What would deregulated maintenence do to used aircraft price?

I doubt that OM would have much effect on used airplane prices and for reasons already stated I think it would likely improve their value a bit assuming that an annual inspection was performed by an A&P-IA each year with special attention paid to whatever the owner had worked on. I also believe that owners should be allowed to tackle almost any job that they want but that this should require a signoff from a certificated A&P that said owner/pilot was trained by that A&P to do the specific job (on that specific model airplane if appropriate).

I think it's absolutely nuts that a pilot can change his oil and filter completely on his own without ever having seen it done before yet cannot change an alternator belt after being shown how. Same for strobe lamps vs strobe supplies. Same for tires but not brakes. The list goes on and on.
 
No kidding.....I don't remember what periodical it was in, but I was reading a story recently about a guy in an EAB who during a fuel stop on a long x-country had a prop strike.....he had a new prop sent in within 24 hrs, slapped it on and went on his merry way.

And what is wrong with that ?
 
The "slippery slope" begins. If you allow uncertified parts in certified aircraft, even if it's like the avionics sample in the post above, then what's next? ...
I do agree that some parts pricing is outrages but that boils down to a scale of market.

BS. My plane uses a Gates Green Stripe alternator belt. $5 from the auto parts store, or $50 from Piper with their part number written in Sharpie on the Gates Green Stripe cardboard box.

My landing light is a headlight from a 1964 Ford Falcon. It's a 4506 bulb. Whelen made an LED replacement for the 4506, it's $25 for a tractor, but the FAA required three years of tests trying to meet standards that the FAA made up on the fly.
Now they cost $239, because Whelen has to recover the million-plus dollars they spent trying to meet ever-changing standards and specifications.

The door handle for a Cherokee is from a 1955 Studebaker.
The trim handle is the window crank from a 1955 Studebaker.
But if mine breaks, I either have to get a 55 year old replacement, pay LOTS of money to Piper, or get a PMA replacement. Current prices are $212+
To meet FAA STC and PMA requirements, they are "Precision machined/close tolerance construction from solid T6 aluminum & 17-4 stainless steel stock."

Seriously?
 
Thinking as a prospective airplane buyer... Right now there is basically no provision for "owner maintained". Whatever I buy, it's going to need a good, thorough pre-buy inspection. I don't trust any random A&P signature in a log book, and even if I did "airworthy" does not equal "has no huge, very expensive problems about to become obvious". I have no idea what the owner has done since the last annual, OR what he's convinced the A&P to ignore or sign off on, OR what the A&P has missed or not felt was bad enough to need fixing.

Now assume we did have an option for the owner to perform his own maintenance, maybe without an A&P return to service, just the same annual that's required now. I see no difference at time of purchase.

Regardless of the level of training and certification required to do any kind of work, it all comes down to the individual who does it. While most are competent, thorough and professional I've met doctors I wouldn't trust to put on a Band-Aid, cops who make Barney Fife look professional and vendor-certified networking/computer/security geeks who are completely incompetent. I would not assume that aircraft owners or mechanics are any different.

Having said that, knowing human nature I'd expect to see a price difference between an owner-maintained and professionally maintained airplane. And I'd probably take full advantage of that difference.
 
Thinking as a prospective airplane buyer... Right now there is basically no provision for "owner maintained".

Wrong, get supervision from any A&P

Whatever I buy, it's going to need a good, thorough pre-buy inspection. I don't trust any random A&P signature in a log book, and even if I did "airworthy" does not equal "has no huge, very expensive problems about to become obvious". I have no idea what the owner has done since the last annual, OR what he's convinced the A&P to ignore or sign off on, OR what the A&P has missed or not felt was bad enough to need fixing.

I believe that your exposure to A&P-IAs have been very limited, all of us are not that bad.

Now assume we did have an option for the owner to perform his own maintenance,

We do

maybe without an A&P return to service, just the same annual that's required now. I see no difference at time of purchase.

Nor do I, simply not having the certificate doesn't mean your a bad mechanic,

Regardless of the level of training and certification required to do any kind of work, it all comes down to the individual who does it. While most are competent, thorough and professional I've met doctors I wouldn't trust to put on a Band-Aid, cops who make Barney Fife look professional and vendor-certified networking/computer/security geeks who are completely incompetent. I would not assume that aircraft owners or mechanics are any different.

Having said that, knowing human nature I'd expect to see a price difference between an owner-maintained and professionally maintained airplane. And I'd probably take full advantage of that difference.

value is in the eye/wallet of the beholder
 
The slippery slope is already here and has been for some time.

An A&P's signature in the logbook is already worth exactly zero today unless you know the A&P personally or someone you know well enough to trust, does. FAA has already created a worthless sign-off by not tossing out the bad ones. Good A&P's should be ****ed but they aren't because they don't want to garner any attention either.

An IA signature *might* mean something. Does, in fact. We're not talking about removing the IA from the process here.

If the A&P system actually worked, a pre-buy wouldn't even be necessary. The inspection would just be a paperwork check by an IA. The IA would already know, as would the owners, in public, who the bad A&Ps are. Not in the shadows and whispers, the scoreboard would be published.

If a pre-buy mechanic finds something wrong, is there any repercussion or public documentation of the A&P who screwed it up? Does their ranking go up on a public scoreboard and the other mechanic's go down?

