The Aircraft Owners and Pilots Association has petitioned the FAA to reverse its final rule on "Type Certification Procedures for Changed Products." According to AOPA, the new regulations could add up to $15,000 to the cost of something as simple as installing a new GPS receiver.
"This new rule would hamper safety improvements to the general aviation fleet, stifle innovation, and cripple the small businesses that are GA's lifeblood," said Dennis Roberts, AOPA vice president and executive director of government and technical affairs. "The small companies that develop safety- and efficiency-enhancing supplemental type certificates (STCs) could be regulated right out of the market."
The new rule (which changes parts 21 and 25 of the federal aviation regulations) requires that changes to an existing product undergo re-certification to meet the most current airworthiness regulations. If the change is to a component, then all "associated systems" would have to be brought up to current standards. (AOPA opposed the changes when they were first proposed in 1997.)
"If you wanted to put new avionics in your aircraft, everything from the mounting rails to the alternator and electrical wiring to cables and antennas might have to be re-certified to the latest standards under an STC," said Roberts. "It could cost an additional $10,000 to $15,000 just to put the latest GPS in your airplane."
That could have an impact on safety.
For example, the FAA's "Safer Skies" initiative anticipates that general aviation will take advantage of new technology avionics to provide better situational awareness, in-cockpit weather information, and terrain and traffic advisories. But the new type certificate regulation could increase the costs of installing that equipment by at least 30 percent, making it much less likely that the improved equipment will be installed.
The change products rule could make the development of safety-enhancing improvements prohibitively expensive. For example, an aftermarket supplier seeking an STC for an improved aircraft seat would have to comply with the latest 26-G crashworthy standards if the FAA considered the change "significant."
But what's a "significant" or "major" change under the new regulation? That hasn't been defined yet. The FAA hasn't written the required advisory circular to explain how to apply the new rule to changes in general aviation products.
"At the very least, the FAA should reopen the comment period until the public has had a chance to review the associated advisory circulars," said Roberts.
"There are many changes to GA aircraft that substantially enhance safety but do not meet the latest certification standards," Roberts continued. "And the FAA has shown no data that this regulation would actually improve safety.
"To the contrary, the regulation would stifle incremental safety improvements to the existing GA fleet. AOPA requests that the FAA not adopt the "Type Certification Procedures for Changed Products" final rule."
A copy of AOPA's petition to the FAA is available online.
The 360,000-member Aircraft Owners and Pilots Association is the world's largest civil aviation organization. More than one half of the nation's pilots, and three quarters of the general aviation aircraft owners, are AOPA members.
August 18, 2000