Icon A5 Request For Weight Increase Exemption Status

Everyone,

We are missing the big picture here. What is best for aviation overall?

The number of pilots is rapidly declining. If this continues what do you expect aviation will look like in another ten years?

The reasoning for a weight increase is to allow aircraft that will be the most attractive to new pilots as well as keeping existing pilots active.
I understand some are attracted to the older rag and tube aircraft but most new pilots want something modern. The best selling LSA is a composite fully featured aircraft.

For example if Icon has a wing design that is substantially safer that definitely will increase new pilots.
Allowing a weight increase for safety equipment such as parachute will encourage it usage and increase safety and increase pilot number at the same time.

This discussion needs to be about whats best for aviation overall.

Mark

Since when is heavier equal to safer in aviation? The argument that Icon needs a higher weight limite for safety is just silly. Lose the gewgaws and doodads and there will be plenty of weight left for the wings.

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Originally Posted by Markmn

Everyone,

We are missing the big picture here. What is best for aviation overall?

The number of pilots is rapidly declining. If this continues what do you expect aviation will look like in another ten years?

The reasoning for a weight increase is to allow aircraft that will be the most attractive to new pilots as well as keeping existing pilots active.
I understand some are attracted to the older rag and tube aircraft but most new pilots want something modern. The best selling LSA is a composite fully featured aircraft.

For example if Icon has a wing design that is substantially safer that definitely will increase new pilots.
Allowing a weight increase for safety equipment such as parachute will encourage it usage and increase safety and increase pilot number at the same time.

This discussion needs to be about whats best for aviation overall.

Mark

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Originally Posted by Markmn

For example if Icon has a wing design that is substantially safer that definitely will increase new pilots.

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I am not convinced that their admittedly unique wing design will result in a substantially safer airplane. The majority of airplane accidents are caused by loss of control during landing (runway overruns, ground loops, pilot induced oscillations, hard landings, etc.). You also have stupid pilot tricks like running out of gas and VFR into IMC. I don't see the design of the Icon resolving any of those issues. My guess is that once the fleet is large enough to compare to other airframes, the accident rate will be nearly the same.

So, if that is the case, then how will they convince the FAA that they need the additional weight?

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Originally Posted by Eric Witherspoon

One thing they don't answer there is where did the original 1232 lbs come from? I don't recall exactly where I heard, but it was in one of the forums at Oshkosh 2012 - that it came from the energy that the 1232 lbs aircraft would have at stall speed. What to compare that with such that it might have some meaning? Building codes. It's the energy to crash your LSA onto the roof of a house and not break through into the living room. But I guess that wasn't an absolute because then they went and added 90 lbs to it.

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Back when the Light Sport regulations were released, the FAA included them in a 452+ page document that gave the justification for for each aspect of the regulation. Here's some of what the FAA says about the weight limit:

"Some commenters wanted the weight increased to permit stronger aircraft structures, use of four-stroke or type-certificated engines, electrical systems for avionics, starters for engines, or ballistic recovery systems. The FAA is increasing the weight limitation of the light-sport aircraft from the proposed 1,232 pounds (560 kilograms) to 1,320 pounds (600 kilograms). The originally proposed weight limitation was based on the 1,200-pound weight limitation proposed by the ARAC’s light-sport aircraft working group. The FAA agrees that there may be a safety benefit to light-sport aircraft designs to include provisions for currently produced type-certificated four-stroke engines and ballistic parachute recovery systems. Commenters submitted data that indicated that an additional 60 to 70 pounds would accommodate four-stroke aviation powerplants, and that an additional 30 to 40 pounds would accommodate the ballistic parachute recovery systems. For these reasons, the FAA has revised its proposed maximum takeoff weight limitation to 1,320 pounds (600 kilograms) for aircraft designed for operation on land."

The ARAC was the "Aviation Rulemaking Advisory Committee," and the US Ultralight Association (USUA) was the chair. Earlier on in the document, it referred to the USUA as having proposed the 1,320-pound limit.

Nothing in the FAA release about crashing through roofs, but that would have been the purview of the ARAC. I'm skeptical, though. Are roof-strength requirements that standard? It would have had to have been based on the weakest, of course.

You can find a copy of the FAA release at:

http://www.wanttaja.com/LSA_final.pdf

Ron Wanttaja

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Originally Posted by FloridaJohn

I am not convinced that their admittedly unique wing design will result in a substantially safer airplane.

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Can someone explain to this poor, knuckle-dragging EE what it is about the wing design that supposed to be safer than other aircraft? The "Design" section of the Icon web page doesn't seem to have any technical information.

