Part 23 Certification changes - NPRM released

I have been waiting for this to add an autopilot........ Let us hope the implementation quickly leads to some avionics upgrade possibilities for the certified GA fleet.
 
I haven't read the NPRM but the summary says absolutely nothing about avionics. Only airframes.
 
These jackals better include primary non-commercial category into the rulemaking. From the read, it looks like they're only making changes to new manufacturing certification standards. If they don't overhaul the real problem, the anachronistic "type certificate data sheet" system and the adjoining STC/PMA/TSO/AD compliance kabuki nightmare, this thing is a non-starter.

Ah who am I kidding. I'll be drawing social security before they ever let my arrow operate as exAB.
 
All you have to do is get Piper to go through the entire certification process for the Arrow again under the new rules.
 
hindsight2020 said:
These jackals better include primary non-commercial category into the rulemaking. From the read, it looks like they're only making changes to new manufacturing certification standards. If they don't overhaul the real problem, the anachronistic "type certificate data sheet" system and the adjoining STC/PMA/TSO/AD compliance kabuki nightmare, this thing is a non-starter.

Ah who am I kidding. I'll be drawing social security before they ever let my arrow operate as exAB.
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Wow. "Jackals"? "Anachronistic 'type certificate data sheet' system and the adjoining
STC/PMA/TSO/AD compliance kabuki nightmare"? You want to "let my arrow operate as exAB"?
Would you care to enlighten a "non-conspiracy theorist" what in the hell you're talking about? o_O

dtuuri
 
He wants certification rule changes to be retroactive, so airplanes will become disposable and most legacy aircraft will be deemed unairworthy?
 
From what I see, the changes would not change your type certification (nor your certification category) retroactively, but would make it easier to get amended TCs and STCs by applying performance- and risk-based standards and by reducing the scrutiny on non-required systems. This would affect avionics and other systems but it's unclear by how much given that avionics often now include a mix of required and non-required functionality.

Page 19 & 20 said:
C. Benefits for the Existing Fleet
The proposed revisions would benefit owners and modifiers of existing part 23 airplanes,
as well as airplane designers and manufacturers. Both currently and under this proposal,
airplanes may be modified by: (1) an alteration to an individual airplane; (2) a supplemental type
certificate (STC) for multiple airplanes, or (3) an amendment to an original type design via an
amended type certificate (TC). This proposal would streamline each of these methods for
modifying airplanes.

The proposed change to § 21.9 would facilitate FAA approval of low-risk equipment
produced for installation in type-certificated airplanes, thereby streamlining the process for
owners to upgrade equipment on their individual airplanes. An example of how this change
would facilitate safety improvements is the installation of inexpensive weather display systems
in the cockpits of small airplanes. These systems allow a pilot to view current weather conditions
along the planned flight route and at the destination airport, avoiding unexpected or deteriorating
weather conditions. Since these systems are not required and because they represent low safety
risk from failure, the FAA believes streamlining its approval process to produce them for use in
existing airplanes could lower costs and increase availability of these systems.
The proposed changes in the rules would also streamline the process for design approval
holders applying for a type design change, or for a third party modifier applying for an STC, to
incorporate new and improved equipment in a model or several models of airplanes. Since the
revised part 23 standards would be much less prescriptive, the certification process for
modifications would be simplified. Certification of an amended TC or STC under the proposed
part 23 standards would require fewer special conditions or exemptions, lowering costs and
causing fewer project delays.
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That's encouraging, although I haven't gotten to the details yet. Thither resideth the devil.
 
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I'm surprised to see the amount of certified part 23 apologists on this thread. I was under the impression you all wanted repreive from the crushing cost structure that keeps younger entrants to this dying avication. Ive certainly overestimated the popularity of my position then. You'll can have certified aviation....
 
hindsight2020 said:
I'm surprised to see the amount of certified part 23 apologists on this thread. I was under the impression you all wanted repreive from the crushing cost structure that keeps younger entrants to this dying avication. Ive certainly overestimated the popularity of my position then. You'll can have certified aviation....
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I'm not seeing any posts fitting the description of "Part 23 apologists" here...if you want relief from the requirements for existing airframes, why are you expecting it from a regulation that "prescribes airworthiness standards for the issue of type certificates, and changes to those certificates, for airplanes in the normal, utility, acrobatic, and commuter categories"?

That's all manufacturer/modifier stuff, and you seem to be looking for maintenance stuff...kinda like going grocery shopping at the car dealership.
 
hindsight2020 said:
I'm surprised to see the amount of certified part 23 apologists on this thread. I was under the impression you all wanted repreive from the crushing cost structure that keeps younger entrants to this dying avication. Ive certainly overestimated the popularity of my position then. You'll can have certified aviation....
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You're living in fantasy land. I'd love to be able to do anything I want to my airplane. But where is there any realistic proposal on the horizon to allow that?

It's like libertarianism. Yeah I might agree with a lot of it in theory but it ain't gonna happen.
 
I understand this doesn't deal with exAB rules expansion. I was simply remarking I find it predictable they won't make primary non commercial a priority, opting to focus instead on new aircraft manufacturing minutiae in a low volume sales environment. IE this won't dent the affordability question for the rank and file. But to appease the happy well to do on here, I'll digress on the primary non commercial clamor and make a separate thread on the topic to avoid the thread drift accusation.
 
hindsight2020 said:
I understand this doesn't deal with exAB rules expansion. I was simply remarking I find it predictable they won't make primary non commercial a priority, opting to focus instead on new aircraft manufacturing minutiae in a low volume sales environment. IE this won't dent the affordability question for the rank and file. But to appease the happy well to do on here, I'll digress on the primary non commercial clamor and make a separate thread on the topic to avoid the thread drift accusation.
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I mean one man's dent is another man's divot. But it does deal tangentially with this question in that it purports to make it easier to get modifications approved.
 
