Part 23 NPRM - ARC - ASTM

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Hot Wings

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So aren't we, in essence, talking about modifying an existing tiered system rather than 'creating' a tiered system?
Sort of, but the existing tiered system is "chunky". Basically there is jet/not jet, twin/single, <6000pounds, <12500 pounds. One example used at the meeting today was certification of twins. Right now it appears that the FAA would make someone that builds a new version of a 337 go through all the steps that are required by a typical non-linear thrust twin. Under the ASTM standards it would be clear up front that the manufacturer would not have to show why their plane need not have a Vmc speed. (kind of a lame example but the best I can do right now)
 

fredoyster

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Edit: #4 who are you? At least let Rienk and I know?
Who me? Sorry I was not able to be on the call today. There might be other lurkers, I don't know. I am more interested in powerplant and system things for the moment, as I'm interested in the next phase of light aircraft, which have to be quiet (my area of contribution, hopefully) as well as all the other good things. It has been great to see at least some movement toward "tailoring" although I'm not sure it will proceed far enough.

And the last point - FAA has no choice in the matter but to use ASTM or a similar body, see the legislation that forces them to use the consensus method, with a new round of this just passed House and Senate a few weeks ago.
 
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Hot Wings

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And the last point - FAA has no choice in the matter but to use ASTM or a similar body, see the legislation that forces them to use the consensus method, with a new round of this just passed House and Senate a few weeks ago.
I know the FAA and other government agencies have been "under orders" since the National Technology Transfer and Advancement Act to use industry consensus groups "whenever appropriate" but I've missed any new legislation. Can you bring me up to date? A link maybe?
 

fredoyster

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I know the FAA and other government agencies have been "under orders" since the National Technology Transfer and Advancement Act to use industry consensus groups "whenever appropriate" but I've missed any new legislation. Can you bring me up to date? A link maybe?
H.R.1848 - 113th Congress (2013-2014): Small Airplane Revitalization Act of 2013 | Congress.gov | Library of Congress

Passed House in July, Senate this month in slightly different forms, I think it needs reconciliation and then can go to WH to be signed.
 

BBerson

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Is it ME? No... probably not, or someone would have told me.
You can join now for 2014 and get a vote. Next year might actually be a very important year for ASTM voting, you could help the future of GA.
This also affects home building because we need the option of a source of certified engines, instruments, etc.
Think about it.
 

Hot Wings

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Interesting meeting today. We are starting the tiering/tailoring process. There seems to be some desire from the older FAA to go back to something more like the CAR 23 certification, what most of the certified planes we use were certified under, for the lower levels. At this point RV's were brought up and it was pointed out that they are selling in large numbers yet there is no way they could be certified to part 23. It was also pointed out the the typical 172/Pa-28 couldn't be certified under part the current 23 either.

The real surprise came when the talk turned to actually reducing the standards to the level that would allow for such planes to be certified. The logic being that the consuming public has indicated that these planes offer an acceptable cost/safety compromise and that the regulators shouldn't mandate a safety level just because that level is possible, but only at a very high cost.

Even if RV'ish planes are ultimately only allowed in the non-commercial/owner maintenance category that would be a significant change.

There was also some talk of making the use of off the shelf parts easier to use buy coming up with some way to accept parts that are already manufactured to very high standards, but have not gone through the formal FAA certification process. Ipads and auto parts were mentioned. Again, some of the FAA people were making these observations.
 

autoreply

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What's the reason the RV's can't be certified under current FAR23, quality control solely? Afaik the LAA has similar standards and after minor fixes it came through as far as the construction/flight etc are concerned?
 

Hot Wings

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The reasons alluded to were control/stability, specifically stick force gradients, and the lack of redundancy in the trim system in the case the primary control system failed. I'm no RV expert so I don't know if these observations are valid.
 

gtae07

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Interesting meeting today. We are starting the tiering/tailoring process. There seems to be some desire from the older FAA to go back to something more like the CAR 23 certification, what most of the certified planes we use were certified under, for the lower levels. At this point RV's were brought up and it was pointed out that they are selling in large numbers yet there is no way they could be certified to part 23. It was also pointed out the the typical 172/Pa-28 couldn't be certified under part the current 23 either.

The real surprise came when the talk turned to actually reducing the standards to the level that would allow for such planes to be certified. The logic being that the consuming public has indicated that these planes offer an acceptable cost/safety compromise and that the regulators shouldn't mandate a safety level just because that level is possible, but only at a very high cost.

Even if RV'ish planes are ultimately only allowed in the non-commercial/owner maintenance category that would be a significant change.

There was also some talk of making the use of off the shelf parts easier to use buy coming up with some way to accept parts that are already manufactured to very high standards, but have not gone through the formal FAA certification process. Ipads and auto parts were mentioned. Again, some of the FAA people were making these observations.
I assume this was a task group meeting? When is the next one? (reference our PM discussion end of last month)


The reasons alluded to were control/stability, specifically stick force gradients, and the lack of redundancy in the trim system in the case the primary control system failed. I'm no RV expert so I don't know if these observations are valid.