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Originally Posted by FloridaJohn

The majority of airplane accidents are caused by loss of control during landing (runway overruns, ground loops, pilot induced oscillations, hard landings, etc.). You also have stupid pilot tricks like running out of gas and VFR into IMC. I don't see the design of the Icon resolving any of those issues.

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Absolutely. I've got a database of nearly 3,000 homebuilt accidents, and structural failure of the airframe only caused 26 of them. That's about 0.8% of accidents, vs. the about 50% for pilot error cases. About half the airframe cases involved wing failure, and most of those were related to aerobatics, improper construction, or VFR into IFR conditions.

Ron Wanttaja

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Originally Posted by Floatsflyer

Your rationale and logic could easily have me going in a whole different direction but I'm going to take the high road and reply in a straight-up manner.

Perhaps no one thought of it before; perhaps they did think of it but couldn't come up with the design solution or technology to make it work; perhaps cost of development and production was a factor; perhaps their designers lived in a culture where new ideas, progressiveness, innovation and thinking outside the box was not tolerated or valued.

By your definition, things are unneccesary if they didn't previously exist or weren't used. How then does anything new happen? How then do we move forward and progress?

You do realize don't you, that your logic negates new ideas, ground breaking technology, innovation, creativity, ingenuity and going where no one else has gone before.

Within my context of the safety issue alone, your definition of unneccesary must apply to, for example, the Cirrus airframe parachute system(CAPS) because no previous GA aircraft ever had it. According to the Cirrus Owners and Pilots Assoc. as of Jan.25, 2013 there have been 42 known CAPS activations. Of these, 32 are considered "saves" that involved 65 survivors with one fatality. Also, no person has died when when the CAPS deployed within the proper airspeed and altitude parameters as set out by Cirrus. Call me crazy, but I'm pretty damn confident that those 65 souls would not define CAPS by your definition of necessary/unnecessary.

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Innovation is great! So just certify the plane in the actual category it ends up in then. If it isn't light enough, then it isn't light sport legal.

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We are missing the big picture here. What is best for aviation overall?

The number of pilots is rapidly declining. If this continues what do you expect aviation will look like in another ten years?

The reasoning for a weight increase is to allow aircraft that will be the most attractive to new pilots as well as keeping existing pilots active.

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If we're betting on little seaplanes to save General Aviation, we're sunk.

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Innovation is great! So just certify the plane in the actual category it ends up in then. If it isn't light enough, then it isn't light sport legal.

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Amen! There's nothing wrong with revising the category in the interest of safety and other features. Besides, I don't think there is a huge market for this aircraft to begin with; amphibs are a niche - making it LSA makes puts it in a niche within a niche.

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Originally Posted by Frank Giger

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Innovation is great! So just certify the plane in the actual category it ends up in then. If it isn't light enough, then it isn't light sport legal.

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Amen! There's nothing wrong with revising the category in the interest of safety and other features. Besides, I don't think there is a huge market for this aircraft to begin with; amphibs are a niche - making it LSA makes puts it in a niche within a niche.

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I suspect Icon isn't attracted towards SLSA certification because it's easier, but because there's a greater market available by making them Sport Pilot eligible.

The Icon is an attractive airplane, even as a landplane. It's got a modern design, the wings fold, and the cockpit is out of the 21st century. As Frank so aptly said, "If we're betting on little seaplanes to save General Aviation, we're sunk." The Icon has to appeal to potential buyers as a general-purpose aircraft. Personally, I really like the look of the thing. If I had a spare $100,000 or so, I'd seriously consider it.

So...why not go for a lower-cost, lower-complexity landplane version, first? Get rid of the power wing fold, get rid of the retractable gear, get rid of the sponsons, etc. Get some planes on the market. Come out with an amphib version later; with a high degree of commonality in parts.

The main worry about that approach stems from the weight issues. Rumor has it that the Icon can't meet the 1,430-pound limit for amphibious LSAs. We don't know how much it's out. If it's out by ten pounds, one might hope that changing to a non-amphibious version might save the 120 pounds necessary. But if it's 150 pounds above the 1,430-pound limit....

Ron Wanttaja

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Originally Posted by rwanttaja

So...why not go for a lower-cost, lower-complexity landplane version, first?

