News came down from the feds the other day that the FAA was forming an aviation rulemaking committee to look into overhauling the standards contained within Part 23 of the regs that govern certification of most light airplanes. This is a great thing. These rules are too complex and complying with them is extremely costly.
But they're there for a reason. They were introduced, in short, to ensure that the airplanes we fly are airworthy in design, that each one of them is the same as the others of the type, and to some lesser degree that they'll hold up over time. I've said this before, and I'll say it again: If that sounds like an easy thing to pull off, you've never been within shouting distance of a company that certifies airplanes for a living.
We need certification. Without it, light general aviation would have ceased to be decades ago. There is room in aviation for the amateur built category, but only as an adjunct to Part 23. Are our certification rules perfect? Far from it. At their worst, they are bafflingly complicated, shockingly expensive to comply with and seemingly arbitrarily enforced. I remember when Cirrus first moved to certify a new airplane, the SR20, nearly 15 years ago now, just how optimistic the company was about the process. Sixty million dollars and several years later, it had succeeded in passing the finish line and educating itself in the fiendish process that is certification. They approached their second airplane with eyes wide open.
Is the process worth it? Absolutely. If you don't think so, all you have to do is contrast the accident rates of the largely self-regulated Light Sport industry with that of Part 23. Certification is at least twice as safe in much larger, faster and more complicated airplanes. And if you compare certified aviation with amateur-built flying, the contrast is even starker. As expensive as it is, Part 23 makes our airplanes safer. That's an indisputable fact. I've flown a lot of Experimental airplanes, probably more than a hundred different models of them, and I'll tell you this. Some of them are very, very well designed and solidly constructed. They are a credit to their designers and builders. But too many others are downright scary to fly. I have a list in my head right of a few that I would never, ever fly again.
Why such a gamut of success? Easy. There are no standards. If you can dream it up, you can sell it as a kit.
Certification is the opposite of that. When you fly an airplane that has been put through the FAA's Part 23 wringer, you know that it meets certain standards. There are rough spots with certain airplanes, sure. But they all meet the standards. A single-engine airplane, for instance, is going to be able to fly right down to 62 knots within a few knots before it stalls. That's a big deal. Especially when you pair it with the hundreds of other requirements that airplanes need to meet before they get that seal of approval. That's peace of mind and safety, safety that can measured in lives saved and lives lost. We should never forget the stakes here.
But there is much room for improvement. What we don't need is so much paperwork. What we don't need is guessing whether Inspector B will disallow the work that Inspector A previously approved. What we don't need are rules intended to keep jets safe applying without good reason to piston airplanes that can't break 140 knots going downhill. What we don't need is the FAA taking so long to inspect work that companies need to furlough workers while they wait. Let's rewrite Part 23's standards to ease the pain on manufacturers while being critically careful to do nothing that would make our airplanes any less safe than they are now.
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Submitted by cfiace on August 26, 2011.
I'd commented previously on Part 23 comb over boiling down to employing FAA engineers, since the appeal to fly seems to have waned and the cost for start-up manufacturers, in the USA at least, is prohibitive . On further consideration, I wonder if current manufacturers such as Cessna, could benefit from streamlined (relaxed) regulation to recertify say a C172 to new standard via paper submission. By recertifying they could realize cost avoidance in existing requirements or move production to facilities in China more easily.
Reminds me of a reverse situation for the Ford F150 pickemup truck 1o years ago +/-. The F150 is, I believe, the most popular truck in the US, but had the worst safety record at the time. New DOT regulations mandated major safety improvements for pickups and manufacturers complied. But Ford wanted to avoid the cost as long as possible and offered the F150 "Classic" at a lower cost, as long as the customer didn't mind an truck with inferior safety rates. I think they finally gave up that model.
Submitted by iused2fly on August 27, 2011.
Come on Robert! First you dangle your list of scariest homebuilts right in front of our noses; Then you yank it away again. Reminds me of Lucy tempting Charlie Brown to kick the ball and then pulling the football away and causing Charlie Brown to land on his back in a cloud of dust.
Be a man and fess up the list. Informing the public about designs which you believe top be really scary to fly would be a valuable public service. Perhaps your bosses are more worried about the flood of lawsuits such an admission might cause, than advocating for free speech and better homebuilts' control systems.
