Part 23 NPRM - ARC - ASTM

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BBerson

Light Plane Philosopher
HBA Supporter
I didn't think there was anyone that was able to qualify a new engine because of the so called " relaxed standards or self certification" ( the 70 year old 0-200 hardly counts)

So, if I joined ASTM and proposed that these standards are still very much too extreme ( based on lack of results so far)
What would happen?

For example, I could claim that standard 5.9.1 is unreasonable. ( it requires crankshaft torsional survey far beyond anything normal for average experimenters)

Topaz

Super Moderator
Staff member
Log Member
Another down turn? When did we get out of the last one?

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.
Gliders/motorgliders are certified under Part 21.17(b), which means that each individual certification process can cherry-pick things out of Part 23, 25, etc. AFAIK, most new glider/motorglider certifications (what few there have been) are being done by showing compliance to the European standard, JAR-22, which is allowed under 21.17(b). AC21.17-2A, which provides guidance for means of certification compliance for gliders/motorgliders, can be found here.

I'll take a look at the ATSM. If I can reasonably contribute in the small amount of time I have available, I may consider it.

EDIT: You may have listed this earlier, but I'd like to confirm that the committee is F44?

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BBerson

Light Plane Philosopher
HBA Supporter
Engines are certified under FAR 33. So I fail to see how this change to FAR 23 will help, since the problem is lack of affordable small engines.

I also noticed that the LSA ASTM consensus standards for piston engines are almost word for a copy of FAR 33.

We have seen these attempts to curb regulation about every 10 years. In my 40 years of watching we had:
Recreational pilot to save aviation....then
Primary Aircraft to save aviation...... then
Sport Pilot....

The only one that was actually working well was FAR 103 with two seat exemption. And that ended in 2004......

Sadly, I see no hope with this process.

Hot Wings

Grumpy Cynic
HBA Supporter
Log Member
Quick update:

Just finished the first of the sub group meetings to take place after the Florida meeting. Nothing much happening yet as we are still waiting on documents to be distributed early next week. It looks like the existing FAA regulations will be used as a starting point for the balloting. This is only because we need a place to start, not that anyone thinks they will just be accepted as is.

I'm not real familiar with the EASA way of doing things but it appears that this process may have some significant impact for those that have to work under this set of regulations.

Here in the US the various FAA A.C's provide one way to show compliance with the regulations, but it may not be the only way. My understanding of the way ED's work under EASA is that they carry the same weight as our regulations and thus are the only way of showing compliance.

It seems to be the intent that once the ASTM standards are in place they will provide those using EASA an alternate method of showing compliance, similar to the way the ASTM regulations do now for LSA's. At least that is what I believe the EASA representative was suggesting. If this is true there should be a lot more flexibility on the East side of the Atlantic?

It also appears that the intent of the FAA is to have the ASTM process replace the A.C. process completely, at some point in the not to distant future.

I'm still learning at this point so if I'm not wholly accurate, or even completely confused, now is your chance to help educate me. onder:

Topaz

Super Moderator
Staff member
Log Member
I'm going to have to do a little educating of myself first.

Thanks for the update! I'm glad to see the process moving forward!

Aircar

Banned
I only just 'noticed' this thread -- as you might recall I spent many years fighting the local aviation authority here to get full FAR 23 certification for ANY Australian designed and amateur built aircraft lifted to at least be equitable for overseas sourced designs and kits . It took until 1999 to get an experimental category introduced --a pyrrhic victory of sorts (we actually had EXTRA conditions to just FAR 23 -including a full fatigue life test --and debate over scatter factors etc so that multiple examples of primary structure might have been required --my aircraft was of all composite construction as well and so essentially fatigue free for all practical purposes . Fatigue testing is extremely expense and time consuming and dwarfes even static structural testing -lest you underestimate the bureacratic mind I would point out that all fibreglass gliders in Australia WERE grounded after some idiot in our aviation authority chanced to read that the German LBA "only" certified glass gliders to 3000 hours flying time. There was not one iota of evidence of any REAL problem and the German practice was to conduct ultimate load tests - to failure- AFTER the fatigue testing and all the glass gliders went to far beyond the required ultimate loads (typically 12 to 14 G )