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Because Kirk & Co wanted to capture recreational boaters first and foremost, that's why. As was observed many times, quite a few of those people throw more at their boats in a year than pilots of Bonanzas, even Cirruses. The S-LSA is central to that plan: every little bit that lovers the barrier to entry is important to the plan. Going after boaters with a seaplane offers some incidentals, too. For example, disconnecting from airports by using marinas. Of course NIMBYs of waterways are vicious too, and the same kind of local mafia is involved that, for example, destroyed the independent FBO at New Braunfels. But expanding the field of battle gives aviators the advantage. Therefore, Icon even mulled a version without gear at all: a pure flying boat (it would be pulled out of the water on the same trailer as a seadoo). I have their old brochure that mentions the gearless option.

I'd love to see the market research that showed that a sizeable number of recreational boaters want to fly an aircraft, and that they're jumping at the chance to pay over a 100K for a plane to do it.

They're not inventing the seaplane, after all. If someone is sitting in their boat thinking "wow, it sure would be great to be a pilot" they'd be a pilot.

I could be wrong, of course.

But saying that boaters suddenly represent a functional market for seaplanes is a bit like saying that sport shooters want to become human cannon balls and will purchase a big a--ed air cannon.

There may not be much evidence to support the marketing effort but Icon is definitely marketing the A5 as a PWC with wings. Even though, modern looks aside, it does nothing that hasn't been done before, but you can certainly tell that Icon has probably spent just as much on marketing as it has on design and test.

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Originally Posted by Flyfalcons

There may not be much evidence to support the marketing effort but Icon is definitely marketing the A5 as a PWC with wings. Even though, modern looks aside, it does nothing that hasn't been done before, but you can certainly tell that Icon has probably spent just as much on marketing as it has on design and test.

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Agree with you there. Market RESEARCH, I don't know.

The customer base is daunting. Start with the number of boat owners (pretty big), weed it down by the number of persons interested in a personal watercraft (smaller), weed it down further by the number who would have ~$150,000 to spend on a personal watercraft, weed it down further by the number of folks interested a flying personal watercraft, weed it down even more by those who would accept a plane with a big "This aircraft does not meet the certification requirements of a standard certificated aircraft" placard.

Finally, weed out those for whom the modern looks and powered wing-fold of the Icon have more attraction than the Searey, which offers similar performance, at lower cost.

But, Icon seems to think there are enough people left over to give them a good batch of sales. If that's the case, fighting the LSA rules don't make a lot of sense: The vast majority of the potential buyers won't already have pilot's licenses, and won't understand the difference between a Sport License and a Private. Twenty hours more training required, when the guy's already considering spending $150K? Trivial. Why fight the LSA weight limits and delay getting it on the market?

Icon would have a big advantage if they offered an ab-initio pilot training program. "With just a 7% addition to the cost of your airplane, we'll give you all the instruction you require gain a license to fly your new Icon." If you're marketing to non-pilots, you're going to have to do something like that....

Ron Wanttaja

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Originally Posted by rwanttaja

Can someone explain to this poor, knuckle-dragging EE what it is about the wing design that supposed to be safer than other aircraft? The "Design" section of the Icon web page doesn't seem to have any technical information.

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I found this description on the Icon website using Google (it looks like it is in the "News" section of the website). It seems like the best description I could find:

About Spins and Spin Resistance

From that link:

"One of the key findings of the NASA studies was that a critical component of spin resistance is controlling the way the wing stalls. They concluded that having the stall initiate near the root of the wing (where it attaches to the fuselage) while the outboard panels of the wing continue to fly is ideal because it prevents the stall from ever fully developing or “breaking” because the outboard panels are still generating lift. Without a stall, a spin cannot initiate. This progressive stall is achieved with a wing cuff, or a discontinuity on the leading edge of the wing that separates the wing into two distinct parts. The outboard segments of cuffed wings have a different airfoil with a drooped leading edge, compared to the main wing, which causes that portion of the wing to stall later than the inboard part of the wing as angle of attack increases. Because the ailerons are located on the outboard panel which is still flying, roll control is preserved even after the inboard panel of the wing has stalled."

So, it looks to me like they have two (or possibly more) distinct airfoils in the wing. This allows the outer part of the wing, with the ailerons, to continue to fly (and have control) while the wing root starts to stall. I guess the "big breakthrough" is that they can completely prevent a spin with the changing airfoils.

The reality is that this is nothing new. Lots of planes have wing designs that allow the wing root to stall before the wing tips. I guess Icon just took it a little further than most do.

Now whether this actually prevents any accidents it's hard to say. I can put my 152 into a non-stalled condition that still results in a descent of over 1000 fpm (i.e. "mushing") that still could result in a crash if I happened to do it at a low altitude. So spin-proof does not necessarily mean safer. I guess one would have to fly an Icon A5 to really see what the implication of the wing design really is. As has been already said, you can hurt yourself pretty bad in a plane without ever entering a stall or spin.

