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Thread: New Part 23 final rule released

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    Registered User gtae07's Avatar
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    New Part 23 final rule released

    Located here: https://www.faa.gov/regulations_poli...65_WebCopy.pdf

    Still doesn't address PNC category or any significant relief for Part 21... but the FAA claims to be "working on it"
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    Registered User Hot Wings's Avatar
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    Re: New Part 23 final rule released

    Only read the first 100 pages or so...

    If Vans were a publicly traded company this would be a good time to invest. Given this NPRM and the speed with which the FAA is likely to revise part 21 Experimentals are going to be the only practical way to design and build the kind of planes that private pilots are likely to fly.

    The ARC report was pretty well ignored by this whole NPRM/ASTM process. The established industry got what they wanted. Job done.

    Typed on tablet. Too many typos to try to correct.
    Last edited by Hot Wings; December 16th, 2016 at 06:11 PM.
    Conventional wisdom and practices yield conventional results. If that is good enough for you:
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    Moderator Topaz's Avatar
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    Re: New Part 23 final rule released

    I haven't had the time to read it yet today. HotWings, it's that bad for new entrants?
    "If you have built castles in the air, your work need not be lost; that is where they should be. Now put the foundations under them." - Henry David Thoreau

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    Re: New Part 23 final rule released

    Quote Originally Posted by Topaz View Post
    HotWings, it's that bad for new entrants?
    It could be debated either way.

    While there is some improvement over the current situation it also heavily favors existing manufacturers that have a track record with the FAA. For example a new manufacturer will have to have everything they do blessed by the FAA/DER with onsite real time witnessing. Existing entities may be able to simply provide video or logs of the testing.

    The requirements for stall avoidance are also much more onerous than the existing part 23. Think 21st century level of technology to replicate the intent of the Ercoupe with a stick shaker. Yet there is zero that will make something simple like the typical Vans any easier to certify since there is only one lump of aircraft below 6 passenger and 6000 pounds (9 and 9000 in one place in the PDF). This means that a new 2 place trainer has basically the same standards to meet as does a new Beech Baron.

    It's probably not as bad as I see it but I still feel kind of used. This whole process started out with the ARC and was intended to be a way to revitalize the American aircraft industry for simple lower performance aircraft via a set of industry consensus standards. But once the existing manufacturers and EASA got involved it evolved into a way to harmonize the FAA and EASA regulations and cement the existing manufacturers hold on the market.
    Conventional wisdom and practices yield conventional results. If that is good enough for you:
    Problem solved.

    "--and pompous fools drive me up the wall. Ordinary fools are all right; you can talk to them, and try to help them out."
    Richard P. Feynman

    “Without deviation from the norm, progress is not possible.”
    Frank Zappa

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    Moderator Topaz's Avatar
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    Re: New Part 23 final rule released

    Quote Originally Posted by Hot Wings View Post
    It could be debated either way.

    While there is some improvement over the current situation it also heavily favors existing manufacturers that have a track record with the FAA. For example a new manufacturer will have to have everything they do blessed by the FAA/DER with onsite real time witnessing. Existing entities may be able to simply provide video or logs of the testing.

    The requirements for stall avoidance are also much more onerous than the existing part 23. Think 21st century level of technology to replicate the intent of the Ercoupe with a stick shaker. Yet there is zero that will make something simple like the typical Vans any easier to certify since there is only one lump of aircraft below 6 passenger and 6000 pounds (9 and 9000 in one place in the PDF). This means that a new 2 place trainer has basically the same standards to meet as does a new Beech Baron.

    It's probably not as bad as I see it but I still feel kind of used. This whole process started out with the ARC and was intended to be a way to revitalize the American aircraft industry for simple lower performance aircraft via a set of industry consensus standards. But once the existing manufacturers and EASA got involved it evolved into a way to harmonize the FAA and EASA regulations and cement the existing manufacturers hold on the market.
    A new 2-seat trainer would require a stick-shaker? It's not the difficulty - just wire a motor with off-center weight to the same sensor as a current stall-warning horn - but it's the principle of the thing. Sheesh.

    Ugh. Just to confirm, this affects Part 23 and not S-LSA certification, correct?
    "If you have built castles in the air, your work need not be lost; that is where they should be. Now put the foundations under them." - Henry David Thoreau

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    Re: New Part 23 final rule released

    Quote Originally Posted by Topaz View Post

    Ugh. Just to confirm, this affects Part 23 and not S-LSA certification, correct?
    Fortunately This does not effect LSA - directly. There has been some attempted meddling with the ASTM F37 group from the F39 (new part 23) but so far ASTM bylaws have prevented it. At one point some of the guys that were new to the ASTM process actually thought that they could unilaterally change the ASTM LSA standards to 'harmonize' them.

    It seems to me that the end result of all of this is that if you want to bring a new simple plane to market it's going to be bound by the LSA limitations simply because it's the only viable route to certification for something that is real world simple.

