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.

The C919's competitiveness in non-Chinese markets has long been questioned, especially since 2010-11, when Airbus and Boeing launched new versions of the A320 and 737 with engines the same as or similar to the CFM Leap 1 on Comac's aircraft. This year's schedule slippages and rejection of a composite material for the center wing box have further diminished the C919's market clout (AW&ST Aug. 19, p. 39).

But even if the aircraft proved to be seriously outmatched, production subsidies could conceivably allow Comac, itself a state agency, to sell it—providing the C919 had the certification that made it eligible for the market.

Subsidies are likely anyway. The announced C919 development budget is 58 billion yuan ($9.5 billion) but the real figure is probably 50% higher, says an industry executive whose company, not a competitor to Comac, has studied the issue. Adding interest, a production run of 1,000 C919s would demand recovery of well over $20 million in development costs per aircraft, a figure the market is not likely to bear.

Comac's Chinese engineers are probably earning about half as much as their counterparts at Boeing or Airbus, but the C919 program is also employing many very costly expatriate foreign engineers. Most important, inexperienced managers cannot be expected to know the most efficient ways of developing an airliner, so program costs should be unusually high, says the executive.

Two years ago Comac had to ask for top-up development funding from the government, which agreed to an unknown amount. The money seems to be budgeted but not assured, however, because Comac has to secure its funds every year from the government, industry officials say.

Since the top-up was approved, Comac has added about a year to the development schedule, implying another year of salaries. It has a three-month buffer in its current schedule, which includes a first flight late in 2015.

Production costs of the C919 will have to be higher than those of the A320 and 737 at first, since Airbus and Boeing have very well-honed manufacturing processes. But studies by the same outside company suggest that when the C919 production line is mature, Comac should be able build more, cheaply, thanks largely to lower wages.

Comac has forecast production of 2,200 C919s and an eventual steady rate of 150 a year. Executives who have studied the program say the actual total will probably be about half of the forecast. They do not see reason to be more pessimistic, because Chinese demand can probably soak up 1,000 C919s, providing the aircraft performs reasonably well. The key performance target is an operating cost 10% below those of current-production 737s and A320s.

The Chinese manufacturer is investing in advanced automatic fabrication equipment, which should cut costs if kept running at an optimum level, as well as guarantee precision. Its new plant outside Shanghai is mostly a final assembly line, however. Major airframe modules will come from Avic, whose efficiency and investment will therefore heavily influence costs.

The quality of Avic's production may be an issue. Comac has been dissatisfied with ARJ21 assemblies from Avic, even though that separate state group is quite capable of excellent work. For example, it produces A320 outer wings, to Airbus's great satisfaction.

Comac is leaning toward aluminum-lithium for the skin of the C919 fuselage, but only in the cylindrical sections, since it does not want Avic to try making the difficult double curvatures of the nose and tail with an unfamiliar material. Comac is somewhat obliged to use the Alcoa metal, because it no longer has a composite center wing box but still needs to meet a government requirement for 30% advanced materials in the airframe. The tail and movable surfaces will be of carbon-fiber composite.

The design is currently overweight, says an executive familiar with development, but the problem is not considered serious. The cause is mainly in the weight of equipment, not the structure.

Assembly of the first prototype should be underway by the end of 2014, assuming no further delays. A delay announced in August was the program's second; the first was not revealed officially but was reported by Aviation Week (AW&ST June 17, p. 96).

The C919's iron bird, a structure on the ground on which systems are tested, was due to be operational around the end of 2013 with mechanical and hydraulic systems. By mid 2014 it should be working with all systems.

The ARJ21, meanwhile, should now be in the last of 12 years of development. The first two production aircraft are due to be completed this month. Judging from recent progress in assembly at Comac's old Shanghai factory, at least one of them will be.

ARJ21 production is said to be supported by a government order for 50 aircraft as official transports. Comac is also selling 30 of the type to itself; Chengdu Airlines, owned by the manufacturer, will be the first operator. Contracts with other airlines probably had little binding effect when signed and, following the enormous development delays, even less now. Shortly after program launch, the ARJ21 was originally due to go into service in 2007.