Considering granting operating license for China's COMAC C909 aircraft

This assessment is particularly significant as Vietnamese low-cost carrier VietJet Air plans to lease this aircraft model. In January 2025, a delegation from the CAAV engaged directly with COMAC and the Civil Aviation Administration of China (CAAC) in Shanghai to scrutinize the design, manufacturing standards, and operational performance of the C909. ​

Read more: Vietnam Considers Regulatory Changes to Import China's Comac C909 Aircraft

Certification and Design Standards

The CAAV's investigation revealed that China's aviation safety regulations are structured similarly to those of the U.S. Federal Aviation Administration (FAA). The C909, officially designated as the ARJ21-700, initiated its Type Certification (TC) application in January 2003 and received approval from the CAAC in December 2014. ​

Aircraft Specifications

The COMAC C909 is a short to medium-haul jetliner with the following specifications:​

• Length: 33.46 meters​
• Wingspan: 27.29 meters​
• Height: 8.44 meters​
• Seating Capacity: 78 to 95 passengers​
• Maximum Takeoff Weight (MTOW): 40,500 kg​
• Cruise Speed: Approximately 825 km/h​
• Service Ceiling: 12,200 meters​

The aircraft is powered by two General Electric CF34-10A engines, each providing 17,057 pounds of thrust. ​

Operational Performance

As of January 5, 2025, COMAC has delivered 160 C909 aircraft to 12 airlines—11 based in China and one in Indonesia. Collectively, these aircraft have transported over 19.16 million passengers across 633 routes, connecting 158 cities and 181 airports. The fleet has accumulated more than 550,000 flight hours and over 330,000 takeoffs and landings. Notably, there have been no reported accidents or serious incidents involving the C909 since its entry into service. ​

In 2024, the average daily flight time per C909 aircraft was approximately 5.2 hours, with a dispatch reliability exceeding 99%. During the same year, the fleet logged around 194,000 flight hours over 135,000 flight cycles. There were 509 operational disruptions, including 131 flight cancellations due to technical reasons, resulting in a technical interruption rate of 3.77 per 1,000 flights and a cancellation rate of 0.97 per 1,000 flights. ​

VietJet Air's Interest and Regulatory Considerations

VietJet Air has expressed interest in integrating the COMAC C909 into its fleet to enhance domestic route offerings. In December 2024, VietJet signed a wet-lease agreement (including aircraft, crew, maintenance, and insurance) for two C909 aircraft from Chengdu Airlines, aiming to operate them on routes such as Hanoi/Ho Chi Minh City to Con Dao during the Lunar New Year peak season. However, regulatory approvals have delayed the implementation of this plan. ​

The CAAV's assessment indicates that China's airworthiness standards have minor differences compared to international norms, primarily concerning the use of the Chinese language on aircraft labels. Recognizing China's design and manufacturing standards could facilitate civil aviation operations, especially amid global aircraft shortages, and provide new growth opportunities for Vietnam's aviation sector. ​

Recommendations for Regulatory Adjustments

To integrate the C909 into Vietnam's aviation landscape, the CAAV has proposed amendments to specific provisions in Government Decree No. 92/2016 and Circular No. 01/2011. These changes aim to acknowledge China's airworthiness certifications, thereby streamlining the importation of the C909 into Vietnam. For wet leases, the CAAV will validate the airworthiness certificates for each aircraft and assess the foreign operator's credentials. For dry leases (aircraft only), the CAAV will incorporate the new aircraft type into the operator's certificate and issue individual airworthiness certificates. ​

Conclusion

The CAAV's thorough evaluation of the COMAC C909 underscores Vietnam's commitment to diversifying its aviation assets while maintaining stringent safety and operational standards. The proposed regulatory adjustments reflect a strategic approach to integrating new aircraft types, ensuring that Vietnam's aviation sector remains resilient and competitive in a dynamic global environment.

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