RV-10 vs SR 22 accident history

[Wanttaja]

Ron, you fly a single seat airplane. I don't think any single seat airplane* has ever been certified in my lifetime.
When the burden is such that no small business can comply, then it is effectively a ban on single seat low powered airplanes.

The only one I'm familiar with is the Mooney Mite, and that was before my (and probably your) time.

However, is the bar to single-seat production-type aircraft the certification cost, or the perceived lack of market? The Mite didn't do well. I'm pretty well tied into the Fly Baby world, and I see planes for sale for a long, long time. Lack of performance might certainly be a factor, but when most people are going to spend a bunch of money for an airplane, they want (at least) a second seat.

I don't see how this effective banning of light airplanes and leaving homebuilts as the only option serves any purpose since homebuilts don't meet the standards.
Frank was a wealthy businessman that could afford to pay the cost (much less decades ago) for an old style design that hardly differed much from the 40's Cub.

How wealthy did he need to be, to pay for a two-inch stack of paperwork? Remember, everybody expected it to be much, much higher. I doubt his money reduced the paperwork burden....made it easier to pay, yes, but not the overall requirements.

Starting an aircraft manufacturing company *from scratch* is NOT a low-cost effort. Certification certainly adds to it, but what's the cost compared to the need to build facilities, hire and train employees, pay subcontractors, etc?

But then, of course, marketing raises its ugly head. We've talked about how single-seat airplanes are a hard sell. If a company is going through all the expense to set up factories, hire and train workers, etc., will they make their investment back quicker on a four-seater? After all, a four-seater is nothing but a two-seater with *killer* baggage space. I think a new company'd be more likely to develop a replacement for the 172 than the 162.

It isn't that easy to get anything approved now. What is needed is relaxed burdens for one and two seat airplanes.

As I understand it, this is what the Light Sport program was set up to do. Looking solely at the SLSA/ELSA records, 65 Vans RV-12s entered the FAA rolls last year, plus 47 LSA CubCrafter Cub clones. That's over half of the total number of SLSA aircraft (not weight shift, etc.) added in 2013. Not a real strong market...no other LSA types added more than 20 planes to the rolls in the entire year.

But I assume you're looking for higher performance than allowed under SLSA.

I don't disagree with relaxing the certification burdens for single-seaters... let the pilot take the risks, just like we're not required to carry ELTs. But I'm afraid anything like "Make it more like homebuilts" is not going to fly, within the FAA. Homebuilts are perceived as having a much worse safety record than certified airplanes (FAA's estimate is roughly seven times the accident rate for certified aircraft...even my analysis shows we're 40% higher). The pilots may be OK with it, but the FAA is concerned about the deaths of passengers who may not understand the higher risks.

Ron Wanttaja

 

[BBerson]

I am not suggesting " make it more like homebuilts". Just the opposite.
I am suggesting that a small manufacturer should be allowed to self- certify compliance to Part 23. Self-certification isn't new, it is used by pilots and mechanics when we sign logbooks. Why not manufacturers?
Imagine if the burden to get a mechanics certificate was so high that only one or two mechanics in the entire country could comply. Would that level of burden provide optimal safety? Of course not. That would never be allowed to happen with mechanics.
But the burden is so high for one and two seat aircraft to comply with Part 23 and the result is that none can comply (past 20 years).

The situation is hardly better with light sport. No single seat light sport has complied yet.


A two inch stack of paperwork says nothing about the actual burden.
The Mooney Mite apparently did allow the company to get started and grow and gain experience before moving to four seats. What's wrong with that?
I am frustrated by this need to argue the case for single seat and two seat affordable options.

 

[Hot Wings]

Back when Frank Christensen certified the Husky, he gave a talk at Oshkosh. Someone asked him how tall the paperwork was for getting the Part 23 certification for the airplane.

He indicated a stack about two inches high. Just two inches.

This was back in mid '80's. The Husky got it's certification in 1987, just 2 years after the drawing started. Back then we had a local FSDO and could get our Experimentals inspected for free, and promptly, by FAA guys that actually liked airplanes. It's a 6 hour drive to Afton and I believe there was one even closer. Boise is the closest now. A lot has changed since then.

