Why We Need New Certification Rules
This week, Robert Goyer reported on the new certification standards that are currently in the making at the FAA. Our industry is in dire need of this change. We need it to improve our safety record and to attract more people into the wonderful world of flying.
I learned to fly in a Cessna 152 that was, at the time of my training, nearly four decades old. Having been through the paces in the training environment, it looked even older. The equipment on the panel was outdated and the interior worn out. It was only my pure passion for flying that kept me going through my training. This type of worn out airplane is unfortunately the norm at many flight schools.
With such antique airplanes, it’s no wonder that few people are attracted to aviation. But flight schools can’t afford to upgrade because new airplanes have become so expensive. The rates the schools would have to charge would be too great for most potential customers. And the outrageous cost of new airplanes is due to the complexity of certification.
Several years ago, I worked for a company called Liberty Aerospace. The Liberty XL2 is one of only a handful of airplanes that have been certified in the past several decades. But despite the fact that the XL2 was birthed from an airplane that had already been flying for several years, the Europa kit plane, the road to certification was extremely long. Liberty was formed in 1998 and the airplane did not receive its FAA certification until 2004. Part of the reason was that the Liberty was designed with new technologies, the most complex of which was its Full Authority Digital Engine Control (FADEC) equipped engine.
The FADEC system electronically optimizes the fuel going into the Liberty’s Continental IOF-240-B, so there isn’t even a mixture control in the airplane. FADEC reduces the workload for the pilot and keeps the engine happier, too.
The Liberty also had a full carbon fiber fuselage, another fairly new concept for small airplanes at the time. But carbon fiber is extremely strong and keeps the people inside safer.
The complexity of the current certification rules actually makes us less safe. It makes it more difficult to get safety equipment such as airbags, angle of attack indicators, structural safety design elements and equipment that helps pilots in case of emergencies (such as the Vertical Power system now in development) into airplanes. Hopefully the ARC will achieve its goal of making certification half as expensive while doubling the safety.
All Comments
Great topic Pia!
I learned in C-150s and 152s as well, in 1974. When I go out to my local airport I see the same old 1970s 172s, Warriors, Tomahawks etc, used for initial training. That isn 't too bad when you're new to it and just want to get airborne. Like Pia, my flight school cannot afford a DA-40 or SR-22 or a retractable, because they are too expensive and don't get rented often enough to pay their way.
A generation or two ago there seemed to be a Cessna pilot center at many airports. When Cessna was running their flight schools they could keep the cost low for training because they didn't have to pay retail for their airplanes. Those were the days, renting a 172 for $35/hour, building time, going places on the weekends. The combination of cheap rentals plus lower gas prices made the whole thing seem to work for me, and probably for most casual pilots. That same ratty, high-time 1970-something Skyhawk is now $110 per hour and my income hasn't risen to match that inflated rental rate. I don't know how flight schools can even keep the doors open with such high prices. A lot of their business now is young men and women training to be commercial pilots in tech schools like Embrey Riddle. The casual student is no longer the biggest driver of their business.
One way to make rentals affordable is for manufacturers to stop making 300 hp fire breathers and build a new generation of simple, two-seat, 100-180 HP fixed gear machines without $200,000 worth of avionics, leather interiors, synthetic vision, TCAS, TAWS and two-axis autopilots. If someone can build an RV-6 is his garage for about $100,000, Cessna should be able to make it in a factory for a lot less and get that plane to market for about $145,000.
Most people can fly A to B with a map, a compass and stopwatch and get there just as fast and nearly as accurately. For the majority of 1-3 hour VFR trips, that plus a VOR or two and transponder are all you really need. Okay, maybe a handheld nav-com for emergencies.
Why does a new 162 have to have the same complexity of avionics as a Baron or King Air? They are students; teach them the basics, including steam gauges, since that's what they'll be renting after their training is over. A student doesn't need a flat panel to be able to read an instrument, or to fly from A to B. It is a luxury that adds cost without giving anything back, except a level of situational awareness that would be lost on many students.
And the cost of certifying new planes is untenable for manufacturers. Beech just went bankrupt trying to sell jets and turboprops and turbine military trainers. Mooney is all but moribund. China owns Cirrus and who knows who the next domino to fall will be.
Perhaps what we need are a new generation of industrialists with manufacturing capacity and without huge the liability tails existing manufacturers struggle with. Let them become the 21st century plane makers. Look at Pipestrel for example, who build the Virus, a two-seat, high-wing composite plane in Slovenia that will go 145 knots on only 100 hp. You can buy it for about $125,000 with a warranty or about $100,000 to built it yourself, including engine, prop, instruments and interior. Why can't North American manufacturers do that?
Any of the existing manufacturers who build aluminum airplanes could purchase the rights to the Grumman American line of singles tomorrow for very little and build them just the way they were in the 1970s, without the huge cost of certifying a new plane. The AA-5 series were simple planes with good performance that were sporty, fun to fly and didn't break the bank. Another good design from yesteryear was the Globe/Temco Swift, which could be put back into production without millions in up-front cost.
Vans recently came out with a certified aircraft. Perhaps they could do the same with there most popular models, the RV-6 and 7 series. Simple planes, no retractable gear, just go fast efficiently with one other person.
Flying is great, if you can afford it. I got out in the 1990s after an inexpressive source for a well-equipped low-time Grumman Tiger dried up. I find Microsoft flight simulator almost as much fun as the real thing now, thought I do get the itch now and then. Fortunately I have a couple buddies who still own planes, so getting some stick time isn't too difficult.