And what makes anyone think that a wing cuff designed in from the outset would carry a substantial weight penalty? Like I said, it's not the wing, it's the doodads that put it over the LSA seaplane weight limit.

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Originally Posted by Matthew Long

And what makes anyone think that a wing cuff designed in from the outset would carry a substantial weight penalty? Like I said, it's not the wing, it's the doodads that put it over the LSA seaplane weight limit.

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I totally agree, although if I were to guess, I would think Icon would say that since the new wing design required the re-introduction of flaps in the wing, and that is the weight "penalty" of the new wing design.

But like you said, I think Icon is using this as a ploy to get more weight allowance. Which is also why I say the FAA will see right through it and deny, just like they did to the Terrafugia when they requested a final weight above the seaplane LSA weight.

As much time as Icon has spent bringing this plane to production, they could have just gone ahead and certified via Part 23. Then they could get all the doo-dads they wanted, sell a few planes, and then strip it down for an LSA version. In all the online articles I have seen, Icon predicted a 2010 date for the first sale. They missed that by three years so far. Meanwhile, Van's has designed an E-LSA, a fly-away factory built LSA version, and has over 200 of them flying in customer's hands. So it can be done in that amount of time.

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Originally Posted by Matthew Long

And what makes anyone think that a wing cuff designed in from the outset would carry a substantial weight penalty? Like I said, it's not the wing, it's the doodads that put it over the LSA seaplane weight limit.

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And when you look at the Icon web page, it says the main doodad (e.g., automatic wing folding) is an *option*. So it ain't the folding wing that puts it over LSA limit.

Ron Wanttaja

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Originally Posted by rwanttaja

And when you look at the Icon web page, it says the main doodad (e.g., automatic wing folding) is an *option*. So it ain't the folding wing that puts it over LSA limit.

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They also list a parachute, landing gear (or, more specifically, deletion of gear), night lighting, and attitude indicator as optional, too.

Maybe Icon should take a look at alternative designs that do meet LSA requirements? Here's a clean, all-metal flying boat that's still well within LSA weight limits. It's a three-seater, not an amphibian, but they could trade that third seat for manually-retracting landing gear. With a light Rotax in place of the original engine, they could use the weight saved to add a canopy, and be good to go as an LSA. Not bad for 1921!

Attachment 2770

Dornier Libelle I

Don't even need to go as far as Dornier Libelle. SeaMax and SeaRey are already available as S-LSA. The latter in particular carries a long kitplane pedigree, while former flied all over the world for years (although last I checked it only scored 5 registrations in U.S.).

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Originally Posted by FloridaJohn

They also list a parachute, landing gear (or, more specifically, deletion of gear), night lighting, and attitude indicator as optional, too.

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They need to check out the limitations of a Sport Pilot. Night lighting? For an aircraft designed for the Sport Pilot which is limited to daytime VFR only?

Sounds like they have a serious issue with "feature creep."

What if a Private Pilot or higher wants to own and fly one?

People want doodads and doodads sell airplanes. As I said earlier we need to look for ways to increase aviation participation.

You guys may be the ones that go to a car dealer and ask for a car without air conditioning and hand crank windows. Nothing wrong with that.
Its just not what most new buyers are looking for. If you cant afford one the only way you ever will is for someone else to buy them so you can buy a used one.

As far as certifying part 23 do you know how much that would add to the cost? Just think a new skyhawk costs $330000.00!!!! and its a 50 plus year old design!!!

Mark

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Originally Posted by Markmn

People want doodads and doodads sell airplanes. As I said earlier we need to look for ways to increase aviation participation.

You guys may be the ones that go to a car dealer and ask for a car without air conditioning and hand crank windows. Nothing wrong with that.
Its just not what most new buyers are looking for. If you cant afford one the only way you ever will is for someone else to buy them so you can buy a used one.

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The problem is when the doodads get in the way of certification. Icon apparently has a plane with all these marketable doodads, and be unable to certify it because it's too heavy. You can't make any money on airplanes that can't fly, no matter how much lipstick you put on the pig.

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Originally Posted by Markmn

As far as certifying part 23 do you know how much that would add to the cost? Just think a new skyhawk costs $330000.00!!!! and its a 50 plus year old design!!!