I tend to agree the it's not the actual compliance to the regulations that is driving the cost of certification. Especially with the LSA's there isn't much that one could trim from the standard that wouldn't be done by a competent engineer and, considering our litigious society, not voluntarily documented.

What is driving the cost is the extra documentation requested by the FAA to clear up ambiguous terms in the regulation and the requirement that all testing be witnessed by the FAA or a DER, requiring a second set of documentation. This may be justifiable for safety at the part 25 level but for the type of aircraft we need I don't think it adds enough safety to justify the cost.

Once the certification is in hand then the whole process gets repeated for the production certificate and there the paperwork is an ongoing task. Does safety provided by tracking each lot of AN hardware, and qualifying each subcontractor and supplier really worth the costs? How about something like control cable? The stuff at the local hardware store often is exactly the same that would be used in a production setting, comes from the same manufacturer, off the same production line, and has the date/lot number stamped on the spool. Does a paper trail really add enough safety to justify the cost to a basic 4 place airplane - even if it is used commercially?

Back in '87 when the Husky was certified I kind of doubt lightning strike assessment took up much time, if any. Current part 23 has requirements relating to lightning an HIRF that didn't even exist in '87. The level of testing required due to numerous ambiguous terms has increased for both new and old regulations.

23.876(c)
(1) Designing the components to minimize the effect of a strike; or

(2) Incorporating acceptable means of diverting the resulting electrical current so as not to endanger the airplane.

I'd not like to be the engineer tasked with designing to meet a regulation written like this and then having to justify my result based on those terms. Could this one section be documented today with only 500 pages of paper?

 

[bmcj]

Ron, you fly a single seat airplane. I don't think any single seat airplane* has ever been certified in my lifetime.

*I am talking affordable here, not Extra 300

In addition to the Mooney Mite and Extra 300 already mentioned, there are also numerous cropduster designs.

And "affordable" is not a term to be used with any aircraft.

 

[gtae07]

I'd say this new category should include four-seaters, too. 3000lb, unpressurized, up to four (or six?) seats. There's no real difference other than just size.

As others have pointed out, most of the Part 23 standards aren't really onerous, and are really just common sense and due diligence. There are places where the regs are prescriptive of one way to do things ("thou shalt do it this way" rather than "here's what you need to achieve") or are inflexible or unacommodating of new technologies. And yes, there are some places where the regs are overkill--e.g. an aircraft-level lightning test is a good idea for a 19-seat commuter, but totally unnecessary for a Cessna 172.

Oversight of the process is fine. "Spot checks" and occasional audits of self-certification reports, fine. But there's no need for the FAA to have someone there in the flesh to witness each test for compliance with his/her own naked eyes--just record the tests with a bunch of GoPro cameras and mail the Feds a DVD of the ones they need for their audit. There's no need for the FAA to send someone to physically crawl over the aircraft and check the configuration of each component before every test (a process that, according to the Part 23 ARC's report costs applicants about $40k a year in travel expenses on average, and up to $200k per month during peak cert efforts, plus several "heads" of manpower, all for a process unique to the FAA) when the company's configuration management process has already documented the exact configuration of the aircraft. This in particular was unanimously highlighted by the ARC as the single biggest cost in a certification effort.

But, certification and compliance of the design is only part of the cost and regulatory problem. The other part is on the production side of the house (Part 21)--the regulations that apply to production certificates, quality management, and so on. The FAA insists that every process be documented and approved at every step, that quality management be specifically approved at all levels, and so on. It's not important that just the final product be documented and checked, but how you get there is just as important to them. It gets so detailed as to specify that you have to notify the FAA in writing if you move fixtures or work tables on the production floor!

There is no other industry where the applicable regulatory agency examines and tracks production to that level of detail. Not medical devices, not pharmaceuticals, not cars and trucks. Yet all of these industries achieve orders of magnitude more product produced at lower defect rates with less paperwork and more efficiency. They use applicable industry-standard quality control methods and manufacturing processes to achieve this whenever possible.