The way I see it these first short steps to talk about modernizing Part 23 are just that, talk. What they need to do is skip the talking and quickly address FAA-created arbitrary roadblocks to success, especially as manufacturers bring to market faster, more expensive and complex light aircraft like the 235 knot Corvallis and 242 knot Acclaim. Hopefully FAA will get around to addressing inconsistency in how rules and regulations are enforced by FAA field inspectors, a never ending problem for airport managers.
Do I think they'll accomplish anything? Hope so. But does anyone really believe FAA bureaucrats will willingly give up any of their rights to add superfluous extra cost to new airplane manufacture? To believe so would be to ignore decades of recent manufacturing history. From the Windecker Eagle to the Beech Starship to the Next Generation Cessna to the Lancair Columbia, the FAA has always made sure to insist on enough extra testing and standard equipment to bleed the manufacturers of cash and rob these designs of sufficient useful load to be viable designs.
Wanna know how to turn a rich man into a poor one? And put a few hundred workers in the poor house? Try certifying a clean-sheet-of-paper design. The reason most of us are still flying Wichita span can is that the Guv makes it nearly impossible to do otherwise.
Most of the FAA types I know tend to think of themselves as being advocates for the public safety. Or as a brake to overly ambitious certification programs. Some hate the arbitrary level of rules developed at head office but are powerless to do anything to reduce the drag their bosses create for designers with good new designs.
Where I live in Canada, Transport Canada has done no better. When the Canadian, nee Bombardier, Challenger was in flight test the company asked TC for a waiver from spin testing, as Lear Jets had obtained from the FAA, asking for a stick shaker/puller system because of the Challenger's high T-tail..
But, no, that wasn't good enough for the TC man overseeing the test program. Later in the program two test pilots and one Challenger prototype crashed after failing to recover from a spin. Shortly after the accident the top brass at Canadair went to Ottawa and read the riot act to the bosses of the TC man who had insisted on spin testing. And, presto! Spin testing waived. You can draw a straight line between that TC man's initial decision to test spins and two widows, with a gaggle of kids without their Dads.
Another time a fellow in British Columbia had come up with an STC to modernize the iconic Dehavilland Beaver into the Turbo Beaver. But TC didn't want anyone competing with Dehavilland. Before he could even get his business off the ground, TC auditors planned to swarm him with enough paperwork to delay him until Dehavilland could engineer their own upgrade. He beat TC to the punch and cleared out of his office just hours before the auditors were ready to rip his business apart. Nice guys, huh?
When have any of us EVER seen ANY bureaucracy do ANYTHING that can reduce their departments' annual budgets?
My fingers remain crossed.
Douglas M
Surrey, British Columbia
Submitted by garnaut on August 27, 2011.
Hold on a second there, Douglas.
I remember that Challenger flight test mishap. I started my career the following year, at De Havilland, later acquired by Bombardier. As a flight test engineer I know the risks every time I step into the airplane. That's part of the job.
That Challenger 600 incident, while tragic, had nothing to do with Transport Canada. That was a US FAA crew doing certification test flights in Mojave. The first officer and flight test engineer bailed out successfully and survived. The captain bailed last but it was too late. He didn't make it.
The test flight that day was NOT for spins, it was to test stall recovery. They got into a deep stall and lost control. Couldn't recover. Last resort deployed the emergency spin recovery chute, which worked, but it wouldn't unhook and got fouled on the tail, spoiling flight controls and dooming the flight.
NTSB determined cause of the crash was four separate systems failures, all of which were known issues with the 600. That is why we have flight tests and certification. This airplane's right engine (Avco-Lycoming turbofan) failed 11 times in previous testing.
It's easy for armchair critics to dismiss the important work we do as "bureaucracy" that can't do anything right. Nothing could be further from the truth.
Submitted by garnaut on August 27, 2011.
Now about the Part 23 rehash. Great idea and way overdue.
First of all, planes like naturally aspirated piston singles can be type certificated under Part 21 Primary Category, which is basically submitting paperwork that meets FAA scrutiny.