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The cost of Part 23 certification is less than a lot of folks think. The base price for the Cirrus SR20 is less than what you quote a new 172 runs for, and Cirrus had to certify the SR20 under modern Part 23 less than 20 years ago. For that matter, the Columbia 300 (which became the Cessna Corvallis) was certified about 15 years ago. Heck, they're even re-certifying the Skycatcher under Part 21.

Years ago, they asked Frank Christensen how high the paperwork was to certify the Husky. He indicated a stack about an inch and a half high...shocking folks who thought it was much more than this.

Part 23 is not unreasonable...it's just thorough. You're expected to prove the aircraft meets the requirements, not just nudge the local FAA in the ribs and wink. If you compare Part 23 and the LSA Consensus Standard side-by-side, you'd see a LOT of similarity. You've gotta do the same engineering, with the difference being that the FAA requires you to formally submit the engineering work for assessment.

If Icon had a Part-23 airplane ready *now* they'd be selling it, and having an income. Like Floridajohn said, they could do an initial version Part 23 and use the income to fund evolution into a Sport Pilot-eligible version. Are there THAT many boaters who can't pass a Class 3 medical?

I'm an engineer with a large Chicago-based aircraft manufacturer (though have never worked on the aircraft side). Saw a sign on the toolbox of a shop worker back when I started, 32 years ago, and it's stuck with me ever since:

"In the life of any project, it eventually becomes time to shoot the engineers and begin production."

Play with the gimcracks and doodads all you want, but eventually airplanes have to start coming out the factory door.

Ron Wanttaja

I can't speak to the cost but I do think that the comparison between cars and airplanes, especially between cars and light sport aircraft, is flawed. Unlike passenger cars, aircraft, any aircraft, are critically concerned with weight. "Simplicate and Add Lightness" as Ed Heinemann used to say. Even the smallest passenger cars are required to include energy-absorbing structures and safety devices that even the most expensive aircraft don't have, never mind the luxury doodads. But that's because they can afford the extra weight--overload the family car and it will still get up the hill, just a bit slower, not hit those trees at the end of the runway.

LSA landplane is limited to 1,320 lbs, an LSA seaplane to 1,430 lbs. For comparison, certainly the smallest, probably the lightest and definitely one of the cheapest cars you can get in the USA is the two-seat Smart Pure Coupe with an empty weight of 1,808 lbs and a maximum gross vehicle weight of 2,315 lbs. That's with manual windows, no A/C or radio with 507 lb payload not including 8.7 gallons of fuel plus a reserve of 1.3 gallons. And that's in a car which is a niche market in the USA, too small, light and spartan for the average buyer.

Aircraft, any aircraft, cannot safely accommodate all the bells and whistles without driving up the weight, which requires a bigger engine, which drives up the weight some more, and so on. Off the top of my head, I don't even know of any four-seat production general aviation aircraft that offer something like A/C as standard, or power folding wings at all. What makes Icon think they can fit all that in when the LSA category of aircraft was designed to be light, slow, simple planes for the low-time pilot? If Icon can't figure that out, then they shouldn't be in the airplane business in the first place.

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Originally Posted by Markmn

People want doodads and doodads sell airplanes. As I said earlier we need to look for ways to increase aviation participation.

You guys may be the ones that go to a car dealer and ask for a car without air conditioning and hand crank windows. Nothing wrong with that.
Its just not what most new buyers are looking for. If you cant afford one the only way you ever will is for someone else to buy them so you can buy a used one.

As far as certifying part 23 do you know how much that would add to the cost? Just think a new skyhawk costs $330000.00!!!! and its a 50 plus year old design!!!

Mark

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Originally Posted by rwanttaja

The cost of Part 23 certification is less than a lot of folks think. The base price for the Cirrus SR20 is less than what you quote a new 172 runs for, and Cirrus had to certify the SR20 under modern Part 23 less than 20 years ago. For that matter, the Columbia 300 (which became the Cessna Corvallis) was certified about 15 years ago. Heck, they're even re-certifying the Skycatcher under Part 21.

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Yeah, and now Skycatcher is officially the 2nd most expensive LSA on the market (behind Carbon Cub), while having about the worst payload and range. Lacks any kind of soundproofing, too, and I smacked my head good upon exposed aluminum in it. Way to go, Cessna. But it has a TSOed G1000, yay!

A regular LSA maker would not sell squat of those certified thingies if they did not already have a captive audience of Cessna Pilot Centers.

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Originally Posted by rwanttaja

If Icon had a Part-23 airplane ready *now* they'd be selling it, and having an income. Like Floridajohn said, they could do an initial version Part 23 and use the income to fund evolution into a Sport Pilot-eligible version. Are there THAT many boaters who can't pass a Class 3 medical?