No sane basis for this action ever existed -nevertheless it happenned . I was asked to tender to repair one wing from a schempp hirth Janus two seater that had been involved in a double fatal spin in accident --the other wing was completely destroyed but the one that was 'recognizable' was far beyond anything normaly considered repairable but the deal was to repair this 'unrepairable' specimen so that also major structural repairs were to be validated (or not) by the same fatigue test --the original airframe had accumulated something over a thousand hours and another Janus was instrumented and strain gauged for actual service load data (the whole thing reported in OSTIV notes --at Hobbs New Mexico world comps conference I think ) --the combined national defence and university,aviation department and gliding federation paid for the on going tests over 11 years . result was -'no problem' --at least this could justify the removal of mandatory fatigue calculation and demonstration even for a one off homebuilt.

some regulations are INTENDED to keep aircraft grounded -Australia has NO bill of rights and no provision for our "FAA" to "foster" aviation --and they know it.

There is NO effective control of the manufacture of aircraft under the RAA now --my experience with Cobra aviation (with framed approvals on the walls by RAA -and NOT ONE single drawing of ANYTHING -not evden athree view, no layup schedules no nothing . plus the 'designer' didn't have evebn the faintest idea of statics or free body diagrams or even a rudimentary understanding of structures --I will post the actual case of his having built (for sale) one aircraft with only half the spar strength he thought he had from a misconception of the most unbelievable kind . Or carbon skins OUTSIDE a fiberglass spar with lengthwise fibre orientation --far from the worst misconstruction.

There needs to be SOME sort of minimal but ACTUAL quality control and 'second checking' to avoid this sort of gross negligence (only 'saved' by a complete major rebuild post failed proof load ...) -- I fully appreciate the excesses of over burdening of process control documentation etc but would not have believed how incompetent some can be at the other end . Something like a complete, properly identified, videotaping of structure and construction including internal structures before close up and evidence of temperatures during cure and materials used could go a long way to recording the important facts painlessly --and likewise for at least prototype testing . (Jabiru have a video showing their load testing for example) Finding a happy medium is the problem- ISO 9000 or some such thing that is being pushed in many fields is creeping exclusion by overkill and even an ex Boeing engineer has warned about this at the top end .

Experimental establishment of compliance to simplified and 'generous' basic criteria is one option for validating individual products rather than the 'certification on a computer screen' . I have yet to look at any of the links or the ASTM papers so this is written in complete ignorance as well as being late to the game.

with 'hybrid' power (back up electric motor and prop) plus benign power failure response it would seem that relaxing engine certification could really be feasible -avoiding the battery failure modes that Boeing is now experiencing as a must though . Certification cost per unit is the real issue and that involves not just less expense but more units sold (you know what I mean ...)

It looks like Hot Wings has a good handle on the process and what outcome is desired and I wish him well and if I can help in any way will try to do so.

PTAirco

Well-Known Member
Just a quick point about ISO 9000 - it is nothing but meaningless paper exercise. It specifies no standards, it is merely a way of controlling whatever standards you choose to comply with. If you decide you want to build airplanes out of waxed paper cups and duct tape, you can freely do so and get ISO 9000 certification, as long as you write up some set of procedures and "quality" control system and create a big stack of useless paperwork that is designed to convince any auditor that yes, you indeed made sure the waxed paper cups and the duct tape are the the same as you specified. My father used to be a consultant for companies getting ISO 9000 certification and I think even he was amazed that they would pay him that much money to develop entirely useless stacks of paper.

Hot Wings

Grumpy Cynic
HBA Supporter
Log Member
Feb 12 F44.10 update:

It looks like the next month will finally get the process started. One interesting item that I wanted to pass on is the wording in the proposed new 23.5(c):

"Acceptable standards may be developed by an industry organization (ASTM for example) or by an individual applicant."

23.5(a)
Compliance to the requirements specified in this part can be accomplished through standards or other means that are acceptable to the administrator.

This is just like the LSA standards. Once the FAA accepts the ASTM standard if you show compliance to the ASTM standard you have shown compliance to part 23. You are still free to show compliance to part 23 by other methods acceptable to the administrator.

23.5(b)
The standards may include a tiered structure to allow requirements appropriate to the aircraft design, construction and intended use.
===============================
This tiered structure is the center piece of the intended simplification of the certification process. These tiers have not yet been established but I expect them to be fairly well developed before the Germany meeting in April. How this tiered structure is actually structured, I think, will have a significant impact on those of us in general aviation that use the most simple aircraft. As these tiers get developed expect me to come here to get feed back from the HBA membership.

Any input on how you think the new tiers should be divide? Should they be based on:
Performance?
Weight?
Complexity of systems?
Other?
Why?

