Part 23 NPRM - ARC - ASTM

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Mad MAC

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This just represents yet another privatization of the aerospace standards (MMPDS, NASM, etc), it just moves the cost around. It just makes everything harder, FAR23 isn't broken, just stretched a little bit far. The move to ASTM is more inline to how Oil and gas is regulated (which we all know works really well).
 
K

Kestas

The simplification of FAR-23/ASTM requirements is very good but not enough. Basic problem for light (or non-complex according EASA) aircraft is FAR/Part-21 system. You must be approved Design organisation (DOA) to be legal holder of Type Certificate, and must be approved as Production Organisation (POA) for manufacturing of certified aircraft. You must have manuals/handbooks/expositions/procedures, quality systems, internal/external audits, record keeping system, approved facilities/personnel, subcontractors/supplyers etc., etc, - for both organisations. And you will be audited periodically - by different administrations. It's lot of papers and bureaucracy .
We in EU already have "lightened" Very Light Airplane class under CS-VLA requirements (MTOW 750 kg, two-seat), but it's dead because of the Part-21 system. The European copy of LSA class also will be killed by Part-21. The ELA1/2 process is some simplification for GA, but it has nothing in common with the initial type certification, it's for maintenance only.
The Part 21 is our main enemy, not FAR-23 only.
 

Hot Wings

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The simplification of FAR-23/ASTM requirements is very good but not enough. Basic problem for light (or non-complex according EASA) aircraft is FAR/Part-21 system. You must be approved Design organisation (DOA) to be legal holder of Type Certificate, and must be approved as Production Organisation (POA) for manufacturing of certified aircraft. You must have manuals/handbooks/expositions/procedures, quality systems, internal/external audits, record keeping system, approved facilities/personnel, subcontractors/supplyers etc., etc, - for both organisations. And you will be audited periodically - by different administrations. It's lot of papers and bureaucracy .
We in EU already have "lightened" Very Light Airplane class under CS-VLA requirements (MTOW 750 kg, two-seat), but it's dead because of the Part-21 system. The European copy of LSA class also will be killed by Part-21. The ELA1/2 process is some simplification for GA, but it has nothing in common with the initial type certification, it's for maintenance only.
The Part 21 is our main enemy, not FAR-23 only.
I really get the feeling that the FAA guys are serious about getting the cost down this time.

It's my understanding (I could be way off) that as part of the ASTM process we will be able to set up methods to work around the part 21 problem in a similar way that we have for the LSA's (ASTM F37) by letting the manufacturers design and implement their own quality control. I'd expect the audit option to be retained. I'd like to see it done by an impartial independent third party rather than a government entity. I really get the feeling that the FAA guys are serious about getting the cost down this time.
 

Hot Wings

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Update after today's F44-20 (flight) organizational meeting:

I got in about 10 minutes late. Mention was made that the upper FAA thought the process schedule was unrealistically short and a year was added to the schedule due to the "precedent setting use of ASTM standards". I do not know if that means the time line given yesterday of July 2014 included that year or if the schedule being addressed was that time line for actual adoption of the ASTM standards which will obviously be some time after the release of the NPRM.

FAA quotes in my notes: (paraphrased - not exact)

"Expect to be compressing part 23 by 80%" (a mention noted that the FAA's goal was 85%)

"low hanging fruit or where to focus the first ASTM standards would be based on cost savings"

"Task groups start with current part 23 and work on 'large safety benefit or large cost savings as the 2 first items' "

Specifically mentioned were section 201, 203, 221, 39(49??) and 562. Seems they are focusing on stall speed and stall/spins as the "low hanging fruit" Specific mention was made about "stall warnings" which I took from context to be about finding/implementing something better than the stall warning horns we now have - if there is such a thing.

F44 30 - Structures F44 40 - Powerplant F44 50 - Systems will be having their organizational meetings over the next few days. I'll report on them as they take place.
 

Topaz

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Thanks for the update!

A lot of that sounds great. Please remind them that expensive technological solutions aren't the way forward, especially for things like stall warning. If it requires any kind of processor, it's the wrong answer.

This would be a great time to put a bug in their ear about Angle of Attack indicators. Want good stall warning? Nothing is better, or even as good, and it can be as simple as a free-pivoting vane out in the wind.
 

BBerson

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The only sensible change to FAR 23, to help the light end, would be a complete elimination of the rule for one and two seat simple aircraft. ( maybe even four seat)
And if anyone thinks this is radical nonsense, consider this:

Right now 6-10 seat composite turbo-prop kits are being sold into the E-AB market with absolutely no mandatory compliance with any part of FAR 23.
But if someone tries to manufacture a one seat airplane that weighs 260 pounds and cruises at 150 kt, then full compliance with FAR 23 is required. ( so no one has done this, as far I know)
Does that make sense?
 

autoreply

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I'm sure will be looking at other certification standards for inspiration and to try to make the ASTM standards as compatible with existing regulations as practical.