Stick forces are pretty light compared to your average spamcan, particularly for the short-wing models; IIRC one of the CAFE foundation reports showed them to be less than normally certifiable. It didn't take much getting used to when I moved over from a C150.

With the trim system, I assume they meant this part?

Trimming devices must be designed so that, when any one connecting or transmitting element in the primary flight control system fails, adequate control for safe flight and landing is available with— (1) For single-engine airplanes, the longitudinal trimming devices
A bare-bones stock RV-3 through -9 has only a vernier-cable-actuated trim tab on one elevator. This setup is very responsive as trim systems go, though I'd still hate to try and land using only elevator trim (assuming free-moving elevators). Electric trim is an option, as are a spring-bias aileron trim (mechanical or electrical), or an electric aileron trim tab.
 

Hot Wings

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I assume this was a task group meeting? When is the next one? (reference our PM discussion end of last month)

The F44.20 has a weekly web meeting every Wednesday morning.

Stick forces are pretty light compared to your average spamcan, particularly for the short-wing models; IIRC one of the CAFE foundation reports showed them to be less than normally certifiable. It didn't take much getting used to when I moved over from a C150.

Stick forces are too high under current part 23 (and LSA) IMHO, and that of a few others. I do like a noticeable progression of stick forces with both speed and "G" load, but my preference shouldn't be put into standard unless there is a good safety reason to do so.

With the trim system, I assume they meant this part?

That was my assumption as well.
 

gtae07

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I assume this was a task group meeting? When is the next one? (reference our PM discussion end of last month)

The F44.20 has a weekly web meeting every Wednesday morning.

What time? It would be much easier to participate if it's near my lunch break.
 

Hot Wings

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What time? It would be much easier to participate if it's near my lunch break.
8:00 AM Mountain. Time seems to be the best compromise for North American and European participants. One can attend via mobile device as well.
 

BBerson

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Interesting meeting today. We are starting the tiering/tailoring process. There seems to be some desire from the older FAA to go back to something more like the CAR 23 certification, what most of the certified planes we use were certified under, for the lower levels. At this point RV's were brought up and it was pointed out that they are selling in large numbers yet there is no way they could be certified to part 23. It was also pointed out the the typical 172/Pa-28 couldn't be certified under part the current 23 either.

The real surprise came when the talk turned to actually reducing the standards to the level that would allow for such planes to be certified. The logic being that the consuming public has indicated that these planes offer an acceptable cost/safety compromise and that the regulators shouldn't mandate a safety level just because that level is possible, but only at a very high cost.

Even if RV'ish planes are ultimately only allowed in the non-commercial/owner maintenance category that would be a significant change.

There was also some talk of making the use of off the shelf parts easier to use buy coming up with some way to accept parts that are already manufactured to very high standards, but have not gone through the formal FAA certification process. Ipads and auto parts were mentioned. Again, some of the FAA people were making these observations.
I am sure you meant CAR 3 (not CAR 23).
I missed today's meeting. But I remain skeptical, because these sorts of deregulation attempts have been tried about every 10 years to get GA going. In 1992 the FAA created the Small Airplane Certification Compliance Program. This included Primary category and Very light Airplane (VLA) category. But it remains that almost no applications get through. It seems the FAA just overwhelms the applicants till they quit.
EAA had suggested using CAR 3 decades ago.
I read CAR 3 and found it to be almost word for word the same as FAR 23.

The problem, I feel, is not designing to meet the existing regulations. The problem is getting the FAA to do anything reasonable to grant your Type Certificate after you apply. Back in 1945 the bureaucrats were apparently more helpful. That isn't the case today, even a simple airman application is likely to be rejected.
 

Hot Wings

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Yes, it's a typo. Should be CAR 3.

If you look at a side be side comparison between CAR 3 and the current part 23 there is a lot more there. Somewhere on the ASTM site there is a spread sheet that compares CAR 3, Part 23, and CS 23 side be side.

It was interesting that someone (IIRC it was one of the FAA guys, but I didn't take that note) thought that even CAR 3 was too much for the very simple aircraft. The EASA representative didn't seem to like any part of the idea to reduce standards below part 23 levels.

It's not all the aircraft certification costs that are driving up costs, its the production certificate where the real bureaucracy comes into play. It could be worse. The Europeans may have conditionally accepted the ASTM standards for LSA's but the US manufacturers are still effectively shut out of the market. Things like the requirement for 2 EASA inspectors at $600/hour (apparently 24/7 while in this country?) and yearly fees to keep the certification active, even if there are no changes just make it too expensive for the small volume.

I'm still skeptical, but I'm going to ride this horse till the buzzards start circling.

