As the FAA readies its sweeping proposal to rewrite Part 23 certification standards for light aircraft, industry leaders have high hopes that the final rule could jumpstart the sagging lighter end of the general aviation industry, bring new technology to market and possibly even take a bite out of cost for aircraft buyers and operators.
The agency has targeted year-end for release of the Part 23 notice of proposed rulemaking, with the stated goal of “twice the safety at half the cost.” Believed to have been coined by an FAA official during a working group meeting, that goal has become the mantra for nearly everyone involved in the effort.
“The FAA and our global aviation partners are committed to streamlining the certification process for general aviation airplanes while enhancing safety throughout the world,” said FAA Administrator Michael Huerta. “The FAA is working on completing its proposal as quickly as possible.”
Manufacturers, long struggling with lengthy wait times and unpredictability in their certification processes, have pushed hard for the overhaul. Moving toward a performance-based approach that allows the top experts, rather than strictly regulators, to help set the standards holds the promise of long-term cost and safety benefits.
But industry leaders caution that “half the cost” does not necessarily mean new aircraft will be arriving on the market with prices dramatically lower than those today. In fact, many acknowledge that until the FAA releases an NPRM, it will be difficult to tell how far the benefits will extend.
Rob Hackman, vice president of regulatory affairs for the Aircraft Owners and Pilots Association, said his association does not expect to see the price of the aircraft drop in half. But he does see significant tangible and intangible benefits.
For starters, he said, the rule change will strengthen what has been an ailing light aircraft sector, he said. A stronger manufacturing sector means a stronger industry overall, said Hackman, who participated on the Part 23 Rewrite Aviation Rulemaking Committee that developed the recommendations for the upcoming proposal.
In more concrete terms, improved bottom lines and a clearer path to certification will encourage new technology, he said, noting the industry has seen few new Part 23 piston aircraft designed in the past several decades. Also, it provides important safety equipment an easier path to market. The process is designed to help not only with approval of new equipment, but also supplemental type certification.
“It is good for the industry,” added Kenneth Byrnes, chairman of Embry-Riddle Aeronautical University’s Flight Training Department. “The rising cost of the certification process has slowed safety innovation.”
Byrnes pointed to the aging piston fleet and the few new entrants to the market. “We still have the same basic airframes, the same basic engines. We are not seeing any advancement,” he said adding. “A lot of manufacturers are still using old airframes that have been around forever.”
While the airframes haven’t changed, prices have–some by as much as 300 percent in the past two decades, he said, a number he attributes mostly to the cost of upgrading avionics panels.
“If [the rewrite] does bring costs down, it’s huge for the training industry,” Byrnes said. He points to research showing cost remains a significant barrier to bringing in new students and a factor in a number of student dropouts. Since ERAU recently refreshed its single-engine fleet, it might be another seven years before it undertakes the process again. Byrnes is hoping that the prices will have at least stabilized by that time, which in effect would be a price drop.
At the same time though, Byrne underscored the importance of being able to bring new technologies and avionics to market sooner. In addition to his ERAU duties, Byrnes participated in the FAA’s 2020 ADS-B working group. Certification remains a stumbling block for installation, he said. Byrnes noted that while manufacturers such as Garmin have developed ADS-B products, those products must be certified on each of the various airframes. The TSO and STC processes are time consuming, holding back the effort, he said, adding that this is true of all safety equipment. “I think that’s why people still use magnetos in their airplanes.”
King Schools co-owner Martha King agreed, noting that new technology attracts new interest in the market. She observed that flat-panel technology, such as Garmin’s G1000, has stirred interest in the training market, and that newer-technology aircraft do the same.
King also noted that the Part 23 effort presents an opportunity for regulators worldwide to take a new look at general aviation. The rewrite has been an international effort that has involved participation from regulatory agencies in Europe, China and Brazil, among others. Too often, international authorities tend to regulate general aviation as commercial aviation, she said. “There’s a general tendency for authority to bring regulations from [the more stringent] Part 25 into Part 23.” This can make development prohibitive and discourage innovation, she said. “It will be a big deal in the U.S. if it helps get new technology to market faster. I don’t know whether it will bring down costs, but I do know costs need to come down.”
The Experimental Aircraft Association’s Sean Elliott notes that until the notice of proposed rulemaking is released, it will be difficult to determine just how far the changes will extend. The FAA has provided a few clues, supporting the European Aviation Safety Agency advanced notice of proposed rulemaking that established a template for changes in Europe’s CS-23 (the counterpart to Part 23).
But even without a rulemaking, Elliott believes the rewrite has already begun to make a difference. “We can point to a shift in culture and philosophy at the FAA.” He cites the angle-of-attack indicator. Early last year the agency released guidance designed to simplify the approval process for installation of AoA instrumentation, in a primary example of cost improvement. The owner of an experimental aircraft had been able to install an AoA indicator for about $800 without the price of undergoing supplemental type certification approval. For a certified aircraft requiring STC approval the price would swell more than six-fold to about $5,000.
Where it does not help–at least not yet–is with field approvals, Hackman said. Byrnes agreed, saying that if the field approval process can be streamlined and expanded, then the industry can move out of antiquated equipment. But instead, he said, the number of field approvals has shrunk.
Elliott concludes that while “no one single thing is going to turn the decline in general aviation,” a Part 23 rewrite stands to build momentum for the industry. “It’s not only the cost aspect, but the safety aspect,” he said, and it has to happen.