# 100LL and O2 sensors; your thoughts

Discussion in 'General Auto Conversion Discussion' started by pfarber, Oct 13, 2019.

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1. Nov 15, 2019

### gtae07

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Not at all. What I'm trying to tell you is that there's a lot more to certification than just testing. It's literal tons of documentation and formal reports and the extra costs of doing things "the FAA way" that someone in the experimental/non-aviation world does not have to pay. That cost gets baked into just about every single thing your company does, from hiring extra employees to handle the paperwork to buying certified materials to auditing paperwork (and auditing the audits). Every argument your DERs have over how to properly fill out the FAA approval form for this little bushing you designed is a cost incurred by certification. Like I said earlier, I work at a certified aircraft OEM. I see non-technical activity that takes place all the time, solely to comply with FAA requirements.

How much would it cost you to fly if you didn't have to meet government-dictated hour minimums (and instead went by competency), could pay your buddy Joe to use his homebuilt, and didn't have to get instruction from FAA-approved instructors or take your tests with FAA-approved examiners? There's the extra cost incurred for meeting hour requirements (vs. competency), the cost of a certified aircraft, the cost of certified maintenance for the certified aircraft, the cost the certified instructors/examiners can command due to the government-controlled supply of instructors and examiners, and so on.

My point is that certification costs are insidious and creep into the product at all levels, from designing it to producing it to testing it. You're just looking at "cost of final test" and assuming that certified and experimental companies do everything exactly the same except for the testing at the end. I'm looking at the entire cost difference of "what would this cost Van's" vs. "what would this cost Cessna".

Also, don't forget that a large part of the certification requirements are simply overkill for light airplanes. In many ways the regs are "one size fits all" and as such the FAA has to cover everything up to and including airliners. The recent Part 23 rewrite helped a little, but the requirements of Part 21 still dominate and the FAA still insists on everything being done its way.

If you can be bothered, take a look at the Part 23 ARC's report from 2013 on simplifying certification of light aircraft. It contains a detailed (but by no means exhaustive) discourse on all of the "non-value-added" activities the FAA requires which companies like Van's and Sonex don't have to worry about.

Last edited: Nov 15, 2019
2. Nov 16, 2019

### pfarber

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But this main points still stand:

None of us know the cost of certification. I can source dozens of articles that quote second hand hearsay. I mean how hard is it to get a number rounded to the nearest $1000??? https://generalaviationnews.com/2012/09/09/the-cost-of-certification/ COST — Some informed estimates from knowledgeable persons suggests the cost of taking a fully designed, tested, and otherwise ready LSA through the full process of ASTM approval, including the manufacturing process, may be the cost of one airplane at retail. In other words, it might cost$125,000-150,000 to “certificate” a new LSA, after all design work and testing has been done.

The cost of Primary Category has been similarly estimated at about $1 million, but understand all these figures are just discussion, not fully informed values. 3. Nov 16, 2019 ### BJC ### BJC #### Well-Known MemberHBA Supporter Joined: Oct 7, 2013 Messages: 9,741 Likes Received: 6,526 Location: 97FL, Florida, USA LSA operate under a special airworthiness certificate (so do E-AB), not an FAA type certificate. Demonstrating compliance with the ASTM standard is very different from gaining type certification. BJC 4. Nov 16, 2019 ### TFF ### TFF #### Well-Known Member Joined: Apr 28, 2010 Messages: 11,727 Likes Received: 3,321 Location: Memphis, TN You are racing down a semantics road. You want something that actually does not exist, a price list for just an application paperwork? The FAA is all or nothing. Pour money until done. Now if you were doing this in the 60s-70s when most of this stuff was done, you just had to get a signature from the right guy. A little Valentin chocolate, a couple of steak dinners could convince someone on the fence that enough due diligence was done. You show up with a EASA certified LSA and they would probably get around$120-150k to review paperwork. From scratch I bet it is a million. Depends on things you can talk your way out of and that cost. Cirrus trying to cut development cost put the parachute in not to save someone’s scrawny butt, but to get around landing gear drop tests and spin testing. That required negotiations and had to have cost them more in paperwork to comply differently. Of course EASA said no to that, but it gave them a couple of years to afford it.
My friend’s AA1 with the 320 I put in is definitely old school certified. Deliver paperwork and accidentally drop a box of cigars on the desk. Probably not, but those were the days the FAA would help you with the engineering. There is not enough manpower to stand next to the water cooler now days. I saw a number on FAAs budget and it was small. Like what it would cost to put through a new certified twin from zero. That AA1 STC could never be done today at any reasonable resell cost. Legacy STCs I hope they don’t die.
I did what I guess was a one time STC. They never liked my regular STC paperwork. They estimated 2 years if OKC checked the numbers. Could not get a DER because is was not going to be a retirement check. Finally a Retired DER who wanted to keep his certification did it reasonably, no FAA cost.

