11/03/2011 10-23 FAX 2024935142 FAA - DMS @|001/006 

Q 

U.S. Depaftmeni 

ot TransDorloiion 

Federal Aviation 

Administration 

October 20. 2011 

Soulhwesi Regidnlf^Mj C)^ 

Arkansas,'llouisiana;! J jKy , i 

New Mexico','Oklahoma ' \^A\ 

:]i! EiOV - 3 A :i- 3 5 

CERTIFIED - RETURN RECEIPT REQUESTED 

Office of Regional Counsel. ASW-7 

2601 MeachafnB^d 

FortWorth.TX 76137 

(817)222-5099 

(817)222-5945/5092 FAX 

RECEIVED 

NOV - 1 2011 

HEARING DOCKET Federal Aviation Administration 

800 Independence Avenue, SW. 

Washington, DC 20591 

Attn: Hearing Docket Clerk. AGC-430 

Wilbur Wright Building—Room 2W1000 -CXA-j c 

Re: 'Bell Helicopter Textron Inc. otoH^ lU ^ 

CaseNo.2010SWl90072 ^ '"^' ^ 

Enclosed herewith please find a copy of a request for hearing, the original, and one copy 

of the Complaint in the above-referenced proceeding. 

The FAA requests that the hearing in this matter be held in the Fort Worth, Texas, area, 

and expects that the hearing will last one (1) day. 

Please address all communications for the FAA to the undersigned, at: 

Federal Aviation Administration 

Southwest Region, ASW-7E4, AC 

Office of the Regional Counsel 

2601 Meacham Boulevard 

Fort Worth, TX 76137 

Telephone: (817)222-5071 

FAX: (817)222-5092/5946 

Sincerely, 

mn]eni: Chenrteul 

Attorns^ 

Safety Enforcement Branch 

Enclosed; Request for Hearing 

Complaint 
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U.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMINISTRATION 

In the Matter of: 

BELL HELICOPTER TEXTRON INC. ) FAA DOCKET NO. 

) 

JUDGE NOT ASSIGNED 

COMPLAINT 

The Federal Aviation Administration (FAA), by counsel, hereby files its Complaint, 

pursuant to Rule 208 of the Rules of Practice (14 C.F.R. 13.208), and states as 

follows: 

I. 

1 On October 4, 2011, Respondent Bell Helicopter Textron, Inc., was 

advised through a Final Notice of Proposed Civil Penalty that the FAA proposed to 

assess a civil penalty in the amount of $26, 250. 

2. On October 17. 2011, Respondent Bell Helicopter Textron, Inc.. 

submitted a written request for a hearing. 

1. Bell Helicopter Textron, Inc., (hereinafter "Bell") is the holder of Air 

Carrier Opei^ating Certificate No. B1HR300N issued pursuant to Part 145 of the 

Federal Aviation Regulations (FAR), authorizing it to operate as an approved repair 

station. 
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2. From June 22 until June 25. 2010. Federal Aviation Administration 

personnel from the Alliance-Fort Worth District Office conducted an audit of the Bell 

Helicopter Repair Station, at Roanoke, Texas. 

3. The audit revealed that Bell Helicopter did not follow Procedure 7.0, 

section 1.3, of its Inspection Procedure Manual when the general manager failed to 

apply his signature to each page of the trainir\g manual. 

4. As a result of the audit it was also determined that Bell Helicopter did 

not maintain a current Inspection Procedures Manual when procedure 4.0 

referenced a regulation in the duties and responsibilities section which was no 

longer current on the day of inspection. 

5. Work Order form X60347 was not being used as required by the Bell 

Helicopter Quality Assurance Inspection Bulletin FLT-19. 

6. Procedure 5.0 of the Inspection Procedures Manual. (Operations, 

Housings, and Facilities) was found to not have been updated to reflect the current 

use of areas since the repair station moved to the Roanoke facility. 

7. Bell's maintenance personnel failed to follow its quality control system 

when they failed follow the Inspection Procedure Manual. 

1. By reason of the foregoing facts and circumstances. Respondent Bell 

Helicopter Textron, Inc.. violated the following Federal Aviation Regulations (FARs): 

a. Section 145.207(a)» in that a certificated repair station must 

prepare and follow a repair station manual acceptable to the FAA. 
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b. Section 145.207(b), in that a certificated repair station must 

maintain a current repair station manual. 

c. Section 145.211(b), in that repair station personnel must follow 

the quality control system when performing maintenance, preventive 

maintenance, or alterations under the repair station certificate and 

operations specifications. 

2. Pursuant to 49 U.S.C §46301. Respondent Bell Helicopter Textron 

Inc., is subject to a civil penalty not to exceed $25,000 for each violation noted. 

3. Under the facts and circumstances of this case, a civil penalty of 

$26,250 is appropriate. 

WHEREFORE, the Agency, by counsel, respectfully requests that the 

Administrative Law Judge enter an order that Respondent Bell Helicopter Textron 

Inc.. be assessed a civil penalty in the amount of $26,250. Respectfully submitted 

this 20^day of October, 2011. 

DAVID L. DONNELL 

Regional Counsel 

Soutt>west Region 

4Kr\f\\enm Cherrnaui 

Age ricy/Attorney 

(817^-222-5071 

FAX (817) 222-5945/46 
n/03/201 1 10 23 FAX 2024935142 FAA - DMS 0005/OOB 

NOTE TO RESPONDENT: 

Pursuant to Section 13.209 of the Rules of Practice for FAA Civil Penalty Actions, a 

Respondent shall file a written answer to the complaint, not later than 30 days after 

service of the complaint. The answer must be dated and signed and may be 

typewritten or legibly handwritten. A person filing an answer shall personally deliver 

or expedited courier the original and one copy of the answer for filing with the 

hearing docket clerk at: Federal Aviation Administration, 600 Independence Ave., 

S.W., Wilbur Wright Building—Suite 2W1000, Washington, DC 20591, Attn; Hearing 

Docket Clerk. AGC-430 or via U.S. Mail at Federal Aviation Administration, 800 

Independence Avenue, S.W., Washington. DC 20591, Attn: Hearing Docket Clerk, 

AGC-430, Wilbur Wright Building—Suite 2W1000. The person filing an answer 

should suggest a location tor the hearing when filing the answer. The person filing 

an answer shall serve a copy of the answer on the agency attorney who filed the 

complaint. 

A person filing an answer shall admit, deny, or state that the person is without 

sufficient knowledge or infonmation to admit or deny, each numbered paragraph of 

the complaint. A general denial of the complaint is deemed a failure to file an 

answer. A person's failure to file an answer without good cause shall be deemed 

an admission of the truth of each allegation contained in the complaint. 

For a full text of Section 13.209, see the copy of the Rule of Practice previously 

provided to you. 
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CERTIFICATE OF SERVICE 

I hereby certify that the foregoing Complaint has been mailed this date by 

Certified Mail. Return Receipt Requested, to: 

Federal Aviation Administration 

800 Independence Avenue, SW. 

Washington. DC 20591 

Attn: Hearing Docket Clerk. AGC-430 

Wilbur Wright Building—Room 2W1000 

and 

Jennifer E. Trock, Esq. 

Pillsbury, Winthrop Shaw Pitman LLP 

2300 N Street, NW 

Washington, DC 20037-1122 

zii^Lj4<u ^M>*^ ^ 

Marquitfa Robinson, Paralegal Specialist 

Federal Aviation Administration 

Southwest Region 

Fort Worth, TX 76137 

Date: October 20. 2011