Ok EAA- The Part 23 rewrite is released. What is your analysis of it? Are we going to get Primary NonCommercial or something like it?
ted
Ok EAA- The Part 23 rewrite is released. What is your analysis of it? Are we going to get Primary NonCommercial or something like it?
ted
I thumbed through what I could find; some 346 pages of FAA jargon titled "Revision_Airworthiness_Standards_ Normal_Utility_Acrobatic_Commuter_Airplanes_NPRM". I saw nothing in it for allowing us to do like Canada and make a Certificated Aircraft into another category allowing the use of non-PMA parts or unapproved modifications. The vast majority of the document seems to be for applicants for a new Type Certificate and the additional standards they will have to meet by making their aircraft "Stall Resistant", "Spin Resistant", and more crashworthy. It hints at loosening up the field approval process for AMOCs, but as we all know, those vary from FSDO to FSDO, so I really wouldn't expect much out of that.Originally Posted by TedK
-Cub Builder
uh, no. Perhaps because it was not even part of the NPRM? The Part 23 rewrite is essentially the same rules re-written to better harmonize with international standards. There is now a "simple" (relative term) way to certify new manufacture lightplanes. I'm not sure if they met the goal of "cutting certification costs in half" and it doesn't matter. Even if they did, the price of a new plane certainly won't be reduced by 50%. The certification cost (as I have said all along) is not really an obstacle to new plane sales. [Wow, just rewriting the rules was delayed by 2 yrs due to the complexity of the task. Is there any way to "simplify" any part of a gov. bureaucratic process??] lol
Here is the good news. A manufacturer can design and build a new light plane (think Cezzna Skythrasher) and it will only cost ~$150,000 to bring it to market! If somebody is dum enough to take that gamble, how many do you think would be sold?? 50 units? It can even scale up to a $250k 4-place. I can just seen people standing in line waving their checkbook!! My prediction is don't expect to see new affordable lightplanes popping up in your neighborhood airplane showroom anytime soon and your time will be better spent pounding rivets into a homebuilt.
Probably depends on your definition of "affordable". I think I live in a different exchange rate area here near Tampa than some other folks. Saw a new Maserati Quattroport GTS parked at the Walgreen's yesterday and a couple years old Lamborghini in Micky D's drivethru line behind a Ford GT40. Those GT40s are ten years old, must be cheap by now, right? My plane, my camper, and both my cars, I still didn't pay what any one of those cars cost new. And they let their rugrats eat in them! Different exchange rate.
Have you read the FAA instructions to the Part 23 Aviation Rulemaking Committee?
They included direction to come up with methods to improve the safety of the existing fleet too. I think the goal was a 50% increase in safety. The ARC responded to that direction with what was called PNC.
The watered down 21.9 doesn't even come close to that the ARC recommended.
EAA (Sean)...those of us who own certificated aircraft are waiting to hear from you.
ted
Two key things I saw:
C. Benefits for the Existing Fleet
The proposed revisions would benefit owners and modifiers of existing part 23 airplanes,as well as airplane designers and manufacturers. Both currently and under this proposal, airplanes may be modified by: (1) an alteration to an individual airplane; (2) a supplemental type
certificate (STC) for multiple airplanes, or (3) an amendment to an original type design via an amended type certificate (TC). This proposal would streamline each of these methods for modifying airplanes.
The proposed change to § 21.9 would facilitate FAA approval of low-risk equipment produced for installation in type-certificated airplanes, thereby streamlining the process for owners to upgrade equipment on their individual airplanes. An example of how this change would facilitate safety improvements is the installation of inexpensive weather display systems in the cockpits of small airplanes. These systems allow a pilot to view current weather conditions along the planned flight route and at the destination airport, avoiding unexpected or deteriorating weather conditions. Since these systems are not required and because they represent low safety risk from failure, the FAA believes streamlining its approval process to produce them for use in existing airplanes could lower costs and increase availability of these systems.
The proposed changes in the rules would also streamline the process for design approval holders applying for a type design change, or for a third party modifier applying for an STC, to incorporate new and improved equipment in a model or several models of airplanes. Since the revised part 23 standards would be much less prescriptive, the certification process for modifications would be simplified. Certification of an amended TC or STC under the proposed part 23 standards would require fewer special conditions or exemptions, lowering costs and causing fewer project delays.
(Pages 19 and 20)
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B. Introduction of Simple Airplanes
The regulations contained in part 23 have gradually become more focused on high performance, turbine-powered airplanes, and this emphasis has become a barrier to the efficient certification and introduction to market of new entry-level, simple airplanes. The Part 23 Reorganization ARC specifically noted that current part 23 does not have appropriate standards for the certification of entry-level airplanes.
