Bill to Simplify Certification Passes Congress

[X3 Skier]

BTW, regarding the question on getting training in newly-built E-AB's during the fly-off period, guess what -- the FAA is already working on that with EAA (among others). No details available yet, but the goal is an announcement at AirVenture.

I assume this is different from the already existing LODA for transition training in type like that offered by Sonex and others.

If its so dangerous because as stated earlier because no two are exactly alike, why would the FAA sanction putting two at risk rather than one? Seems that for at least kit built aircraft, transition training in type would be a sounder approach.

Cheers

 

[poadeleted20]

I assume this is different from the already existing LODA for transition training in type like that offered by Sonex and others.

Yes, it is. In those LoA cases, the training provider is providing the aircraft as well as the training. The change I'd like to see is to allow an instructor to get in a newly-completed E-AB aircraft during the initial 40-hour flight period, which currently must be solo, in order to train the owner/builder in the actual plane the owner/builder will be flying later.

If its so dangerous because as stated earlier because no two are exactly alike, why would the FAA sanction putting two at risk rather than one?

Several reasons. First, the owner/builder doesn't know how the plane is supposed to fly, and cannot tell when something's not right about it. Better to have someone familiar with the intended characteristics be there for first flight (which I would suggest the instructor make solo rather than with or by the builder). Second, it's not that easy to get the owner/builder together with an approved aircraft and an approved instructor for in-type training -- much easier just to get the instructor to the builder and then fly the builder's own plane. Finally, the variations in build which are common even among kits may result in flight characteristics signficantly different from one provided by the factory, and the builder/pilot needs to explore those with someone who can tell what's different and how to deal with it.

 

[steingar]

Several reasons. First, the owner/builder doesn't know how the plane is supposed to fly, and cannot tell when something's not right about it. Better to have someone familiar with the intended characteristics be there for first flight (which I would suggest the instructor make solo rather than with or by the builder).

As is you can have a test pilot legally fly the airplane for you and tell you all about it.

Second, it's not that easy to get the owner/builder together with an approved aircraft and an approved instructor for in-type training

What's so hard about it? Instructor likely has the type of aircraft in question, and can be found through type clubs or manufacturers.

-- much easier just to get the instructor to the builder and then fly the builder's own plane. Finally, the variations in build which are common even among kits may result in flight characteristics signficantly different from one provided by the factory, and the builder/pilot needs to explore those with someone who can tell what's different and how to deal with it.

Easier too, but not necessarily game-changing. Not saying it's a bad idea, but I imagine the FAA needs a great deal of impetus to change fundamental rules (like only solo flight during the flight testing phase of an experimental airplane) and I don't see it here. Not that I wouldn't like to see it pass, but if an ignoramus like me can effectively play devil's advocate I suspect a desired rule change is dead in the water.

 

[txflyer]

Alright! I can't wait for my C-180 panel to look like this ....

 

[poadeleted20]

As is you can have a test pilot legally fly the airplane for you and tell you all about it.

That's not nearly the same as being there in the cockpit with someone who knows how it should fly compared to how it does fly. If what you said was true, we would need only ground school for transition training, and it is well-established that that is not true.

What's so hard about it? Instructor likely has the type of aircraft in question, and can be found through type clubs or manufacturers.

Time, distance, and cost.

Easier too, but not necessarily game-changing.

I don't agree. Getting training in your own truly unique airplane rather than one just similar to it is important, especially when there may be differences in engines, props, and actual construction/aerodynamics.

Not saying it's a bad idea, but I imagine the FAA needs a great deal of impetus to change fundamental rules (like only solo flight during the flight testing phase of an experimental airplane) and I don't see it here.

Well, AFS-800 is already working with EAA on making the changes, so they do seem to see it.

 

[Tom-D]

Well, AFS-800 is already working with EAA on making the changes, so they do seem to see it.

Don't get your hopes up, when was the last time we got what we asked for.? Or for that matter anything that didn't restrict GA in one form or another.

 

[Geico266]

Don't get your hopes up, when was the last time we got what we asked for.? Or for that matter anything that didn't restrict GA in one form or another.

Maybe you need different company. I've seen EAA win a ton of battles.

 

[Tom-D]

Maybe you need different company. I've seen EAA win a ton of battles.

Can you design and build an aircraft with out government interference ?

What do we really have in this new proposal?

We have congress giving the FAA authority to write more regulations.

No matter how anyone tries to spin it, that is all we have.

Do you really think for a minute they will write them selves out of any control over you?

 

[Geico266]

Can you design and build an aircraft with out government interference ?

