Regulatory and Certification Policy
November 4, 1998
Mr. Ervin Dvorak
Federal Aviation Administration
Regulations and Policy Branch, ACE-111
Small Airplane Directorate
601 East 12th Street
Kansas City, MO 64106
Ref: AC 23.1309-1C
Dear Mr. Dvorak:
The Aircraft Owners and Pilots Association (AOPA), representing the aviation interests of more than 340,000 pilots and aircraft owners, submits the following comments to draft Advisory Circular (AC) 23.1309-1C Equipment, Systems, and Installation in Part 23 Airplanes. In general, we strongly support this draft AC and applaud the efforts of the Federal Aviation Administration (FAA) to redefine the manner in which general aviation equipment and systems are certificated for Part 23 airplanes.
AOPA has invested heavily in the efforts associated with RTCA Task Force 4 which is designed to examine safety and certification issues with the goal of simplifying the existing certification process while reducing the accident rate across the full spectrum of aviation activities. One of the leading observations for general aviation being discussed by the RTCA Task Force 4 is that with greater benefit-cost ratios and the resultant increase in avionics equipage rates, improved pilot situational awareness could occur. Such an improvement could have a significant positive impact on the general aviation accident rate. AOPA strongly supports this observation.
Clearly, pilot situational awareness can be improved by enhancing the quantity, quality, and presentation of situational data available to the pilot in the cockpit. Unfortunately, many of the technologies for carrying this out are not available to general aviation due to the prohibitive cost associated with product certification. We believe that draft AC 23.1309-1C represents a first significant step in reducing the burden of certification for general aviation systems and thus will contribute to an increased availability of situational awareness enhancing equipment for general aviation. This can only result in an overall reduction in the general aviation accident rate.
The efforts of the FAA Small Airplane Directorate to reduce the cost burdens of system and equipment certification for general aviation is also very timely. The aviation industry as a whole is on the threshold of a revolutionary change in the manner in which communication, navigation, and surveillance of aircraft operations is conducted. This complete overhaul of the National Airspace System (NAS) is intended to take advantage of new technology and will likely result on the long-term replacement of nearly all avionics and instrument equipment in the existing fleet as well as new production aircraft. If general aviation is to operate within a revised NAS system, it is imperative that new technologies be made available and affordable for general aviation aircraft.
Under the existing certification process, new technologies such as digital communications, data buses, satellite-based navigation, and data link would be unaffordable for general aviation. This situation would result in either incomplete NAS Architecture implementation or exclusion of large portions of the general aviation fleet from the NAS system. Neither situation is desirable or acceptable. However, by applying many of the multi-tiered certification principles outlined in draft AC 23.1309-1C to the certification of new NAS-related systems and equipment, we believe that some of the technologies can become affordable for general aviation in the future, assuring access and improving safety.
AOPA strongly supports the policy and procedures outlined in draft AC 23.1309-1C and we urge the FAA to finalize the advisory circular and begin implementation of its stated procedures as soon as possible. We thank you for your time and consideration in this matter and look forward to working with your office on certification projects in the future.
Douglas C. Macnair