BBerson

Light Plane Philosopher
HBA Supporter
The tiered system is much needed. I have advocated this for LSA also.
For me, my interest is one seat with lowest cost. This one seat tier category should be, by far, the simplest.

The standards for one seat should be chosen by the individual.
Starting with no standards for ultralights that fly in unpopulated areas and moving up with complication.

A slightly higher category ( created by me) could allow me to choose higher speeds for someone like me ( since I have a pilot certificate).
If the individual could choose, that would be optimal. The focus should be on standards that the individual can sign for himself, without a DAR or third party. I heard some DAR's charge $500 per hour. As it is now, even someone holding a CFI and Airline Transport Certificate cannot teach in an ultralight and that makes no sense. I think someone holding a CFI, for example, can inspect and approve a light airplane as needed. thanks for your efforts. autoreply Well-Known Member Any input on how you think the new tiers should be divide? Should they be based on: Performance? Weight? Complexity of systems? Other? Why? Currently, all the regulations I know of differ on MTOW, stall speed, stall speed without flaps, fixed pitch props, fixed landing gear, no of occupants and another half a dozen of variables. Some of them are IMHO complete nonsense (fixed pitch prop, max cruise speed for example). I'd look at only 3 criteria, the ones that are fundamental to the type of aircraft you can have. MTOW, fixed landing gear and stall speed. I'd pick these two: *750/810 kg mtow, fixed gear, stall <45 kts dirty @ max gross. Aligns nicely with EASA-VLA and gives room for anything, from the small, basic 2-seat ultralight, to the fast and small MLA's, or a generous 2-seat payload, or a small family plane like the Dyn'Aero MCR4 or the new "ONE". (Sling 4 | At The Airplane Factory in Johannesburg, South Africa) *1200 kg max, fixed gear, stall <55 kts dirty @ max gross. C712 territory, up to and including the Van's RV10. Getting rid of all the "ridiculities", like the artificially limited cruise speed (WHY exactly) for LSA's can be a major source of innovation. I'd also suggest to give a free MTOW increase for a list of things that improve safety. I can now think of BRS, ELT, transponder, roll over bars, reinforced seats etc. Part of that is done under EASA already (MLA's) PTAirco Well-Known Member I think someone holding a CFI, for example, can inspect and approve a light airplane as needed.. Absolutely not! A CFI is has the privilege to teach people to fly. There is no requirement for them to know anything more than the barest essentials about aircraft maintenance and absolutely nothing about aircraft design, structures or aerodynamics beyond a most basic grasp of what an airfoil does. I know many CFIs, and some are even good at their jobs, but they know NOTHING about aircraft design or structures. Sometimes their lack of knowledge shocks me. They are not qualified to judge what makes a safe airplane design. Having said that, many DAR's don't know much either - they usually have a maintenance background, not a design/engineering background and that does NOT qualify you to judge a new design, apart from pointing out missing nuts and things like that. BBerson Light Plane Philosopher HBA Supporter Absolutely not! A CFI is has the privilege to teach people to fly.. It is that sort of reaction that is killing sport aviation. Actually, i think any person, not just a CFI could inspect an airplane using a proper checklist and determine if it meets basics standards. That's all that a DAR does now with EA-B. I am talking about the lower tier here. Not commercial aviation Every pilot makes airworthiness assessments on every preflight. Most older CFI's have accumulated a lifetime of additional knowledge about airworthiness. Perhaps some additional training could be offered, if needed. But the the idea that only certain "officials" are required to determine everything, is killing the light end. It requires a transfer of liability, and this drives the cost. Self certification is best for private aviation. Commercial is another matter and needs a higher tier. Hot Wings Grumpy Cynic HBA Supporter Log Member . Commercial is another matter and needs a higher tier. Commercial is what part 23 is!? We may be having a communication problem? If you want to build planes to sell there are certain minimum standards with which society expects us to comply. Lawyers will see to it that those minimum standards are met even if the FAA doesn't. Getting ASTM standards in place that are easier to comply with than part 23 will go a long way to getting the lawyers out of the game because the ASTM standards are "consensus standards" that have been agreed on by a group of producers AND consumers thus setting the industry standard for safety and performance. We already have the Experimental amateur built designation that lets us build and self certify almost anything we can dream up. Actually, i think any person, not just a CFI could inspect an airplane using a proper checklist and determine if it meets basics standards. That's all that a DAR does now with EA-B. There is a huge difference between a DAR going down a check list to make sure all the forms are filled out right, the safety wires are in place. and the N numbers and placards are where they should be and someone qualified to bless a new design as being designed and built