If I were a young person looking a flying as a hobby I might pick golf or skiing or almost anything else, because at the end of the day all you get for copious amounts of money paid for rentals are entries in a logbook and some nice memories. Pay a grand for golf clubs and you have something tangible to use for years. Buy a pair of skis and you can shush your hearty out for a decade.
Douglas M
Surrey, British Columbia, Canada
The FAA has made aircraft operation and ownership more and more difficult over the years. The cry for "reform" has been an ongoing thing for the half century I've been alive! I own and operate one of those "antique" aircraft. For God's sake, the FAA has now made it impossible to get a field approval for any sort of alteration. Good going FAA, that should help aircraft operators improve safety!!!
There is some incredibly "wrong headed" thinking going on at the FAA. Real world light aircraft safety has never been the issue. Incredible effort goes into aircraft certification, yet near zero effort goes into risk based analysis of accident prevention.
Sorry, but LSA aircraft are not the answer. They are limited in speed, performance and capability. The LSA "gift" the FAA gave us is a joke. I simply can't fly my family, my dog and my gear across the continent in any LSA.
FAA is not being creative enough in thinking about this - which is a shame, because the organization has shown bursts of creativity in the past (Part 103, LSA)
FAA should offer several levels of certification as options for private aircraft - but eliminate the requirement for certification (at least for private use). This may seem radical, even shocking, but consider: cars are not safety-certificated by any Federal agency (their fuel efficiency, yes, but not safety).
Then, demand for its certification services would help it to determine how conservative it needs to be. It could even think about offering different levels of certification.
We already see lots of people flying Experimental (almost, but not quite entirely lacking FAA oversight in their design and construction), pointing to a portion of the market that is willing to use other indications of airworthiness, at a price.
At the other end, well-heeled buyers want "nothing but the best" for themselves and their families, and "wouldn't be caught dead" in an Experimental aircraft.
So, there is demand for both extremes, and probably several levels in between.
Also, FAA should provide for a path to certification via fleet experience. Essentially, if, say, Vans or Rans can document that a fleet of RV-7s or S-6s has accumulated more than 5,000 hours of operation, there should be a path to allow builders who construct the aircraft exactly as designed, to apply for an FAA Normal Airworthiness Certificate (perhaps after a further test period for the individual aircraft). This approach would allow aircraft designs to be introduced at low cost, and only the ones that prove popular (as Experimental designs) would then go through the incremental cost of certification - which would be small, if fleet experience were acceptable as part of the flight testing.
Remember how SLSA were going to be made on the cheap, less than $100k because the FAA stepped back and allowed consensus design criteria? And how so many new pilots would be minted and increase the flagging pilot population. Neither happened. Why is anyone's guess—but thinking that a redesign of Part 23 will add scads of new, cheaper aircraft attracting new students is not realistic. People are doing other things with their spare change and time. Until an in-depth, expensive and honest study on the many facets of appeal, training and retention is done by the GA industry even cheap aircraft will only see a marginal increase in pilot population.
"I learned to fly in a Cessna 152 that was, at the time of my training, nearly four decades old."
There aren't any 152s that old yet. You meant Cessna 150, right?
I'm glad they are dusting this off, but I'm not optimistic. Like someone commented already, LSA has very little of FAA hinderance and most examples are still not cost effective.
I can't figure out why everything costs $100K? Is it the liability insurance creeping in there?
Brent
http://iflyblog.com
"People are doing other things with their spare change and time. Until an in-depth, expensive and honest study on the many facets of appeal, training and retention is done by the GA industry even cheap aircraft will only see a marginal increase in pilot population."
I agree, cfiace, except for one thing—running a study doesn't change a thing. That study has already been run, IMO. Read Martha Lunken's column "A Tale of Two Pilots" in the October issue of FLYING....she hits the nail squarely on the head. It's a societal issue, not a temperament or "entertainment choice" problem. People don't fly because they don't want to fly.
"FAA should offer several levels of certification as options for private aircraft - but eliminate the requirement for certification (at least for private use). This may seem radical, even shocking, but consider: cars are not safety-certificated by any Federal agency (their fuel efficiency, yes, but not safety)."
Thomas Boyle, you're a genius. Seriously. Unfortunately, people are too scared and dependent on government to want to assume the risk that would entail. Plus, have you ever heard of a bureaucrat giving power and control back to the people they took it from? You'll see a farm fly before that happens. :-)
SBarnettW,
Thanks for the hat-tip there!
You said, "have you ever heard of a bureaucrat giving power and control back to the people they took it from?"
Yes! I have! I've seen the FAA do it FOUR times, and I see it inching in that direction again! That's why I have hope on this front - although I admit it will likely be slow. But the fact is, the FAA has gone through waves of "giving the power back to the people" on sport aviation.
Consider:
- The FAA didn't have to allow Experimental - Amateur Built, but it did it.
- The FAA could have regulated ultralights (probably out of existence), but instead chose to pass the most libertarian regulation I've ever seen - one that actually specifies that NO airworthiness or operator regulations can be required (and this supersedes and state laws attempting to do so).
- The FAA could have just said "no" to LSA, but instead chose to try it and see how it turned out (pretty darned well!).
- The FAA could have just said "no" to the driver-license-medical Sport Pilot rating, but instead chose to try it and see how it turned out (pretty darned well!)
Don't give up on the FAA. It has shown that it can resist the natural pressure to expand its own powers, to do the right thing once in a while. There are good people there. We need to help them to understand and justify giving the power back to the people. I have hope!