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Please, Ron. The Part 23 to LSA never works, get real. The only airplane that managed that is Sky Arrow and how well that worked out? Magnaghi had to buy assets and restart production, and guess what: only LSA version survived. They are still certified in Europe, of course, and might have the old legal standing, but they do not sell Part 23 anymore. The only other example that's close is 7EC Champ, which is not LSA, of course.

If Icon started with Part 23, their income would not be sufficient to pay back their financing, and they would end in bankrupcy, same as Eclipse. You think that having some income is better than no income (which is what they have now), but it's not true. You only burn through the financing quicker.

The only sensible path is from kit to LSA, like SeaRey, RANS, Van's etc. Not in the opposite direction. Read Christiansen's book, it's the law of northeast migration.

P.S. They advertise a certified Sky Arrow 650TCNS on the website now. So yeah, someone got something useful out of the money that 3I's investors lost in bankrupcy. Still doesn't prove that it's a workable idea.

I think it takes a few overweight designs before a new designer understands about building light.
Having someone with 30 or 40 years experience on the design team wouldn't hurt.

Had a conversation with an AME friend on the subject of LSA weight and durability. He provided this example: A 600Kg Skycather vs. a 757Kg 150/152 have close to the same weight for engine and fuel capacity and use almost the same traditional construction methods and materials. So where did the 157kg go?? It went to structure he said. Structure equates with durability/sturdiness which equates with safety and many other in-the-field operational considerations like after sale maintenance and repair costs, etc.


So while the LSA weight number mostly came from somewhere, perhaps it's not the correct number. Perhaps increasing the weight restriction for all allows the manufacturers to build the kind of aircraft that they would all like to build, all flight schools would like to have for training and you would want to own and fly.


If Icon does not receive the excemption, in my mind they will have 3 options:

-Build to current LSA certification standards

-Build the plane as it currently stands to FAR 21.24 Primary Category Type Certification as I mentioned before. This is the most viable direction and is the most cost effective. Primary costs close to about $1 million for approval(compared to Part 23 which can be from $25-50 million). Cessna has done this with the Skycatcher for sales purposes only outside the US.(LSA is not recognized in many countries).
http://www.faa-aircraft-certificatio...-category.html

-Manufacture both models so they don't lose their sport flying recreational consumer market. This could be the best business model.

All this could be moot when they receive the excemption. So, just for a moment, does anyone have any real insider info on the status of the excemption request?

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So while the LSA weight number mostly came from somewhere, perhaps it's not the correct number. Perhaps increasing the weight restriction for all allows the manufacturers to build the kind of aircraft that they would all like to build, all flight schools would like to have for training and you would want to own and fly.

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But that defeats the basic premise that LSA rules were designed to spur development of a new class of aircraft....

We know that LSA compliant float planes can be built; there are numerous examples to draw from. That some manufacturers can't cut the mustard on the standards is no reason to change them.

Floatsflyer, these numbers are really interesting to me, where did you get them? Are they based on the average cost to certify an aircraft in Part 23, and would it really be that expensive to certify to Part 23 an Aeronca Champ, for example, in 2013? It seems very strange that Part 23 vs. Primary would be a 25-50 times increase in cost for the same aircraft.

Also, if a primary category aircraft meets the LSA definition (like some of the old, light Aeroncas, Pipers, Ercoupes, etc.), wouldn't that be the best of both worlds--internationally recognized certification plus the ability to be flown by sport pilot certificate holders without a medical?

Cheers,

Matthew

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Originally Posted by Floatsflyer

Build the plane as it currently stands to FAR 21.24 Primary Category Type Certification as I mentioned before. This is the most viable direction and is the most cost effective. Primary costs close to about $1 million for approval(compared to Part 23 which can be from $25-50 million). Cessna has done this with the Skycatcher for sales purposes only outside the US.(LSA is not recognized in many countries).
http://www.faa-aircraft-certificatio...-category.html

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Originally Posted by Floatsflyer

Had a conversation with an AME friend on the subject of LSA weight and durability. He provided this example: A 600Kg Skycather vs. a 757Kg 150/152 have close to the same weight for engine and fuel capacity and use almost the same traditional construction methods and materials. So where did the 157kg go?? It went to structure he said. Structure equates with durability/sturdiness which equates with safety and many other in-the-field operational considerations like after sale maintenance and repair costs, etc.