to reasonable standards for sale to consumers. Making such a determination takes someone, or a team of someones, with a set of skills and knowledge that can't be duplicated by a simple check list. If you are thinking more along the lines of owner maintenance for non commercial aircraft, maybe up to the weight and performance of a high performance 4 place single, there are expectations that this new set of standards will set fairly reasonable privileges for such. They may even make allowances for some limited commercial operations that don't involve passengers for hire, such as towing, photography, and spraying. This has all been mentioned, but none of it is a done deal. If you thinking along the lines of being able to buy a kit 172, assemble it, have an A+P inspect it as conforming to specs, and then being granted an airworthiness certificate equal to a Cessna built 172 ............. it may not be out of the question. This type of thing was done in the past. BBerson Light Plane Philosopher HBA Supporter Commercial is what part 23 is!? We may be having a communication problem? . Commercial means flights for compensation or hire. Any airplane used for hire such as air taxi or cargo requires that the airplane have a Type Certificate issued. FAR23 prescribes airworthiness standards for normal, utility, acrobatic and commuter categories. (FAR23.1) A normal category airplane must meet FAR 23 and have a Type Certificate to be manufactured. The problem is: FAR 23 applies to personal use airplanes also, not just commercial for hire. So lets say I want to manufacture a one seat personal use airplane that weighs 350 pounds empty and cruises at 160kts with a VW engine. In order to that today, I would need a Type Certificate for the airplane, the engine and the prop and accessories. This is virtually impossible under current rules. No one seat 160 kt airplanes have ever been type certificated, as far as I know. The bar is set much to high for very light airplanes with a small market segment. The standards need to be lower. Something as simple as only requiring 100 hours of flight testing might work. It works for EA-B. A one seat airplane has no passenger concern at all. Why should the same rules apply? The FAA administrator said the rules need to be cut in half. Great! How will you do that? Consensus standards won't help a small manufacturer if the consensus becomes just another rewrite of FAR23 ( so that, for example, a type certificated engines is required) That is what happened with SLSA and the result is no low cost one seaters are viable. Hot Wings Grumpy Cynic HBA Supporter Log Member This is virtually impossible under current rules. No one seat 160 kt airplanes have ever been type certificated, as far as I know. Mooney Mite with an STC engine mod and a good wax job? :gig: I agree that for single place planes the bar needs to be quite a bit lower, but what your asking for just isn't going to happen. Any plane sold as a finished product needs to meet some minimum standards and 100 hours of flight testing is a long way from reaching even the bottom rung of an acceptable ladder. It works for E-AB because we have a bunch of restrictions on the use of the final product. In the eyes of the FAA even E-AB doesn't really work because our accident rate is significantly higher than certified planes. The LSA standards, with no speed limits, are realistically the minimum that we can expect. To be very blunt if a commercially built plane doesn't meet at least the LSA standards it's nothing but lawyer bait. The only way a company can know, and prove, that it's plane meets those basic standards is to do the testing. Once that testing has been completed complying with the consensus standards is only a matter of paper work. That paper work needs to be in place no matter what the FAA or ASTM standards say if you have any hope of keeping the lawyers from taking all of your profits. If company can't design, test, document, and build a plane to at least the ASTM standards for an LSA it really doesn't have the resources to be building planes for public consumption. I'd like to see a set of standards that is simple and concise enough that the only thing standing in the way of a company producing a modern version of the Mooney Mite is it's bean counters in the marketing department. We should all know in 2 or 3 years if this is going to happen. BBerson Light Plane Philosopher HBA Supporter If company can't design, test, document, and build a plane to at least the ASTM standards for an LSA it really doesn't have the resources to be building planes for public consumption. . This comment is somewhat offensive. In researching manufacturing options, I found that no ASTM approved engines exist in the under 50 hp range of my interest. So I suppose your comment could be rewritten like this: If your company can't design, test, document and build the needed engine for the light LSA category you want to build, then you really don't have the resources to be building planes for public consumption. In the history of airplane manufacturing, not very many startup aircraft companies have had the resources to build and certify the engine as well. Hot Wings Grumpy Cynic HBA Supporter Log Member Just a quick update. The ASTM meetings that took place in Germany at Aero are over. I was not able to attend :depressed but the minutes are now being posted. There is both good and bad to report. First the bad. It's becoming rather obvious, to me at