December 16, 2013
Chances are rising that the Comac C919 will be largely limited to the Chinese market, as the manufacturer works toward local airworthiness certification while seeing no sure path to the desired FAA endorsement of the type.
The Chinese market is big, so sales of perhaps 1,000 units remain plausible, in the opinion of program officials. But the 158-seat narrowbody's prospects for making much of an impact on the wider market, perhaps never large, are diminishing.
The problem emerged in 2011 and is still unresolved. Delays in Comac's earlier program, the ARJ21 regional jet, are holding up FAA recognition of the certification competence of the Civil Aviation Administration of China (CAAC) (AW&ST Sept. 12, 2011, p. 24). That casts doubt on the FAA's eventual acceptance of the CAAC's current work on C919 and therefore the Chinese type certificate. Without Western airworthiness endorsement, the C919 cannot be sold in main commercial aircraft markets outside of China.
“As we see it, this is a highly complex situation,” says an executive closely involved in the C919 certification effort. “Because the FAA's position is affected by the ARJ21, we currently have no way of resolving this problem.” For the moment, the C919 program can only work on obtaining CAAC certification and hope the Chinese authority and the FAA can come to a helpful agreement. Comac has not given up, the executive adds: FAA endorsement is still a C919 objective.
Under a Bilateral Air Safety Agreement, the FAA is coaching and supervising the CAAC in dealing with the ARJ21 certification application. If and when the process is correctly completed, with the issue or refusal of a type certificate, the FAA will recognize the CAAC as a certifying authority. The FAA is similarly helping the Japanese Civil Aviation Bureau, with the Mitsubishi Aircraft MRJ regional jet as the test case. The FAA and European Aviation Safety Authority support authorities of other countries in this way because Americans and Europeans also fly on the foreign aircraft.
The ARJ is not now expected to be certified until the end of 2014, by which time the CAAC will have accumulated at least three years of C919 work with little or no FAA involvement. The issue is whether the FAA will recognize the validity of that work retrospectively once the CAAC proves itself with the ARJ21. The FAA would have to accept that its Chinese counterpart had followed the same procedures with the C919 as it used for the ARJ21. Last year, an official familiar with the FAA's options suggested that it could do so. Comac officials have no assurance that it will, however. And the FAA's confidence can only decline as the volume of unrecognized work rises.
Customers of the C919 have expressed a desire for FAA endorsement of the certification, even though they are all Chinese and therefore do not need it. There is no suggestion the CAAC would be soft on Comac; on the contrary, it is repeatedly reported that the Chinese authority is tougher than the FAA.