Is there an FAA database I can look up the A&Ps who cause all the problems that the IA's found?

I can look up complaints about Doctors if I try. Not easy, but way ahead of A&P transparency.

As far as Certified parts go, I'm with Alan. My alternator is a Ford product. Cessna didn't manufacture something new for their airplanes. They bought off-the-shelf well-tested automotive parts to keep costs low.

The running joke about the Monarch fuel caps is that they're the best 1960's General Motors fuel caps ever made. And remember, the FAA "certified" the recessed caps that killed people the Monarchs replaced, and it took years of very public bashing of those to get people to remove them because FAA dragged their heels.

You can buy the guts of a Monarch cap at NAPA in the "classic cars" display area.

And I'll take it a step further...

If I paid a qualified avionics shop to put a Dynon in the panel of a certified aircraft and *remove* all of the certified instruments from 1975, I know my risk has gone *down* and is decinitely no worse off than buying a Garmin.

Why? Because the Experimental guys have already done the testing!

Seen Garmin's bug list and number of patches available for the G1000 lately? It ain't pretty.

That product is no better quality having been certified than the stuff that isn't. The Experimental beta testers worked our Dynon's kinks just as fast as Garmin leaks theirs out. One was in public. The other is negotiated behind closed doors with the FAA. Which one is more trustworthy? How much does Garmin spend on lobby efforts? Conflicts of interest galore.

Plenty of people fly hard IFR in Experimentals behind non-certified instrumentation every day. It's already being done. FAA blessed even. That same FAA says it can't be a primary instrument in a Cessna but it can in an RV.

Inconsistency breeds contempt. Is that a surprise to the FAA folks?

How about a rule where once an avionics product reaches X number of documented flight hours in Experimentals it becomes certified? Efficient, leaves the tracking problem, but lowers costs dramatically.

Experimentals are already the "beta testers" and have far more operating experience with what's good and what's bad than FAA could ever hope to amass on certain products. They have thousands of unpaid testers. Every weekend.

It'd be great to remove the Cessna instrument cluster and put in something digital and non-certified. Plenty of engine instrumentation that's got plenty of flight hours on it in the experimental world, too. Proven gear.

On the one hand, you have Experimentals with the "new" system of maintenance complete with some accidents, and on the other you have FAA allowing no significantly new technology into Certified cockpits or replacement of like for like (in the case of tractor lights meant to run for only 25 hours in the day now where we've learned long ago that landing lights aren't just for landing at night and should be on most of the time). Neither one exonerates me as PIC from deciding whether I should fly the darn thing.

GE makes a drop-in 100 hour version of my landing light bulb. It's $5 online at the farm store for tractors. FAA can't seriously think that's less safe than the PMA'd 25 hour version. CPA says if you hit just the right FSDO on just the right day, they might sign you a 337 to use the newer bulb. Why is it a damn crap shoot?

Inconsistency breeds contempt.

And as Alan pointed out, LEDs are $235?! I have something like 12 LED flashlights and never has one of the LEDs failed.

It's not like it was "difficult" technology to evaluate. How many LED lighting systems and engineering specs does one need?! I'm already running a bulb already *guaranteed* by the manufacturer to fail before the next oil change that they re-designed to meet the market's expectations of longevity 25 years ago! The crap-ass 25 hour bulb that's FAA certified will burn out. The tractor guys have better tech than the FAA will allow in the same sized lamp holder at the same heat/wattage level from the same manufacturer! How utterly stupid is that?!

I can get a $80 HID lighting upgrade kit for my truck. It's a little tough to believe that the FAA certification process added $920 in value to the same hardware for my airplane. Yeah I know HID ballasts can throw RF noise. I'll buy one someone guarantees from the factory not to interfere and hold them to it. I'll do flight tests if necessary. But a 10x price increase means massive waste is happening somewhere.

Someone, somewhere, in the FAA, is getting paid too much and wasting my money because I chose a 35 year old non-Experimental.

I could maybe even see doubling the price, but factors of 10 or more, depending on the product, when the parts utilized were known to be COTS automotive parts to begin with, in the 1960s and 1970s?

Come on. There's no salient points to be made for safety on many of these parts having a PMA sticker.
 
[citation needed]

I have several databases available to me with all sorts of information. In the public domain there are searches available if you want to put out the effort.

I've personally gone out on accident investigations and routine ramp inspections, sometimes what we find is alarming. Some people will always try to cut corners as justification to aircraft ownership even at the expense of their and their passenger's lives.
 
The rate is higher to be certain, but not by all that much, at least according to the analyses Ron Wattanja has published. Most experimentals crash for the same reasons as certificated aircraft.


A biased search will give whatever results the seeker wants.

And the guy you cited previously wasn't biased?? :dunno:
 
BS. My plane uses a Gates Green Stripe alternator belt. $5 from the auto parts store, or $50 from Piper with their part number written in Sharpie on the Gates Green Stripe cardboard box.

My landing light is a headlight from a 1964 Ford Falcon. It's a 4506 bulb. Whelen made an LED replacement for the 4506, it's $25 for a tractor, but the FAA required three years of tests trying to meet standards that the FAA made up on the fly.
Now they cost $239, because Whelen has to recover the million-plus dollars they spent trying to meet ever-changing standards and specifications.