What do we really have in this new proposal?

We have congress giving the FAA authority to write more regulations.

No matter how anyone tries to spin it, that is all we have.

Do you really think for a minute they will write them selves out of any control over you?

Tom, the bill chops regulation by allowing a new class of aircraft to rejuvenate the 40 year old GA fleet call "non certified". That is a good thing.

 

[Tom-D]

Tom, the bill chops regulation by allowing a new class of aircraft to rejuvenate the 40 year old GA fleet call "non certified". That is a good thing.

That's a matter of opinion. on what they consider " non certified"

After the FAA Lawyers are done you may not recognize the new aircraft.

 

[poadeleted20]

Don't get your hopes up, when was the last time we got what we asked for.?

A couple of months back -- in fact, they even put my name on the rule change. The new head of AFS-800 really does get it. Ask anyone who's met him (say, at AirVenture, to which he flew his own Tiger last year).

 

[txflyer]

So I Frankenstein my skywagon with the latest non-TSO'd avionics and stuff, I wonder if that will be appealing to buyers, or a turn off?

 

[Henning]

That's not nearly the same as being there in the cockpit with someone who knows how it should fly compared to how it does fly. If what you said was true, we would need only ground school for transition training, and it is well-established that that is not true.

Time, distance, and cost.

I don't agree. Getting training in your own truly unique airplane rather than one just similar to it is important, especially when there may be differences in engines, props, and actual construction/aerodynamics.

Well, AFS-800 is already working with EAA on making the changes, so they do seem to see it.

Time distance and cost will be the same whether the experienced in type CFI provides their plane or uses yours. If you have the test pilot experienced in type fly off the required solo hours, they can then check you out in your plane. I would even stand to argue that you could call the experienced test pilot 'required crew during the test flying phase to document data while you operate the aircraft.

 

[Tom-D]

A couple of months back -- in fact, they even put my name on the rule change. The new head of AFS-800 really does get it. Ask anyone who's met him (say, at AirVenture, to which he flew his own Tiger last year).

I knew that, and it was a pretty good ego boost for you, ( as it should be ) but It really didn't effect me and a whole lot of others very much, but it is a step forward.

We must remember the entire process does not depend upon one person, but it does have a lot of influence from the aircraft manufacturers such as Cessna, they have liability on the GA fleet and will fight this new regulation tooth and nail. simply because they don't want any duffus working on their newest models like the 172 R&S.

Plus we are now effecting the whole A&P work force, but it is really too early in the process to know what the end result will be.

I would really like to see an owner maintained category that must meet its design each 12 cal months, and the relaxed minor modification requirements.

 

[Henning]

I knew that,, It really didn't effect me and a whole lot of other very much, but it is a step forward.

We must remember the entire process does not depend upon one person, but it does have a lot on influence from the aircraft manufacturers such as Cessna, they have liability on the GA fleet and will fight this new regulation tooth and nail. simply because they don't want any duffus working on their newest models like the 172 R&S.

Plus we are now effecting the whole A&P work force, but it is really too early in the process to know what the end result will be.

I would really like to see an owner maintained category that must meet its design each 12 cal months, and the relaxed minor modification requirements.

As far as job protection for A&Ps goes, I don't see it making much difference. People who are mechanics already work on their own planes, most pilots though aren't mechanics and will still hire A&Ps to do their work. Where it will make the greatest difference is in the avionics available, and that is the driving force behind this, the ability to implement full NextGen, because it will be the only way to integrate UAVs fully and safely into the NAS.

 

[Tom-D]

As far as job protection for A&Ps goes, I don't see it making much difference. People who are mechanics already work on their own planes, most pilots though aren't mechanics and will still hire A&Ps to do their work. Where it will make the greatest difference is in the avionics available, and that is the driving force behind this, the ability to implement full NextGen, because it will be the only way to integrate UAVs fully and safely into the NAS.

my thoughts on A&Ps is simple, they are mostly working in the FBO's that repair aircraft that will not fit this category anyway.
The tailgaters, it will probably effect them some.

 

[Henning]

my thoughts on A&Ps is simple, they are mostly working in the FBO's that repair aircraft that will not fit this category anyway.
The tailgaters, it will probably effect them some.

For tailgaters it may have a positive benefit as people will make some changes to their plane that were not economically available to them previously.

 

[Tom-D]

For tailgaters it may have a positive benefit as people will make some changes to their plane that were not economically available to them previously.

Your key words there was " the owners (people) will"

We will wait until we see the final rule to see who can do what.

 

[Henning]

Your key words there was " the owners (people) will"

We will wait until we see the final rule to see who can do what.

