Opinion: The Mystery of the Part 23 Rewrite
Kansas Congressman Mike Pompeo has sponsored a House bill that would set a timetable for the FAA to adopt liberalized certification standards for Part 23 airplanes. Just days ago the aviation rulemaking committee (ARC) working on updating Part 23 sent off its recommendations to the FAA, after 18 months of work by many dozens of industry leaders.
The strange part is, we know next to nothing about the substance of the recommendations, only that they are an attempt to use industry consensus standards (as in the Light Sport category) to cut down on the complexity/cost equation of Part 23 certification and to incubate innovation, something painfully lacking in most current Part 23 projects, though such projects are few these days.
The big idea so far seems to be that the new certification guide will take the old guidance, often pages long, and condense it into the real meaning of it. An example that Earl Lawrence of the FAA's Small Airplane Directorate gave was the verbage describing crash worthiness, which would replace dozens of specific pieces of guidance with a single, "The Airplane, though it may be damaged in emergency landing conditions, must be designed to protect each occupant under those conditions," and that "the structure must be designed to give each occupant every reasonable chance of escaping serious injury." The manufacturer would then be charged with figuring out how to accomplish that main mission. The FAA would retain certification approval authority, so presumably the manufacturers would be held to a high bar, though one that would be far less prescriptive. The hope is that strategy would cut down on complexity and paperwork and, hence, cost.
There’s no timetable for the unveiling of the ARC’s recommendations, but when they do come out, expect a full and rigorous analysis in Flying. The devil, as they say, is in the details, and until the details are released, it’s hard to know what to make of the fruits of the ARC’s labors. So far, the outline sounds promising, to say the least.