There is absolutely no reason why aircraft production (or aircraft part/component production) needs to have the level of direct regulatory involvement that it currently does. Direct adoption of standards and processes from other industries should be more than sufficient to ensure consistent build quality and conformity, especially with light, simple aircraft.

 

[gtae07]

There is no other industry where the applicable regulatory agency examines and tracks production to that level of detail. Not medical devices, not pharmaceuticals, not cars and trucks. Yet all of these industries achieve orders of magnitude more product produced at lower defect rates with less paperwork and more efficiency. They use applicable industry-standard quality control methods and manufacturing processes to achieve this whenever possible.

To add to my point:

Total (certified) general aviation piston airplane deliveries for 2013 totaled 933 worldwide. That's singles and twins, all manufacturers.

The average passenger car, truck, or SUV is roughly comparable in systems complexity (if not even more complex, considering the engine and transmission technology) than even a modern piston-powered aircraft.

Even if we consider only domestic US sales, and assume a 24/7 constant production run to reduce average hourly output, Ford produced more F-150 trucks (that is, vehicles of comparable complexity to a light aircraft) in 11 hours than the entire general aviation industry produced in airplanes all year.

That's just one model, from one manufacturer. They did it at a lower defect rate than we see in aviation. But they didn't have extensive quality control checks at every step, they didn't have paper trails for every single component, every lot of fasteners, every block or sheet of raw material.

And they didn't have the DOT or DMV or NHTSA standing over their shoulders dictating how they should do quality control, or keeping tabs on the layout of their production floor, or crawling over every one of their suppliers doing the same.

 

[Matt G.]

They did it at a lower defect rate than we see in aviation. But they didn't have extensive quality control checks at every step, they didn't have paper trails for every single component, every lot of fasteners, every block or sheet of raw material.

They also have more automation than any GA aircraft manufacturer.

 

[tspear]

If any of you are into software, look at CMMI level four/five. That is the production expectation that the FAA requires for aviation. Rather overkill I think. Good idea for a spaceshuttle, maybe for a jumbo jet, but not my little plane.
Why do so many people want to use weight as a metric for certification standards? This is a horrible concept, as technology and other factors have changed what can be done with 3,000lbs or 6,000lbs or 12,500lbs... Instead certification standards and requirements should focus on how the plane is to be utilized. e.g. For private use, once set of standards, allow it to used for hire (rental, school..), add a few more items to the standards, when you carry passengers make the standard even more strict...
You get the idea. get away from weight, number of engines, engine types... and focus on purpose.

Tim

 

[Matt G.]

Ron, you fly a single seat airplane. I don't think any single seat airplane* has ever been certified in my lifetime.

*I am talking affordable here, not Extra 300

Many, many single-seat gliders have been type-certificated...

 

[BBerson]

Many, many single-seat gliders have been type-certificated...

Can you name one glider that was first certified in the United States in the last 10 years?

 

[Matt G.]

Can you name one glider that was first certified in the United States in the last 10 years?

No, because there is no longer a portion of the FARs for their certification like there used to be. You did not specify a time period, you know...

I think there is some sort of bilateral agreement in place with EASA in which some come from overseas certified to CS-22, but it seems most of them end up in the experimental exhibition category with operating limitations that require them to be operated and maintained similar to a TC'd aircraft.

Edit: One example slightly older than 10 years (but that doesn't matter because the certification process for them doesn't really seem to have changed since) is the Schleicher ASW-28. It was not "first certified" in the US, but I don't understand why that really matters.

 

[Hot Wings]

You get the idea. get away from weight, number of engines, engine types... and focus on purpose.

Tim

The original idea was to do just that and get away from the weight/and powerplant type divisions. That is still the idea but no clear or workable method has evolved.

My thought is that the only rationalization for any rules at all is to protect the public. (I don't consider politics a rational reason)

Break this down into 2 groups, those on the plane and those on the ground. Base the divisions of hazard to ground dwellers on the kinetic energy of the plane, kind of like the rational used for part 103's. Base the hazard ranking to crew and passengers on the number of same, stall speed, and the complexity of the craft - pressurized, turbocharged/turbine, FBW, IFR into icing etc. Assign points for each and then let the overall score determine the hazard ranking and the required level of testing and documentation appropriate for each. This would give the designers a lot more flexibility than they now have with regulations that tend to make designing to the very edge of each division the only marketable choice.