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Hope you meant "A&P", not "AME" (Aviation Medical Examiner). :-)

I can believe it, though. First time I took a look at a Skycatcher, I was a bit dismayed by the metal work on the leading edge of the wing. Really a change from my old 150. Still, SOMETHING has to give, when you have to pack the same basic capability in a ~270-pounds lighter package.

Just seems weird that Icon missed the weight budget so bad that they have to ask for a waiver. They've got some Scaled Composites veterans in some high places, and what looks to be good engineering qualifications all around. Does make you wonder how much marketing is driving the engineering.... "You MUST include XXXX, YYYY, and ZZZZ in the design!" Seen that sort of thing before....

Ron Wanttaja

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Originally Posted by Matthew Long

Floatsflyer, these numbers are really interesting to me, where did you get them? Are they based on the average cost to certify an aircraft in Part 23, and would it really be that expensive to certify to Part 23 an Aeronca Champ, for example, in 2013? It seems very strange that Part 23 vs. Primary would be a 25-50 times increase in cost for the same aircraft.

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Strange or not Matthew, actually the Part 23 cost to certify is currently as we speak twice that much!!! Greg Bowles, GAMA Director of Engineering and Manufacturing says it's $50-100 million.

http://www.avweb.com/podcast/podcast...?kw=AVwebAudio

As you may or may not know a review of Part 23 is underway with many reforms including costs being considered. The objective with costs is to reduce them by at least half. My figure was based on this possible outcome so I applied some simple mathematical optimism for near future certification approval.

http://www.flyingmag.com/pilots-plac...23-time-change

From NBAA website, October 10, 2012:

"Speaking in the city that manufactures more than 40 percent of all standard general aviation (GA) aircraft in the world, Huerta said he expects the FAR Part 23 changes to slice new-aircraft approval cost by as much as half by ‘harmonizing’ the FAA’s rules with those of other countries. He cited a required wing-strength test, saying that each country might have a slightly different requirement for the test, costing manufacturers millions of dollars to make slight changes to satisfy each country"

The Primary Category cost is based on osmosis -talking and listening to people discussing the subject.

Your question about the Champ is exactly what the Part 23 review is all about which is basically to shift the Rules from the being weight based to being performance based.

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Originally Posted by Floatsflyer

Strange or not Matthew, actually the Part 23 cost to certify is currently as we speak twice that much!!! Greg Bowles, GAMA Director of Engineering and Manufacturing says it's $50-100 million.

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Here's a good article by Dan Johnson that applies pretty well to our discussion here:

The cost of certification

In this article, he says,

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A major organization has estimated the cost of Part 23 certification to be valued at $50 million, however, that figure reportedly includes the cost of designing and testing…so certification cost alone might be perhaps half, or $25 million. It’s challenging to be certain of the total cost of certification as some expenses will be commingled or “burdened” by non-certification tasks.

So, in round numbers — and just for discussion — certification costs might be $150,000 for an LSA, $1 million for a Primary, and $25 million (or so) for Part 23. Even if the numbers are off by a wide margin, the differences are huge — and you don’t have to be an economist to see how this affects the retail price of airplanes.

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Just to add a little more information to this discussion, I also ran across this article from Flying Mag in 2011:

ICON Aircraft Receives $25 Million Cash Infusion

So maybe if Icon spent a little less on marketing, they could just go ahead and pay for full certification. :eek:

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Originally Posted by rwanttaja

Hope you meant "A&P", not "AME" (Aviation Medical Examiner). :-)

Ron Wanttaja

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No hope involved, no typo made. In Canada an A&P is called an AME--Aircraft Maintenance Engineer. Way too many damn acronyms in aviation that mean different things in different jurisdictions. Can get confusin':)

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Originally Posted by rwanttaja

Just seems weird that Icon missed the weight budget so bad that they have to ask for a waiver. They've got some Scaled Composites veterans in some high places, and what looks to be good engineering qualifications all around. Does make you wonder how much marketing is driving the engineering.... "You MUST include XXXX, YYYY, and ZZZZ in the design!" Seen that sort of thing before....

Ron Wanttaja

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I believe that marketing and engineering works best when it's a two way street, one driving the other and vice-versa. This works very effectively but only in an atmosphere like Icon where the business plan is sound, the company is extremely well capitalized so they can afford to be methodical and thoughtful(no need to rush to market with anything less than the full realized design vision) and the engineers are "A" List totally suited to the design and its optimum execution.

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Originally Posted by Floatsflyer

I believe that marketing and engineering works best when it's a two way street, one driving the other and vice-versa. This works very effectively but only in an atmosphere like Icon where the business plan is sound, the company is extremely well capitalized so they can afford to be methodical and thoughtful(no need to rush to market with anything less than the full realized design vision) and the engineers are "A" List totally suited to the design and its optimum execution.

