11/30/201 1 10:47 FAX 2024935U 2 FAA - DMS @]001/005 

Q l r OcK'ififMEMTOF 

uUU I ,HAf«PORIATIOfvi ••..'CKET OPERATIONS 

flllsbury Winthrop Sh?iw Pittman LLP 

2300 N Street MW I Washington. DC 20037-1122 | lel 202.6&3.5000 1 fa« 202.663.8007 ^^^. 

^fjif NOV 30 A iG: 50 

Jennifer L. Trnck 

ParTJit-T 

rel202.S63.9i79 

Jennifer. irocl:(a!pillsburyla'A'.cr>m 

November 22, 2011 

VIA FACSIMILE AND FIRST CLASS MAIL 

Hearing Docket 

Federal Aviation Administrauon 

Attn: Hearing Docket Clerk, AGC-43 0 

Wilbur Wright Building, Room 2W100 

}<0n Independence Ave, SW 

Wa^ihington, DC 20591 

^Oll- 11 zz^ 

Re: Answer of Bell Helicopter Textron, Inc. 

FAA Case No. 201OSW190072 

Enclosed herein please find the onginal and one copy of the .'\nswcr to the Complaint 

served on October 20, 2011 m the above-referenced proceeding. 

Best regards, 

Enclosure 

cc: Annjenei Chennauli 

Federal Aviation Administration 

Southwest Region, ASW-7E4 

Office of the Regional Counsel 

Fon Worth, TX 76193 RECEIVED 

N0V2 8 2OH 

HEAR/NG DOCKET 

WAVu.pillsburylaw.corn Answer to Cotnplainl DOC 
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V.S. DEPARTMENT OF TRANSPORTATION 

FEDERAL AVIATION ADMLMSTRATIO N 

In the Matter of 

BelJ Helicopter Textron, luc. 

FAA Case No. 2010SWI90072 

) 

ANSWER 

Pursuant to 14 C.F.R. § 13.209, Bell Helicopter Textron, Inc. (-'Bell") by and through ils 

coxJDsel, Pjllsbury Winthrop Shaw Pittman LLP. hereby submits its .Answer in response lo the 

Complaint scr^xd October 20. 20n . 

I. 

1. On October 4, 201 L Respondent Bell Helicopter Textron, Inc.. was advised through a 

Final Notice of Proposed Civil Penalty that the FAA proposed to 2s.^css a civil penalty in 

the amount of 526,250. 

Response: Admitted. 

2, On October 1 7, 2011, Respondent Bei! Helicopter Textron, Inc., submitted a wnnen 

request for a hearing. 

Response: Admitted. 

II 
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L Bell Helicopter Textron, Inc. (hereinafter ''Bell") is the holder of Air Carrier Operating 

Certiticate No. B1HR300N issued pursuant to Part 145 of the Federal Aviation 

Regulations (Fy\R). authorising it to operate as an approved repair station. 

Response: Admitted. 

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 P.epair 

Station: ^^ Roanoke, Texas. 

Response: Admitted. 

^. 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 training manual. 

Response: Admitted in part and denied in part. There is no requirement that the 

manager sign each page. 

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 ol inspection. 

Response: Admitted in part and denied in part. There was a minor 

t>pographical error in the ManuaL 

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

Assurance Inspection Bulletin FLT-19. 
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Response: Denied. 

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. 

Response: Admitted in part and denied in part. 

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

to follow the Inspection Procedure Manual. 

Response: Denied. 

III. 

1. By reason of the foregoing facts and circumstances, Respondent Belt 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. 

b- Section 145.207(b), in that a certificated repair station must maintair. a current 

repair station manual. 

c. Section 145.21 l(bX m that repair Station personnel must follow the quality control 

systan when performing maintenance, preventive maintenance, or alterations 

under the repair certificate and operations specifications. 

Response: Denied. 
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2. Pursuant to 49 U.S.C. § 46301, Respondent Bell Helicopter Textron. Inc. is subject to a 

civil penalty not to exceed 525,000 for each violation noted. 

Response: Admitted in part and denied in part. 

3. Under the facts and circumstances of this case, a civil penalty of S26,250 is appropnate. 

Response: Denied. 

IV. Affirmative Defenses 

1. For Its first affirmative defense, Bell asserts that Complainant has failed to state a claim 

upon which relief can be granted. 

2. For its second affirmative defense. Bell asserts that the proposed civil penalty is 

excessive and is not appropriate in this instance where all alleged violations relate to 

minor administrative inconsistencies and have been fully remedied. 

WHEREFORE, Bell Helicopter Texlron, Inc., by counsel submits that it has fully answered the 

Complaint, and respectfiiUy requests that the Administrative Law Judge find in favor of the 

Respondent, Bell Helicopter Textron, Inc. 

Respectfully submitted, 

Kenr^ei^ P'^^inn 

Jennifer E. Trock 

PILLSBURY WINTI-IROr 

SHAW PITTMAN LLP 

2300NSn'eet,NW 

Washington, D.C. 20037 

Tel: (202)663-8000