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Thread: FAA Test Pilot Regulations

  1. #1

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    FAA Test Pilot Regulations

    I attended the NTSB Experimental Aircraft Safety Seminar yesterday at Ashburn, VA. Very good session and well run by NTSB.

    During Q/A, someone asked when the FAA would have the draft test pilot regulations out. The person from the FAA, Tom Glista, FAA Manager of GA operations branch AFS-830, said it would be out in Jan 2014, but that he needed AOPA and EAA and other industry members to come to some agreement on what they should be.

    Questions:
    1. What is this all about? Why do we now need FAA regulations in this area?
    2. The EAA rep (Tom Charpentier) said there had been meetings on this topic at AV. What did EAA do and what is their position on this topic?

  2. #2
    EAA Staff Tom Charpentier's Avatar
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    Happy

    Thanks for attending the presentation, and sorry if we confused you. What Tom Glista and I were talking about was a proposal that would allow a second pilot to fly with the builder during Phase I. Since this is not currently allowed we would need a set of requirements for that second pilot to meet to ensure that they actually add safety to the flight testing process. There is no proposal on the table to regulate solo test pilots, and we have consistently opposed any attempt to do so.

    This would be an optional alternative to the current Phase I rules, which allow any appropriately rated pilot to fly the aircraft as long as they are solo. These rules would not change.

    Thanks again for coming, and I hope you enjoyed the talk! If you have any other questions feel free to ask.

    Tom
    Last edited by Tom Charpentier; 08-25-2013 at 02:48 PM.
    Tom Charpentier
    Government Advocacy Specialist
    EAA #1082006

  3. #3

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    I'm not aware of new regs on the horizon for test pilots (assuming this is limited to amateur experimental). For certified aircraft under part 21.37 calls for:

    21.37 Flight test pilot.
    Each applicant for a normal, utility, acrobatic, commuter, or transport category aircraft type certificate must provide a person holding an appropriate pilot certificate to make the flight tests required by this part.

    However, there are also Designated Engineering Representative (DER) Test Pilots who are authorized to determine compliance with FARs on behalf of the FAA. I can't see FAA flowing this requirement to the home built world. The requirement to become a DER test pilot is much higher and is contained in the designee management handbook:

    http://www.faa.gov/regulations_polic...rs_inspectors/



  4. #4

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    Tom,
    Thanks for the reply. You did a great job with your presentation. I guess I question the need for any FAA regulation. Do they regulate OEMs and their test flight operations. We have learned that when we ask the FAA for help, we may not get what we want. The recent response to the EAA Young Eagle program is a good example.

    The NTSB has provided the data that shows the FAA and its rules are actually making us less safe than the GA fleet. That is in our flight test operations and our transition training. There rules which as I understand it were designed to limit exposure and deaths are causing more.

    We should push very hard for them to make two very simple changes and only those two: 1) Allow A/B aircraft to be used for transition training for hire (And only transition training) 2) Allow for a flight crew to be used for test fight for piloting and data capture. It is crazy that one person should have to perform both functions and it is no wonder that phase is has more accidents.

  5. #5

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    Quote Originally Posted by Tom Charpentier View Post
    ...What Tom Glista and I were talking about was a proposal that would allow a second pilot to fly with the builder during Phase I. Since this is not currently allowed we would need a set of requirements for that second pilot to meet to ensure that they actually add safety to the flight testing process....
    Wow, that was certainly open to misinterpretation. I know because I misinterpreted it. I can find NO prohibition in Pt91.319 or in FAA Order 8130.2G on operating Phase I test flights with a second pilot. Nor a prohibition on carrying NON pilots. What is in the books? Permission to carry crewmembers as needed to complete the stated test. We all know Boeing and Cessna etc don't fly test flights solo. They use minimum crew to achieve the goals of the written test plan developed and published before the flight. And so do we, right, ladies and gentlemen? Minimum crew!

    "8130.2G para 4104 b (10) During the flight testing phase, no person may be carried in this aircraft during flight unless that person is essential to the purpose of the flight."

    Tom, took me a while to realize you were addressing carrying folks like instructors to teach the owner to fly the rest of the test plan. Flight instruction is obviously not part of the test procedure, and doing things not part of the test procedure during Phase I is obviously not permitted.

  6. #6
    EAA Staff Tom Charpentier's Avatar
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    Fair enough, that was my goof on the description. We have been colloquially calling this proposal "2nd pilot." But you're right that that's a bit of a misnomer. And of course you're also right that it's required flight crew, not always a solo pilot.

    This isn't really about instruction during Phase I. It's more about mitigating the emotional factor of a builder wanting to flight test their airplane even if they aren't the best qualified by allowing the builder, at their option, to bring in a qualified test pilot to handle the first few flights while the builder rides along. The builders we want to reach are those who might otherwise handle the flights themselves if they were not allowed to be involved.

    We are working to make the standard for this "second" (test) pilot as flexible and as reasonable as possible (there has to be some standard or we won't be able to justify the safety benefit of exposing a second person to risk). We're working with the HAC and other community experts to develop a plan for FAA to consider, and we will carefully review and comment on their resulting proposal. Rest assured through this whole process your right to test fly your own airplane or anyone else's (with the appropriate ratings) is safe.
    Last edited by Tom Charpentier; 08-25-2013 at 06:38 PM.
    Tom Charpentier
    Government Advocacy Specialist
    EAA #1082006

  7. #7

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    Big Brother or We should take the initiative

    Quote Originally Posted by Tom Charpentier View Post
    Thanks for attending the presentation, and sorry if we confused you. What Tom Glista and I were talking about was a proposal that would allow a second pilot to fly with the builder during Phase I. Since this is not currently allowed we would need a set of requirements for that second pilot to meet to ensure that they actually add safety to the flight testing process. There is no proposal on the table to regulate solo test pilots, and we have consistently opposed any attempt to do so.