Edit: CMMI = something that has been banished in Redmond?

 

[BBerson]

No, because there is no longer a portion of the FARs for their certification like there used to be. You did not specify a time period, you know...

I think there is some sort of bilateral agreement in place with EASA in which some come from overseas certified to CS-22, but it seems most of them end up in the experimental exhibition category with operating limitations that require them to be operated and maintained similar to a TC'd aircraft.

Edit: One example slightly older than 10 years (but that doesn't matter because the certification process for them doesn't really seem to have changed since) is the Schleicher ASW-28. It was not "first certified" in the US, but I don't understand why that really matters.

It doesn't bother you that no one can afford to certify a glider in the U.S. ?
It used to be possible back in the Schweizer days. The burden gets worse every year.
That is why drastic action is needed such as self- certification. Even Congress mandated the FAA do something before 2015 and the President signed the bill.

 

[Matt G.]

It doesn't bother you that no one can afford to certify a glider in the U.S. ?
It used to be possible back in the Schweizer days. The burden gets worse every year.
That is why drastic action is needed such as self- certification. Even Congress mandated the FAA do something before 2015 and the President signed the bill.

The Germans apparently can.

I never said it didn't bother me, and I completely agree that what we have now isn't a good solution. My intent was to correct your erroneous generalization.

As recently as the '70s, there were kit-built TC'd gliders for which the builder could apply for a standard airworthiness certificate if their finished aircraft conformed to the type certificate. That went away long before my time, though...

 

[BBerson]

My intent was to correct your erroneous generalization.

Which generalization?

 

[tspear]

The original idea was to do just that and get away from the weight/and powerplant type divisions. That is still the idea but no clear or workable method has evolved.

My thought is that the only rationalization for any rules at all is to protect the public. (I don't consider politics a rational reason)

Break this down into 2 groups, those on the plane and those on the ground. Base the divisions of hazard to ground dwellers on the kinetic energy of the plane, kind of like the rational used for part 103's. Base the hazard ranking to crew and passengers on the number of same, stall speed, and the complexity of the craft - pressurized, turbocharged/turbine, FBW, IFR into icing etc. Assign points for each and then let the overall score determine the hazard ranking and the required level of testing and documentation appropriate for each. This would give the designers a lot more flexibility than they now have with regulations that tend to make designing to the very edge of each division the only marketable choice.

Edit: CMMI = something that has been banished in Redmond?

Now the Redmond comment is unfair. CMMI is all about repeatable, you can almost always make a computer get the BSOD the same way each time. So there, they do follow some level of CMMI.

You are still making it to complicated. If the concern is hazard on the ground, e.g. they do not want a small company making a 747 sized plane and selling it to Hollywood pilots, then limit it by impact energy. Easy enough to state in terms of kilo newtons. e.g. Make it the equivalent of a MB S600 hitting a wall at 100 MPH which I have seen the aftermath (kid took parents car and went off the road and through a barn). By making the requirement based on kinetic energy, then you can build a plane with 3000lbs and a 200 knot stall speed, or a plane that weights 6000lbs and 50knot stall speed. Leave it to the designer...

Tim

 

[Matt G.]

Which generalization?

Once again...

I don't think any single seat airplane* has ever been certified in my lifetime.

*I am talking affordable here, not Extra 300

 

[gtae07]

They also have more automation than any GA aircraft manufacturer.

So?

The FAA doesn't care if a given manufacturing process is automated or not, and it doesn't much care whether it's a brand-new proces or one that is used in every industry that makes items more complex than rubber chickens, and has been documented in the public domain for decades. You still have to prove all over again to the FAA that every step of every process works as intended, and so does every one of your suppliers.

