bnt83
Final Approach
Ok how about a life vest? Do you fly over water in NY? Is it the blow up type? If so the CO2 can is also a pressurized container that falls under DOT regs.
FAA, Let us make our planes safer!
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hindsight2020
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hindsight2020
Not quite. I WISH the FAA gave me option #1. They've ALREADY said NO to installing a Dynon EFIS on a certified airplane. So, no, even the STC/337 route is not available to me in order to undercut Garmin and Aspen pricing and attain the same level of safety and redundancy as experimental aircraft have available.
Also, and more to the fundamental point, they keep saying NO to owner experimental. I mean, what's it to them if I wish to fly my Arrow to the standards of certification (or lack thereof) of an RV7? I'd be taking the hit on resale (hell for all I now that would actually RAISE the value of it!
) but otherwise it'd be no different than flying an RV-7 in IMC. They let RV-7s fly in IMC with non-TSOd primary attitude equipment, so the credibility of their "safety" position is shot right there. How is it safe to operate in IMC over people's houses with a $10 coffee maker in an experimental certificate, but all of a sudden it's blasphemy to do it on a standard certificate? Let's be serious, there isn't a credible distinction in that supposed safety argument. So what's the deal with stiff-arming owner experimental then?Trust me, if I could buy an experimental Grumman Tiger or Cessna 182 for the same money I can get a certified tiger/182/arrow, I would have done so already. All I see is 2 seater sardine cans at that price point. Otherwise it's housing priced RV-10s or the oddball BD-4 or CH-whatever some yahoo in Idaho mothballed years ago. There are no experimental Grumman Tigers. There could be, if owner-experimental was a possibility. Why isn't it? Safety? I don't think so, I think they shot down their own safety argument when they let experimentals fly IFR/IMC without certified avionic requirements....
bnt83
Final Approach
Not quite. I WISH the FAA gave me option #1. They've ALREADY said NO to installing a Dynon EFIS on a certified airplane. So, no, even the STC/337 route is not available to me in order to undercut Garmin and Aspen pricing and attain the same level of safety and redundancy as experimental aircraft have available.
Also, and more to the fundamental point, they keep saying NO to owner experimental. I mean, what's it to them if I wish to fly my Arrow to the standards of certification (or lack thereof) of an RV7? I'd be taking the hit on resale (hell for all I now that would actually RAISE the value of it!
Trust me, if I could buy an experimental Grumman Tiger or Cessna 182 for the same money I can get a certified tiger/182/arrow, I would have done so already. All I see is 2 seater sardine cans at that price point. Otherwise it's housing priced RV-10s or the oddball BD-4 or CH-whatever some yahoo in Idaho mothballed years ago. There are no experimental Grumman Tigers. There could be, if owner-experimental was a possibility. Why isn't it? Safety? I don't think so, I think they shot down their own safety argument when they let experimentals fly IFR/IMC without certified avionic requirements....
I didn't write the rules and I'm not sure how the IFR on unapproved avionics really makes sense. But EAB still must go through 24 month IFR part 91 testing requirements, yes? So it's still being watched to a degree.
I'm sure there is lobbying etc that goes on from GAMA (general aviation manufacturer's association) too.
Is a fire extinguisher required by the FAA to be installed by an A&P? Is it necessary for it to have an STC or 337? Actually, I think that fire extinguishers are an exception to the rules that make it nearly impossible for increasing the safety of an aircraft without onerous cost. There are a variety of acceptable ones and they can be removed or installed at will. Compliance with 23.851 is voluntary.
But, for those of you who want to make this a thread about me, we have a nice, new, modern and safe fire extinguisher which is tested periodically. My grandfather and several uncles have been fire officials. One of our most frequent passengers is a fireman and EMT who does a check of the fire extinguisher with every flight he is on. During the preflight passenger and crew briefing, he always says something like, "In the unlikely event of smoke or fire, you will fly the plane and I will put out the fire."
But, for those of you who want to make this a thread about me, we have a nice, new, modern and safe fire extinguisher which is tested periodically. My grandfather and several uncles have been fire officials. One of our most frequent passengers is a fireman and EMT who does a check of the fire extinguisher with every flight he is on. During the preflight passenger and crew briefing, he always says something like, "In the unlikely event of smoke or fire, you will fly the plane and I will put out the fire."
JHW
En-Route
setting aside the "equally safe" notion, please elaborate on your perception of restrictions of where an E/AB plane is allowed to fly.
bnt83
Final Approach
Fuel Gauge accuracy. AP, fuel gauge accuracy is simple when you understand the limits of the typical float system.
