What in The actual ****, Hartzell?

Exactly. And aircraft OEMS and vendors prove that on a regular basis. Where there is a viable market, OEMs design and build new aircraft and engines, vendors design and build new aviation equipment, and the FAA certifies those products and articles. Plenty of recent examples on how this has worked for years.

Perhaps post some specific regulatory barriers that are preventing whatever issues you find are lacking?

Ok, let's say you have an idea. You spend the considerable sums to obtain the required technical data and testing and prototypes to satisfy the FAA's technical requirements, and after what can be an extended and expensive process you have an STC, which you own forever, barring competitors from using your data, but you're not done yet. To sell your new product, you need a PMA. The cost to maintain said PMA ain't cheap. It requires annual audits, calibrations, etc. also, depending on the product, there are parts obsolescence issues and supplier management to deal with…..and there Is the never ending insurance and product liability risks.

When volumes are low, it may not pay to sell any products. That's a barrier to entry.

The FAA recognized this and tried to address it with NORSEE,but it doesn't go far enough, IMHO.
 
Because what happens is that you have a company that's selling that product for $500 which, while it sucks, isn't a deal killer. Then, PE comes in and buys the company and says "Hey, we have a captive audience, so F those guys! Let's add another zero!" And then the product is $5000 and the person sells the airplane, probably at a big loss, and quits flying, making the market ever smaller.
Well, that doesnt actually make the market smaller. If the guy sells the airplane, then someone else buys it and pays through the nose -- or figures out a way around the patently absurd, abusive, and indefensible price they charge for the parts.
 
Since you’ve brought different topics in a single post, I’ll address each separately and see where it goes. Otherwise, we can easily slide down a rabbit hole trying to address them all together.

Ok, let's say you have an idea. You spend the considerable sums to obtain the required technical data and testing and prototypes to satisfy the FAA's technical requirements,
“Considerable sums” is very subjective and highly dependent on the part complexity, part use, in-house capabilities, etc. For example, if you plan to PMA a single run of 100 simple parts vs multiple runs of 100 complex parts, your costs will be greatly different. However, once you have obtained a PMA, any future part development will have a reduced cost.

and after what can be an extended and expensive process you have an STC,
Again, very subjective on several levels. There is no one size fits all here. For example, given there are different types of STCs, you can have some STCs that are merely a paperwork exercise vs STCs with a long physical certification process.

But the first question most STC or even PMA applicants ask themselves is if they even need an FAA design approval and/or production approval which is what an STC and PMA actually are.

Some vendors develop aircraft parts without either and let the buyer/installer determine how to install them on their TC’d aircraft. And to ensure they don’t violate Parts 21.9 or 3.5, those vendors will designate them as “experimental” parts or use a product code like Wag Aero does.

which you own forever, barring competitors from using your data,
Your approved data, yes. Unfortunately, STCs do not prevent someone from copying your idea and getting their own approved data. Nor would a PMA stop me from looking at your PMA product, find a similar OTS part and install it on an aircraft as an alteration.

To sell your new product, you need a PMA. The cost to maintain said PMA ain't cheap.
Not necessarily. As mentioned above it depends on what your part is, what your market is, etc. Some vendors have been successful providing parts without a STC, PMA, or TSO. But even if one were to obtain one of those approvals, the upkeep of that approval is again subjective to the part, etc.

and there Is the never ending insurance and product liability risks.
Which has zero to do with the FAA.

When volumes are low, it may not pay to sell any products. That's a barrier to entry.
Except that is a market barrier. All the aviation vendors I’ve been involved with over the years determined market volumes, market volatilely, ROI, etc. well before they started any part production or FAA part approval processes. That is business 101.

For example, the reason you see very limited new part options for Part 91 recreational aircraft is simply because that market is stagnant and to some is in a state of decline. Where is the financial incentive if there’s no growth potential? And so on.

The FAA recognized this and tried to address it with NORSEE,but it doesn't go far enough, IMHO.
They recognized this long before NORSEE and the other policy memos they released to streamline equipment installations. For example, AC 23-27 was issued in 2009 but there were others going back to the 90s. And the main reason most of these FAA efforts lose traction at the private Part 91 level is that these owners do not embrace these efforts in any meaningful numbers for a variety of reasons, ie., the market does not respond nor is it viable.
 