The door handle for a Cherokee is from a 1955 Studebaker.
The trim handle is the window crank from a 1955 Studebaker.
But if mine breaks, I either have to get a 55 year old replacement, pay LOTS of money to Piper, or get a PMA replacement. Current prices are $212+
To meet FAA STC and PMA requirements, they are "Precision machined/close tolerance construction from solid T6 aluminum & 17-4 stainless steel stock."

Seriously?

You would be shocked to see what I've found in certified aircraft. :yikes:

So if some owners refuse to comply with the standards as they are now written would you expect them to comply with a new set of standards if they were relaxed? Or would you expect them to cut even more corners?

I've said before one of the problems of GA is people buy airplanes they can't afford. Anyone with a little bit of effort can educate themselves (especially today) on what's required to properly maintain an airplane before they buy. However they still continue to buy, often more airplane than they can reasonably afford then proceed to either cut corners or ignore maintenance.

As to what a manufacturer charges for their replacement parts, the FAA cannot control that, the market place does. A huge part of replacement part cost goes to a thing called Product Liability Insurance. The premiums have been increasing each year on this due to the ever expanding glut of lawyers looking for easy money via frivolous lawsuits.
 
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You would be shocked to see what I've found in certified aircraft. :yikes:

So if some owners refuse to comply with the standards as they are now written would you expect them to comply with a new set of standards if they were relaxed? Or would you expect them to cut even more corners?

I've said before one of the problems of GA is people buy airplanes they can't afford. Anyone with a little bit of effort can educate themselves (especially today) on what's required to properly maintain an airplane before they buy. However they still continue to buy, often more airplane than they can reasonably afford then proceed to either cut corners or ignore maintenance.

So the existing regulations serve only to punish the people who try play "by the book"?

Those that chose to ignore the rules and cut corners are pretty much not affected one way or the other.
 
Total BS thread. Experimentals have been around a long time and they get fixed by their owners. They crash more frequently than certificated aircraft, but mostly from dumb pilot tricks, and not poor maintenance.

Ehhh... from what I see it's six of one an half dozen other. The reality is that both statistics are higher.
 
Ehhh... from what I see it's six of one an half dozen other. The reality is that both statistics are higher.

Maintinance would be suggested by a higher accident rate due to mechanical failures after years of service.

Poor system design would be suggested by a higher accident rate in the first year / first 100 or so hours.

IIRC the accident rate on homebuilts during the first few hours is the highest.
 
Man, I do hate having to sort out these replies where someone just tacks stuff into the middle of a quoted post. But I'll do it, mostly because I don't want there to be any misunderstanding. Tom-D, especially -- I don't want you thinking I have no regard for A&P-IA certified mechanics, just that I'm not going to blindly trust anything that has a signature on it.
Originally Posted by DaleB
Thinking as a prospective airplane buyer... Right now there is basically no provision for "owner maintained".

Wrong, get supervision from any A&P
Yes, I know that... didn't go into it simply to keep the post from getting too long. But my point was (and I thought it was apparent taken in context with the subject of this thread), there is no provision now for the non-A&P owner doing other than routine preventive maintenance without an A&P supervising and signing off.
Whatever I buy, it's going to need a good, thorough pre-buy inspection. I don't trust any random A&P signature in a log book, and even if I did "airworthy" does not equal "has no huge, very expensive problems about to become obvious". I have no idea what the owner has done since the last annual, OR what he's convinced the A&P to ignore or sign off on, OR what the A&P has missed or not felt was bad enough to need fixing.

I believe that your exposure to A&P-IAs have been very limited, all of us are not that bad.
I never said anything of the sort! My point was, and I thought I made this quite clear (like in the highlighted portions of the last paragraph here), that I would not place blind trust in the signature of a mechanic I don't know, simply because he happens to hold an A&P certificate. I'm sure MOST of them are good, honest, competent individuals. Maybe almost all of them. But as a buyer I'm not going to assume they ALL are. Hence the pre-buy inspection, which is going to happen no matter who has been turning wrenches on the airplane..

Now assume we did have an option for the owner to perform his own maintenance,

We do
Please allow me to finish a sentence.
maybe without an A&P return to service, just the same annual that's required now. I see no difference at time of purchase.

Nor do I, simply not having the certificate doesn't mean your a bad mechanic,

Regardless of the level of training and certification required to do any kind of work, it all comes down to the individual who does it. While most are competent, thorough and professional I've met doctors I wouldn't trust to put on a Band-Aid, cops who make Barney Fife look professional and vendor-certified networking/computer/security geeks who are completely incompetent. I would not assume that aircraft owners or mechanics are any different.
I stand by my original point... If there were a provision for owner maintenance without A&P supervision, it would not affect my buying decision much, if at all. I'd still have the same pre-buy inspection done -- by an A&P. :)
 
Maintinance would be suggested by a higher accident rate due to mechanical failures after years of service.

Poor system design would be suggested by a higher accident rate in the first year / first 100 or so hours.

IIRC the accident rate on homebuilts during the first few hours is the highest.
That would seem to me to reflect neither maintenance, nor design... I'd suspect two factors. First, QC -- improper assembly and adjustment. The design can be great, but if it's put together wrong there's a price to be paid. Second, I wonder how many pilots with recently completed homebuilts are trying to fly an airplane that is beyond their skill level, maybe because they just spent several years building instead of flying.