    The only other option would be to gather up a bunch of aviation enthusiasts to form a new ASTM group to put in place a set of standards to provide 'another path to show compliance' (FAA speak) for Primary category aircraft. IIRC the original Primary NPRM (which I can't find right now) specifically stated that the standards were intended/desired to be set by an industry standards group. Noting ever became of that idea. For what many of us would like to see there is a lot good to be found in the Primary category. It's basically describes a 172 that can be flown at night, IFR, and as fast as you want.

    If such an ASTM group were to be formed I'd put in some time provided it's an outgrowth of the F37 (Sport) and not F39 (part 23) - after the spring semester is over. Don't expect to have much free time until then.
    Conventional wisdom and practices yield conventional results. If that is good enough for you:
    Problem solved.

    "--and pompous fools drive me up the wall. Ordinary fools are all right; you can talk to them, and try to help them out."
    Richard P. Feynman

    “Without deviation from the norm, progress is not possible.”
    Frank Zappa

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    Re: New Part 23 final rule released

    The "simple airplane" category was dropped.
    Glad I dropped out of the process.

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    Re: New Part 23 final rule released

    The thing I absolutely love about the ASTM standard for S-LSA is that it allows a complete spectrum of kit "completion", from plans-only all the way up to fully-completed airframes, ready-to-fly. That's a real opportunity for a new entrant to slowly "bootstrap" themselves up from start-up to a "real" airplane company. I don't see the LSA restrictions as particularly onerous, since from my own research it seems that there's a broad interest in airplanes in that performance category, from both Sport Pilots and Private Pilots.

    I need to pick up a copy of the LSA certification standard. Maybe that'll be my Christmas present to myself.

    Thanks for all the information, HotWings. Interesting stuff.
    "If you have built castles in the air, your work need not be lost; that is where they should be. Now put the foundations under them." - Henry David Thoreau

    Design Project: Conceptual Design of an "Inexpensive" Single-Seat Motorglider
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    Re: New Part 23 final rule released

    Quote Originally Posted by Topaz View Post
    . I don't see the LSA restrictions as particularly onerous,
    From an aircraft certification point of view I don't either. Check you private e-mail...
    Conventional wisdom and practices yield conventional results. If that is good enough for you:
    Problem solved.

    "--and pompous fools drive me up the wall. Ordinary fools are all right; you can talk to them, and try to help them out."
    Richard P. Feynman

    “Without deviation from the norm, progress is not possible.”
    Frank Zappa

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    Re: New Part 23 final rule released

    Quote Originally Posted by Hot Wings View Post
    Quote Originally Posted by Topaz View Post
    I don't see the LSA restrictions as particularly onerous
    From an aircraft certification point of view I don't either. Check you private e-mail...
    I just want to see the ability to make aircraft/kits the same way we make S-LSA and E-LSA, but for aircraft up to at least the RV-10 category, if not the full "under 6000lb and 250kt" category mentioned in the 3rd class medical exemption. Every day at work I learn more about what goes in to actually certifying an aircraft, in terms of the paperwork and bureaucratic mess I just don't see how in the heck a smaller company fresh to the market could ever hope to certify a new airplane. In one of our training classes the instructor even said "the FAA doesn't add value".

    Part 23 isn't really the problem. It's Part 21 and the FAA's insistence that it have its dirty little paws into every single step of every single process of every single part of manufacturing every single aircraft that causes the problem. It's the FAA's use of the meetings to schedule meetings, forms to authorize the forms that authorize the forms, the processes that generate paperwork whose value in simply the raw cost of paper exceeds the cost of the actual part being authorized, and the sheer magnitude of non-value-added paper-pushing that makes certification so hard. I'd estimate that certifying an aircraft "the FAA way" at least doubles your design and testing costs and adds 50% to your build labor cost, compared to designing, testing, and building the exact same airframe without the regulations.
    I reserve the right to be smarter tomorrow than I was yesterday.

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    Re: New Part 23 final rule released

    Quote Originally Posted by gtae07 View Post
    I just want to see the ability to make aircraft/kits the same way we make S-LSA and E-LSA, but for aircraft up to at least the RV-10 category, if not the full "under 6000lb and 250kt" category mentioned in the 3rd class medical exemption.
    That would be all well and good but who is going to buy them? An RTF RV-10 certificated with consensus standards would cost >$250k at the retail level. Are there 1000's of people that have that kind if money burning a hole in their pocket just waiting to buy a personal plane? I find it hard to believe.
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    Registered User Hot Wings's Avatar
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    Re: New Part 23 final rule released

    Quote Originally Posted by Hot Wings View Post
    If such an ASTM group were to be formed I'd put in some time provided it's an outgrowth of the F37 (Sport) and not F39 (part 23).
    Correction: F39 should be F44 in all of my posts on this thread.
    Conventional wisdom and practices yield conventional results. If that is good enough for you:
    Problem solved.

    "--and pompous fools drive me up the wall. Ordinary fools are all right; you can talk to them, and try to help them out."
    Richard P. Feynman

    “Without deviation from the norm, progress is not possible.”
    Frank Zappa

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