Too bad industry does not care and has not brought out one single plane under this rule. Two kit plane makers have certified two separate models under this rule, one being a Rans S7 (cub clone with a Rotax 4 stroke) another being a Quicksilver 2-seat ultralight with a Rotax 2-stroke.
If these companies can get the TC then anyone can. Shows how streamlined and smart this rule is. You can find the entire rule under Part 21 of the FARs.
Why isn't industry doing this? They long ago abandoned the piston segment and are just going through the motions. Yes there is a tiny niche market for upscale pistons like the Cirrus and Corvallis but the price is out of reach for 99 percent of would-be airplane buyers.
So there is no fault here on the part of the rulemakers. The rules already exist for bringing out inexpensive simple piston singles up to 2700 lb, fixed gear and naturally aspirated. They have to meet all the part 23 criteria, but the process is mostly paperwork although the feds do reserve the right to examine and test the airplane.
This is a huge difference from LSA which has no government oversight whatsoever and the "certification" is basically outsourced to the private sector (ASTM). Ridiculous. The results are obvious. Dismal safety record and uneven flying qualities in the entire segment.
What the Part 23 revamp will do is streamline the process for more advanced and heavier piston singles like turbos etc that are too big and complex for Primary Category.
This is absolutely the right approach. It does not make sense to apply the same yardstick to a 200 mph piston as you do to a 500 mph jet. A 500 mph bizjet weighing 12,000 lb will have 25 times as much kinetic energy as a 3000 lb airplane flying at 200 mph. That is too big a stretch.
Submitted by rikunhi on August 27, 2011.
What we need are "safety standards" not "certification standards." The reality is that "four-seater" general aviation is nearly dead. From a high of 17,000 new planes manufactured per year in the late seventies we see only a few hundred new planes built each year – only a few hundred. And who can afford them ?
Is there any other agency that micro-regulates manufacturing to the degree of we endure with the FAA? Boats, cars, motorcycle, trains?
The question we need to ask ourselves in the most objective and open-minded fashion possible is the FAA really competent? Keep in mind this is an agency that until very recently gave away the questions to the written exam. Given that 80% of general aviation fatalities are due to "pilot error" was that the right thing for the agency to have done? Was that competent? How many unqualified pilots died?
Having made an effort to have been involved in the Part 23 re-regulation efforts I have no faith that a timely and workable re-write of the regulations will come out of all of this. Several years have passed since the need to change the regulations was identified in 2008, there has been a substantial effort made already to re-write regulations, but it sounds like we're back to square one with the start of a new committee to propose new regulations. The regulators involved are so focused on the minutia of FAA practice and policy that trying to propose any significant change does not register with them. There is a total failure to look at and understand the big picture.
In other progressive industries such as computing or engineering most of the standards are set by those who are employed in the field, have the expertise and are motivated to set changes by marketplace factors.
The FAA failed badly on its last attempt to modernize the ATC system wasting billions of dollars. The AOPA and airline industry is not on board with the FAA's newest modernization program which is on track to become an even costlier boondoggle.
Unless the industry presses to have greater control and oversight and bring to bear its greater expertise, and pilots themselves raise hell with the bureaucratic status quo in Washington our only hope to see safer, less-expensive planes in the market place is if an emerging foreign country provides a better regulatory environment for innovation.
Until we automate flying and advance autopilot technology and make it widely available at an affordable cost, death rates will remain too high in aviation. A reasonably priced plane is no longer possible unless new entrants can compete with the handful of old-time manufacturers.
Submitted by garnaut on August 27, 2011.
I agree with you that the piston segment of GA is just about dead. Yes from 17,000 planes a year down to 700 a year now.
Unforgivable.
But what I don't understand is how this is the fault of the FAA? Please have a look at the type certification rules for Primary Category under Part 21. http://www.faa-aircraft-certification.com/21-24-primary-category.html
There could not possibly be a better, smarter and more streamlined set of rules for getting industry to pump out affordable light pistons with practically zero cost for regulation compliance.
And what has industry chosen to do? They have completely ignored this cheap and easy type certification process.
So please get real and start pointing fingers at industry not the FAA. Here is the 2010 GAMA stats book: http://www.gama.aero/files/GAMA_DATABOOK_2011_web.pdf
Have a look at the tables on page 15. The average cost of a piston plane has increased by 261 percent since 1994, while our purchasing power has eroded by only 47 percent.
