Below is what you posted on the website. However, those liability issues have zero to do with the FAA. So, again, why do you continue to push the benefits of your 172 if it was not your intent to sell the STC in the US in the first place?
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So what makes your un-certified V8 engine any different than the un-certified engines that Lycoming, TCM, Viking, or AeroVee sell to the general public with some in kit form? They obviously are not prohibited from selling them by the FAA.
This is the most interesting part for me. You’ll continually use the term experimental but list references that only apply to amateur-built aircraft, which your 172 will never meet the definition. For example, the 1952 CAA policy you mention re-established the experimental amateur-built category which had been deleted from the CARs. And that guidance (policy) defined the limits on the use of certified aircraft parts and components on an amateur-built aircraft. The same guidance is still in effect today. So I don’t quite follow how that applies to your 172 project on any level.
I don't know what else I can tell ya outside of the novel size post I just wrote ..... I try one more time to answer
Liability issue... as I clearly stated, has nothing to do with FAA stuff....it was issue due to selling a product in US, and I clearly stated in no uncertain terms was seeking certifying it (and selling) outside US with foreign CAA that would later make it possible to get FAA cert based on foreign STC and service history to reduce liability insurance cost. I never mentioned liability was a FAA issue, but a commercial issue.
EXP issue.... again, our kit design was for converting from standard to special AWC/EXP/exhib, not AB. I stated we did not want to make a AB focused kit for a few reasons, one of which being we didn't feel market size was sufficient for the size engine we were involved with (believe it or not, it takes a lot of resources to do it right.....our kit was designed to part 33, 23, CAR 3 regs which made it more complicated than others already making exp autoconversion engine kits). We did have a design for a exp crate engine but unfeasible as a stand alone product without the selling of certified kits. These were prudent business decisions, if you must know. Lycoming and others you mention have enjoyed a long run of selling mostly same product that was fully capitalized decades ago, and merely offer the same units with different branding and little additional SFC overhead.... this scale allows them to do what you mentioned.
RE your question of AB....again, I detailed this in earlier posts but will break it down fundamentally as not knowing your background. I apologize in advance if it seems to be speaking down, not my intention, but want to answer your question without more follow up. There are 2 types of airworthiness certificates (AWC), standard (as with a stock C172 or B787 for example), and special (there's a number of categories .... of which experimental is one, and there are subcategories of experimental, with exhibition and amatuer-built being 2 of them). You can install a ceiling fan on a amatuer built if you want (although a FAA DAR would need to sign it off when issuing its exp AB AWC).
However, to modify/make alterations to a standard AWC plane, like the C172 by installing a non- certified engine (engine not listed on its type certificate/design or have existing STC), its not so simple. You would either have to ask Cessna to certify the engine and add to TC/design, or obtain your own engine TC and then seek a STC for the C172.
Experimental typically refers to non-certified (aircraft or components not having/part of a TC or other CAA approved or recognized standard such as a TSO), so these terms are used interchangeably, but technically it's non-certified.
To put a standard plane into EXP there are specific requirements with many restrictions. For more recreational missions, the EXP-EXHIBITION category gives you about same operating limits as AB. However, you have to demonstrate a reason for converting to EXP that meets part 21 requirements and there'a a lot of hoops to jump thru.
FAA policy is to make changes to a standard aircraft thru the certification process, not the EXP route, and although easier to do than years ago, its still not for everyone. for example, converting to EXP-exhibition to save money is not a basis for converting. There's a special AWC called primary category, but that's another topic. With this base of regulations from CAR 3 and other cert basis, FAA often publishes policy and guidance, think advisory circulars or orders, to help with compliance of said regulations, which brings us to the CAR policy you mention. You are correct in that the specific 1950 ish policy is for converting standard to AB. This policy was mostly to stop guys from simply rebuilding a certified aircraft into exp or using cert'd parts and claiming it as exp. Without specific guidance for converting standard to exhibition, this policy was referenced in that overall policy was to avoid getting around obtaining approval for making alterations for previously standard certified aircraft... so even though our alterations were for exhibition, this was the closest guidance they had for our case and reflected overall view of converting from standard cat as it seemed to reflect the overall policy of making changes through the standard process.
As mentioned, this was just a policy, not directed to exhibition, not a regulation. But, if we sold a C172 or C182 kit and buyer had problem getting AWC he/she would have to likely argue their case and spend time and money while their plane was grounded, or later have some violation of some reg that may ground the bird and requiring litigation to resolve. AWC's, even pilot certificates, have been revoked in the past for such reasons. Additionally, FAA regs and policy give considerable leeway in what FAA may require, and to what depth, to issue any exp AWC. We had to present manuals, engineering data, structural analysis, ect, acceptable to FAA MIDO to get our initial multipurpose AWC, but because it would only be a EXP category kit without a TC, the DAR or FAA inspector inspecting a customer's plane for initial exp AWC could ask for more that the owner may not likely be able to provide.
Our kit was not a one-off, which changed the normal dynamics of historical exp approvals.
We tried resolving this and other issues early with FAA but got nowhere, over now a 4 year period. Our next step was to seek formal ruling from FAA counsel, which I feel we would likely get on this specific issue but without a specific regulation it may be difficult as specific interpretation is normally based on a reg..... We got nowhere after 4 years with a petition process, for example.
but it was clear FAA leadership did not want anything that could keep old planes flying on a scale such a kit may do, and other kit manufacturers would later make if we were successful, and FAA had great leeway in what would be needed by each applicant converting. so we needed a clear policy path forward with FAA either way but got nothing.
Without such a written path, and not wanting to sell kits and see what happens to us or others, it would be foolish to move forward with the exp kit. This is primary reason for STC but ran into same roadblocks even after G1 issue paper (a document essentially that FAA approves of things like cert basis and test plans, ect..), and grew tired. Too bad really, as our plane significantly reduced cost and emissions, easy to install, and wanted worldwide. It was used to get pilot certificates to many that financially struggled through GA high cost and such a kit could have grew GA without the leaded fuels, allow both recreational and professional pilots live a dream or avoid huge debt. For flying clubs to have such costs (about $20/hr), it would have made a big difference for many as rental cost would be about $60-70/hour, or aspiring pilots could buy a plane already converted and fly for about $20-25/hour getting their SE ratings. Last month a young Marine used it for his commercial training, time build and checkride all-in for about $2,300 with CFI dual and DPE fees, which would have taken him 6 months paying as he went at the flight school he was at. Got our first initial CFI ride in a couple of weeks which is a cool milestone for the plane. Couple of local CFI's flew it to last Oshkosh and build time and figured out the most efficient (read cheap) speed. GA needs new stuff to reduce costs so more can participate, and hope others continue the fight.
You mentioned the restricted and POA cat .... we had interest from fire spotting and public safety agencies operating in these categories. These cats provide different means of compliance and certification than standard AWC, but the numbers at the time didn't make sense based on smaller PAM size.
there's really not much more to it. If you have more questions, please DM me as most PoA'ers likely have little interest in this mumbo jumbo but I don't have much more to add...