#1 Float buoyancy - It takes a certain amount of fuel to lift them and there aren’t dimples in the bottom of the tank like some cars have so there is a certain amount of fuel that is known as “ungaugable” or un-measurable by the indicating system. And it works the same for “Full” and “Empty”
#2 No rubbing – The mechanical stops on the transmitters in the tanks are there to prevent the floats from rubbing on the tops and bottoms of the fuel tanks causin an increase in the amount of fuel that is un-gaugable.
#3 When was the last time the gauges were even tested?
With all this known here’s hypothetical –
“Full” really means in a 25 gallon tank that there are over 23 gallons in there, because it may take the removal of three gallons before the gauge will move.
“Empty” really means there is less than 3 gallons left as it may take three gallons just to lift the float and register on the gauge.
#1 Float buoyancy - It takes a certain amount of fuel to lift them and there aren’t dimples in the bottom of the tank like some cars have so there is a certain amount of fuel that is known as “ungaugable” or un-measurable by the indicating system. And it works the same for “Full” and “Empty”
#2 No rubbing – The mechanical stops on the transmitters in the tanks are there to prevent the floats from rubbing on the tops and bottoms of the fuel tanks causin an increase in the amount of fuel that is un-gaugable.
#3 When was the last time the gauges were even tested?
With all this known here’s hypothetical –
“Full” really means in a 25 gallon tank that there are over 23 gallons in there, because it may take the removal of three gallons before the gauge will move.
“Empty” really means there is less than 3 gallons left as it may take three gallons just to lift the float and register on the gauge.
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bnt83
Final Approach
Depends on how it's installed. Most OEM's already have a mounting solution provided. Now if you want to mount it in a different place say on the hat rack directly behind your second row passenger's head that would clealy be a safety issue as that thing would likely injure someone in a crash.
If your plane was certificated to 23.851 it is no longer optional. If you fly under 135 or 121 it would also be mandetory to have a cabin fire bottle regaurdless of certification regs of the airplane treated just like burn certs for 135 and 121.
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VanDy
Cleared for Takeoff
AC 20-42D
Chapter 2. Gaining FAA Approval for Fire Extinguishers
I. How are Hand Fire Extinguishers Approved?
a. Federal ReguJations for Hand Fire Extinguishers. Hand fire extinguishers are required under 14 eFR §§ 23.85 1, 25.851 (a)(I), 29.851 (a)(I), 29.853(e) & (I), 91.513(c),
119.25, 121.309(c), and 135.155.
We approve hand fire extinguishers to be used on aircraft
under the provisions of 14 CFR § 21.305(d). Accordingly, this AC is provided as one means acceptable to us for the approval of hand fire extinguishers, other than water solution extinguishers approved under TSO·CI9.
Note: Although 14 CFR parts 91 and 125 don't require our
approval of hand fire extinguishers: we consider the infonnation in
this AC acceptable for use by Part 91 and 125 operators.
bnt83
Final Approach
91 doesn't cover the certification of aircraft, meaning if the aircraft met 23.851 at the time of certification, it's a major alteration to remove the fire extinguisher because the airplane no longer meets type design.
wsuffa
Touchdown! Greaser!
Question: If a experimental goes down that was purchased "used", does the original builder stay in the liability chain?
My fear of staying in the liability chain would pretty much mean that I'd part out or destroy any plane I built, rather than selling it for someone else to fly. At least with a certified plane, there is reduction of liability risk.
Do you know which countries?
The problem is how do you define "equally safe". It seems that the regulations were created to make planes more insurable, and to set a product safety requirement that the government can point to (in theory, this mitigates builder liability as long as the plane complies with government standards.... it's not much different than the building permit process used in real estate). Much of the auto regulation was driven by Ralph Nader & the left political wing in the US... you cannot import a vehicle yourself unless it meets the US auto standards (back when the Smart car was new, folks wanted to import it to the US but had to wait until they could prove it met US standards).
To this day, some states restrict the modifications you can make to a vehicle through annual inspection programs, and Federal law prohibits certain modifications to the emissions systems.
Oh, and don't think of E/AB as necessarily being the solution: there are folks in the NTSB and FAA that would LOVE to impose more regulations.
Perhaps a solution would be to allow certified planes to be moved into Experimental status, but I don't see that happening any time soon.
flyingcheesehead
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JHW
En-Route
According to the EAA there has never been a liability judgement against a builder by a later purchaser or their estate.
bnt83
Final Approach
denverpilot
Tied Down
If you count the bailout, all of them from domestic manufacturers except Ford.