I am sure you meant CAR 3 (not CAR 23).
I missed today's meeting. But I remain skeptical, because these sorts of deregulation attempts have been tried about every 10 years to get GA going. In 1992 the FAA created the Small Airplane Certification Compliance Program. This included Primary category and Very light Airplane (VLA) category. But it remains that almost no applications get through. It seems the FAA just overwhelms the applicants till they quit.
EAA had suggested using CAR 3 decades ago.
I read CAR 3 and found it to be almost word for word the same as FAR 23.

The problem, I feel, is not designing to meet the existing regulations. The problem is getting the FAA to do anything reasonable to grant your Type Certificate after you apply. Back in 1945 the bureaucrats were apparently more helpful. That isn't the case today, even a simple airman application is likely to be rejected.
 

Hot Wings

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FWIW, EAA is reporting that HR 1848, the "Small Airplane Revitalization Act of 2013" has been reconciled and passed in both houses of Congress and has been sent to the President for signature.

Link to text of bill
How can we take any bill with less than 1000 pages seriously? :gig:

And just my luck, the one time the government mandates something that I'm doing - it's not a paying position. :depressed
Sec 3 (b) (4)
 

autoreply

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Honestly, I can't think of a single article one could take out without reducing safety from CS23/FAR23, save some irrelevant details (those high stick forces come to mind).

IMHO, in the methods of showing compliance and the documentation/quality control is where the real cost reduction could be made.
 

Hot Wings

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Honestly, I can't think of a single article one could take out without reducing safety from CS23/FAR23, save some irrelevant details (those high stick forces come to mind).

IMHO, in the methods of showing compliance and the documentation/quality control is where the real cost reduction could be made.
All pretty much true. The proposed new part 23 is pretty general. An example:

23.143 Controllability and maneuverability.
Scope. This section addresses the safety related airplane flight characteristics which allow a pilot to
safely maneuver the airplane and control flight path.
Purpose. The intent of this section is to ensure that the maneuvering flight characteristics are safe and
appropriate throughout the flight envelope and the maneuverability results in repeatable and smooth
transitions between turns, climbs, descents and level flight. It is also intended that configuration
changes, such as flap extension and retraction, landing gear extension and retraction and spoiler
extension and retraction, along with asymmetric thrust due to engine failure, will result in safe
characteristics owing to the airplane’s controllability characteristics.
Application. This section applies to all part 23 airplanes.
Requirement.
(a) The airplane must be safely controllable and maneuverable during all flight phases.
(b) It must be possible to make a smooth transition from one flight condition to another.
(c) The requirements of paragraphs (a) and (b) of this section must be met, without requiring
exceptional piloting skills, alertness, or strength, throughout, but within, the operating envelope defined
as required by Subpart A (including configuration changes and, for multi‐engine airplanes, the sudden
failure of the critical engine).


That's it for the new part 23* with regard to controlabality. All of the details will be in the ASTM standard. Hopefully we can tailor the standards to be appropriate to the complexity level of the plane and the hazard it is likely to present to the public. Not only should the new standards be simpler to read and less open to interpretation there will be some ways for the manufacturers to self certify a lot of the process rather than have to wait for an FAA observer or hire a DER.

That still leaves the problem and cost of production certification. Proving that the plane is designed to do "X" is one thing. Proving that each plane produced will match the test sample and design specifications to an acceptable level is where the real money can be consumed. Simply accepting existing ISO, or other industry accepted, certification of suppliers rather than having to go through the whole FAA certification process would save a lot of money.

* subject to change before and after the publication of the NPRM.
 

Topaz

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...That still leaves the problem and cost of production certification. Proving that the plane is designed to do "X" is one thing. Proving that each plane produced will match the test sample and design specifications to an acceptable level is where the real money can be consumed. Simply accepting existing ISO, or other industry accepted, certification of suppliers rather than having to go through the whole FAA certification process would save a lot of money.
This, this, a thousand times this. FAR 23 really isn't that onerous for the aircraft itself. Some of the specs can be backed off a touch without compromising safety, IMHO, but the thing isn't awful as it is. Showing compliance and wading through the mountain of government paperwork related thereto is the first problem, and one that relates solely to the aircraft.

Certificating the manufacturer is the 800# gorilla in the room that nobody wants to talk about. ALL of the rest of the world's industry has found that ISO and other standards are perfectly adequate for even mission-critical manufacturing methods. The FAA's continued insistence on absolutely absurd lengths like certificating a given process as-performed by each individual manufacturer and supplier is what's making the process virtually impossible for anyone hoping to get into the business, and artificially inflating the cost of introducing new designs. The rest of manufacturing in the world has this figured out. Please, for the love of all that's holy, can we get the FAA to recognize that?
 

Hot Wings

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Please, for the love of all that's holy, can we get the FAA to recognize that?
It may not be the FAA that is going to be the real roadblock. I'm getting the impression that EASA is going to be harder to work with. The FAA still wants to "harmonize" all the standards, believing that by doing so there will be a reduction in certification costs needed to sell planes in other markets. If EASA doesn't want to go along with relaxing the standards then there is a lot of political pressure to deal with.
 
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