The theory was you would be able to change different parts like props and certain modifications to become exab,and when you wanted to sell if you installed original equipment ,you would be a part 23 certified aircraft again
 
frfly172 said:
The theory was you would be able to change different parts like props and certain modifications to become exab,and when you wanted to sell if you installed original equipment ,you would be a part 23 certified aircraft again
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Where did that theory come from?
 
MauleSkinner said:
Where did that theory come from?
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FAA ARC proposal that delineated the concept and application of the "primary non-commercial category" portion. Final report dated 5 June 2013. It's on the web, google Part 23 ARC. 8ish MB PDF file.
 
petrolero said:
You're living in fantasy land. I'd love to be able to do anything I want to my airplane. But where is there any realistic proposal on the horizon to allow that?

It's like libertarianism. Yeah I might agree with a lot of it in theory but it ain't gonna happen.
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As long as everyone believes that, you're right -- it will never happen.

Signed,

A Libertarian EAB Aircraft Owner
 
I've read the notem a couple times, I see it as a try to lighten up on new certifications, I see very little to indicate retrofit will change much. I really hope it does, but I'll wait to see.
 
Tom-D said:
I've read the notem a couple times, I see it as a try to lighten up on new certifications, I see very little to indicate retrofit will change much. I really hope it does, but I'll wait to see.
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In the video they posted, one lady was quoted as saying that this is only for new construction initially and then they'd go back and address the legacy fleet. The video didn't give me much hope.
 
hindsight2020 said:
FAA ARC proposal that delineated the concept and application of the "primary non-commercial category" portion. Final report dated 5 June 2013. It's on the web, google Part 23 ARC. 8ish MB PDF file.
Click to expand...
Care to post a link? That Google search didn't work for me.
 
mkosmo said:
In the video they posted, one lady was quoted as saying that this is only for new construction initially and then they'd go back and address the legacy fleet. The video didn't give me much hope.
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I don't put much trust in ladies giving their opinions on federal policy. video or not.
 
Personally what I would like to see happen with this is, to make retro fitting many of the appliances we have seen use in E/HB aircraft for years become easy to install on a 337 with only data required would be the manufacturer's installation instructions. that way the FAA could track changes in the aircraft History records, and the IAs could insure quality of installations and the fit form and function was proper.
IOWs make the manufacturer's instructions the STC.
 
mkosmo said:
I went back and looked... It was Peggy Gilligan. She's an FAA Associate Administrator for Aviation Safety. Her opinion carries a touch of weight.

http://www.faa.gov/tv/?mediaId=1258
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This may be true, but thru the years I've seen the administrators not get there way. Lots of pressure from all directions yet to be seen.
 
Okay fellows, I'm all over this one. I've been following and went as far as talking to one of the guys at the FAA rulemaking division and here's what you absolutely HAVE to do. Go to this link https://www.regulations.gov/?utm_campaign=March14Newsletter&utm_medium=email&utm_source=newsletter&utm_content=IRS Comments&&vsmaid=715&vcid=4944#!docketDetail;D=FAA-2015-1621 After you get there, click on the COMMENT button next to the NPRM. The only way we get traction is to make comments that are required to be addressed by the FAA. I have a whole file on this mess that I've been collecting. If you go back and compare the ARC recommendations for Part 23, which in essence said that Part 21 also had to be addressed and recommended the PNC category (in no uncertain terms) with what came out in the NPRM....it's just not there. Go and raise a big stink. After you do that, google HR. 4441 and scroll to section 315. Here you will find that Congress has noticed the poor performance and lack of cooperation by the FAA and has written the EFIS requirements for our birds into law. The law has not passed yet. Next, read this article https://www.openflightsolutions.com/faa-reauthorization-what-it-means-for-ga/ If your representative is on the Aviation Subcommittee, please submit the recommendation from the article regarding putting teeth into section 315. I have already done so via my rep. The bad news at this point is that 4441 has been shelved for the short term due to infighting over privatization of ATC and the Senate is already making their own bill. That's okay, we still have to get ahead of the game and make sure section 315 remains and is expanded to align it with the PNC category.
 
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As an addendum, the Senate Commerce Committee will be the ones wading in with their own bill. http://www.commerce.senate.gov/public/index.cfm/committeemembers
If you have a Senator on that committee, then get to writing. Post this information on Facebook and Twitter. Talk about it at your aviation meeting and around the hangar. Talk about it to all your GA friends and group members. Lots to do, no time for griping. Both houses were 100% on passing the Small Airplane Revitalization Act of 2013 which codified the incorporation of the ARC recommendations into Part 23 and the ARC recommendations included the Part 21 harmonization and PNC. Point that out to your reps. This should be a no-brainer which is perfect for Congress.
 
Okay, found one more. The Senate Bill, SB 2658 has passed the commerce committee and now goes to the full senate so just contact your state senator. The pertinent section for GA efis relief is section 2225, but still has no teeth. It's not specific enough. You can track both bills at www.federalbriefing.com/legislation/faa_reauthorization.aspx This needs to be attacked from every side!

Sent from my SM-T700 using Tapatalk
 
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