Since you’ve brought different topics in a single post, I’ll address each separately and see where it goes. Otherwise, we can easily slide down a rabbit hole trying to address them all together.


“Considerable sums” is very subjective and highly dependent on the part complexity, part use, in-house capabilities, etc. For example, if you plan to PMA a single run of 100 simple parts vs multiple runs of 100 complex parts, your costs will be greatly different. However, once you have obtained a PMA, any future part development will have a reduced cost.


Again, very subjective on several levels. There is no one size fits all here. For example, given there are different types of STCs, you can have some STCs that are merely a paperwork exercise vs STCs with a long physical certification process.

But the first question most STC or even PMA applicants ask themselves is if they even need an FAA design approval and/or production approval which is what an STC and PMA actually are.

Some vendors develop aircraft parts without either and let the buyer/installer determine how to install them on their TC’d aircraft. And to ensure they don’t violate Parts 21.9 or 3.5, those vendors will designate them as “experimental” parts or use a product code like Wag Aero does.


Your approved data, yes. Unfortunately, STCs do not prevent someone from copying your idea and getting their own approved data. Nor would a PMA stop me from looking at your PMA product, find a similar OTS part and install it on an aircraft as an alteration.


Not necessarily. As mentioned above it depends on what your part is, what your market is, etc. Some vendors have been successful providing parts without a STC, PMA, or TSO. But even if one were to obtain one of those approvals, the upkeep of that approval is again subjective to the part, etc.


Which has zero to do with the FAA.


Except that is a market barrier. All the aviation vendors I’ve been involved with over the years determined market volumes, market volatilely, ROI, etc. well before they started any part production or FAA part approval processes. That is business 101.

For example, the reason you see very limited new part options for Part 91 recreational aircraft is simply because that market is stagnant and to some is in a state of decline. Where is the financial incentive if there’s no growth potential? And so on.


They recognized this long before NORSEE and the other policy memos they released to streamline equipment installations. For example, AC 23-27 was issued in 2009 but there were others going back to the 90s. And the main reason most of these FAA efforts lose traction at the private Part 91 level is that these owners do not embrace these efforts in any meaningful numbers for a variety of reasons, ie., the market does not respond nor is it viable.

You've got me at a disadvantage here because I don't know how to clip and paste as well as you do, so let's narrow this to where I started, simple parts that are essentially unobtanium, like the aforementioned torque tube or transmission jackscrew. A Hoof fuel valve component that's little more than a disk with holes in it. Small run, simple but essential parts for which there are no OTS substitutes.

Everything you said above may be true when developing a new product, but it's also true that unless the manufacturer makes their data available, the current rules, less the exception for owner produced which isn't a course available to everyone, make it difficult if not impossible for those parts to be produced.
 
so let's narrow this to where I started, simple parts that are essentially unobtanium, like the aforementioned torque tube or transmission jackscrew.
Post the part number and specific aircraft model for the tube and jackscrew. And if you know the particulars of the replacement stab torque horn produced in Australia you mentioned in Post 40, post that info as well.

less the exception for owner produced which isn't a course available to everyone,
Except it is available to every single owner/operator. And at the Part 91 level its normally the most cost efficient unless you want to earn income by selling the parts. But if you’re up for it, we can go through the motions for an OPP on one of the parts you identify above or even on a different part?
 
Yeah I’m coming to the same conclusion. Had to do my 500 hour mag inspection/overhaul, and got quoted $2200 for the work. So looked at new Slick mags as an alternative and that would have cost nearly $4000. Pretty sure that price has more than doubled in the last six years.

Wow! Shocked! It absolutely has doubled! Looks like I'm going with PowerUp mags in 200 hours...
 
Well, that doesnt actually make the market smaller. If the guy sells the airplane, then someone else buys it and pays through the nose -- or figures out a way around the patently absurd, abusive, and indefensible price they charge for the parts.
You're assuming he's selling it to another pilot. An unairworthy airplane that requires a repair more costly than it's worth is, more often than not, going to the salvage yard and getting gutted for parts.
 