    This would be an optional alternative to the current Phase I rules, which allow any appropriately rated pilot to fly the aircraft as long as they are solo. These rules would not change.

    Thanks again for coming, and I hope you enjoyed the talk! If you have any other questions feel free to ask.

    Tom
    Tom,
    Could you describe what some of the proposals are? I guess this is going to be another one of those "Freedom" vs Government knows best arguments.

    I can not believe that any Aircraft builder would needlessly risk additional personnel. I also don't want the classic government over-engineered solution. There are parts of the flight test process where having more than one person can help and actually make it MORE safe. Heck even the OEMs have more than one person on many flights. Of course they have the luxury of having real time telemetry to capture many data points also.

    On the second topic of the FAA presentation. I think the current LODA process is ridiculous. Why does any person have to put together a full package of information and submit to the FAA to get transition training for a A/B aircraft. I can image that many packages are kicked back for being inadequate or incomplete. The EAA should demand that the FAA make transition training for hire legal in ALL A/B aircraft period. I would hope we would see an immediate improvement in the accident rate due to this change so we can show the FAA that they have needlessly caused many deaths and accidents through their rules. What SONEX has done is a good thing, but we can't all travel to SONEX nor does it scale to all of A/B with 33,000 aircraft.

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    Quote Originally Posted by Tom Charpentier View Post
    ...We are working to make the standard for this "second" (test) pilot as flexible and as reasonable as possible (there has to be some standard or we won't get FAA buy-in)....
    OK, think I got it. If that's all you're working on, having the owner in the aircraft while the qualified PIC makes it happen safely, we already have that. We don't need a new FAA standard, they already gave us the standard, the CREWMEMBER must be ESSENTIAL to the purpose of the flight. Who better than the manufacturer to devise the test plan and define how it must be executed? The FAA didn't design or build the aircraft, the manufacturer did. If the manufacturer says a crewmember is essential to raise the flaps, set the trim, or monitor the engine, OAT, altitude, etcetcetc then the crewmember is essential. Ever heard of CRM? The FAA crammed that into our cockpits, they should be glad we listened. Doesn't matter how simple the aircraft appears to be or how much automatic equipment is installed, the only reason for the crewmember might just be to monitor the automatic equipment and back up the data at specified intervals in case of automatic system failure. Now, if the crewmember is only there to provide ballast, well, geepers, folks be a bit smarter than that when you (yes, you, the builder, the manufacturer) write out the test plan card. Plan it out, write it out, do your paperwork, be safe.

    Don't negotiate away what we already own. We'd be best to say "thank you" and sit down and shut up.
    Last edited by cdrmuetzel@juno.com; 08-26-2013 at 07:26 AM.

  9. #9
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    As someone that did the full gamut of testing (structural, handling, performance) on my own aircraft, I think it would have been EXTREMELY helpful to have a second set of eyes to help with recording data while I was paying more attention to the actual flying part.
    I'll come up with something profound

  10. #10

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    Quote Originally Posted by cdrmuetzel@juno.com View Post
    OK, think I got it. If that's all you're working on, having the owner in the aircraft while the qualified PIC makes it happen safely, we already have that. We don't need a new FAA standard, they already gave us the standard, the CREWMEMBER must be ESSENTIAL to the purpose of the flight. Who better than the manufacturer to devise the test plan and define how it must be executed? The FAA didn't design or build the aircraft, the manufacturer did. If the manufacturer says a crewmember is essential to raise the flaps, set the trim, or monitor the engine, OAT, altitude, etcetcetc then the crewmember is essential. Ever heard of CRM? The FAA crammed that into our cockpits, they should be glad we listened. Doesn't matter how simple the aircraft appears to be or how much automatic equipment is installed, the only reason for the crewmember might just be to monitor the automatic equipment and back up the data at specified intervals in case of automatic system failure. Now, if the crewmember is only there to provide ballast, well, geepers, folks be a bit smarter than that when you (yes, you, the builder, the manufacturer) write out the test plan card. Plan it out, write it out, do your paperwork, be safe.

    Don't negotiate away what we already own. We'd be best to say "thank you" and sit down and shut up.
    CDRMUETZEL, you have nailed it. The regulations allow us to do exactly what the EAA is trying to get the FAA to allow. They should stop what they are doing and put out guidance and information on how to have the builder (or other person) fly with a more qualified test pilot and do the crew functions or data gathering that their test plan calls for. I would recommend the EAA take the FAA AC on flight test and put out supplimental information on how the builder/manufacturer can have more than one person peform the test flight functions. The two crewpersons could then divide up the tasks as they see fit. If some training and familiarization occurs during the test, so much the better.

    The good news is that our government has actually allowed a very open Amateur built community to exist and gives great latitude to its buillding and flying. We should not be asking them for things that we already have. If we do proceed with this effort, I can image that the FAA will want the EAA to manage a "Test pilot" list. To get on the list will require a long process and will be costly. These test pilots will have to charge a fee to recoop those items. Therefore, what may have been a good idea will be one that is not very often used.

    On the LODA process for transition training, does the EAA have a sample or approved LODA that people can use to go to their FSDO and get approved. How long does it take? How often are the first drafts disapproved?

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