OOOPS my redneck just showed.
Ray
OOOPS my redneck just showed.
Ray
That is encouraging to hear, but my understanding is that the Canadian insurance market is quite different than the US insurance market. Not sure you are comparing apples to apples.
Best of luck,
Wes
N78PS
Perhaps a Canadian Apple is different than a US Apple. :-) But they are similar.Originally Posted by WLIU
In addition to CAMO, we have E-AB and LSA doing OM today with US insurance. But your point is well taken, even if the govt gives us the latitude, the insurance market will be a major factor. If PNC turns out to be unsafe, the Insurance market will dry up and we will be begging for that IA to restore the original AW certificate. The FAA won't need to undo its regulation.
Market Based regulation....I feel the unseen hand....
A valid comparison might be taken from those who went from S-LSA TO E-LSA. I know about half a dozen folks who have gone this route with no change in insurance.
As many of those commenting here are comparing this proposal to the Canadian Owner Maintenance (OM) category, I wonder how many have bothered checking out the total number of Canadian OM aircraft (since that programs inception in 2000) ?? Well here's the link, http://wwwapps2.tc.gc.ca/Saf-Sec-Sur...ycatresult.asp . As can be seen, only 612 (as of Feb 2014) aircraft have been moved into the OM category since that programs inception in 2000. For comparison Canada currently has 4072 homebuilt aircraft registered. Ergo, it doesn't look as if the Canadian OM has been an overwhelming success (similar to the US Recreational Pilot category of which their are less than 500) !! So how again is supporting the addition of a whole new section of FAR's/regulations (which we all know will not reduce cost) for a very, very small percentage of US aircraft owners going to help/save private aviation ??
“PNC” pink airplanes…. Terrible acronym!! What we were actually going for when we were writing this was “ANV” Antique – Non Commercial – Vintage. (Some of you history buffs might also recognize ANV from another group of patriots trying to defeat an invading and conquering army - kind of poetic justice and that’s why I picked it) Naturally I like ANV better, but call it PNC or whatever, what is in a name anyway.
So where to start….
The whole idea of the ANV category was to allow an owner of any non-turbine powered Part 23 airplane to be operated as if it were an experimental so long as it was not being used commercially. Now, as common sense as that may sound to all of us, imagine trying to sell this to an aviation rulemaking committee – oh and BTW, you need to get a nearly unanimous vote for it from more than 90 representatives on the committee.
So, what was needed was an angle here. We came up with was that we would not invent anything new, everything proposed in the ANV category was a rule already in use today with a proven safety record. Obviously maintenance came from Experimental AB, the conversion back and forth to standard category from restricted category, the repairman’s certificate from LSA. Last but not least the hated requirement for the aircraft to be 20 years old, originally this was compared to antique plates on a car (thus the A in ANV) but a few of you already guessed correctly the real reason.
The idea of the above is that we could take real world safety data from the categories mentioned above along with the Canadian owners MX class and prove statistically that the incorporation of ANV would not cause a safety problem. In this way we met both the ARCs requirements of cost savings for owners and proven safe operations. Plus it made it really hard for the FAA to argue what we were proposing was a safety risk as they would have to admit that the current regulations were unsafe.
To prove this though, we had to spell out EXACTLY how this was to be done, by what regulations, by what FAA Orders, instructions for how to have a repairman’s class and even instructions to the inspectors on how to accomplish this. All of these are included in the ARC recommendation. (Mac seems to have missed all this when he said that the ARC had not figured out how to implement these concepts and that it may be limited to 4 seats.. oh well…I think he only read the first few pages) I have attached a copy of the ARC recommendation, don’t let it scare you, it’s only 26 pages)
In the end of we did get the nearly unanimous vote (only one guy from Cessna voted no) (well technically a guy from EASA voted no too, but he did not seem to realize that he was not allowed to vote anyway)
So where are we today… sadly the same place we were a year ago. Unfortunately SARA was craftily amended to not cover any recommendation made by the ARC save for the Industry Standards rec. (which changes Part 23 into LSA, but don’t get me started on that stupidity) I have also been told that the FAA vehemently opposes any deregulation of this type and considers the ANV category a closed issue. The person that told me this (who actually is in favor of it) suggested that the only way to implement the ANV will be through legislation.
So if we want this, it is going to have to come through congress. I think one possible and viable course of action would be to tack it onto the Pilots Protection act currently making the rounds. Less face it, if we are going to deregulate the pilots, we may as well deregulate the airplanes. Pragmatically speaking, if a congressman or senator was going to vote yes on ending third class medicals, do you really think adding in a new primary category that no one understands but pilots is going to scare them off?
In the end this will have to be a grass roots effort. If you want this or something like it, you guys are going to have to fight for it.
Oh, to protect myself -- I have to say everything I have said here is in my strictly my opinion in my role as NATCA representative to the PART 23 ARC.
Last edited by scott f; 03-29-2014 at 02:16 PM.
BTB
The problem with the Canadian category is once it goes in, it basically can never come out again. In fact you even have to stamp all the rotables on the airplane as OM so they never again enter into the parts pool for certified airplanes. This hugely devalues the airframe (like sticking a Cessna into experimental). You are also forbidden to fly the aircraft into the US or sell it to a US owner. In short, move it over and you have created the proverbial white elephant.
We actually were briefed by the guy who started Canadian OM, courtesy of AEA, during the ARC development of the ANV category. We attempted to fix some of the issues that made the Canadian system less popular than it could have been.
But remember ANV is VOLUNTARY. Unlike most ARC proposals, there is nothing in this that forces people to do anything.
Moving to Experimental Exhibition.
This is a good idea except... the problem is that if an aircraft originally held airworthiness certificate in the Standard Category, it must still me maintained per part 43 and part 21. (this can be found in FAA order 8900.1) Thus, you still need an A&P to sign off your MX, IA to do your annuals and PMA parts for all areas of your plane that are not experimental. Now, in all honesty we could probably come up with a program that fixes the parts issue, but what is really needed here was a straight forward way to allow all this stuff in a new category.
That is not necessarily true. It depends on how the operating limitations are written. I have seen quite a few gliders in the experimental exhibition category that require only a condition inspection performed by a normal A&P. Your mileage may vary...
ScottF - Thank you for the background!
I have to do a fair bit of "working the hill" in my day job and asked some of my Lobbyist colleagues how best to proceed here. They reviewed the Bills and legislative history and were unanimous in their opinions and recommended strategy. To paraphrase the spaghetti sauce commercial, "Prego -Its in there". They all cautioned me not to give any public credence to the FAA's arguments.
Politically, we can sabotage ourselves by wringing our hands and giving the impression that the FAA might be justified in not putting it in the NPRM.
Our attitude should be that the ARC and its recommendations are legitimate. Congress recognized that and SARA is for ALL of the recommendations.
We need to prepare to have the Chairman of the House Aviation Subcommittee write a diplomatic letter to FAA politely pointing out that SARA is for all of the recommendations. That will mean political shoe leather getting the whole of the committee onboard.
But your background info on the voting rules strengthens our case.
But most importantly, we must believe and act like we are going to get PNC. We have to act like anything less than PNC is theft.
EAA, when are you going to start scheduling those PNC Repairman classes?
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