[Peetwo]

Another first class offering from Hitch  The comment on the USA initiative valid and oh so true.   The comment on Dick’s latest is also spot on.  But the whole thing needs to knitted up, the dots joined.  With Hitch’s forbearance I shall tinker.

A bi-partisan bill was sent to the senate floor that will pave the way for the FAA to make new aircraft certification cheaper and easier.

Successive governments have shown complete apathy towards general aviation, and there's nothing to give me confidence they would suddenly wake up and get enthusiastic no matter what happens.

Spot the difference? – My cracked rhetoric – survivors clinging to a broken mast after a ship wreck only have time and energy for survival.  Desperately clinging to that which supports them, while hoping and praying for rescue.  It becomes an individual effort to endure, there are few thoughts spared for much else.  Once rescued thoughts may turn to more esoteric topics such as cooperation and improving things; but those thoughts will not appear until the survivors are safe at home, warm, safe, fed and watered.  GA is lost in storm tossed sea, those who could make a difference must survive before energy can be poured into real reform or even assisting their fellow sufferers.  

Cheers Hitch – enjoy Tyabb.

&..

A truly remarkable comparison.

Wow, the video really shows the stark differences.  The totally different attitude of the FAA toward the industry they regulate and the industry response and cooperation the FAA receive in return perfectly captures how far from reality CASA is.  Remarkable.
 

P2 – “The comparison is so stark it is embarrassing.”

Spot on.  But it’s not the only embarrassment though, is it.  Another will come from speed of delivery, when the FAA and the USA industry agree terms and sane, sensible, understandable, workable legislation comes into being, in the shortest time possible. 
 
Another red face area will be the demonstration of how true collaboration, through real consultation with industry experts provides a rule set which makes nearly everyone ‘happy’.  Smiles all round, hope for a future and a willingness to comply with rules industry had a real part in making.  Remarkable.
 
The final agony and ultimate embarrassment for Australia is the part where after all the American innovation and effort, CASA decide that they are not having a bar of these new fangled aircraft coming out of the USA and impose their own, unique, draconian impositions.  These ‘requirements’ making it just too hard to leave the stone age and the venerable C 172, overweight with unique Australian modifications, flying under exemption, with the strict understanding it will need to be rebuilt every 1500 hours, for safety’s sake, will be the way of the future. 
 
Just another prime example of why Australia leads the race to the bottom.  How I wish Australian government could see the way forward as clearly; alas.
 
Bravo FAA and well done American industry.   I’m going to watch it again, maybe with a pile of tissues handy, lest I weep for the sad, sorry, crippled thing we call the Australian aviation industry. 
 
Toot, sniffle, toot.

Well in a follow up to the US GA industry & FAA initiative on renewing & improving Part 23 to foster & promote the aerospace & small aircraft manufacturing sector, courtesy the JDA Journal:

Part 23: The Massive, much awaited revision is here—initial observations on innovative GA aircraft certification by FAA

TOPICS:NPRMsPart 23

Posted By: Sandy Murdock March 10, 2016

Part 23

The FAA released on March 9, 2016 a much anticipated Notice of Proposed Rulemaking, entitled the Revision of Airworthiness Standards for Normal, Utility, Acrobatic and Commuter Category Airplanes. Included in the press release is an 8 minute video in which the Administrator, the Associate Administrator for Aviation Safety, industry leaders and foreign representatives present their perspectives why the new Part 23 makes sense.

[It looks like the interviews were taken during the EAA AirVenture®, which was 6 months ago?]

The proposal is the first systematic revision of the GA plane certification standards, 14 CFR Part 23, since its original “codification” of the CAR standards in 1964. As noted in the preamble, the history of the evolution of this certification has been an accretion of rules/standards/criteria in response to specific problems.

It was declared that it was time to take a fresh look at how the FAA (and many other CAAs) will perform this critical safety function of certification of these smaller aircraft. The collective wisdom of all involved in developing the new and improved Part 23 was that the tenor of that regulatory regime was to move from “prescriptive,” detailed requirements to performance-based airworthiness standards. The new regulation would delete current weight- and propulsion-derived categories Part 23 with a single performance- and risk-based parts for airplanes of 19 passengers seats or less and with a maximum takeoff weight of  no greater 19,000 pounds.

[For folks who follow the FAA’s regulatory philosophies, this new concept is reminiscent of Associate Administrator for Aviation Standards Walter Luffsey, who introduced in the 1980s the concept of “regulation by objective” in recognition that compliance could take many valid forms. His novel idea was beyond the vision of many at that time.]

The document is 283 pages long; so much time will be required to see whether the proposed text, in fact, accomplishes the goals of the industry, foreign CAAs and the senior FAA management sought to “reduce the time it takes to get safety enhancing technologies for small airplanes into the marketplace while also reducing cost.”
Its promulgation is most notable for a number of reasons:

• It has been gestating almost ten years.
  
  

• It was the subject of two statutes (FAMRA and SARA) exhorting the FAA to expedite the issuance of these rules.
  