Bottom line is that the price of a new piston plane is double what it should be. Not to mention that if we really wanted to we could design and build and certify a basic light single for basically peanuts. Less than what it cost in the heyday of piston GA, due to improvements in engineering and manufacturing.
Submitted by garnaut on August 27, 2011.
And what FAA modernization are you talking about that failed badly? The outsourcing of FSS?
Yes it is a disaster now that "industry" is running it. So much for your ideas about privatization and market forces.
have a look at my comments on that in Goyer's recent blog on privatizing the FAA.
And just wondering on what basis you are equating the computing industry with aviation? Since one is governed by industry so should the other, right?
You are dangerous.
Submitted by garnaut on August 27, 2011.
I have to wonder if these "privatization" and "free market" ideologues have any common sense at all.
You want to build a deck on your house? You have to have government oversight for crying out loud.
Yet aviation standards and rules is something that should be decided by "industry?"
Shining example there with LSA and the industry ASTM standard. The feds should pull the plug on that whole ridiculous scheme. And look at the "value" they are delivering with this "industry" oversight.
Even a Cirrus at half a million is a far better value proposition than one of these sportplanes at $150,000.
Submitted by rikunhi on August 27, 2011.
Walter Beech commented more than 50 years ago that the plane he flew cost three times that of his luxury car. Planes now cost ten times that of a luxury car. Not many can afford a Cirrus at $500,000.
The criticisms of the LSA market are valid although don't ask the administrator of the FAA, Randy Babbit, he thinks their record is "marvelous." And don't just look at the statistics superficially. Setting a weight limit as low as they did forces compromises in the design. Fly an LSA with power off and tell me what you think of the handling characters of those short, low-aspect ratio wings. And do LSA's usually have a quality autopilot? How about a crosswind-component of 12 knots or less? Again, 80% of fatal aviation accidents are because of "pilot error" so how does the caliber of LSA pilots stack up?
And agreed there is a lot of reason to not have much respect for the old guard manufacturers. John and Martha King will tell you that general aviation flying is seven times more hazardous than automobile driving when compared on a mileage basis. If we are going to have regulation it should be much better than what it is. Industry has looked to the FAA and legislative branches of government to insulate them from making safer planes [please don't dismiss this point arbitrarily!]. Take a look at the irresponsible effort to block manufacturers from liability in the 90's. All the long-time manufacturers thought this protected them but if you know the history of the settlement against Cessna in which the jury awarded hundreds of millions of dollars to the victims, the manufacturer's negligence didn't play well with the jurists.
No matter where you stand on the political spectrum from right wing Libertarian to Marxist Socialist you have to recognize the industry is failing. There is no short-cut to safety. We'll pay for it somewhere if planes are not safe. Given that the existing system doesn't work we'd be much better off completely de-regulating aircraft certification and getting it away from an agency that does not have a lab to test certification data, many of its employees are not aeronautical engineers or even A&P's, most are not pilots, their employees take too long - often years to certify aircraft and have compiled what they call their certification bible that is too complex to be consistently applied - jurisdiction by jurisdiction.
There is reason to believe that if we had left it to industry but not tampered with the liability laws, that the old guard manufacturers would have been forced to make safer planes or go out of business. There would be more alternatives in the marketplace.
As for the ATC modernization efforts a couple sources you can consult are the DOT's Inspector general's office - http://www.oig.dot.gov/oversight-areas/aviation/air-traffic-control-oper... and the GAO http://www.gao.gov/search?q=faa+atc+modernization&Submit=Search.
This is from the GAO's report GAO-04-227T
"Over the years, systemic management issues, including inadequate management controls and human capital issues, have contributed to the cost overruns, schedule delays, and performance shortfalls that FAA's major ATC projects have consistently experienced. These problems occurred, in large part, because FAA lacked the information technology and financial management systems that would have helped it reliably determine the projects' technical requirements and estimate and control their costs and schedules. In addition, organizational culture issues discouraged collaboration among technical experts and users, and frequent changes in FAA's leadership--seven different Administrators and Acting Administrators in the first 10 years--hampered the modernization efforts."