As I said, most owners are not mechanics and would not do their own work if they are allowed, plus most of the tailgaters are reasonable in their prices. What I expect to see are some aftermarket EFI and electronic ignition systems that will allow us to use pump gas at well increased efficiencies. These systems can pay for themselves in less than 500 hrs in fuel savings even using 100LL, quicker using MoGas.

 

[PilotAlan]

For tailgaters it may have a positive benefit as people will make some changes to their plane that were not economically available to them previously.

That's exactly right I had this chat with my A&P.
He will get the install labor for an autopilot and EMS the first year. Then an EFIS, then all lights and strobes changed to LED, then whatever else I change later. None of the would happen with certified gear.

The folks that are comfortable doing their own work already are.

 

[dbflyer]

We must remember the entire process does not depend upon one person, but it does have a lot of influence from the aircraft manufacturers such as Cessna, they have liability on the GA fleet and will fight this new regulation tooth and nail.

Cessna (and other industry) representatives were part of the ARC. I think you're assuming a little too much.

 

[Tom-D]

Cessna (and other industry) representatives were part of the ARC. I think you're assuming a little too much.

This is the bill we have as of today,

https://www.govtrack.us/congress/bills/113/hr1848/text

It taxes the FAA with a method of streamlining the certification of new aircraft and a way to retrofit the older aircraft.

I'm saying let's wait and see what the FAA comes up with before trying out guess each other on what comes out of OKC.

I'm sure that every aircraft manufacturer will be trying to get their aircraft thru the certification process in any easier way they can.

As the certification process works now is in need of a change, simply because it treats Cub Crafters trying to certify a new super cub in the same way it treats Boeing trying to certify the new 777X.

 

[AcroGimp]

This is the bill we have as of today,

https://www.govtrack.us/congress/bills/113/hr1848/text

It taxes the FAA with a method of streamlining the certification of new aircraft and a way to retrofit the older aircraft.

I'm saying let's wait and see what the FAA comes up with before trying out guess each other on what comes out of OKC.

I'm sure that every aircraft manufacturer will be trying to get their aircraft thru the certification process in any easier way they can.

As the certification process works now is in need of a change, simply because it treats Cub Crafters trying to certify a new super cub in the same way it treats Boeing trying to certify the new 777X.

Part 23 is in no way similar to Part 25 from a certification burden and cost standpoint.

I agree that the current Part 23 rules are unecessarily burdensome, but Part 25 is a whole other kettle of fish.

'Gimp

 

[Bob Noel]

As the certification process works now is in need of a change, simply because it treats Cub Crafters trying to certify a new super cub in the same way it treats Boeing trying to certify the new 777X.

fyi - the part 23 aircraft can have a different (and much easier) certification basis than the new 777X. To be nit picking, an applicant can chose a more stringent set of requirements for the certification basis if they are foolish.

Compare 23.1309 vs 25.1309 (and the related ACs).

 

[poadeleted20]

Time distance and cost will be the same whether the experienced in type CFI provides their plane or uses yours.

Ummm...no, since it's a lot cheaper to transport just the CFI than the CFI and his plane.

If you have the test pilot experienced in type fly off the required solo hours,

40 hours? YGBSM.

I would even stand to argue that you could call the experienced test pilot 'required crew during the test flying phase to document data while you operate the aircraft.

If you make that argument before the FAA, you will lose the argument.

 

[Henning]

If you make that argument before the FAA, you will lose the argument.

Why? Plenty of precedent of flight tests being done with entire crews.

 

[Tom-D]

Part 23 is in no way similar to Part 25 from a certification burden and cost standpoint.

I agree that the current Part 23 rules are unecessarily burdensome, but Part 25 is a whole other kettle of fish.

'Gimp

You should tell that to the resident FAA inspector at CubCrafters.

It's been over 2 years trying to certify a new Cub. it was nearly 3 for the carbon cub. (factory built)

 

[Tom-D]

How would you find a high time pilot that is proficient in thunder mustang.

After investing nearly 10 years and close to half a mil. you are going to allow a schmo with 350 hours and a cfi to test it ?

yeah right - - A 1 seat aircraft, nothing comes close to the performance, so how would the schmo check you out?

 

[Henning]

How would you find a high time pilot that is proficient in thunder mustang.

After investing nearly 10 years and close to half a mil. you are going to allow a schmo with 350 hours and a cfi to test it ?

yeah right - - A 1 seat aircraft, nothing comes close to the performance, so how would the schmo check you out?