You're assuming he's selling it to another pilot. An unairworthy airplane that requires a repair more costly than it's worth is, more often than not, going to the salvage yard and getting gutted for parts.
Or is shoved to a ramp somewhere to rot, taking the aircraft AND any salvageable parts out of circulation.
 
Post the part number and specific aircraft model for the tube and jackscrew. And if you know the particulars of the replacement stab torque horn produced in Australia you mentioned in Post 40, post that info as well.


Except it is available to every single owner/operator. And at the Part 91 level its normally the most cost efficient unless you want to earn income by selling the parts. But if you’re up for it, we can go through the motions for an OPP on one of the parts you identify above or even on a different part?
The Aussie horn that terminates the FAA AD on affected Comanches is replacement Comanche Stabilator Horn P/No ADS 1002080828
The torque tube that is commonly required to be replaced when the horn is installed is p/n 20203-002, referenced in SB 1160A
The PA-24 anding gear transmission is one of two, the better being a Dukes P/N PN 25720-00 4587-00-1, I've not been able to find an exploded diagram with a specific p/n for the jackscrew.
AeroDesigns PA24-0100-01 Oleo Housings

If we're picking one, the torque tube seems to be the one causing to most heartburn in the Comanche community at this time, in the price, if you can find one, is rapacious. Followed closely by the Oleo housings, or trunions..

You're very generous with your time, thanks
 
The Aussie horn that terminates the FAA AD on affected Comanches is replacement Comanche Stabilator Horn P/No ADS 1002080828
I must have misunderstood your intent with the Aero Design parts horn. A quick check found the horn and oleo with FAA STCs based off the CASA STC. Not much we can do with that unless you need an AMOC for the AD?

The torque tube that is commonly required to be replaced when the horn is installed is p/n 20203-002, referenced in SB 1160A
So the tube you are referencing is marked by the red arrow and the letter “M” in the pics below?

If so, we’ll need to drill down the part number to its most basic form. The 20203-002 number seems to cross to a tube assembly from some quick research. I’ve found a possible base number of 22655-02 in addition to a collar P/N that appears to slide over the tube as shown in the pics. Maybe one of these numbers is the base tube and collar only?

The key to this is to produce the tube vs the assembly.

See if you can locate a copy of the instructions and inventory sheets from SB 1160A kit 652-580 as shown in the 3rd pic. A picture of the kit contents would be a great addition.

1741820055840.png

1741820076247.png

1741820095392.png

The PA-24 anding gear transmission is one of two, the better being a Dukes P/N PN 25720-00 4587-00-1, I've not been able to find an exploded diagram with a specific p/n for the jackscrew.
By "jackscrew" you mean the red arrow below or the blue arrow?

1741820188590.png
 
When the Plane Power (Hartzell) alternator failed for the second time in 700 hours on my plane, and the price went from $700 to $1500, I took it to a local alternator shop who rebuilt it for $200.

My plane is experimental, but I'd do the same on a standard category plane under the 'owner produced parts' work around.
 
Yeah I’m coming to the same conclusion. Had to do my 500 hour mag inspection/overhaul, and got quoted $2200 for the work. So looked at new Slick mags as an alternative and that would have cost nearly $4000. Pretty sure that price has more than doubled in the last six years.
I just had my Slick 4370s inspected for 500 hours and reinstalled. Total bill about $1300 all-in including the cost for me to ship them to CA, ship them back, and reinstall. I removed them myself and reinstalled them under A&P-IA supervision. That price also includes the inspection shop installing a new impulse coupling to comply with the SBs, as well as the usual new parts.

The magneto shop did great work at a reasonable price. And they turned them around in 3 days, while the place in Montana estimated 6 weeks. The shop was AeroAcc in Van Nuys, in case anyone is interested. I recommended them to another member here and he had a great experience with them too.

One way I keep my ownership costs under control is doing as much of the work myself as I can. Whether entirely on my own per Part 43, or with A&P supervision. When parts get crazy like that it's down to calling shops around the country or eBay.

Regarding auto parts, I've seen plenty of them fail too. Any machine that gets used will have wear & tear. Especially ones that are decades old like most of our airplanes are. We can minimize it with good operation & maintenance habits but we can't eliminate it. There is always something and if you don't find it during annual inspections then you aren't looking hard enough.
 