We nationalized their debt, remember?
As a lawyer, I would have thought you would know better. It's not the lawyers; it's the judges that refuse to throw out bad cases, and let almost any crappy case go to a jury, and it's we, the people, that make up the juries that sometime award lottery-like verdicts. The lawyers are just making the best of the system. (Okay, in fairness to you, the judges are lawyers, too. So, I am picking nits, here.)
VanDy
Cleared for Takeoff
Precisely. Look at the top of page six in the AC you quoted. 'Not regulatory' how ever if an aircraft is certified under FAR23, after 23.851 was implemented, what bnt83 said above is 100% true
-VanDy
bnt83
Final Approach
I may get flamed for this one but, it is what it is.
Consider LED Navigation lights under part 23. Can you legally replace the whelen incandescent nav lights with a like Whelen LED part without any proof of certification? They both meet a similar TSOs yes but what do the TSOs say? The TSOs do not contain all data for approval in this case. If your airplane was certificated to 23, how do you know for sure the new LED lights meet the following without proof or measuring it yourself?
§23.1385
Position light system installation.
§23.1387
Position light system dihedral angles.
§23.1389
Position light distribution and intensities.
§23.1391
Minimum intensities in the horizontal plane of position lights.
§23.1393
Minimum intensities in any vertical plane of position lights.
§23.1395
Maximum intensities in overlapping beams of position lights.
§23.1397
Color specifications.
If you compare the TSO of the two parts you will find both have a minimum intensity requirement that as long as the individual light assemblies are over that minimum, they got a TSO. Now when installed, the ?brighter? LED system may violate §23.1395 Maximum intensities in overlapping beams of position lights.
But my mechanic said it was a minor! (Only if the Nav light system as installed meets all the requirements)
Consider LED Navigation lights under part 23. Can you legally replace the whelen incandescent nav lights with a like Whelen LED part without any proof of certification? They both meet a similar TSOs yes but what do the TSOs say? The TSOs do not contain all data for approval in this case. If your airplane was certificated to 23, how do you know for sure the new LED lights meet the following without proof or measuring it yourself?
§23.1385
Position light system installation.
§23.1387
Position light system dihedral angles.
§23.1389
Position light distribution and intensities.
§23.1391
Minimum intensities in the horizontal plane of position lights.
§23.1393
Minimum intensities in any vertical plane of position lights.
§23.1395
Maximum intensities in overlapping beams of position lights.
§23.1397
Color specifications.
If you compare the TSO of the two parts you will find both have a minimum intensity requirement that as long as the individual light assemblies are over that minimum, they got a TSO. Now when installed, the ?brighter? LED system may violate §23.1395 Maximum intensities in overlapping beams of position lights.
But my mechanic said it was a minor! (Only if the Nav light system as installed meets all the requirements)
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So, what we have here is an unneeded regulation concerning whether I can change, add, or remove the fire extinguisher in my spam can. Would you say that I can put in a new halon extinguisher in my mid-70s aircraft? If so, at what cost?
bnt83
Final Approach
"I" wants safer airplanes with more gadgets, but only if "I" don't have to pay for it and the FAA doesn't mandate any type of regulation pertaining to it.
VanDy
Cleared for Takeoff
No, what we have here (AC 20-42D) is GUIDANCE for installing a fire extinguisher in some aircraft that may have possibly been made in the 70's (Manufacturer date doesn't have a lot to do with what it was certified under) if you are talking 1 1978 Cessna 172N then you may use the AC as guidance.
But an aircraft that was built in 1970 with a FAR 23 certification basis may require a fire extinguisher and can not be removed with out paper work, im too tired to look it up right now, but that is the jist of it.
But an aircraft that was built in 1970 with a FAR 23 certification basis may require a fire extinguisher and can not be removed with out paper work, im too tired to look it up right now, but that is the jist of it.
In my opinion, many of the accidents that occur today that are "pilot error" are also "FAA error" because those pilot errors could be mitigated or eliminated if improved aircraft safety were cheaper and allowed.
bnt83
Final Approach
I would ask if anyone has the factory installation on a type specific club and ask for pictures, see if a service bulletin exists or look it up in the parts manual. It may be just a few adel clamps around a seat support that are bolted to whatever mount comes with fire extinguisher.
bnt83
Final Approach
a Nobel thought but even on aircraft with every gadget known to aviation (airliners) pilots still kill everyone.
reference the Colgan accident
or crash the recent SanFran.
I mean common! How many damn stall indication and avoidance systems do you need?
