On June 7, 2000, the FAA issued the "Type Certification Procedures for Changed Products" (aka the Changed Products Rule) final rule. The Changed Product Rule (CPR) amends those parts of regulations 14 CFR ï¿½11, 21, 25 that address the way in which aircraft modifications requiring a Supplemental Type Certificate (STC) receive FAA certification. The "Changed Products Rule" (CPR) requires that any "significant" modifications to an aircraft requiring a Supplemental Type Certificate (STC) and all systems affected by that STC modification must meet the latest amendment to the certification standards, regardless of the earlier certification regulation that was used to certify the aircraft being modified ("original certification basis").
As a required part of the CPR implementation plan, an Advisory Circular (AC) 21.101 was issued August 3, 2001 that addressed large aircraft but did not address the needs of typical small General Aviation aircraft. A draft revision of AC 21.101 was published April 23, 2002 to address small aircraft needs.
AOPA strongly believes that CPR has the potential to stifle the necessary development of safety and/or operational enhancing STC modifications. There is no doubt that there will be substantially increased costs to the STC manufacturer in order to develop additional engineering and research data necessary to meet the requirements of CPR. Many STC'd modification developers and manufacturers may simply elect not to pursue an STC, thus denying many aircraft owners an opportunity to upgrade. At the very least, the additional costs of STC development will be passed on to consumers. As a result of CPR, many potential safety or operational enhancing aircraft modifications may never come to the average GA market and many other STC'd modifications will simply be too costly for the average GA aircraft owner.
In addition, an Advisory Circular guidance addressing the "small aircraft" section of CPR is necessary so that applicants and the FAA may begin to understand the application CPR to small aircraft.
AOPA strongly feels that CPR was not necessary, especially for GA. AOPA believes that requiring an aircraft modification to meet the latest amendment to the certification regulations instead of the earlier original certification basis of the aircraft being changed does not necessarily mean that a more safe condition will prevail. In fact, the overall safety record of the GA fleet indicates that the previous method of certifying modifications requiring a Supplemental Type Certificate (STC) has continually resulted in GA safety improvements. There is no specific safety data or safety study presented by the FAA that supports its safety reason for promulgating the "Changed Product Rule" (CPR) or to include GA. In addition, the economic burden placed upon small businesses (who produce a majority of GA aircraft STCs) and the majority of small aircraft owners (which comprises the majority of the entire U.S. aviation fleet) will only serve to considerably stifle and suppress the cause of safety.
AOPA actively lobbied the FAA to live up to its regulatory responsibilities under the "Smaller Aircraft" exception of CPR and that it adopt the agreed to recommended changes and additions to AC 21.101. As a result, the FAA has published a draft revision to the AC and AOPA agrees with the changes as they pertain to small aircraft.
AOPA thanks our members for their continued support in protecting the freedom to fly.