Opening the door to new airplane certification and revitalized general aviation
Certification of light airplanes has, since the bygone days of CAR 3 (under which many of the most popular airplanes have been certified), become ever more complex, time-consuming, and expensive. Compared to earlier rules, certifying a new airplane under Federal Aviation Regulation Part 23 is a bit like getting a miniature 747 approved; the process can be way out of proportion to the complexity and mission profile of a light airplane. As a result, proving that a new design meets all current requirements demands a huge, potentially unrecoverable, investment from a manufacturer. It is a major disincentive to entering the market.
Such onerous certification rules (and the stringent testing and documentation process, to boot) are, fortunately, changing. Recently, the FAA agreed to accept certification standards based upon the European Joint Airworthiness Regulations-Very Light Aircraft (JAR-VLA) category, which, as the name suggests, applies to small, light airplanes that fall between ultralights and four-seat singles. The changing global economy and the desire for European makers to get all members of the European Community to agree on certification standards prompted the JARs. Major industry groups have been promoting just such a new standard, including International AOPA offices, the Sport Aircraft Manufacturers Association, and the Experimental Aircraft Association. All these groups have helped convince the FAA that such a global standard would be in everyone's best interests.
Don't reach for the aspirin if you feel a touch of deja vu or the brush of confusion. Among the many proposals for reducing the cost of designing, producing, and maintaining new aircraft, the VLA is but one part.
First there was the Primary category, proposed originally in the early-1980s, that would help reduce certification costs through simpler compliance with FAR Part 23, and that would help cut operating expenses by allowing the owner to perform more unsupervised maintenance than is currently allowed. The proposal has been through several public comment periods, and is expected to be released in final form very soon. Among the working limits of the Primary category are that the aircraft have no more than four seats, about 200 hp, and a maximum gross weight of around 2,500 lb. At press time, industry observers said that any of these parameters could change, though probably not significantly, but there will be some fine-tuning.
On a similar front, there is the Small Airplane Certification Compliance Program, spearheaded by the EAA and SAMA. This proposal does not address current production or existing airplanes, as does the Primary category, but in other ways is quite similar. In essence, EAA and SAMA were seeking from the FAA an assurance that new airplanes could be designed (or existing homebuilts could be put into production) without having to work through the tedious certification compliance paperwork and testing. Both groups voiced support for the Primary category, as well.
According to several kit manufacturers, getting an airplane to conform to Part 23 standards is not an issue, but proving compliance is. This is where all these proposals — VLA, Primary, and SACCP — come together to try to cut though the tide of red tape and (some would say) needless compliance testing.
Regarding VLA, those in the industry and here at AOPA also believe the operational limitations of the VLA will be fine-tuned as well. Currently, the VLA calls for a maximum of two seats, 1,654 pounds gross weight, and a 45-knot stall speed. What's more, the rule limits airplanes in this category to day/VFR operation. The FAA has agreed that, with some experience approving airplanes under the JAR-VLA, such restrictions could be removed, which would vastly improve the utility of the segment and only bolster the airplanes' chances for success.
But to get from here — a time when the FAA and industry have agreed to agree — to a point where new light airplanes are rolling off assembly lines will still take some effort. Much of the thrust of the EAA and SAMA has been to convert current kit-built airplanes into production-ready VLA models. And while this method has some strong advantages, like proven airframes, known systems, and a manufacturer infrastructure already in place, there are still some major hurdles.
For example, while the VLA rules make compliance with some certification requirements simpler, that doesn't mean that if it's got wings and wheels a production certificate will immediately follow. Among the advantages of VLA (and Primary and SACCP, for that matter) over Part 23 certification requirements: no fatigue testing for some components, the potential for less stringent requirements for composite structures, and no fuel-system lightning protection test requirement. Moreover, such items as spin testing will be simplified so that if the airplane passes a basic matrix of spins, no further testing will be required. The point is this: Testing and proof of compliance will still take place but with some simplification.
One other hurdle is engine certification. For the kit maker currently using production engines, this is really not an issue; although it's likely that the FAA will want to see plenty of testing on an "unapproved" engine/prop combination. (For the homebuilders, the standard flight-test duration is 25 hours with an approved engine/prop combo but 40 hours if either is an unknown to the FAA.)
Denney Aerocraft Company, maker of the Kitfox kits, is contemplating entering production but cannot make any decisions until the FAA has approved the Kitfox's Rotax 912 engine; dropping a production engine in the diminutive Kitfox would be a bit like strapping a dragster motor onto your Honda Accord — it might run but not well. Much testing is yet to be done. The 912 current is approved under JAR in a number of motorgliders.
Otherwise, Denney, among several other companies that produce kits that potentially fall into the VLA category, is considering giving a green light to the project.
There is, naturally, more to putting a kit airplane into production than handing all the pieces to the assembly-line workers and saying, "Make it so." Kit airplanes are designed to be put together by one person, using a minimum number of specialized tools. In the hands of the mass manufacturer, such a design would be unnecessarily time-consuming to crank out. As such, expect several under-the-skin changes to these popular models, changes that will take some time for the companies to engineer and test.
Also, some of the sportier kit-builts will likely have to undergo modifications to make control responses and flight characteristics more like standard production aircraft. While sport pilots might wax poetic over feather-light controls, heart-pounding roll rates, and high G forces, you can bet the FAA will want to see that any certified airplane — VLA, Primary, or the usual categories — behaves conventionally.
Finally, there's the issue of money. Simplified testing and certification procedures notwithstanding, you still have to bend some metal (or cure fiberglass or stretch fabric), and here the basic economies of production don't care one whit about how the airplane's certified. Dick VanGrunsven, designer of the long-popular RV series, estimates that a basic RV-6A (the side-by-side, tricycle-gear model in the RV lineup) would cost between $60,000 and $70,000 completed. Denney wouldn't speculate as to the cost of a finished Kitfox, but it's hard to imagine that, with materials, labor, and basic avionics, the airplane could come in much under $40,000. The basic kit runs $25,000 alone with many of the popular options, and this is before radios or paint are added to the price tag.
True, the journey for VLA-certified airplanes is just beginning, as is the route to be taken by the Primary- and SACCP-style airplanes, but one must not ignore the fact that this is a ground-breaking bit of rulemaking. That the FAA has acknowledged the need to do business differently is a most positive sign. In a way, the ball is now in the manufacturers' courts; they must do the marketing, do the planning, and find the investors to help usher the only currently successful market niche — the homebuilts — from specialty to general interest. With that move comes the potential to turn the industry around, to fill the need for new production airplanes, and, indeed, to offer some much- needed good news to general aviation enthusiasts.
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