Working With Industry To Study Changing Part 23 Rules

By: Chris Batcheller

We may have to put away our FAA jokes, or at least some of them. The FAA has been working with the various aviation industry groups to study changing the Part 23 Rules to make it easier and faster to certify a Part 23 airplane. Finally they may be able to say “We’re with the FAA and we’re here to help”.

The FAA has worked for the last 18 months with the EAA, AOPA, NBAA, GAMA, AEA and other aviation organizations to study the Part 23 Certification Process and make recommendations for the next 20 years. A similar process was conducted in March 2002 for Part 25 regulations. The result of this work has been a report of recommendations to the FAA. The team made a total of 56 recommendations with 5 key focus areas. The results of this work can be read in “Part 23 – Small Aircraft Certification Process Study, Recommendations For General Aviation For The Next 20 Years”.

What does this mean for the general aviation aircraft owner?  The short answer is, lots of good things. With the advent of technology, the old Part 23 regulations are cumbersome both on aircraft manufacturers and the Federal Aviation Administration. The FAA has recognized that it can’t do business as usual, and its enlisted industry to help collaborate on the new process.

The first key area is to make the regulations complexity and performance based in place of the current weight and type based rules. This is probably the most strategic change that was recommended.

FAA John Colomy

The recommendation calls for aircraft to be placed in one of three categories: Type I, II and III. The categories would be divided by performance and complexity. A Type I airplane would not be more complex and have the performance up to that of a Cessna 150. Type I would be limited to 14,000 feet and must have a stall speed less than 61 knots. These airplanes must be unpressurized and have generally simple structures and systems.

A Type II airplane includes all airplanes from, for example, a Cessna 150 to a Cirrus Vision. They would have a maximum altitude of 25,000 feet and a maximum speed less than Mach 0.6. This maximum speed aligns with EASA. The airplanes may be pressurized, have conventional control systems, construction and configuration.

Cirrus Vision

The third group would include very high performance and complex aircraft such as the Cessna CJ4. This group would have unlimited performance and complexity.

The idea is that the rules would be tailored to meet the performance and complexity for each group. It is very easy to understand that a light single engine should be certified to less stringent rules than a business jet. Under today’s rules, with some exceptions they are certified under the same rules.

I think that this is a step in the right direction and I hope that the FAA is able to follow through with such a massive change. I would like to see an extra category inserted between the Type I and Type II to include unpressurized medium complexity airplanes such as a Cirrus SR22 or a Beechcraft Bonanza type airplane.  (Chris Batcheller, ANN)

The recommendation was also made to coordinate these rule changes with certification agencies around the world to obtain a global standard for the design and certification of airplanes weighing 19,000 lbs or less.

The next recommendation was to improve on “Approved Model List” for Supplemental Type Certificates or AML-STC’s. Doing this will make it easier to complete modification to a product, particularly installing avionics.

Next was development of a process to approve ICA’s or “Instructions For Continued Airworthiness”. The FAA has a process to approve AFM and AFM flight manual supplements and the recommendation was to develop a similar process for ICA’s,

A recommendation led by the EAA was to add regulations that consider the degradation of aircraft over time. They advised that the FAA develop an advisory circular to be used as a “Best Practices Guide”.

The FAA led the recommendation on Data Management . They recognized that the FAA uses little modern technology to deal with data and that this area could be improved upon. They also noted that for Part 23 Airplanes, the SDR (Service Difficulty Reporting) system is not used often and that a solution needs to be developed so that data can be collected and used to improve aviation safety.

The final category dealt with pilot interfaces. This recommendation was to “get back to stalls and stall recovery techniques” and to “do it in simulators, do it in airplanes”. They also recommended that the FAA inform pilots about load limits. Particularly that staying below Va, maneuvering speed only protects the airplane from structural damage in pitch. It does not protect the pilot in yaw or roll. They also recommended that the FAA should encourage business jet pilots to fly at Vref or Vref -5 in place of the current Vref +/- 5. This is in response to several accidents where business jets run off the ends of runways.

The FAA’s next chore is to develop and implementation plan. Starting in the fall, the FAA will conduct a regulatory review of Part 23, and they will use this report as a basis for changes to the regulations. They plan on holding a series of public and industry meetings. We will see what the future holds. The hope among some is that it will make it less expensive and easier to certify a small airplane.

Copies of the report can be requested from the FAA Aircraft Certification Service, Small Airplane Directorate in Kansas City, MO.

FMI: http://www.faa.gov