30-Jan-2014 Source: HeliHub.com
EASA has recently issued full details of an appeal hearing between two organisations – EASA itself and Robinson Helicopter Co. The case concerns the amount of the invoices being raised by EASA on Robinson for the work that EASA is putting in to the type certificate for the R66.
Here are the numbers
Invoice 90009422 of 26-May-10 for €281,400.85 covering the period 14-May-10 to 13-May-11
Invoice 90026809 of 07-Dec-11 for €180,651.82 covering the period 14-May-11 to 31-Dec-11
Invoice 90037084 of 27-Nov-12 for €290,182.95 covering the period 01-Jan-12 to 31-Dec-12
The first two of these invoices were paid. The third invoice was the subject of the appeal after Robinson requested it be rescinded and that “an appropriate and fair flat type acceptance fee should be determined” for the certification costs. Further, they considered that “the fee should not exceed the sum of the two previous invoices” – effectively saying that they consider they had paid enough in the first two invoices totalling €462,052.67 and that the costs should be capped at that point.
A selection of the points put forward by Robinson include a comparison between other types certified by EASA and costs for the R66 across different countries. Robinson postulated that it would be reasonable to expect EASA charges for certification costs to be similar between helicopter types. Using the Robinson R44 II as the 1.00 bench mark, they cited the Bell 429 at 1.06 times, while the R66 costs were currently running at 6.63 times the R44 costs.
Robinson then looked at costs for the R66 across different countries – all converted to US Dollars for a fair comparison
– Argentina – $2,709
– Brazil – $18,759
– Canada – $80,650
– Chile – $7,253
– CIS – $178,000
– Japan – $6,048
– Malaysia – $5,875
– Mexico – $6,837
– South Africa – $170
– USA – no charge
A further comparison was made between Canada and EASA, where very similar extra validations (over and above the FAA’s findings) have been requested. Comparing the costs at the end of 2012, EASA had charged over 10 times what Transport Canada had levied in the same period of time.
Ultimately the appeal by Robinson failed and a twenty page statement was issued by EASA on 17th January 2014 to that effect with the full details of the appeal – from which we have picked the details above. Robinson has two months from that date to appeal again, this time to the General Council of the EU. If that fails, then the numbers above suggest Robinson will face fees of around €300,000 for the work done by EASA in 2013. This would take the total to date to €1,050,000 and imply a further €25,000 per month thereafter.
The whole situation should weigh heavy on the conscious of those in high-flying roles in EASA due to the hugely disproportionate fees being levied. It is clear that the R66 certification by EASA will be further delayed for some time while these charges are debated again and again. We imagine other aircraft manufacturers could be put off trying to gain EASA certification for their aircraft too as a result of this case.
That said, Robinson have enjoyed great success with the R66, with 192 built in 2013, and the 500th soon to be produced and likely to feature at Heli-Expo next month in Anaheim. The EASA market is huge for Robinson – a recent capacity review by HeliHub.com found 738 R22s and 1155 R44s in EASA countries. Robinson has a huge fan base, and could reasonably expect 500-600 sales of R66s into EASA countries within a few years of certification.
Looking at other current production five-seat turbine helicopters, the Torrance-based manufacturer can rightly consider their current competitors as insigificant – although that excludes the new five-seat Turbomeca-powered helicopter from Bell which remains an unknown quantity. While we don’t have exact numbers from Enstrom, our detailed analysis of production data suggests a figure of 18 480s produced in 2013, with the Japanese order now being delivered at the rate of two per month. In the same year, Eurocopter (since renamed Airbus Helicopters) produced an estimated 13 EC120s with over half of those delivered to customers in Russia and China.
What price success?
Jeremy Parkin – HeliHub.com