least, that this process (F44) is going to take a long time to get to what most of us on HBA are looking for. The whole process seems to be controlled by the existing players, mostly due to the fact that they are compensated by their existing organizations for their time and expenses. Those of us that have to take time from our other duties and spend our own shekels just don't have the influence needed to steer this process. Those of us that were looking forward to the tiered structure of the new "simplified" standards with the least complex aircraft receiving attention first are probably going to have to wait until the "big boys" get what they want implemented. I also find it rather frustrating that those in control have been so institutionalized by the existing system that they are having a very hard time thinking outside the box that they have be constrained by for so long. Many seem to think that a better organized and simpler to read version of part 23 is all that is needed. Some even want to have cross references to existing part 23 regulations! The good news comes from F-37 (LSA). There has been a new sub-committee activated (F37-80) to look into standards for 120Kg aircraft. This may give those of us in the US some hope for getting a replacement for the lost 2 seat training exemption for part 103. 264 pounds isn't a lot to work with for a 2 place but it at least shows that the F-37 members are willing to look at the low end of the performance spectrum. I've asked ASTM to look into setting up a new committee to come up with standards for the FAA's primary category of aircraft. It was part of the original intent of the primary aircraft imitative that the standards be turned over to an industry consensus group but for some reason this was never accomplished. My motivation for asking the ASTM to set up the new entity was to use this a platform to get the tiered, and simplified, standards in place that I was expecting F-44 to come from F-44. So far I've not heard back from ASTM. I'd like some feedback on this idea from those interested in reducing the cost of certifying simple airplanes. If we could get a group of people interested AND willing to spend some time on this that weren't dependent on the existing aviation "old boys" club for their income, maybe we could get something accomplished in less than a decade? BBerson Light Plane Philosopher HBA Supporter I might join ASTM to serve on this new F37-80. Can anyone join the sub- committee? ( or is it by appointment?) PTAirco Well-Known Member The good news comes from F-37 (LSA). There has been a new sub-committee activated (F37-80) to look into standards for 120Kg aircraft. This may give those of us in the US some hope for getting a replacement for the lost 2 seat training exemption for part 103. 264 pounds isn't a lot to work with for a 2 place but it at least shows that the F-37 members are willing to look at the low end of the performance spectrum. A 120 kg or 264 lbs category of aircraft is next to useless as far as 2 seat airplanes are concerned. There is no way you can make a practical 2-seat training aircraft that weighs 264 lbs. You can barely make a useful single seater with that. This particular category seems completely pointless. And also, what is the point of creating categories based on empty aircraft weight? How many aircraft are operated empty? fredoyster Well-Known Member Joining ASTM costs$75 a year, and gives you access to all the standards within one volume (which in this case includes all of the F37 documents, I imagine that F44 will be there too.) Initially I did that rather than pay a lot more for copies of the LSA standard. I joined F37 a few months ago and had a chance recently to approve the new lighter-than-air LSA consensus standard, not that I know anything about that. I signed up for F44 today and will be interested to see it develop.

I listed my interest as R&D, because that's what I'm doing. My company makes microphones for acoustic measurement among other things. Personally I'm interested in design and construction of an ultra-quiet airplane and think that's key to wider adoption of light aircraft generally. I don't believe that requiring low noise performance in a standard (as required in Europe bu ICAO Annex 16) is appropriate, but I do want to be sure that noise is measured accurately (today, it's not, but there is progress, mostly in Scandinavian countries.)

I have to look at things from the viewpoint of an engineer who has worked in development and manufacturing for 30 years. As an amateur airplane builder I have the same frustration with cost of little engines as described by others in this thread -- but as a manufacturer that uses a lot of specialized machine shops for small volume production (100-1000 pieces in a lot) I can tell you that the the cost problem is principally volume, not regulation. The situation is getting better, though, it no longer takes 10,000 pieces to get reasonable prices, because CNC capabilities have really gotten better in the last 20 years. Unless you can piggyback on an existing high volume production effort (a la Aerovee, and to a certain extent Jabiru, UL Power, etc.) it's going to be expensive, and you are going to need some expensive chickens before you can get any cheap eggs. We are going to need to figure out how to interest people in small airplanes even if they cost Rotax/Tecnam/Skycatcher kind of prices, because that's what they will cost even with self-certification.