The FAA proposes to define “simple airplanes” in § 23.5 to recognize the entry-level airplane. Simple airplanes would be limited to airplane designs that allow transport of no more than one passenger (in addition to the pilot), are limited to VFR operations, and have both a low top speed and a low stall speed. These airplanes are similar to EASA’s Certification Specification-Very Light Aeroplanes (CS-VLA), which are currently imported to the U.S. and certificated as special class airplanes in accordance with 14 C.F.R. § 21.17(b). The proposed change would allow these airplanes to be certified as normal category airplanes under part 23.
The FAA believes that permitting certification of simple airplanes would allow more certified entry-level airplanes to enter the marketplace. The FAA expects simple airplanes to be a more basic sublevel within proposed certification level 1, but recognizes that because of similarities between simple and non-simple airplanes within certification level 1, creating this category may be unnecessary. For this reason, the FAA is specifically asking for comments concerning the utility of creating a separate, simple airplane sublevel.
(Page 30)
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Basically, simplified STC process for "low risk equipment," and simplified certification for less-complex aircraft.
Ron Wanttaja
Yes, there are real improvements that could bring us cheaper new aircraft in a decade but for the existing fleet the 21.9 modification requirements still require "approved data." Sure it will let you have a WX receiver or a CO detector (not that you couldn't really have them before) but since it requires approved data you can't add a low cost non-TSO'd autopilot.
From Page 51 of the ARC Final Report:
- An STC or alteration must be shown to comply with the regulations by means of any acceptablemeans of compliance. (emphasis added)
From the NPRM:
G. Production of Replacement and Modification Articles
The Part 23 Reorganization ARC recommended simplifying certification requirements for non-required systems and equipment, with an emphasis on improvement in overall fleet safety from the prevailing level. In the past, the FAA has not established different production requirements for required and non-required equipment that may enhance safety, or for articles whose improper operation or failure would not cause a hazard. The current requirements for producing articles and representing those articles as suitable for installation on type-certificated products are well suited for articles manufactured in accordance with a product's TC or STC, as well as for TSO and PMA parts. However, they may unnecessarily constrain the production of non-required, low risk articles.
Current standards for the production approval of these articles can create a barrier for their installation in the existing fleet of aircraft. Examples of such articles include carbon monoxide detectors, weather display systems, clocks, small hand-held fire extinguishers, and flashlights. In many cases, these articles are “off-the-shelf” products. It is frequently difficult for a person to install these articles on a type-certificated aircraft because the level of design and production details necessary for these articles to meet the provisions of current § 21.9, as expected for more critical articles, are frequently unavailable.
The FAA is therefore proposing to revise § 21.9, Replacement and Modification Articles, to provide applicants with an alternative method to obtain FAA approval to produce replacement and modification articles. This proposed change would allow a production approval applicant to submit production information for a specific article, without requiring the producer of the article to obtain approval of the article's design or approval of its quality system. The FAA intends to use the flexibility provided by this proposal to streamline the approval process for non-required safety enhancing equipment and other articles that pose little or no risk to aircraft occupants and the public. The FAA requests comments on this proposal, and particularly is interested in comments regarding whether the proposed change would safely facilitate retrofit of low risk articles and whether there are alternative methods to address the perceived retrofit barrier.
There is a huge thrust to avoid Loss of Control, but this does nothing for help the existing fleet.
I have now had a chance to read, and reread, this looking for the pony for the existing fleet. It isn't in there.
To the FAA, I say "Shame!" You chartered an ARC, gave them direction to include the existing fleet, and then ignored the ARC's response.
To EAA, If you want to be useful to those of us who have certificated aircraft, we are looking for your response to us and engagement with the FAA in responding to this NPRM.
Ted
Last edited by TedK; 03-12-2016 at 02:52 PM.
I don't think the ARC's recommendation has been ignored. Over time, other aspects of the directive will trickle into the regulatory process. My guess is you'll see a NPRM on a PNC category by 2018. Of course, delays could push that back by ~??? yrs? After all, this current jewel was delayed by ~2 yrs?
I agree some what with Marty, this is far from rule, When they make it easy for us to update the older technology with new, the manufacturers of the old technology will pitch a fit. When it becomes legal to run dual electronic ignitions systems, B&C alternators, for example. you'll see companies like Slick, TCM, And electro, apply a lot of pressure to keep themselves in business.
Plus the fact the FAA's priority is not the retro fit of the fleet, it is the manufacture's ability to certify the new aircraft types. And that is a narrowing market, arguably too small to commit large money in new product.
Last edited by Tom Downey; 03-12-2016 at 06:12 PM.
Uhhh.... no... ANV!!!!
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