These failings cost us tens of billions of dollars!
The issue is pilot error. That is where the focus of our attention should be. There needs to be a recognition that human beings have limitations and begin designing reliable planes that reduce pilot workload and prevent situations that cause pilots to make mistakes.
Submitted by iused2fly on August 28, 2011.
To Garnaut: I yield to your indisputable facts, re the Canadair Challenger flight test accident. I further apologize to you, and other forum members, for putting to print that which I failed to accurately research.
But my central point, that bureaucrats are unwilling to do anything that would reduce their annual budgets, eliminate turf wars or ease anyone's regulatory burden, remains undisputed. And due to the size of FAA and other bureaucracies, once a bad policy or poorly researched regulation, standard or best practice is implemented it takes forever for these glacially-paced institutions to address said mistakes.
Want another example of heavy handedness from Transport Canada?
In 2002/03 TC forced all Canadian airports above a minimum threshold of movements to enhance their emergency response capability on site, by mandating higher levels of fire suppression vehicles, equipment and emergency preparedness training be brought on board within 2003. This in the wake of 9/11, where airport budgets were stagnant—if not bleeding red ink. Sure it is always a good idea to have a bigger, more capable fire truck with larger water/foam tanks at the airport, but where was the sensitivity to the bottom lines of these airports?
It was a case of poor timing, brought on by the sense of unreality senior bureaucrats work under. And TC's one-size-fits-all approach to regulating airports at the federal level. I have no doubt the same type of thing happens repeatedly at FAA. American pilots and airplane manufacturers succeed (if you can call a few hundred new planes a year a success) as much despite the FAA as because of it.
A year or two later TC reintroduced the Airports Act, contentious legislation roundly criticized in 2003 by airport management across Canada. New, inflexible rules that did little more than add a few more Canadian flags to the breezeways at big airports. Where was the burning need for such extra cost, merely to add a bit more beauty or patriotism to airports with plenty of Canadian flags and good looking facilities? I could list a dozen more, but lack of space in this forum precludes it.
Remember everybody, your government is your friend...not!
Douglas M
Surrey, BC
Submitted by rikunhi on August 28, 2011.
Goyer's article states it cost over 60 million for Cirrus to get certified. That the same amount Christian Dries says it took them, over 60 million dollars, to get FAA & EASA certification for the Austro Engine. How much will DeltaHawk have to pay to get their desperately needed diesel engine certified?
So, who is going to want to enter a field where the entry states are this high, this expensive? Sell only a 1,000 planes or engines and you've got to get pilots to pay $60,000 each just for the regulatory burden.
What I would ask of Mr. Goyer is that he provide a detailed explanation to prove his off the cuff statement that FAA certification is making planes safer. There have been so many compromises that it negates the validity of the entire process.
If you are an established manufacturer you can piggyback on prior certifications. A huge advantage for those who have a long-standing, cozy relationship with the FAA. Wonder why general aviation aircraft have advanced so little in terms of airframes and power plants in 50 years - this is why.
The GAO will report their findings in scholarly terms and avoid inflammatory rhetoric but if you read their reports they tell you this is an agency that is flying blind, without a map, with no clue as to how much gas is in the tank. Count of the cost of their failings and the only question which has been the more expensive waste, FAA blundering or the BP oil spill?
If you are a trade journal publisher can you afford to continue losing subscribers to failings of an incompetent agency?
If you are an association can you afford to continue seeing your membership decline because of an incompetent agency?
If you are a pilot is it going to be safe flying that plane that is 10, 20, 30, 40 maybe 50 years old until you are too old to fly because an incompetent agency has driven the price of new planes way above the stratosphere?
Submitted by robert goyer on August 28, 2011.
I don't need any detailed analysis to prove that certification makes airplanes safer. I believe I clearly said that all the evidence you need is to look at Part 23 versus amateur-built. The EXP safety record is many times worse than that of certified airplanes, to the point that the FAA has essentially turned a blind eye to pro shops building "homebuilts," the justification being that these airplanes are better built and, hence, safer, than those truly built by the consumer.
I also very clearly said that I am very much for lowering costs of certification.
