Why SARA and PNC are different

[TedK]

Thanks for posting this. Not only did SARA specifically reference the ARC report, it also includes a specific annotation in the findings:

(8) General aviation safety can be improved by modernizing and revamping the regulations relating to small airplanes to clear the path for technology adoption and cost-effective means to retrofit the existing fleet with new safety technologies.

Nothing would do more to meet that objective than reducing the cost of upgrades. Nothing would do more to cut upgrade costs than allowing non-TSO / non-PMA systems and parts. That points directly at the PNC proposal. I only wish they had called it out specifically as they did several other items in Section 3(b).

SS- the ARC Report was clear, the only way the ARC could get the overall safety the FAA desired was by going beyond the strict PART 23 changes but to an easier avionics method and the PNC recommendations. It does seem counter-intuitive but the study participants (FAA, TC, EASA, Brasil, Japan, etc) felt that PNC was a safety enhancement. Also note that the study report says the FAA told the study particiapants that they were not limited to Part 23

It it is likely that we (EAA, AOPA, letter writing constituents) will have to get The House Aviation subcommittee to write a much more diplomatically worded letter to FAA that generates the thought cloud, "what do you not understand about implementing the whole report?"

The ARC Report (pg iv) Executive Summary notes that these recommendations are different and "unlike many recommendations from other ARCs, are not stand alone. The following recommendations are considered a package. ...implementation...short of the full package will not provide the transformations in safety or reductions in cost that aredesperately needed..." Further, "All recommendations in his report had overwhelming majority agreement." These were the Feds, professional regulators from many countries writing this report!

The introductory paragraph of the report (pg 1) makes clear that the ARC could not achieve the desired improvements solely by changes to Part 23 . "Over the course of the first few meetings, the ARC determined that including improvements to the existing fleet was an absolute necessity to get the desired safety increase in a reasonable timeframe."

The above points indicate that implementing the ARC's recommendations without Appendix G will not meet the statutory requirements expressed in SARA. To let the FAA restrict changes to strictly Part 23 would not only be morally wrong but most likely in violation of SARA, illegal.

Mike Berg- your comments are at the heart of the ARC Study Recommendations. The ARC understood you argument precisely, and that is exactly what is in the Appendix G PNC recommendations.