Until you have the big stack of papers to deliver, they will not tell you how much. With present government situations, they will make you pay big. Probably to scare you away.

5. Nov 16, 2019

### gtae07

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Nobody's going to tell you that. Besides getting into internal company financials that companies aren't going to share with anyone but their own finance/accounting people and major stockholders/board members, any numbers you would get are as subject to Hollywood accounting as, well, Hollywood.

What I can tell you is that your argument--essentially, that certification is just a simple matter of showing up at the FAA one day, paying a nominal fee, and doing the last single bit of specified testing, and that the "cost of certification" is just that last step, is absolutely ludicrous. Because beneath it lies a ridiculously false assumption--the assumption that everything else leading up to that last single bit of specified testing-every report, every test, every audit, every signature, every last bit of that process--would be done exactly the same for an experimental product vs. a certified one, and that the only thing holding everybody back from certifying things is paying a little bit of gas money for the final certification flight.

In the actual reality we all live in, this assumption does not hold. I'm going to see if I can explain this a little more clearly.

And right here is where you're missing the point. Designing to meet FAA requirements, versus showing that you meet the FAA requirements the way the FAA wants to be shown and building your aircraft to the FAA's requirements, are two ENTIRELY DIFFERENT THINGS. Anyone can design to meet the FAA requirements. Showing that you meet FAA requirements is a very specific, defined process with lots and lots of paperwork, testing, etc. throughout the entire design process, not just at the end; building to FAA requirements involves a whole lot of additional paperwork and getting FAA approval of all of your processes. And all of it costs money. Unless you are intending to certify, you aren't going to do all of that stuff. Look into the experimental-market products that eventually went certified (either STC or TC) and you'll find that a whole lot of time and money was spent obtaining that certification, because a lot of the work had to be re-done (or at least re-shown) all over again and the production processes brought up to what the FAA wants to see.

As one small example, here's a small excerpt from one part of AC 33.28-3, which basically explains how the FAA wants you to show compliance with 33.28. This specific example shows what the FAA wants you to collect and report to them if you're going to use commercial/industrial grade electronic parts (i.e. things that are not milspec, aviation-standard, or otherwise aviation-certified) in order to "show compliance":
You might well be collecting this data for yourself anyway, but writing it up the way the FAA wants it written up, and all the time spent getting extra information and preparing it for the FAA, and then chasing down the right FAA people to approve it, are all costs that you wouldn't incur if you weren't expressly intending to certify.

In other words, certification is not just one final test. It's a process, with lots and lots and lots of paperwork and non-technical, non-value-added activity--and lots of non-technical people employed to handle all that non-value-added activity.

The example is a stretch, but imagine building a detached garage on your property. The difference here is between you having a building that you designed to meet code in every respect and paid your buddy JimBob to build for you, vs. going to City Hall, getting a building permit, hiring licensed contractors, getting all your inspections, etc. You're arguing that the "certification" cost is simply the cost of having the inspector come out and do the final walk-through. And that's just absurd.

6. Nov 16, 2019

### BJC

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Confucius said, “Never argue with a fool. He will drag you down to his level, and beat you with experience.”

BJC

7. Nov 16, 2019

### gtae07

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8. Nov 16, 2019

### TFF

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Of course the most famous reply to the feds during certification

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9. Nov 24, 2019

### pfarber

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First, you're reported for a personal attack when you could have just stayed quiet. If you don't like the topic, then have a giant cup of 'please be quite'.

Second, no one has answered, or even gotten close to the original question. Sure, I know the FAA's process. I used to work on spaceflight certified components, and even did a little SubSAFE QA. I know paperwork.

Lastly, most of what the certification wants (for items like components/piece parts) is done by the supplier. You don't test aluminum for proper composition, the supplier supplies a statement from the manufacturer, ditto for electrical parts. So no, you're not starting from scratch and having to provide spectrometer results for the carbon used in your resistors (unless the are wire wound, then you still don't need to do it, it comes from the manufacturer).

Basically, the only real answer is that none of you/we/us know.

10. Nov 24, 2019

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