EAA Fails older aircraft on Part 23 rewrite.

[TedK]

EAA, AOPA, AEA and GAMA provided a joint letter on the Part 23 NRPM. The basic comments of the letter pertain to the basic portion of the rule for reducing the certification burden for newly produced aircraft.

However, EAA and AOPA were silent and failed to advocate for inclusion of the PNC (ANV) provisions offered by the ARC.

You squandered a fabulous opportunity to have codified an easy way to upgrade and modernize older Certificated aircraft.

Ted

[crusty old aviator]

My '41 Porterfield is certificated under CAR 3, why would want it "updated to" to the "new and improved" Part 23? Admittedly, many of the young dolts at MIDO's look at my paperwork and say, "WTF???" when they see anything with CAR 3 certification, because all most of them know is bizjets, airliners, and helos...but I still believe aircraft certificated under CAR 3 and CAR 4 are fine, as is.

[TedK]

Crusty- when FAA chartered the Part 23 Rewrite Aviation Rulemaking Committee, they (FAA) included in that charter that the ARC find ways to improve the safety of the existing fleet in addition to simplifying certification for new airplanes to be built under Part 23.

The ARC proposed that there be a method where aircraft older than 20 years, not used commercially, could essentially be treated much like an Experimental Homebuilt and the owner could use non TSO'd equipment. It was call Primary NonCommercial (PNC) in the ARC output.

There was no intent to raise the certification bar for existing aircraft, or to have you leap a higher bar.