X-Virus-Scanned: clean according to Sophos on Logan.com Return-Path: Sender: To: lml@lancaironline.net Date: Wed, 10 Sep 2008 21:29:55 -0400 Message-ID: X-Original-Return-Path: Received: from web55701.mail.re3.yahoo.com ([216.252.110.32] verified) by logan.com (CommuniGate Pro SMTP 5.2.7) with SMTP id 3122959 for lml@lancaironline.net; Wed, 10 Sep 2008 14:06:35 -0400 Received: (qmail 35131 invoked by uid 60001); 10 Sep 2008 18:06:35 -0000 DomainKey-Signature: a=rsa-sha1; q=dns; c=nofws; s=s1024; d=yahoo.com; h=X-YMail-OSG:Received:X-Mailer:Date:From:Subject:To:MIME-Version:Content-Type:Message-ID; b=bxi83S9eReGtvVJh7JMwdev78IH/2U+c1sMyEyrw3jDiFU/00tmE7biHFca1RAgkMmcaWkdQ+PGmQ7nw3S+N09ueWH0SzK2oTFjFzZWKOgLc837v/sLIoM1GiTrNeW4J86iaI2UpEnF8l6QAOXKGMAQOiN3gA5qfKT0ZBmk8yP0=; X-YMail-OSG: o1vBoAQVM1nSrKouh1nn09l18EVmj8XYYm9oXIY8qbfHSCxEx0uc9_wzu.Dgep6.DR0zBBUxxV2wJleT2IZJUWsMdO85yWRU59c1dqmeyCYG3YblirWgr2HO44HJSESIrsHgHXfuEBKucwLg4k3r Received: from [71.31.132.122] by web55701.mail.re3.yahoo.com via HTTP; Wed, 10 Sep 2008 11:06:34 PDT X-Mailer: YahooMailRC/1096.28 YahooMailWebService/0.7.218.2 X-Original-Date: Wed, 10 Sep 2008 11:06:34 -0700 (PDT) From: J H Webb Subject: Re: [LML] Re: Part 23 vs Guaranteed Safety X-Original-To: Lancair Mailing List MIME-Version: 1.0 Content-Type: multipart/alternative; boundary="0-1842608726-1221069994=:33428" X-Original-Message-ID: <951991.33428.qm@web55701.mail.re3.yahoo.com> --0-1842608726-1221069994=:33428 Content-Type: text/plain; charset=iso-8859-1 Content-Transfer-Encoding: quoted-printable Mark,=0A=A0=0A=A0 Having worked for several years in Certification Flight T= est under part 23, I discovered that most of the rules are written in blood= . Some of the rules go overboard in trying to eliminate possible problems t= hough. For example the DC 3 could not be certificated to day and there are = many other examples of aircraft that are loved and have preformed well, tha= t could not be certificated today without significant changes. They are onl= y built based on a grandfathered type certificate. =0A=A0=A0=A0 It is not g= uaranteed safety or guaranteed reliability but it is an attempt to eliminat= e obvious life threatening problems. It works but not easily or cheaply. Th= at should be changed.=A0 A lot of homebuilt come close or meet most of part= 23 requirements but most have a problem with stall speed, handling at the = stall, stability at aft CG, static discharge protection, and seat loads (pr= ogressive failure) to name a few.=0A=A0=0AJack Webb=0ABSAE =0AFormer Chief = Engineering Test Pilot for a major manufacturer=0AL360 LIV=0A=0A=0A=0A-----= Original Message ----=0AFrom: "marknlisa@hometel.com" =0ATo: lml@lancaironline.net=0ASent: Tuesday, September 9, 2008 7:40:10 = PM=0ASubject: [LML] Re: Part 23 vs Guaranteed Safety=0A=0ARob Wolf said: = =0A=A0=0A"But blanket statements like "all homebuilts are safer than certif= ied airplanes" and "the certification process adds no safety -- it is purel= y bureaucratic BS" are based in ignorance."=0A=A0=0ANow, now Rob, let's not= put words in others' mouths... I didn't say the certification process is "= purely bureaucratic BS."=0A=A0=0AHere's what I said:=0A=A0=0A"...FAR Part 2= 3 certification guarantees nothing=A0except that=A0a certificated aircraft = meets the bureaucratic standards contained within the FAR."=0A=A0=0AI belie= ve certification CAN (and should be) be a good thing, and=A0I think the FAA= started out that way back in the day.=A0But like most bureaucracies, it=A0= has evolved (in my opinion) into an organization more concerned with its ow= n self interest and turf (read money) protection than with those ethereal i= deals of "safety" and "reliability."=0A=A0=0AHere's one example of why I th= ink so:=0A=A0=0AI believe if those managing the FAA were truly concerned ab= out safety and reliability, General Aviation aircraft would long ago=A0have= exited the production line=A0with engines sporting safe and reliable (comp= ared to magnetos) computer-controlled ignition systems, as well as computer= -controlled=A0fuel injection systems. These "newfangled" systems would=A0en= sure our engines could burn a READILY AVAILABLE fuel. Instead, aviation eng= ine manufacturers who live in the real world of FAA certification are just = now taking their first tentative steps into the 21st century of internal co= mbustion engine technology -- a place automobile manufacturers not saddled = with a "certification process" have lived for nearly three decades. Which b= egs the question, do you think Lycoming=A0waited this long to join the like= s of Chevrolet and Honda in the spirit of safety and reliability?=0A=A0=0AI= n my opinion, if our FAA certification process worked, it would have DEMAND= ED such "safety" and "reliability" innovations. Instead, our FAA mandates m= anufacturers traverse a circumspect and ridiculously Byzantine "certificati= on" process to prove -- only to the FAA, not our courts -- such systems are= safe and reliable.=0A=A0=0AIf you can think of a better example of "bureau= cratic BS" than that, you have my admiration!=0A=A0=0AI learned an interest= ing statistic in speaking with the management and development team at Delta= Hawk engines (currently seeking certification for a heavy-fuel piston aviat= ion engine). They=A0told me that from drawing board to FAA certification,= =A0they estimate the development cost for a new-design engine to be=A0$20 m= illion. I know the team had a flyable prototype installed in a Velocity wit= h around $5 million invested (including purchase and build cost for the Vel= ocity kit). That means they are estimating FAA certification costs at somew= here north of $15 million. The ignorant and inquiring among us (me) asks ho= w can it possibly cost SO MUCH to determine an engine meets minimum safety = and reliability standards? Where is all that money going? Could it possibly= be to keep an aging and voracious=A0bureaucracy alive and well?=0A=A0=0ACa= n you say=A0"bureaucratic BS?" I knew ya could...=0A=A0=0ARegards,=0A=A0=0A= Mark=A0=0A=0A=0A --0-1842608726-1221069994=:33428 Content-Type: text/html; charset=us-ascii