And that's a guess, not a statement of fact.
 
I have several databases available to me with all sorts of information. In the public domain there are searches available if you want to put out the effort.

I've personally gone out on accident investigations and routine ramp inspections, sometimes what we find is alarming. Some people will always try to cut corners as justification to aircraft ownership even at the expense of their and their passenger's lives.


It's not just maintenance either, any short cut to make it cheaper or easier.
 
I personally believe the state of aircraft maintenence and resale value of airplanes are much improved under the A&P system vs owner maint.

I still recall some of those classmates that never made it through the program years ago. Some bounced for cheating.

Despite many flaws mentioned, things could be worse. I think the model worked well enough that the auto industry copied it by implementing SAE certified mechanics, and that industry has benifeted as well.

In my first job as an A&P (late 1970s) , I was fired for refusing to put a voltage regulator purchased at Roses Auto on an old 182 (part 135 operator). It had the same shape as the original, but I opened them both up and there was zero resemblance inside. The aircraft also had a number of other descrepancies that really stuck out like a sore thumb.

As I was looking at the airplane, people kept coming out of the woodwork (likes Dicken's ghosts) explaining pieces of the history.

The centrifical cooling fan on the pad mounted alternator turned backwards, (baffling), turns out the owner had taken the DC generator out and converted it to AC using parts from the local automotive alternator place. I was looking at it because the battery dried and fried the points in a Cessna voltage regulator. The high school kid doing the 100 hour inspections forgot to check water in the battery.

Over voltage light had been replaced and the system had a ballast resistor in it, some local guy had wired it up using an old chiltons manual as a guide.

I was out of work for 3 months. I never regretted leaving.

On a different note:

I do believe the FAA needs to implement some reasonable mechanisim to allow an operator to approve replacements for unreliable parts.

That is a lot of the work we see in an airline engineering office. If a part is too expensive to keep operating, we'll try to find a replacement.

If it's a complicated computer that plays a key role in Cat III landings, certification of a substitute by an airline will be out of reach.

Lamps are another matter.

From a certification standpoint, I'd say try to substutite a more reliable lamp from a different airplane. The approval substantiation should be easier. I haven't tried it though. I'm still working up the nerve to buy my first airplane.
 
You would be shocked to see what I've found in certified aircraft. :yikes:

So if some owners refuse to comply with the standards as they are now written would you expect them to comply with a new set of standards if they were relaxed? Or would you expect them to cut even more corners?

No, I would expect that those same "some" PEOPLE would continue to do bad things, while the rest of us would appreciate utilizing new technology built and designed sometime after 1960, to make ourselves safer and better off.

FAA needs to go after those people. When you've found those things, what happened to those people? Are they still involved in maintaining aircraft after proving without a doubt that they're not worthy of doing so?

'Cause slapping a PMA sticker on a Ford alternator isn't stopping them today or even effective, as you've just pointed out.
 
After owning three airplanes, I agree with all sides of this question.

For sure, having an FAA-mandated inspection each year enhances safety. It keeps the people who would cut every possible corner honest.

Unfortunately, it also allows unsavory mechanics to fleece dumb owners. The A&P's conflict of interest is just too great for some unethical people to handle, and they use the regs to bludgeon ignorant new owners into replacing or repairing stuff that doesn't need replacing or repairing. Been there, done that, got the scars.

On the other hand, our planes are riddled with stupid crap that should and could be improved. Take my wheel pants, for example. They had stainless steel screws holding them together, thankfully -- but with Phillips heads. Over the years, these routinely stripped during the annual, requiring costly and time-consuming extraction.

So, I suggested that we put in square-drive (or Torx) head screws. You would think I had suggested smoking crack before a flight -- the answer was "No!".

The following year, we stripped several more screws. This time, I TOLD my mechanic I was going to replace the damned things with Torx screws. He shrugged, and signed off the annual. He also allowed as how they were VERY much better than the originals.

This year, now that I'm flying more in the salt air on the coast, the screws that hold the fuselage to tail fiberglass fairing on are showing signs of corrosion. This is an entirely cosmetic piece (early Cherokees don't even have it), so I'm replacing them with stainless steel.

Should I get an A&P sign off? Probably. Will I? Probably. Is it stupid beyond measure? Yes. Those screws should have been stainless from the factory, for Crikey's sake.

So, would deregulating maintenance (and parts) make sense? Yes. Would it marginally reduce safety? Possibly. Would it help a dying industry by allowing manufacturers to keep prices lower? Absolutely.

Will it happen? Not a chance. There are just too many bureaucrats benefiting from the current system to allow for change.
 
As to what a manufacturer charges for their replacement parts, the FAA cannot control that, the market place does. A huge part of replacement part cost goes to a thing called Product Liability Insurance.
The FAA can't control it, but they can AND DO make it nearly impossible to bring a product to market in an reasonable and efficient manner. And impose huge development costs that must be recouped over a small customer base.

I have personally spoken to multiple companies who have been forced by the FAA to spend millions of dollars and years of development to get certification for things like landing lights, LED marker lights, door handles, and minor parts.

I already mentioned Whelen's brain damage trying to meet ever changing FAA requirements for a LED landing light. Another company gave up after 24 months and $150,000.