I do not know how much coordination there has been with the EASA. There are at least 7 FAA representatives, one EASA representative, 2 Transport Canada representatives and 1 New Zealand Civil Aviation Authority representative on the roster so there has been some coordination. (Each group can only have one official voting member per ASTM bylaws)

This whole thing is in the primordial stages of development at the ASTM level. Most of us don't even know exactly what is in the final ARC report. We should be getting more information at or slightly before the January Florida meeting.
I hope that gets a bit more attention. Let's see:

FAR103
SSDR
LTF-L
MLA
RA (Aussie)
Ultralight (Canada)
LSA
VLA

And then, ELA1 and 2 add some more categories (certification only, no difference to CS23 in operation).

It'd be most helpful if we wouldn't get even more sets of regulational categories. EASA's ELA1 (up to 1200 kg) and 2 are pursuing exactly the same goal as you are:

http://easa.europa.eu/rulemaking/docs/research/EASA.2009.C53/03 - Final Report 26 Nov 10.pdf

The only sensible change to FAR 23, to help the light end, would be a complete elimination of the rule for one and two seat simple aircraft. ( maybe even four seat)
And if anyone thinks this is radical nonsense, consider this:

Right now 6-10 seat composite turbo-prop kits are being sold into the E-AB market with absolutely no mandatory compliance with any part of FAR 23.
But if someone tries to manufacture a one seat airplane that weighs 260 pounds and cruises at 150 kt, then full compliance with FAR 23 is required. ( so no one has done this, as far I know)
Does that make sense?
Yes, but not necessarily to those who decide...
 

Hot Wings

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Does that make sense?
Depends on from which side of the equation you look from. The last thing we want to do is to present this argument to the FAA or the public (or the TSA :shock:) from the point of view that there are already "unregulated" equivalents of King Airs flying around. Rather than give us more options they could very easily place speed and weight restrictions on ALL Experimental Armature Built planes to "protect the public".

I'd rather not poke this particular hornets nest.

@Autoreply

Thanks for the ELA-1 link. I'll read it in more detail but it does look very similar to our process. It sure would be nice to get all the regulations harmonized.
 

Hot Wings

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Update after power-plant subcommittee organizational meeting:

The ARC committee has apparently revised part 23 subpart E (Powerplant) down to 9 section from the current 82. The ARC report is apparently about 80 to 85% written. We may, or may not, get a copy of it before the January Florida meeting.

The plan at the moment is to adopt "amendment 62" as at least part of the ASTM standard. I'm not up on my FAA jargon so I'm not exactly what "amendment 62" is but from my research today it appears to be just the version of part 23 as adopted in December of 2011?? If anybody can educate me on exactly what amendment 23-62 is (or provide a link) I'd be real appreciative! What I could find on the FAA site (and a general internet search) was inconclusive.

It was noted during the meeting that both Lycoming and Continental did not have representatives on the roster? I also noted that the ONLY engine manufacturer that supplies non certified experimental engines was Rotax. I think we need to get some of the Experimental suppliers that may have an interest in selling certified engines involved in the process. I'll be sending off a few e-mails later suggesting that they join in the process. If any of you think there is an engine supplier that should be on this list please let me know.
This is my list so far:

Limbach
Great Plains
Aerovee (Sonex is on the main roster)
Revemaster
Hirth
Jabiru
UL
HKS

Please also add any part or prop suppliers that you may think should be involved.

Another interesting development is that some of the FAA guys weren't aware that the ASTM process will only allow 1 official vote from the FAA and there was some indication that some of them were looking for a way to get an official vote by changing their affiliation from FAA to something else. I'll be resisting that and objecting if I see it happening since it is my opinion that if this is to be an "industry consensus standard" then it should be created by the industry. I'm not to sure how ASTM will view the distenction between DOT FAA and NTSB?

Also there is a very noticeable lack of people on the roster from the "consumer" and "general interest" voting block. The ASTM process specifies a balance between these 2 classifications and the "producer" classification. Right now I don't think there are enough non producers on the roster (of any subcommittee) to fill the needed voting slots so if any of you would like to be part of this process, or know of someone that would, please consider joining ASTM and be part of the process.

A lot of the heavy duty work, agenda creation and task group assignments is/are done at the face to face meetings. The first of which is in Florida in January, and the second is in Germany during AERO in April. (mention made of an optional meeting during Oshkosh) This means that if one wants to be fully involved it requires the time and money to travel at least twice a year. I might be able to free up the time but the cash needed is going to be a real problem. The supplier representatives of course have their expenses paid by their respective companies so if there are any of you that would be classified in the "user" or "general interest" category that have the time and money to attend these meeting PLEASE become part of the process.

I'm classed as "producer" on the LSA F37 committee and don't know if that will lock me into the "producer" slot for F44. I hope not.
 

Topaz

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...Also there is a very noticeable lack of people on the roster from the "consumer" and "general interest" voting block. The ASTM process specifies a balance between these 2 classifications and the "producer" classification. Right now I don't think there are enough non producers on the roster (of any subcommittee) to fill the needed voting slots so if any of you would like to be part of this process, or know of someone that would, please consider joining ASTM and be part of the process.