I've also written on dozens of occasions about the need for the FAA to be reformed. Because I support one function of the agency hardly means I'm a fan across the board. The opposite is very much the case.
Submitted by rikunhi on August 28, 2011.
The numbers with or without certification will always be higher for any industry that is innovating and we can all agree that LSA & EXP numbers should be better, but is that really going to happen with EASA or the FAA? A point was made that many of the key personnel at the FAA lack the technical expertise, Mr. Goyer, did you see that? Have you looked at the GAO and DOT Inspector General's reports? How many private firms could operate as does the FAA and remain in business?
Again we need "safety standards" not "certification standards" The question is has the FAA's certification of aircraft: 1) substantially improved aviation safety; 2) significantly improved aviation safety; 3) had no impact on aviation safety; 4) hindered aviation safety.
If you're going to stick with an off the cuff remark and don't feel any journalistic responsibility to investigate further there may be little point in I or anyone commenting on your blog.
Obviously, you're comfortable with high death rates in aviation. When you say that homebuilts are many times more dangerous that GA planes maybe so if your perspective is comparing EXP to GA, but if you're comparing cars to GA/EXP or airline numbers to GA/EXP the fractional differences between EXP and GA are just a few percentage points.
We should have planes that are many times safer than what they are, but we are hampered severely by regulators, associations and journalists who only look at what is and won't take the time to really open their minds to the deeper issues - to see the big picture.
Take a look at this list of items, the FAA repeatedly certifies conditions that compromise safety. What did we really gain in all the cost of certification if inferior designs get rubber stamped at the end of the gauntlet? Just how absurd does the certification process have to be until people see what a waste the entire process has become?
a. Noise levels in the cockpit above that which OSHA studies have found to be hazardous to health.
b. Turbo charged piston engines that have TBO's of only 1,200 hours, that are susceptible to cooling and over heating issues.
c. Twin engine planes with anemic single-engine climb rates and that can get out of control quickly on engine failure.
d. Crosswind component ratings of less than 20 knots, even as poor as 12 knots.
e. Poor visibility out of the cockpit - especially on landing.
f. Lack of good warning systems to alert when landing gear is not deployed on an approach.
g. Approval of non-ergonomic chairs that can cause fatigue and pain on long flights.
h. Flaps and landing gear that can be extended when they are out of safe airspeed range.
i. Poor instrumentation failure warnings, whether glass or steam gauge
cockpits, that would not let the pilot know the readings are false.
j. Autopilots that still control the plane, yet provide no warning, when specific inputs fail.
k. Aircraft, especially multi-engine planes, that cannot recover in a spin and have to rescue parachute.
l. Ballistic rescue parachutes that if deployed above certain speeds will rip apart from the airframe and even when successfully deployed provide no ability to control descent to a landing target.
m. Acceptance of poor stall characteristics, narrow wings with low aspect ratios, small planes with little mass where basic physics laws of arm and moment are not used to create much longer wings that will be more stable, not mush so badly near stall speed on an approach?
n. Avionics that cannot be reset if they fail in the air, must be restarted on the ground.
o. No de-ice on many aircraft certified for IMC.
p. Poor occupant compartment protection.
q. No fuel dumping mechanism to use before an emergency landing to reduce burn hazard.
r. Airframe designs that may cause fuel to pool in the cockpit after a crash.
s. Unreliable fuel gauges that do not provide audio or flashing alerts to warn well in advance that fuel is running low.
t. No carbon monoxide detectors required although cracks in heater venting/manifolds sometimes allow CO to enter the cockpit.
u. Little redundancy on small planes –no back up of critical flight control instrumentation.
v. No secondary system should any flight control fail on most small planes.
Submitted by garnaut on August 29, 2011.
Rikhuni, I agree wholeheartedly with your points about the absurdly high cost of piston singles.
But this has nothing to do with the FAA. I have said here before that a light piston single is a very simple machine that is closer to a RC model than a transport category airplane.
There is no need for basic piston singles to be certified under Part 23 when we have the Primary category for that. Nobody is giving the FAA credit for bringing out a rule that could reinvigorate lightplane production.
Industry has chosen not to take advantage of this. Now the FAA is revamping Part 23 with a further eye toward modernizing the rules. Yet somehow it is again at fault.