Whelen also tried to make an LED drop-in replacement for 1157 marker light bulbs, that would simply replace the filament with LED. Better light, lower draw, never burn out.
The FAA invented a ton of requirements that never existed before, and that Whelen could not meet. So now, you have to replace the entire marker and strobe assembly (the FAA would not even allow them to have you move the strobe element from the old wingtip assembly to the new one).
So, $300 for a new assembly, rather than $5-$10 for an LED bulb.

Another company is making LED replacement marker lights, and have spent 3 years and over a million dollars going through the same rigamarole.

Another company was making a cheaper 406 ELT. They were required to go through over a million dollars of testing, and after getting a successful test result from a government lab (supposedly the last step in the process), the FAA arbitrarily required another full test from an independent lab at a cost of another $250,000.

So excuse me if I find your position either uninformed or misleading.
 
And Alan's story leaves out another effect the FAA has.

Many of the smaller manufacturers will only say negative things about the certification process verbally, in-person. They will not contact user groups in writing and ask for public outcry for the ridiculousness (since after all, the FAA is supposed to be tempered by political will) for fear of retribution.

Whelen makes lighting assemblies for all sorts of high-dollar public safety applications. They may be one of the few manufacturers who could walk away from the FAA's silliness, but they've dealt with government agency silliness for decades. They also have the revenue base to not care all that much if their aviation business were suddenly, magically, unable to get anything through the process due to someone having a stick in their craw at FAA over something they said.

That said, some great products and companies have managed to get their products through the process, but they keep their collective mouths shut or almost so, about FAA certification. They'll say it was expensive and maybe even tedious, but they won't share specific stories or names of FAA personnel who personally made their lives hell.

Alan carefully said "another company" in his comments, probably because the company representative asked for anonymity or because Alan in his work role, understands better than the rest of us how this silent get-back-at-the-troublemaker mentality works when a government agency has ultimate power over the success or failure of a small business. Especially when the agency can claim "safety reasons" to trump any reasonable argument.

Anyone want to defend FAA's position on Whelen's replacement marker lights and the "new rules" horse-hockey? I bet the pro-FAA folks go silent on that one. Because... Once again I say... We're not collectively that stupid. Even a layman can see that Whelen's bulb idea was just fine, added longevity, added safety, and lowered costs.

I'm not claiming that FAA is inherently bad, it's just that the process is pretty ripe for abuse of power without much openness or repercussions for using my money to abuse manufacturers. That's got to be the part that gets me the maddest about Alan's story: I paid FAA to do that to lighting manufacturers?! No! That is NOT what we the People intended or wanted from a Certification system. Fix it.
 
I don't have access to specific cases mentioned in the thread. I do think it's worth keeping a few things in mind.

When the FAA is working with an applicant trying to obtain certification for a product, I believe the FAA is unable to discuss the conversations held with that applicant with any third party.

I don't know of it's a legal requirement. I guess for ethics reasons, and to safeguard intellectual property. This can be extremely frustrating for the applicant's customers.

When a manufacturers marketing representative tells you how the federal governments stupidity and incompetence is the reason his company can't do something, I'd be at least open minded. Typically they are not permitted to confide that their own technical or management incompetence killed the product.

After all as a company with bottom line profit as the primary motive, they might have designed a product that could burn you alive and their "leadership" might be OK with the idea that that if it's a statistically significant problem, the problem will be "regulated" by an associated drop in sales.

Oh yes they will also lobby heavily against large jury awards and tort reform too. They are bad for business you know.

There are a lot of players with an agenda.

Also, LED for example lighting is not always as simple as it seems.

In my own project work, I was surprised to find out that the LED replacement for cockpit annunciator warning lights drew almost the same current as filament lights. It had to do with matching rheostat adjusted cockpit lighting still in place and the requirement that all the lighting in the cockpit adjust at about the same levels.

The intensity curve and color shift in LEDs is different. Ultimately the OEM had to insert a small circuit board in the assembly to match the curve using a Pulse Width Modulation scheme.

Ensuring a source of inexpensive 3rd party parts is not on anyone's agenda when the airplane is being designed.

One of my favorite comparisons has to do with old 727 era attitude indicators. By now, the blue and brown paint on the ball is very faded in every one of them.

Compare that to what you have to go through to test the colors on a CRT or flat panel display that gets returned to service.

The test fixture is a dark chamber equipped with a colorimeter mounted on a 6 axis CNC controlled fixture and associated computer hookups to drive the display under test. It's probably at least a $500k bench.

It tests every color to some tolerance from every angle to some tolerance.

Now when the airframe OEM wrote their spec for the display, they wanted to ensure they got a very high quality unit from the avionics supplier. Those same specs tend to become the basis for TC paperwork and post repair test paperwork.

Years later when a reputable CRT or flat glass repair outfit comes along, the over kill in the original specs (originally a risk management measure instituted by the airframe OEM) can be a very expensive barrier to over come.

This is where open industry specifications pay off for everyone. They allow competition and substitutions.
 
The FAA can't control it, but they can AND DO make it nearly impossible to bring a product to market in an reasonable and efficient manner. And impose huge development costs that must be recouped over a small customer base.

I have personally spoken to multiple companies who have been forced by the FAA to spend millions of dollars and years of development to get certification for things like landing lights, LED marker lights, door handles, and minor parts.

