 

West Building Ground floor. Room W12-I40 

1200 New Jersey Avenue, SE 

Wasliington, DC 20590 

Subject: Request for exemption undtsr FAR 21.195 : 

Dear Administrator: '-rl 

Pursuant to title 14 CFR § 11 -61(b) Bell Helicopter-Textron is seeking an Exemption from P3 

14CFR §21,195(d)(2) with respect to the 50 hour requirement for a new type design. - - -

Background 

Bell HeJicopter, the original manufacture of the Bell UH-IH, has modified a UH-IH into a Huey 

II configuration. The modifications are dynamic components and engine from the Bell Model 

212 (Type Certificate H4SW). This configuration has been sold by Bell Helicopter through our 

company US Helicopters to numerous US Government entities including the US Customs and 

Border Protection, the Department of State and other domestic/foreign government. 14CFR 

§21,191(f) authorizes the issuance of an Experimental Certificate of Airworthiness for Mai'ket 

Surveys as provided by 14 CFR § 21,195(dX2). 

On April 14,2010, the f AA v^^ill Revise § 21.195(dX2) to read as follows; 

Sec. 21.195 Experimental certificates; Aircraft to be used for market surveys, sales 

demonstrations, and customer crew training. 

(d) * * • 

(2) The applicant shows that the aircraft has been flown for at leait 50 hours, or for at 

least 5 hours if it is a type cenificated aircraft which has been modified. The FAA may 

reduce these operational requirements if the applicant provides adequate 

justification. [Emphasis added] 

It is evident that the FAA has already contemplated the relief sought by Bell Helicopter by the 

new wording of 14CFR §21, 

Petition for the Benefit of Public Interest 

The basis for the Huey II is a surplus US Army UH-IH helicopter (s/n 67-17431) manufactured 

in the United States, The modifications to the UH-1 are components from a US type certificated 

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product. Granting of this peiition will have significant economic benefit as parts and labor to 

manufacture this modification are domestically produced. The first domestic flights are 

contemplated after the Helicopter Association Internaiional HeliExpo February 20-22, 2010. 

There are over 16,000 US and international registrjints to a typical HAI Heli-Expo who are 

potential customers. The first international market survey will be through Centra] and South 

America en route to Feria Intemacionai del Aire y del Espacio (FIDAE 2010) in Santiago, Chile 

March 23-28,2010, The international demonstration trip will provide an excellent opportunity 

to showcase American aerospace products to potential foreign customers and their respective 

goveniment. 

Equivalent Level of Safety 

The 240 Huey II aircraft manufactuied to date have accumulated in excess of 260,000 flight 

hours The flight time far exceeds the requirements of 14 CFR 21.195(d)(2). Additionally, we 

flew a now sold, Huey II (sn 68-16144) under a Marlcet Survey from January to April 2006. 

_We propose the exemption to read: ..--( FonrnttadiFortt; Times N*W 

Beii Helicopter is hereby granted an exemption from FAR 2"i."r95(d)i'2> to allow ciirria^ic of ; Roman, iz pt 

persons and/or pi lot demonstrations involved in sales and marketiniii of Restricted Catepor\' 

helicopter model UH-1 H. s/n 67-17431 while this helicopter meets the operational aiid safety 

reouirements ot FAR 91 and the FAA-approved Piogram Letter. 

Pursuant to 14 CFR §11.87 good cause exists to waive publication of this petition for exemption 

in the Federal Register, because the delay would adversely impact Bell Helicopter and the 

impending Final Rule for part 21 will provide this relief anyway. 

Therefore, Bell Helicopter petitions the Administrator to grant the Exemption fl-om I4CFR 

§21.195(d)(2) with respect to the 50 hour requirement for a new type design and allow the 

issuance of a Market Survey Experimental Airworttuness Certificate. Questions or comments 

concerning this peiition for exemption may directed to Tim Harrington, Deputy General Counsel 

at the above. 

Thank you for your courtesy, 

Very truly yours. 

^^^f-^-^ 

Tim J, Harrington, Jr. 

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