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Well.... agree fully on the first sentence. We won't know if it's working effectively at Icon until they actually have a product on the market.

Kind of like the Monty Python Cheese sketch. Guy's trying to buy cheese in a cheese shop, but the guy behind the counter says they're out of stock on every type of cheese the guy asks for. There's eventually an exchange that goes like this...

"This *is* a cheese shop, isn't it?"

"Yes, sir, finest in the district!"

"Explain the logic behind that remark."

"It's so CLEAN!"

"Well, it's certainly uncontaminated by cheese....."

Icon might have a great atmosphere between the marketers and engineers, and the business plan might be sound, but they're certainly uncontaminated by airplanes.

Ron Wanttaja

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Originally Posted by rwanttaja

Icon might have a great atmosphere between the marketers and engineers, and the business plan might be sound, but they're certainly uncontaminated by airplanes.

Ron Wanttaja

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Appreciate the analogy and understand the skepticsm. The aviation graveyard is filled with too many start-ups with bad business plans, horribly under funded and too quick to take your deposit money for development, production and try to get to market and deliver something. For some of these "companies" and we all know who they were, these startups were run almost like a ponzie scheme-as long as the money was flowing in, they were Ok, as soon as it stopped they(and depositers and vendors) were f***ed.

We don't need more of that because we need to attract VC's, and private equity placement investors to believe in small airplanes that are market driven and will be delivered. I don't believe in saviors for anything but I do believe that Icon can and will provide the much, much needed shot in the arm that is so desperately required.

Meanwhile Janice Wood regurgitates Icon's newsletter today that trumpets the start of production and includes the following curious snippet:

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The horizontal tail tip removal system is another area in which ICON’s industrial design and engineering teams have collaborated closely in recent months. The tips of the horizontal tail are removable in order for the A5 to fit within the Department of Transportation’s over-the-road width limit when the aircraft is being trailered. The system has been designed around a sliding action with positive locking pin, which is both user-friendly and serves to ensure that the tip of the tail is securely installed, company officials said.

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Brilliant, yet another weight-adding item.

I'm on Icon's email blast list and received this newsletter. Janice Wood of GA News has misled her readers with the headline "...Production Begins On Icon A5" The newsletter is a "Production Update", the most current one of many Icon has sent out in the last few years. Amongst many things it sets out production status including that certain tooling masters and production articles for components are being produced in preperation for delivery to and manufacturing by Cirrus. Janice Wood must have come from Fox News because she writes things unsupportable by facts. This is irresponsible journalism at the least. Just last week she wrote an article about LSA that included the statement that LSA prohibited engines greater than 100hp.


The real "curious" thing for me is that Icon, in the absense of an FAA exemption decision, continues to move forward rapidly as if they've received approval. Either that or they are supremely confident or know something that has not been made public as yet or they are proceeding regardless of yea or nay decision by preparing to go ASTM or Primary or both.

Maybe they invested very well when it comes to Congressional and Senate lobby efforts. Nothing cuts through red tape like a congressional inquiry....usually just asking the question is enough to get resolution in a favorable way.

"Yes, Mr. Congressman/Senator, we've looked into the matter you asked about and, as a matter of our careful and efficient processes, have found in favor of granting the waiver. We at the FAA have as our mandate to encourage aviation in every way, helping domestic innovation and the jobs they create. I have directed the appropriate department to contact Icon representatives by telephone and email as to the decision; it may take a week or so to follow on with the official waiver as recent fiscal challenges within the FAA have caused an administrative delay in most of our notifications.

"Unfortunately, we will have to advise Icon to not announce the waiver approval until such time as they receive the official issuance. Thank you again for your interest in this matter and please do not hesitate to contact us again if you require more information or have any other questions."

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Originally Posted by Floatsflyer

The real "curious" thing for me is that Icon, in the absense of an FAA exemption decision, continues to move forward rapidly as if they've received approval. Either that or they are supremely confident or know something that has not been made public as yet or they are proceeding regardless of yea or nay decision by preparing to go ASTM or Primary or both.

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I would guess that they are preparing for multiple courses of action depending on the FAA's decision. If the FAA decision is favorable, then they go with Plan A. If they get some, but not all, of what they want, they go with Plan B. If they are completely turned down, then they go with Plan C. It's probably what I would do in their shoes. That way they can announce their plans immediately after the FAA decision, and hopefully start delivering planes as soon as possible.