A lot of the heavy duty work, agenda creation and task group assignments is/are done at the face to face meetings. The first of which is in Florida in January, and the second is in Germany during AERO in April. (mention made of an optional meeting during Oshkosh) This means that if one wants to be fully involved it requires the time and money to travel at least twice a year. I might be able to free up the time but the cash needed is going to be a real problem. The supplier representatives of course have their expenses paid by their respective companies so if there are any of you that would be classified in the "user" or "general interest" category that have the time and money to attend these meeting PLEASE become part of the process....
I really wish I could. I'd love to be involved in something like this, but the travel is out of the question. My (non-aviation) business has to be my priority, especially with the likelihood of another economic downturn coming.

Again, thank you for your work on this, and for keeping us updated. I've got this thread subscribed and set to notify me of updates. I'm keenly interested in this one.
 

Hot Wings

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Where and when are these meetings being held? Are you attending or teleconferenced?
The organizational meetings (this week) are being done via teleconference. There has been a request for the meeting in Florida to also have a virtual option. Why that isn't a standard option with our modern technology I really can't understand. Of course the company representatives get a paid mini vacation;). I could probably justify the expense as a tax deduction but you have to have the free $'s in the first place:depressed

I've seen some pretty strange things get funded on Kickstarter :ponder:
 

BBerson

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Do you have a list of approved engines made in the United States? ( meeting ASTM Light Sport consensus standards)

My guess is that no new engines have been approved (U.S.) in past eight years. Because only an existing manufacturer could comply ( as I read the standards). Further, no existing snowmobile or other engine company would want to touch aviation for liability reasons.

And I don't see how Sonex can buy parts from Brazil or Mexico and comply with quality standards.
Actually, Limbach announced they had closed the company because of compliance cost. Then a China company bought the assets, I think, and may remain in business for a while.

As a consumer and potential future business owner, I could probably get involved enough at Oshkosh, but not Germany.
And, I don't care much for the ASTM system, from what I see, it favors large foreign companies ( like Rotax)
Consumers and struggling future entrepreneurs don't have time for this, so big companies send reps to get what THEY want. Nothing new.
BB
 

Hot Wings

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I really wish I could. I'd love to be involved in something like this, but the travel is out of the question. My (non-aviation) business has to be my priority, especially with the likelihood of another economic downturn coming.
Another down turn? When did we get out of the last one?:confused:

It's not required that the members attend the face to face meetings, but if we want to have any input on the agenda that is where it's made. Kind of like the various committees in the congress control what gets to be voted on.

After the meetings we get sent the proposed standards via the ASTM site to vote on. All it takes is one negative vote from a member to bring everything to a stop until the next meeting so there is still some power in just being a member.

I'll be coming back here as needed for advice on areas where I have little real experience. You and Autoreply can count on getting some questions regarding gliders and Steve will be pestered for his input as well.
 

SVSUSteve

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Hot Wings said:
I've seen some pretty strange things get funded on Kickstarter
That's not a bad idea. LOL

I like your thinking! :gig:
Does that mean I can count on a donation when I start looking for funding for the construction and testing of the Praetorian?

By the way, no, I am not kidding. I am trying to put together a non-profit to develop it under and given that it is a proof of concept project to advance the safety of light aircraft I think it would qualify for Kickstarter just as John McGinnis and the Synergy project did.
 

bmcj

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Does that mean I can count on a donation when I start looking for funding for the construction and testing of the Praetorian?
Yes, I'm a very giving person, but the only thing I have that I can share right now is debt. :wail:
 

Hot Wings

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Do you have a list of approved engines made in the United States? ( meeting ASTM Light Sport consensus standards)

My guess is that no new engines have been approved (U.S.) in past eight years. Because only an existing manufacturer could comply ( as I read the standards).

You are probably right. (Maybe the new lightweight O-200?) But I still think it's more market force (Rotax) than a too expensive ASTM certification procedure.

And I don't see how Sonex can buy parts from Brazil or Mexico and comply with quality standards.

That's one of the nice things about the self certification. If a company states in their quality control documentation that pistons from company "A" in Brazil only need to be gauged, visually inspected, and weighed, then that is all the quality control that is needed. Just as long as company "A" can document that they actually do their specified quality control, if the FAA asks, then every thing is good. There is no need for jumping through all the hoops in part 21. The proof of compliance testing needs to be done on an item that is sourced and built using the same quality control specifications.

And, I don't care much for the ASTM system, from what I see, it favors large foreign companies ( like Rotax)
Consumers and struggling future entrepreneurs don't have time for this, so big companies send reps to get what THEY want. Nothing new.


Yes, the way the system is set up money does have a bit of an advantage, which is all the more reason we need full participation, from those of us that really would like to see things change, in the non-producer classifications. As I told Topaz, all it takes is one negative vote to drag the process to a halt. I have seen the ASTM overrule an F37 committee finding that a negative vote was determined to be "non persuasive" and force the members to reconsider. So there are some checks and balances in the system to prevent those with money having a free hand.
 
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