Better equipment for less: Reg rewrite targets cost, safety

November 29, 2012

If the cost of a panel-mounted GPS were close to that of a handheld, would you upgrade? If new equipment for certified aircraft cost a fraction more than the experimental version, instead of an order of magnitude, would pilots keep more safety-enhancing tools at their fingertips?

The goals of lowering costs and increasing safety are driving a government-industry effort to revise the certification rules for aircraft from simple piston-engine airplanes to highly complex twinjets. Streamlining certification under Part 23 of the federal aviation regulations could make it simpler and cheaper to bring new aircraft and products to market. Pilots could experience the benefits first in the form of more affordable equipment available by supplemental type certificate.

“It will enable pilots to have wonderful new toys at much less cost,” said Earl Lawrence, manager of the FAA Small Airplane Directorate, during a recent visit to AOPA headquarters in Frederick, Md. The “toys” are more precisely “nonrequired safety-enhancing equipment,” he explained: items like angle of attack indicators or GPS units, which can enhance a pilot’s situational awareness and make flights safer.

The widespread use of handheld GPS units in the cockpit, for instance, has contributed to a significant reduction in accidents involving controlled flight into terrain, he said. These units don’t meet the certification rules for Part 23, he added, but they’re helping pilots.

The current regulatory structure makes it more difficult—and costly—to bring a comparable certified device to the cockpit. The Part 23 Reorganization Aviation Rulemaking Committee is developing recommendations that would put more of those devices within reach for pilots and reduce the cost of bringing aircraft to market, paving the way for new and innovative designs to enter the GA marketplace. The goal: improve safety by a factor of two while reducing costs of bringing a new product to market by 50 percent.

“We want to make the process easier for them to bring stuff to market,” Lawrence said.

The working group’s recommendations would define airplanes by complexity and performance rather than weight and propulsion, making it easier for simpler GA aircraft to come to market. It also would give manufacturers an alternative to today’s prescriptive certification requirements: The FAA would set standards based on safety and accept industry consensus design standards as one means of compliance.

Today, crashworthiness standards for aircraft include detailed requirements for the seats installed in the aircraft. Prescriptive regulations such as this can’t keep pace with technological developments, explained AOPA Vice President of Regulatory Affairs Rob Hackman, who represents AOPA on the committee, and actually disincentivize manufacturers from implementing new technologies. Designers are constrained by the details of the regulations; they may forego a better, safer solution if it doesn’t fit the existing regulations.

In the certification system under consideration, the FAA could state the desired result instead of the nitty gritty. For instance, the FAA could specify the load factor occupants could sustain in order to make an emergency landing survivable, Lawrence said. A 40-knot airplane might be able to meet the requirement with only airbags, he added, whereas faster airplanes would have to incorporate other features such as a dynamically crash-tested seat. The manufacturer could prove compliance by demonstrating to industry consensus standards.

Light sport aircraft illustrate the cost benefit of using consensus standards in lieu of today’s cumbersome Part 23 requirements. The industry may not have delivered the $60,000 airplanes many pilots hoped for, but consider the price tag of the two-seat Cessna 162 Skycatcher compared to the Part 23-certificated Cessna 172 Skyhawk: The LSA’s $149,900 base price is less than half of that of the four-seat version.

The industry is looking to develop standards through ASTM, which developed the standards for light sport aircraft, although the FAA could accept standards from other bodies. Aviation authorities from around the world have worked together and are expected to accept the certification standards, so Part-23 certificated aircraft could enter the worldwide market easily.

Consensus standards such as those developed by ASTM require involvement from consumers as well as manufacturers. Type clubs and other industry organizations could provide valuable insight into what pilots need from aircraft certification; and AOPA urges those interested in participating in the process to join the ASTM F44 committee, which will create these new standards, so you can voice your opinion on what is needed.

The working group, which meets regularly, will deliver its recommendations to the FAA in the spring of 2013. The FAA will consider the recommendations as it develops a proposed rule for rewriting the certification rules of Part 23; Lawrence encouraged pilots to bring their suggestions to their representatives such as AOPA. “They bring all the ideas together,” he said.