S-LSA downsides

Discussion in 'Rules and Regulations / Flight Safety / Better Pil' started by PTAirco, Jan 14, 2020.

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  1. Jan 25, 2020 #81

    gtae07

    gtae07

    gtae07

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    If by "motivated" you mean "able to travel to all the meetings in person", then maybe. I was on the committee for the Part 23 standards for two years but was only able to participate via email, and every single one of my comments on proposed rules got summarily dismissed.

    Essentially, the manufacturer reps got the votes, and the regulators (who weren't allowed voting rights but still got to participate) largely set the terms of the discussion. The few of us involved as individuals were basically treated like we were three-year-olds trying to sit at the grownups' table.
     
  2. Jan 25, 2020 #82

    Hot Wings

    Hot Wings

    Hot Wings

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    Yes, we used a lot of existing regulation as the basis for the original ASTM standards. However I have to disagree that they are as formidable as you seem to interpret. The ASTM standard for a spark ignition engine is only 4 pages, one of which is taken up by appendix and notes.

    Other than the detonation test Pete with his O-100 has already done 90ish% of the testing needed to certify it per ASTM.
    We have LOTS of latitude with ASTM. If the manufacturer wanted to specify that the core engine was whatever they could buy used of eBay from XX brand and ZZ model of scooter and then overhaul it per their inspection/standards it would qualify if that is what they did for the engine(s) used for the certification testing. Pete will be free to change vendors for the forging and machine work of his crank as he sees fit - as long as it meets HIS documented standards that were used to build the test engine(s).

    It's nothing like having to document the history of the seed used to grow the tree and the history the resulting tree from the time it hit the forest floor till it gets glued into a rib of a part 23/21 certified plane.

    The reason we don't see any sub 50 Hp ASTM certified engines is that there just isn't a market for them, because there aren't any ASTM certified planes being designed that could fly on that low power. This in turn is because there are few sub 50hp certified engines available for a marketable price. If Pete actually finishes the ASTM certification process for his O-100 we might see that situation change.
     
  3. Jan 25, 2020 #83

    BJC

    BJC

    BJC

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    Just wait until you are trying to get agreement among four or five federal regulatory agencies, four state agencies, and a dozen organizations and legal entities that have legal standing just because they raised their hands and said, “I’m interested.” BTDT. Led to spending $$$$, and 5 + years to get license renewals for two run-of-river hydroelectric generating facilities. BTW, some environmental organizations do not consider hydroelectric generation to be “renewable energy” and advocate for removal of all dams. They even oppose the flood minimizing benefit of dams with large reservoirs.

    My dealings with the FAA have been minor in comparison, but I can imagine what others have experienced.


    BJC
     
  4. Jan 25, 2020 #84

    Hot Wings

    Hot Wings

    Hot Wings

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    I can rubber stamp that this post and add:
    The original ARC project, which led to the ASTM part 23 redo project, was intended to revitalize the USA's market. The ASTM process went down hill pretty fast after EASA got involved, because ASTM decided that they wanted to be an international standard organization.

    Also the various regulating bodies DID have an 'official vote', limited to one member from each body in the beginning.* However that 'official vote' only was with regard to the final votes, which all took place at the face to face meetings that those of us participating on our own dime couldn't afford to attend. Their votes were not limited in the work groups where the standards actually get crafted. If they didn't want it to get out of the work group and past the the first round of voting - it didn't.

    *I believe that the FAA finally realized that having their personal have an official vote was an ethical violation of the law that mandated them to rely on an INDUSTRY standards organization. I don't know if EASA has any similar ethical conflict.
     
  5. Jan 26, 2020 #85

    PTAirco

    PTAirco

    PTAirco

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    That solves nothing. My partner in this is an A&P/IA.
     

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