Have a couple thousand hour Ag pilot fly the first flight and generate real numbers and test the envelope for bad characteristics and brief you on how to best check yourself out in the plane. However, by the time someone is doing a Thunder Mustang project, they are likely quite experienced themselves and have enough T-6 time that they will be able to handle themselves and had enough money that they were flying and building concurrently. The big problem is the guys who build a plane "because they can't afford to buy one" and ended spending 5+ years not flying while building, do a BFR in a 172 then proceed to crash the plane they just built.

 

[RotorAndWing]

Why? Plenty of precedent of flight tests being done with entire crews.

When Boeing is in the flight testing stage on a new plane sometimes there are 20 plus people on the flight, the pilots (of course) plus the various technicians and data collection people also on the airplane.

 

[poadeleted20]

Why? Plenty of precedent of flight tests being done with entire crews.

In planes requiring only one crewmember? I don't think so...in the typical E-AB, the "entire crew" is just one pilot.

 

[Henning]

In planes requiring only one crewmember? I don't think so...in the typical E-AB, the "entire crew" is just one pilot.

Crew is determined by operational need which goes beyond the handling of the aircraft. Having crew whose duties are the monitoring of data and sundry functions is commonplace in test flights and various operations in Restricted category aircraft which also only allow required crew members.

 

[poadeleted20]

Crew is determined by operational need which goes beyond the handling of the aircraft. Having crew whose duties are the monitoring of data and sundry functions is commonplace in test flights and various operations in Restricted category aircraft which also only allow required crew members.

Sure -- in large airplanes with complex data recording systems, but that's not what we're talking about. Please cite any case in which the FAA approved a second crewmember in a one-pilot E-AB during the initial fly-off period. There is no provision for that in any FAA Order I can find.

 

[Tom-D]

Sure -- in large airplanes with complex data recording systems, but that's not what we're talking about. Please cite any case in which the FAA approved a second crewmember in a one-pilot E-AB during the initial fly-off period. There is no provision for that in any FAA Order I can find.

If that is even considered by the FAA as a requirement for safe operation, it will be stated in the letter of limitations for the test period.

I say IF..

 

[Henning]

Sure -- in large airplanes with complex data recording systems, but that's not what we're talking about. Please cite any case in which the FAA approved a second crewmember in a one-pilot E-AB during the initial fly-off period. There is no provision for that in any FAA Order I can find.

Who has ever asked for the allowance?

 

[poadeleted20]

Who has ever asked?

Thank you for admitting the irrelevance of your statement to the discussion at hand, to wit, allowing type-qualified CFI's to give training to new owner/builders of E-AB aircraft during the initial fly-off period rather than making the owner/builder fly solo during that period.

 

[RotorAndWing]

Was there an Act of Congress that told the Administrator to rewrite the flight and duty time provision, with attached new language and a provision mandating that the "Administrator shall issue a final rule on or before..."?

14 CFR Part 117

It was recommended by the NTSB to Congress to strengthen the 121 duty and flight time regulations.

 

[Geico266]

Sure -- in large airplanes with complex data recording systems, but that's not what we're talking about. Please cite any case in which the FAA approved a second crewmember in a one-pilot E-AB during the initial fly-off period. There is no provision for that in any FAA Order I can find.

This has been argued in the EAB world for decades and dismissed. Most, if not all EABs the "essential crew members" are 1 person. There certainly have been people fly with two, but they are clearly breaking the intent of the rules, IMHO.

Allowing CFIs to transition train in their EABs will go a long way in preventing first flight accidents. EAB transition training is really coming on strong now. It took years for CFIs to catch on.

 

[denverpilot]

When Boeing is in the flight testing stage on a new plane sometimes there are 20 plus people on the flight, the pilots (of course) plus the various technicians and data collection people also on the airplane.

One of my ham radio buddies was on the 747-8 flight test crew. I was jealous. As soon as it was over, Boeing said "move to Seattle or your Denver job is gone". He chose early retirement. Seems to be enjoying himself immensely.

 

[Jim Logajan]

UPDATE:

The FAA says they expect to issue a final rule by November 2017.[1]
Almost four years from now.
The congressional bill said the final rule should be issued by December 15, 2015 - about two years after passage.[2]

The dragging of heels is occurring despite the likelyhood of an increase in FAA funding for the next two years.[3]

Oh well, it was a nice idea while it lasted.

[1] http://www.faa.gov/news/fact_sheets/news_story.cfm?newsId=13672
[2] http://beta.congress.gov/bill/113th/house-bill/1848/text
[3] http://www.hmmh.com/blog/?p=1358