6139523298 

# 1+1 Transport Canada 

### Ottawa, Ontario 

### KIAON8

August 01, 2013

Docket Operations Transports Canada



### M-30, U.S. Department ofTransportation (DOT) 1200 New Jersey Avenue SE RoomW12-140 West Building Ground Floor Washington, DC 20590-0001 Attn: Eric Haight 13:50:43 08-02-2013

Yourfile Votre reference 

### Docket No. FAA-2013-0502
Ourfile Notre reference 

### RDIM:S # 

### 8634739



### Subject: FAA Special Conditions: EurocopterFrance, EC175B; Use 

### of30-Minute Power Rating DearMr. Haight, By means ofSpecial Conditions (SC) No. 29-030-SC the FAA proposes three (3) requirements for the EC 175B helicopter to use the "30-minutes power rating" that was certificated on the PT6C-67E engine (refer to FAA 33-010-SC). This new engine power rating is more than the rated maximum continuous powerbutno more than the rated take-offpower. This new rating allows the EC175B helicopter Hovering out ofGround Effect (HOGE) in hot and high ambient conditions to 

### hover for more than 5 minutes. Overthe years, Several Special Condition have been issued byFAA for the same feature and they provide minimum certification requirements for an uniform level ofsafety, but Special Conditions previously issued by the FAA have only two (2) requirements. 29.1045 Hover Cooling Test conditions 29.1521 Powerplant Limitations The following requirements were added to this proposed SC when not present on previous helicopter SC such as 29-004-SC: 29.1305(a)(25) Countdown Timer 29.1521 Powerplant time limit per flight 

# C d... · ana a 214

,.'1 lk_.:,,:,6139523298 13:51:07 08-02-2013

As proposed as section (b) ofthis Special Condition 29-030-SC: A countdown timer is not required of5 minutes Take-offpower or 2.5-minute OEI oreven 30- rninute OEI power, it should not be required ofa 30-minute AEO (All Engine Operating) power. It should be noted that a countdown timer is in lieu ofinstrument markings as per 29.1549(e) at Arndt 29-34
.. Ref: 

### [(e) Each OE!limit orapprovedoperating range mustbe markedto be clearly differentiated from the markings of paragraphs (a) through (d) of this section except that no marking is normally required(or the 30-second OE!limit.]. A countdown timer in lieu ofan instrument marking is inappropriate for any rating of2.5 minutes or longer duration. The countdown timer is not provided in the engine Special Condition 33-010-SC for the PT6C67E. The whole section (b) as proposed should not be required on the ECl75B by Special Condition as itwas not required previously on other USA helicopters. It should be removed. As proposed in section (c) ofthis Special Condition 29-030-SC: Forpowerplant limitations, 29.1521, in addition to the 30 minutes limit peruse, a 50 minutes limitperflight is proposed. 50minutes was not demonstrated and is not certified as an engine limitnor is required by FAA engine Special Condition. 30minutes powerrating for longer hovering does not need tobe assured as HOGE is not required for continued safe flight and landing. The 30minutes powerdoes not cause accelerated damage on the engine nor require close monitoring to ensure continued airworthiness ofthe engine. A time limit perflight would causeregulatory problems should an operator mission be approved by the engine authority for more HOGE events, each less than 30 minutes perHOGEevent, but for a total ofmore than 50 minutesperflight. It would also be problematic ifanother engine model with a 30-minute power rating was installed on the EC 175B helicoptercausing a difference (refer to EC130T2). A 50minutes per flight limit should not berequiredby Special Condition as it was not required previously on other USA helicopters. Overall and based on 29.1521(g), our suggestion is to replace both section (b) and (c) by: (b) Section 29.1521 Powerplant limitation, at Amendment 29-41. 

### In addition to the requirements ofthis section, the special condition states: 30minute Power Operation. The powerplant operation must 

### be limited to turbine powered rotorcraft with rated 30-minute powerengines for no longer than 30 minutes peruse. The use of the 30-minute power must also be limited by
- ( 1) The maximum rotational speed, which may not be greater than- (i) The maximum value determined by the rotor design; or (ii) The maximum value demonstrated during the type tests; (2)**Th~** maximum allowable turbine inlet or turbine outlet gas temperature; (3) The maximum allowable powerortorque for each engine, considering the power input limitations ofthe transmission with all engines operating; (4) The maximum allowable engine oil temperatures; and, (5) The maximum allowable transmission oil temperatures.

2 3/46139523298 13:51:41 08-02-2013



### Thankyou for this opportunity to comment on FAA Final Special Condition: Eurocopter France, EC175B; Use of30-Minute Power Rating- Part 29

Shouldyou require further information, please do not hesitate to contact Yves CousineauSenior Engineer, Powerplants and Emissions by phone at (613) 613-952-4413 orby email at Yves.Cousineau @tc.gc.ca.

Yours truly,

..

# --.~~~~· Aaron McCrone · Director Standards Branch Transport Canada

Copy: Mr. David Turnbull, Director- National Aircraft Certification Branch 4/4