You put a lot of stock in some BS reports out of the beltway political circus. I know different. I work on the industry side in certification of Part 25 aircraft. I have nothing but respect for the FAA and Transport Canada test pilots and FTEs and other individuals.
These claims that they are not qualified and that private industry has a better grade of people is completely nuts. Nobody I know thinks this way, either on the industry or government side.
As far as safety is concerned, reliance on technology is never a good idea---as per your harping about autopilots. Technically advanced airplanes have no better safety record and that is already well established. I and many others suspect that equipment-inspired overconfidence could in fact be a real problem.
Yes most crashes are due to human error, which is why procedure based operations like the airlines have a much better safety record. An individual piloting his or her private plane is not going to have a system a system like that because he or she is on her own.
We can never take human error out of the equation. What certification does is to make it all but certain that the airplane is not going to fail you.
Yes amateur built airplanes do have a problem, their accident rate and fatality rate are both about four times the norm of certificated piston singles, based on hours flown. Lsas have a problem too.
Which shows that certification works.
Submitted by Thomas Boyle on August 29, 2011.
The irony, here, is that I believe the regulator has decided that re-(de-)regulation is the right thing to do. FAA already knows where it needs to go on this. And, for small airplanes, that's going to look a lot more like the rules for a model airplane, than for a business jet. After all, people like Richard VanGrunsven and Randy Schlitter have shown they can churn out fine designs at a pretty good clip. If you have some sound design software, appropriate engineering principles, a proper production line, some handling standards (e.g., for control harmony), and you test-fly the prototype for 100 hours, what more do you really need?
Looking at E-AB, I'm not aware that there's an unusually high rate of structural failures after the test phase. There's a problem with engines/fuel systems during the test phase, and the remaining excess (and it is excessive) accident rate seems to be tied to the "sport operations" aspect of E-AB, and possibly to the owner-maintenance aspect (engines, again).
Looking at LSA, I'm also not aware of a big mechanical problem, or that the fatal accidents have been tied to issues that would be affected by certification. There have been complaints about control harmony, but that's hardly fatal in VFR, nor hard to fix as designs mature (for that matter, there are some awful-handling certificated machines). There was one model accused of fluttering, but the problem proved elusive, and occurred in a fleet that had flown thousands of hours - making it unlikely that Part 23 would have helped. It's been noted that the manufacturers have not really been audited - by anyone - and while that needs to change, it also means that, with no-one looking over their shoulders, they have overwhelmingly produced fine flying machines! We need some standards and some auditing to keep out bad actors; we don't need to swat the fly with a sledgehammer. That's what the FAA is trying to tell us when it says that LSA is a "success".
I don't know why the Primary Category didn't work. It's an interesting question. However, VanGrunsven has reportedly said that he'd like the Primary certification process simplified, to follow the ASTM-type process.
Even accepting that some people want to build, more than to fly, the number of E-AB being produced makes NO economic sense; factories should be far more efficient than individual producers. From a safety point of view, too, it would be much better to see these airplanes come off a proper production line. The fact that it is going on, points to two possible culprits: liability costs, and certification costs. But which?
LSA suggests an answer. A huge number of LSA designs have come on the market in the past 6 years. These are manufactured aircraft, suggesting that the problem isn't the liability: it's the certification cost of Part 23. And I believe the FAA has reached the same conclusion. But it's not entirely clear, either: again, VanGrunsven isn't producing factory-built RV-12s, presumably because of liability concerns.
Submitted by Dietrich Fecht on September 01, 2011.
Minimum speed of 62 knots for all single engine airplanes? That is not necessarily an absolut saftey feature. This number was set at a time, where the aerodynamics, stall caracteristics and handling qualities including autopilots of small airplanes were generally not so far developed as they could be with mordern designs today. It is the question if this number of 62 knots is a blessing or a relict of technical possibilities of older decades.
When slow means safe there is a discrepance in conjunction with flying. Flying was always fast. And the mainly benefit for flying is a shorter time to travel with higher speed.
The slow stall speed of 62 knots has a negative impact to make planes faster, ergo to get more benefits out of it by shorter travel time and less fuel consumtion.