The thing is, automation doesn't make a difference with massive paper trails for raw stock or hardware. It doesn't make a difference in how much paperwork you generate in your quality system. Whether a given assembly was put together by a person with a rivet gun or by an automated welder, you still have to inspect it at some point. The difference is in how you inspect it, and how much of a paper trail is generated. Automakers churn out complex items consistently without filing a stack of regulatory paperwork for every single part that traces every single step from raw stock to the final component.


The quality manual basically lays out "here's how we inspect things, here's what we do with things that don't meet spec to make sure they don't get into the final product, and here's how we control the process". There are standards for this that have been hashed out, refined, and excruciatingly documented by SAE, ISO, etc. They work. We know they work, because every other industry uses them. But to the FAA, that's not good enough. You can't simply say "we're going to follow SAE XXXXX". You have to rewrite it all yourself, to the FAA's satisfaction. There's no good reason why an aircraft manufacturer can't use the same quality control process that Ford or Toyota or Volkswagen uses--only the FAA saying "well, this is airplanes we're talking about, so it's special, and it has to be different because we say so".

And, the mere fact that they use all that automation works in our favor. Getting to that level of high-speed production with automated systems takes a lot of testing and optimization, each iteration of which would be considered by the FAA to be a "change to the manufacturing facilities that may affect the inspection, conformity, or airworthiness of its product or article". If Ford had to notify regulatory agencies every time it moved an automated welder, or rearranged its transmission assembly area, or rerouted its supply distribution, they would have never gotten to that level (or there'd be an entire department that did nothing but continually churn out notifications to the FAA that something moved). Yet that's what the FAA requires aircraft manufacturers to do.

The FAA doesn't need its fingers in everything. Let the manufacturers control their own processes. The occasional audit would be fine, but a manufacturer shouldn't need a priori permission for every step of every process, especially when those processes are already documented and standardized and used in other safety-critical industries.

 

[autoreply]

It doesn't bother you that no one can afford to certify a glider in the U.S. ?

Why "certify in the US" if it's already certified and can legally be flown in the US without trouble?

The truth is much simpler, there is just no market for single-seat aircraft, save a few exceptions. Absolutely nothing to do with certification.

Come to think of it, the ASH30 is a good example where certification hinders safety. New fuselage, so has to meet new regulations with a stricter crash-impact requirement. They failed a test and had to redesign, retest=>$$$$$$$$$

Competitors simply use the certification basis for their old fuselages and upgrade the other wings and aerodynamics and thus don't meet those stricter crash-impact criteria. Most of those would like to meet the new criteria, but not with formally testing and certifying it ($$$). See there, certification burders working against safety.

 

[Hot Wings]

Now the Redmond comment is unfair. CMMI is all about repeatable, you can almost always make a computer get the BSOD the same way each time. So there, they do follow some level of CMMI.

Yeah, that was probably a bit unfair to make such a sweeping generalization. There must be some Linux users living there.:whistle: To be fair I am comfortable with XP but I just had to deal with "lost documents" on my wife's Win 7 box because of the dumbed down file structure display. If she would just save her files on the server...........

You are still making it to complicated. If the concern is hazard on the ground, e.g. they do not want a small company making a 747 sized plane and selling it to Hollywood pilots, then limit it by impact energy. Easy enough to state in terms of kilo newtons.

I must be speaking some dialect of Redmondese onder: because I agree with this. I'd just break it down into maybe 4 levels of energy. Level 1 up to what the rest of the world calls an ultralight traveling at around 100 mph. Level 2 - up to your MB or a GMC pickup traveling at 60 mph. Level 3 equal to a typical class B motor home at the same velocity with level 4 being everything above that. Decide if the energy calculations should be done at stall or cruise speed (maybe a combination of both to satisfy the bureaucratic mind) and the general public has been protected.

That still leaves protecting the passengers. Single place planes should have zero limitations with regard to occupant protection, other than maybe predictable and consistent control response.

Since the greatest hazard to the passengers and crew occurs during landing and take off define the levels of hazard based on the number of occupants and the the other parameters, such as flaps, stall speed, retractable gear, IFR, and what ever the standards group considers relevant. There will be others that want inflight parameters such as pressurization, number of engines, and propulsion type to be considered.