I already mentioned Whelen's brain damage trying to meet ever changing FAA requirements for a LED landing light. Another company gave up after 24 months and $150,000.

Whelen also tried to make an LED drop-in replacement for 1157 marker light bulbs, that would simply replace the filament with LED. Better light, lower draw, never burn out.
The FAA invented a ton of requirements that never existed before, and that Whelen could not meet. So now, you have to replace the entire marker and strobe assembly (the FAA would not even allow them to have you move the strobe element from the old wingtip assembly to the new one).
So, $300 for a new assembly, rather than $5-$10 for an LED bulb.

Another company is making LED replacement marker lights, and have spent 3 years and over a million dollars going through the same rigamarole.

Another company was making a cheaper 406 ELT. They were required to go through over a million dollars of testing, and after getting a successful test result from a government lab (supposedly the last step in the process), the FAA arbitrarily required another full test from an independent lab at a cost of another $250,000.

So excuse me if I find your position either uninformed or misleading.

You're confusing one issue here, manufacturer replacement parts vs aftermarket parts via PMA. They are not one in the same.

The manufacturer has latitude in selecting parts that will go into the airframe after the airframe has been TC'ed.

If someone other than the manufacturer wants to build a replacement part then they do that through the PMA process which can be lengthy and expensive depending upon many factors. That process goes through the FAA MIDO (Manufacturing Inspection District Office). I've personally known of people that have applied for and gotten PMA approval on parts and got the process done quit efficiently and quickly by having a good working relationship with the MIDO and having their act together before submitting. I've known others that spend considerable time and money to accomplish the same process because they didn't have their act together and bumbled through the process.

As far as your comment:

The FAA invented a ton of requirements that never existed before, and that Whelen could not meet.

The FAA doesn't "invent regulations" on the spot. The PMA process is spelled out in the CFR's and there is Guidance on that process. At times like any other regulation or guidance they are up to interpretation. Anyone going into the PMA process would go through the application process by first reviewing the requirements and clarifying any portions within it before acting upon it. That's called due diligence.

I'm not sure what Whelen has been going through with their products or what the true situation is, and I highly doubt you have the whole story either.

I have personally spoken to multiple companies who have been forced by the FAA to spend millions of dollars and years of development to get certification for things like landing lights, LED marker lights, door handles, and minor parts.

The FAA cannot force any company to spend millions of dollars. The applying company makes the determination whether the cost involved are worth the recoup in the market place.

So excuse me if I find your position either uninformed or misleading.

I could make the same comment about your position as well. :rolleyes:
 
And Alan's story leaves out another effect the FAA has.

Many of the smaller manufacturers will only say negative things about the certification process verbally, in-person. They will not contact user groups in writing and ask for public outcry for the ridiculousness (since after all, the FAA is supposed to be tempered by political will) for fear of retribution.

Whelen makes lighting assemblies for all sorts of high-dollar public safety applications. They may be one of the few manufacturers who could walk away from the FAA's silliness, but they've dealt with government agency silliness for decades. They also have the revenue base to not care all that much if their aviation business were suddenly, magically, unable to get anything through the process due to someone having a stick in their craw at FAA over something they said.

That said, some great products and companies have managed to get their products through the process, but they keep their collective mouths shut or almost so, about FAA certification. They'll say it was expensive and maybe even tedious, but they won't share specific stories or names of FAA personnel who personally made their lives hell.

Alan carefully said "another company" in his comments, probably because the company representative asked for anonymity or because Alan in his work role, understands better than the rest of us how this silent get-back-at-the-troublemaker mentality works when a government agency has ultimate power over the success or failure of a small business. Especially when the agency can claim "safety reasons" to trump any reasonable argument.

Anyone want to defend FAA's position on Whelen's replacement marker lights and the "new rules" horse-hockey? I bet the pro-FAA folks go silent on that one. Because... Once again I say... We're not collectively that stupid. Even a layman can see that Whelen's bulb idea was just fine, added longevity, added safety, and lowered costs.

I'm not claiming that FAA is inherently bad, it's just that the process is pretty ripe for abuse of power without much openness or repercussions for using my money to abuse manufacturers. That's got to be the part that gets me the maddest about Alan's story: I paid FAA to do that to lighting manufacturers?! No! That is NOT what we the People intended or wanted from a Certification system. Fix it.

When in doubt, go the conspiracy theory route. :rolleyes:
 
I don't have access to specific cases mentioned in the thread. I do think it's worth keeping a few things in mind.

When the FAA is working with an applicant trying to obtain certification for a product, I believe the FAA is unable to discuss the conversations held with that applicant with any third party.

I don't know of it's a legal requirement. I guess for ethics reasons, and to safeguard intellectual property. This can be extremely frustrating for the applicant's customers.

When a manufacturers marketing representative tells you how the federal governments stupidity and incompetence is the reason his company can't do something, I'd be at least open minded. Typically they are not permitted to confide that their own technical or management incompetence killed the product.

After all as a company with bottom line profit as the primary motive, they might have designed a product that could burn you alive and their "leadership" might be OK with the idea that that if it's a statistically significant problem, the problem will be "regulated" by an associated drop in sales.

Oh yes they will also lobby heavily against large jury awards and tort reform too. They are bad for business you know.