With a higher minimum stall speed for example of 90 knots for high performance airplanes instead of 62 knots, an airplane can be designed with smaller wings with less drag and with a more lightweight mechanical construction of the airframe and flap system in many ways. A higher stall speed would have only benefits. With new rules for the design of § 23 single engine airplanes this should be checked.
There is no no safety problem. The accident rate is extremly low. Small airplanes are safe enough. The main question for the future is if smaller planes can hold up with the generell development to faster, cheaper and more comfortable transportation as we see it in airline transportation.
Very often in the past new burdensome regulations found their way through wishes from the industry, or parts of the industry. How often I heard “If we can save one life it is worth that (complication) and that..(additional equipment)". One example of this bad practice he discussion for safety belts in small airplanes. But this lobbying does not help to reactivate small airplane production. It is driving it deeper and deeper in the mess.
The new small planes have to become cheaper, faster, more fuel efficient, more comfortable and better silenced as they are now. And all that with a §23 certification what is much less expensive and much less difficult as it is today. This are not unrealistic wishes. This is an absolute must when small airplanes for private transportation should survive in the future.
Submitted by rikunhi on September 17, 2011.
If you put enough rigor into a process many people, especially those who have a vested interest and think that protectionist policies help them (and are blind to how they devastate an industry as a whole), will support a rigged system. Again the FAA does not have a lab. Attempts to ask them, even through the intervention of my congressman and both state senators, have resulted in no data explaining how many staff involved in aircraft certification have technical expertise - that's how little accountability we have in American government. That is how arrogantly an agency can thumb its nose at anyone who questions their competence.
Dismissing GAO and Office of Inspector General Reports, calling them BS, fails to recognize that billions of dollars were wasted, a lack of vision and oversight in regulatory management has left the agency adrift and making decisions without the knowledge and experience needed to do the job has and will continue to result in waste. If this is the consensus among pilots, that the FAA's regulation works, there is little reason to believe the general aviation industry in North America has a future. And it's no wonder that the few visionaries we have including Dries see little future for GA in the the U.S. Are you aware of how Klapmeier failed to obtain funding for the Cirrus Jet? John Stewart, in a serious interview, commented that there are too many vested interests in Washington for us to see any serious change - and this is a classic example.
If the FAA had stayed out of the way and left it to pilots, manufacturers, insurance companies and liability law had not been used to protect the old guard we would have more choices - probably safer choices. Again the FAA does not have a lab. Their system is primarily based on flying the plane long enough, and at an enormous cost, have the manufacturer jump through as many hurdles as possible, usually over a period of years - and that will catch some problems but what's the point? Taking just one example - once you have opted to go with a piston vs. a turbo prop you've increased your exposure to an accident ten times. Certification is a badly compromised system as established by the FAA and EASA that contributes little to safety.
The great myth about LSA aircraft is that they are deregulated - when you look into it they still have much of the same burden - have many of the same rules to comply with but they get less help and support from the FAA. Their accident rates should be higher for a number of reasons mentioned already. But whether they are "many" times more dangerous is a dubious point. We need credible numbers. I do wish that people who were making claims would cite their sources. Part 23 regulators have told me they have difficulty getting information within the agency for hours flown of various aircraft makes that are needed for accurate comparisons so where are you all getting your numbers? What's your background in methods research, data analysis and statistics?
We should put more stock in system that left more of the responsibility on the pilot to decide how much risk they'll accept rather than have government rubber stamp a process that helps a handful of connected and established manufacturers. I would have much more faith in Underwriters Laboratories than the FAA to tell us how to make planes safer. Most of all, those companies that fail to produce safer planes should be pushed out of the marketplace and innovators have a level playing field.
Submitted by rikunhi on September 18, 2011.
I'm not sure whether Mr. Goyer reads these blogs, will take time to examine the issues we raise, or has any respect for those who contribute. Mr. Goyer has made no effort to respond to many points raised that challenge his assertion that the FAA certification process enhances safety. Please have the chief editor of your magazine provide a citation or explain where Mr. Goyer compiled the statistics Mr. Goyer uses to claim LSA accidents are "many" times more dangerous than general aviation accidents if Mr. Goyer will not or cannot provide evidence.
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