AOPA urges FAA to enact Part 23 changes quickly

In joint comments to the FAA, AOPA and other general aviation organizations urged the agency to “implement the changes being proposed in as short a time frame as possible,” adding that “this must be an absolute priority for the FAA.”

The GA groups praised the FAA for its efforts to understand and address the GA industry's concerns throughout the nine-year process leading up to the current Part 23 rulemaking proposal. And they emphasized the significance of the move toward a more risk-based approach to certification along with the adoption of industry-consensus standards.

The 27 pages of comments, which were signed by AOPA, the General Aviation Manufacturers Association (GAMA), the Aircraft Electronics Association (AEA), and the Experimental Aircraft Association (EAA), address detailed technical issues with the notice of proposed rulemaking.

In a separate letter to NTSB Chairman Christopher Hart, AOPA and other GA groups responded to comments filed by the NTSB on the Part 23 notice of proposed rulemaking.

While the letter noted that the GA industry shares the NTSB’s goal of improving GA safety, it addressed some of the assertions made by the NTSB in its comments.

The letter specifically emphasized the economic and safety benefits to come from the proposed use of industry-consensus standards, something the GA industry has long sought. The letter also noted that the NTSB’s discussion of the potential risks was based on problems with an aircraft model that did not conform to industry-consensus standards.

AOPA also reminded the NTSB of Part 23 reform’s alignment with the FAA’s risk-based approach to aircraft certification, a philosophy that one level of safety may not be appropriate for all aircraft certification levels. The letter noted that the NTSB’s concerns over the new certification process appear to have been based upon incidents involving transport category airplanes certified under Part 25, not Part 23.

“We strongly believe that proposed Part 23—including the use of performance-based regulations and industry-consensus standards—accomplishes this goal and will lay the foundation for the next generation of innovative and safe products for the GA community,” the groups wrote.

In addition to AOPA, the letter was signed by AEA and EAA.

More information about proposed changes to Part 23 and what they will mean for GA is available in “Understanding Part 23 Rewrite.”