There are a lot of players with an agenda.

Also, LED for example lighting is not always as simple as it seems.

In my own project work, I was surprised to find out that the LED replacement for cockpit annunciator warning lights drew almost the same current as filament lights. It had to do with matching rheostat adjusted cockpit lighting still in place and the requirement that all the lighting in the cockpit adjust at about the same levels.

The intensity curve and color shift in LEDs is different. Ultimately the OEM had to insert a small circuit board in the assembly to match the curve using a Pulse Width Modulation scheme.

Ensuring a source of inexpensive 3rd party parts is not on anyone's agenda when the airplane is being designed.

One of my favorite comparisons has to do with old 727 era attitude indicators. By now, the blue and brown paint on the ball is very faded in every one of them.

Compare that to what you have to go through to test the colors on a CRT or flat panel display that gets returned to service.

The test fixture is a dark chamber equipped with a colorimeter mounted on a 6 axis CNC controlled fixture and associated computer hookups to drive the display under test. It's probably at least a $500k bench.

It tests every color to some tolerance from every angle to some tolerance.

Now when the airframe OEM wrote their spec for the display, they wanted to ensure they got a very high quality unit from the avionics supplier. Those same specs tend to become the basis for TC paperwork and post repair test paperwork.

Years later when a reputable CRT or flat glass repair outfit comes along, the over kill in the original specs (originally a risk management measure instituted by the airframe OEM) can be a very expensive barrier to over come.

This is where open industry specifications pay off for everyone. They allow competition and substitutions.

Agreed. :thumbsup:
 
When in doubt, go the conspiracy theory route. :rolleyes:

Got any better theories? We The People expect process and cost improvement over time just like our real-world jobs require us to do. When we have no information showing that it's likely we'll assume the worst.
 
Got any better theories? We The People expect process and cost improvement over time just like our real-world jobs require us to do. When we have no information showing that it's likely we'll assume the worst.

So you are active in the PMA process and have a working knowledge of all the requirements?

Or are you just going on Internet rumors for your information?
 
So you are active in the PMA process and have a working knowledge of all the requirements?

Or are you just going on Internet rumors for your information?

What company other than government doesn't publish information about what benefits they provide and how they're improving their processes and lowering the costs of them?

If all I have to go on is the stories of those claiming the system is broken, the FAA has a problem. Maybe it's a process problem, maybe it's a PR and Marketing problem.

I'm not "active" in the process of *any* company I pay for products for. That's a chicken-crap answer. I wouldn't accept it from any vendor, I purchase services by the results.

They tell me why I should buy their products and if I agree, I buy.

Considering that 40% of all of my money goes to the parent company of the FAA, I'm probably a bit more sensitive to waste in that larger organization than wasting $100 on some other gadget or product.

Considering manufacturers claim that this organization that I pay for is the number one thing in the way of them bringing economical products to market, yeah... I'm very concerned. In business I would be looking for a better provider of services and preparing to fire them unless they showed their process had significant safety or other positive impact on the product.

The manufacturers say the process is a mess and wasteful. Where's the published public counterpoint?

If I weren't seeing $230 landing lights I might not care. But the cost analysis is backing up their claims without better information. Costs are headed the wrong way.

So I say: What am I paying for? Don't tell the guy paying the bill he doesn't understand the process unless you have documentation to back up the statement. Published where he/she can find it.

What specifically caused Whelen's costs to jump to ten times the typical cost of a comparable product. They say FAA. What does FAA say? Where can I find it? I'm not paying for secrecy. I'm paying for an open public book at an open public agency.
 
P.S. Alan works for a similar government agency on a more local scale. They can tell me where his budget goes and he can back it up his expenditures, without attitude.

I don't think it's too much to ask of the same from Federal government as I already get from local government.
 
P.S. Alan works for a similar government agency on a more local scale. They can tell me where his budget goes and he can back it up his expenditures, without attitude.

I don't think it's too much to ask of the same from Federal government as I already get from local government.

When dealing with government, I rarely find that you can attribute to malice that which mere incompetence will explain.
 
When dealing with government, I rarely find that you can attribute to malice that which mere incompetence will explain.

Color me funny, I don't like paying for incompetence and if I'm paying for it, I get to call it out or get more of the story.

Let me be clear, there are plenty of FAA jobs that are adding tons of value. I just can't find a lot of evidence that the Certification program isn't broken.

In the spirit of openness I'm happy to accept evidence in these specific cases mentioned above that shows evidence to the contrary.

I'm also a very loud voice in the fight to get a REAL FAA budget and not these half-assed continuing resolutions from my Congresscritters.
 
P.S. Alan works for a similar government agency on a more local scale. They can tell me where his budget goes and he can back it up his expenditures, without attitude.

I don't think it's too much to ask of the same from Federal government as I already get from local government.

I worked for the federal government for 47 years in one capacity or an other, military and civilian.

I had to account for every penny I spent, the worker bees do not get the privileges that the elected critters get.

Remember the public only sees the 2% that make the headlines, they never hear of the many that come to work and do their jobs in a professional manor every working hour of every working day.

And also remember that I take offense when you generalize and make statements like you just did. How would you feel If I grouped you with the 2% of your occupation that were A.H.s?
 