  

• It represents that work of one of the most impressive, international and inclusive ARCs.
  
  

• It reverses a regulatory postulate established by Secretary Pena in 1995 labeled “One Level of Safety” and announced a “safety continuum philosophy” in which “…one level of safety may not be appropriate for all aviation. The FAA accepts higher levels of risk, with correspondingly fewer requirements for the demonstration of compliance, when aircraft are used for personal transportation.”
  
  

• As mentioned by some of the private sector commenters in the Video, now that the rules have been released, there may be some question whether the field staff charged with implementing the new “performance-based” standard will be able to revise their regulatory perspective—
  
  • from a process of dialectical submission of data by the TC proponent and FAA review
    
  • to a more collaborative mechanism in which the TC applicant and the regulators assess the safety risks of the design and then work toward a testing program with the assistance of ATSM.
    

• The lengthy history of this NPRM is unusual in that the work product of the Certification Process Study/ Part 23 Regulatory Review/Part 23 ARC efforts was thorough, extremely well-written and by all accounts ready for publication. In spite of that extensive preparation of what was considered to be a final project, the staff took over two years to issue an NPRM. To add to the curious delay, Congress passed FAMRA and SARA urging that the rule be promulgated, thus
  
  • adding some credibility to the inference (noted in the video) that the staff is resisting the new concept.
    

• While the general theme is to become less prescriptive, the NPRM includes two new specific criteria. The Part 23 applicant must demonstrate the aircraft’s design as it relates to Loss of Control and Super-cooled Large Drop Icing.
  
  

Quotes from the press releases summarize the introduction of the new Part 23 and industry reactions:

• Secretary Foxx:
  
  

“This proposal would improve safety, reduce costs, and leverage innovation to ensure the highest level of safety is designed and built into small airplanes…General aviation is vital to the U.S. economy, and this proposal would benefit manufacturers, pilots, and the general aviation community as a whole.”

• Administrator Huerta:
  

“This proposal would streamline how we approve new technologies for small piston-powered airplanes all the way to complex high-performance executive jets…The FAA’s collaboration with industry and international partners reflects a performance-based, flexible approach which would accommodate today’s rapidly changing aviation industry and technological advances now and in the future.”

• GAMA President and CEO:
  
  

“With today’s issuance of the NPRM, GAMA commends the FAA for taking the next important step toward revitalizing the outdated rules that govern small airplane design and alterations. This proposal is the result of nearly a decade of work by the entire aviation community, and is critical to fulfilling the objectives of the Small Airplane Revitalization Act, which the U.S. Congress passed unanimously and President Obama signed into law in 2013. We especially appreciate the continued support of members of Congress, the U.S. Department of Transportation, and the U.S. Office of Management and Budget for this vital rule, which will help improve general aviation safety and bolster the piston, turboprop, and light jet market, as well as remove barriers to certification for new technologies such as electric and hybrid propulsion.


‘GAMA member companies and staff have spent countless hours working with the FAA to evolve the current requirements to better embrace new technologies and facilitate future innovations. Going forward, it will be critical that the public and key aviation stakeholders respond quickly with meaningful comments and for the FAA to engage with other global aviation authorities, so a well-harmonized and effective final rule can be issued by the current administration. If they do so, the FAA, through its leadership, can put in place a lasting legacy that will benefit general aviation safety and the vitality of the general aviation industry for decades to come.”
[emphasis added]

The “performance-based” regime for GA aircraft draws many parallels with the SMS process on the operating side of the FAA. If the implementation of this revised part is successful, it will be interesting to see how quickly this performance-based philosophy is applied to Part 25, the commercial aircraft standard.

Further, this prominent statement of the “safety continuum” philosophy is an interesting rearticulation of the old Pena philosophy. Whether and how that relative risk tolerance is applied in other contexts will be carefully tracked.
 
Press Release: FAA Proposes Rule to Overhaul Safety Certification Standards

 
Take heed Miniscule, this can be a very positive initiative for GA utility aircraft manufacturers like Mahindra, which resides in your electorate. Not to mention Jabiru the biggest manufacturer of aero-engines in Oz, the company that CASA & the ATSB appear to currently have it in for. Note comment from Jabiru owner off Flying Oz article - http://www.australianflying.com.au/news/...ure-report :

Blair Carruthers • 6 days ago


It sounds like CASA have made up their minds and no amount of evidence will change it. In typical Australian fashion they will kill off an outstanding icon of Australian aviation on the basis of hearsay rather than rigorous evaluation. Whatever the reasons, I now cannot fly the Jab out of Bankstown because of a blanket decision.  

Get with the program Miniscule your constituents deserve the leg up the US FAA initiative on FAR Part 23 will bring. However if you dare to dream for your constituency, beware you will find much resistance in the halls of Fort Fumble (Aviation House) to the concept of PBR (Performance Based Regulation) that the rest of the aviation world is seemingly rushing to embrace..
MTF...P2