Stall warning (audible) stall warning visual FLASHING lights, Angle of Attack, Stick Shaker, and a STICK PUSHER? The EGPWS YELLING "DONT SINK" & "PULL UP" (stick pusher may not have been installed)
You cannot gadget a pilot INTO situational awareness.
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poadeleted21
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When you look at the functionality, liability and size of the target market for a GTN750... I doubt the certification process adds much to the overall cost.
There's no shortage of safety features for certified planes, just get your checkbook out and get a slot on a new biz jet and hire well trained and current pilots.
Ted
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Peggy, what you have shown through this thread is that people like you are the reason the regulations exist. They are there so that people who don't know better are prevented from doing things that they think are improvements but really aren't.
Not meant as an insult, just an observation.
Not meant as an insult, just an observation.
wabower
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Yep, and easy to prove by examining the perfect safety record of the Cirrus fleet with all that junk installed vs. the rest of the fleet that doesn't.
Ted
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It's my belief that the only reason people still go after the airframers is because they have enough money to be worth going after. I doubt if anyone would go after an experimental builder. It would be much easier to go after Lycoming, who probably built the engine.
This is exactly the point. The cert requirements aren't perfect, far from it. I hope they will improve, and there seems to be some glimmer to that hope. But, the accident reports seem to indicate that certified aircraft are safer than E-ABs. Ultimately, the reason comes down to certified aircraft having some level of protection between bad decisions and the people in the plane. With E-AB, you make a bad design decision and just go fly.
Which is a shame, because I do believe that it would do a lot for aviation.
If this was possible, I can say with certainty that the 310 would have a different set of engines on it right now. Probably also different avionics, etc.
hindsight2020
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hindsight2020
What exactly is the hangup regarding owner-experimental? Wouldn't moving all these personally owned/operated certified cans into owner experimental further remove the liability away from the current manufacturers? Isn't this a step in the right direction to incentivize investment in GA? Furthermore, such a move would make safety via equipment more accessible due to a substantial cost reduction. I guess I don't see who is against it from a corporate/institutional perspective.
Ted
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iFlyNothing
I think it's more an FAA issue. The whole thing behind E-AB is that it was built by some guy in his garage, at least so goes the theory. Some of the E-AB "owner assist" setups are pretty much getting a plane from the factory these days, but they figure out how to get that 51% just barely. Then there's the aspect of someone wanting to get the plane back to Normal cert, if it were ever desired.
I don't see the hangup, personally, but the right heads need to get locked in a room and not let out until they solve the problem.
hindsight2020
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hindsight2020
Is this something AOPA/EAA advocacy could positively effect? Or are these institutions as worthless as they are described on this board? I figured writing my senator would do little in the way of spearheading momentum towards getting my piper arrow Ok'd for Owner-EXP....
Ted
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iFlyNothing
If anyone could do it, it'd be EAA. Which reminds me, gotta go renew my membership.
bnt83
Final Approach
I would NOT rule out the possibility of some sort of vintage Type Certificated transferred to Experimental ?_______? in the future, but my guess is that any type of flying for hire in them would still be prohibited.
wsuffa
Touchdown! Greaser!
Follow the money....
And remember that a bureaucracy, at some point, exists to protect and expand the bureaucracy. The term "public interest" does not mean making it easier for owners, it means preserving authority and maintaining control of the sanctity of aircraft approval.
flyingcheesehead
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Huh? Aren't you ranting against the regulations here? It's the regulations, not "the FAA", that cause it to be somewhat difficult and expensive to make modifications to certified aircraft. Yes, the FAA writes the regulations, but you seem to be saying that the regulations are "reinforcing safety" and hurting it at the same time.
I could agree that both are happening, depending on the reg - I'd say part 91 tends to help safety while part 23 and to some extent part 43 hurt it, but you're talking in circles if you leave those details out.
wabower
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Wayne
Not invented here.
N2124v
Line Up and Wait
What I don't understand us why can't I take my plane, that I own, that is flown privately, and make modifications to it as I see fit. It's my butt on the line if something goes wrong. The liability issue can be handled by requiring placarding and logbook entries that this aircraft is not be operated in accordance with the certification standards but under the experimental/amateur built rules. Once that step is done, there is no going back. Seems pretty straight forward and clean to me.
nddons
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I haven't read all the posts, but this is a good, thought-provoking thread, AP. 
wabower
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flyingcheesehead
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What weight of paper was it printed on in 1995 vs. 2010? What typeface, size, margins, spacing? Were ligatures used?
Even if all those were the same, if they re-worded things to make them easier to understand, the book would be thicker. The book's thickness is absolutely meaningless.