I worked for the federal government for 47 years in one capacity or an other, military and civilian.

I had to account for every penny I spent, the worker bees do not get the privileges that the elected critters get.

Whoa there now. Never said they did.

Remember the public only sees the 2% that make the headlines, they never hear of the many that come to work and do their jobs in a professional manor every working hour of every working day.

Sigh. When did I target anyone in particular. I targeted a very specific job the FAA does that seems to have lost effectiveness. I pay for that job to be done, therefore... Since I'm a Citizen... I say, "What the hell is going on? Why are all the manufacturers claiming that this process is broken?"
[/QUOTE]

And also remember that I take offense when you generalize and make statements like you just did. How would you feel If I grouped you with the 2% of your occupation that were A.H.s?

Two responses to that. My boss doesn't give a rat's butt if I take any offense to him checking up on if I'm doing my job. I'd better damn well be doing it right or he'll fire me.

The 2% who are A.H. get fired if they don't do useful stuff for the company. That or they continue to be A.H.'s while they make the company lots of money. Have seen both.

Your post does prove one of my bigger picture points that I've been saying for a while now, though. You "identify" with being a government employee in a number of varying roles that are drastically different jobs... As you say, "Military and Civilian". Those are radically different. One works for Congress, one should have a much tighter customer focus on Citizens.

But... And here's why that's interesting... Government is the largest Company in the country. By far. The protestors lament the "giant evil Corporations" while government and it's workers are the number one largest Special Interest Group in the country. Huge lobby money, voting recommendations from government-based union groups, and even individuals who defend bad service by entire divisions full of other government employees they've never even met. Comraderie. Esprit de Corps.

Why do *you* personally care if I question the Certification group's effectiveness?

As I mentioned last post... Plenty of sharp, on-point, service-oriented government groups in all branches.

But we can't get answers as to why Certification costs keep rising and rising with no end in sight and no public statements about how it's going to be addressed.

I never said it was salary or perks. I said something's ineffective and it needs to be fixed or explained to those of us footing the bill.

As far as the folks who claimed I was making up conspiracies goes, I wasn't. I was saying there's a very difficult and fine line to be walked when you're a private business who's livelihood depends on a Certification from a single-source like FAA. It's been proven time and time again that FAA FSDOs aren't consistent in application of rules, which can lead to something that is approved here -- not being approved somewhere else. That makes FAA the biggest risk in starting an aviation-related business.

There's nothing in my statements you should take offense at unless you didn't provide the best service possible in your government work and never applied the rules any differently to any organization than any other government representative. If you always worked hard and spent those nickles and dimes wisely and for real safety reasons, we're also right as rain Tom. I suspect you did a fine job.

All those of us watching from the checkbook writer's seat are seeing is that Certification costs continue to climb, manufacturers say its the main reason they can't or won't bring new products to market, and we need information as to why. Thus the mass exodus out of Certified aircraft to Experimentals.

I seriously doubt the Experimental crowd wants to be known as Experimental. What they want is a high-quality aircraft and avionics for 1/2 the cost of the same Certificated aircraft. They grit their teeth and bear building 51% of the aircraft or they pay someone else to do it and lose the ability to do the annual condition check, so they can afford to fly the best modern technology has to offer, for 1/2 the price of aircraft that can't even replace a landing light with modern technology that's very well-known and understood, without a bureaucratic process driving the price up two to ten times the price of the same product off the same factory assembly line without a PMA sharpie marking.

My tax bill goes up every year faster than inflation. If all taxes are included it's 40% or more of every dollar I make. I am willing to pay that bill and retain the people who are making things better in government.

I expect a better product or services every year for that ever-increasing bill. Otherwise government layoffs and a falling tax bill each year would be more welcome. Make sense?

Not every Citizen can watch over all of it. But I can ask pointed questions about the few problematic things I hear about. Government employees always act shocked when the Citizenry says, "Are you worth what we're paying you? Can you quantify it?" In the private sector that analysis happens every day. "Downsizing" is often a convenient term for "tossing out deadwood". I've never heard of government downsizing.
 
Not every Citizen can watch over all of it. But I can ask pointed questions about the few problematic things I hear about. Government employees always act shocked when the Citizenry says, "Are you worth what we're paying you? Can you quantify it?" In the private sector that analysis happens every day. "Downsizing" is often a convenient term for "tossing out deadwood". I've never heard of government downsizing.

Every government agency I know of has undergone a contractor advisory study in the past 10 years, if they are not now a contractor, they have proven they can do the job better and more efficiently than out sourcing them.

BTDT twice.
 
Every government agency I know of has undergone a contractor advisory study in the past 10 years, if they are not now a contractor, they have proven they can do the job better and more efficiently than out sourcing them.

BTDT twice.

Interesting. Never heard of such a thing. Are they viewable by the public?

Would love to see one.
 
Every government agency I know of has undergone a contractor advisory study in the past 10 years, if they are not now a contractor, they have proven they can do the job better and more efficiently than out sourcing them.

BTDT twice.

The pendulum swings.

The USAF (or at least AFMC) decided it could do the required job with contract engineers and program management contractors instead of doing it organically. Then the USAF (or at least AFMC) decided to convert engineer and PM slots to civil servants. And before the slots were converted a hiring freeze was put into place. Leaving.... yes, unfilled slots.
 
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