There is always something and if you don't find it during annual inspections then you aren't looking hard enough.
And you can extend your good mx habits by regularly looking over your aircraft in between annuals. Its even recommended and keeps the aircraft more inline with the requirements in Block 6 of the AWC.

but I'd do the same on a standard category plane under the 'owner produced parts' work around.
Interesting. Don't know of any owner part "work arounds" for that type of work, however an A&P could sign the work as a repair and keep you legit on the TC side.
 
I must have misunderstood your intent with the Aero Design parts horn. A quick check found the horn and oleo with FAA STCs based off the CASA STC. Not much we can do with that unless you need an AMOC for the AD?


So the tube you are referencing is marked by the red arrow and the letter “M” in the pics below?

If so, we’ll need to drill down the part number to its most basic form. The 20203-002 number seems to cross to a tube assembly from some quick research. I’ve found a possible base number of 22655-02 in addition to a collar P/N that appears to slide over the tube as shown in the pics. Maybe one of these numbers is the base tube and collar only?

The key to this is to produce the tube vs the assembly.

See if you can locate a copy of the instructions and inventory sheets from SB 1160A kit 652-580 as shown in the 3rd pic. A picture of the kit contents would be a great addition.

View attachment 138981

View attachment 138982

View attachment 138983


By "jackscrew" you mean the red arrow below or the blue arrow?

View attachment 138984

As for the Aussie parts, I was simply wondering out loud how those parts were produced under a system different from our own in terms of required approved data, in terms of " considerable sums".

The jackscrew to which I'm referring is the red arrow. That is the part that becomes brindled over time with wear as it shuttles a ball screw to push and pull the conduits which mechanically raise and lower the landing gear, much the same way an electric car seat moves. As a matter of fact I believe that is the origin of the assembly. The blue is a worm gear.

That parts diagram you provide is the same as what appears in the PA-24 parts catalog. Yes, that aluminum collar is riveted to the tube. I've never seen the kit or instructions, what you get from Piper these days is just the tube, and often it doesn't meet OD spec. Would instructions be necessary for this exercise, would it be sufficient just to reverse engineer from a tube that met the specs defined in SB1160A? For arguments sake, let's say we have that tube in hand. How would you go about determining material, cad plating thickness and other design and manufacture data points to satisfy OPP requirements?
 
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As for the Aussie parts, I was simply wondering out loud how those parts were produced under a system different from our own in terms of required approved data, in terms of " considerable sums".
The CASA system requires the same approved data but operates in a different way. The only reason I see it was done over there was someone felt there was a market for the product that no one in the US thought there was. But in comparing the CASA to the FAA on STC approvals, you’ll find the FAA process is much easier than the CASA process and is even shown by the numbers. I believe in total there are less than 750 CASA STCs vs 40,000+ FAA STCs.

Would instructions be necessary for this exercise, would it be sufficient just to reverse engineer from a tube that met the specs defined in SB1160A?
I’ve learned the more detailed info you have on the OEM part the more refined the OPP process is. No need to reinvent the wheel when the OEM can provide some free intel. Everything counts to include pics, instructions, part numbers, etc. of what the OEM provides.

So if your intent is to OPP the bare tube with the collar riveted on, then we need to determine the OEM part numbers for the bare tube, P/N for the collar, and P/N for the tube/collar assy. This path will give more options on the OPP side.

If this truly is a sore point for Comanche owners, start with inquiring on the type forums for the numbers above. I’ve got some numbers from the IPC but we need to confirm them. And it never hurts to muster the troops to find those P/Ns and how Piper sells it. ETC. ETC.

For arguments sake, let's say we have that tube in hand. How would you go about determining material, cad plating thickness and other design and manufacture data points to satisfy OPP requirements?
Several routes. But which one usually is dictated by how we will obtain our approved data for the OPP. At this point we’re still in the research stage. Once we verify the OEM P/Ns, confirm how the OEM provides this part, then we can move to the next level on how to design, material, etc.

But for arguments sake, it could be as simple as requesting and receiving the OEM drawing for the part which will have all that info listed.
 
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