Mark,

 

  Having worked for several years in Certification Flight Test under part 23, I discovered that most of the rules are written in blood. Some of the rules go overboard in trying to eliminate possible problems though. For example the DC 3 could not be certificated to day and there are many other examples of aircraft that are loved and have preformed well, that could not be certificated today without significant changes. They are only built based on a grandfathered type certificate.

    It is not guaranteed safety or guaranteed reliability but it is an attempt to eliminate obvious life threatening problems. It works but not easily or cheaply. That should be changed.  A lot of homebuilt come close or meet most of part 23 requirements but most have a problem with stall speed, handling at the stall, stability at aft CG, static discharge protection, and seat loads (progressive failure) to name a few.

 

Jack Webb

BSAE

Former Chief Engineering Test Pilot for a major manufacturer

L360 LIV



----- Original Message ----
From: "marknlisa@hometel.com" <marknlisa@hometel.com>
To: lml@lancaironline.net
Sent: Tuesday, September 9, 2008 7:40:10 PM
Subject: [LML] Re: Part 23 vs Guaranteed Safety

Rob Wolf said:
 
"But blanket statements like "all homebuilts are safer than certified airplanes" and "the certification process adds no safety -- it is purely bureaucratic BS" are based in ignorance."
 
Now, now Rob, let's not put words in others' mouths... I didn't say the certification process is "purely bureaucratic BS."
 
Here's what I said:
 
"...FAR Part 23 certification guarantees nothing except that a certificated aircraft meets the bureaucratic standards contained within the FAR."
 
I believe certification CAN (and should be) be a good thing, and I think the FAA started out that way back in the day. But like most bureaucracies, it has evolved (in my opinion) into an organization more concerned with its own self interest and turf (read money) protection than with those ethereal ideals of "safety" and "reliability."
 
Here's one example of why I think so:
 
I believe if those managing the FAA were truly concerned about safety and reliability, General Aviation aircraft would long ago have exited the production line with engines sporting safe and reliable (compared to magnetos) computer-controlled ignition systems, as well as computer-controlled fuel injection systems. These "newfangled" systems would ensure our engines could burn a READILY AVAILABLE fuel. Instead, aviation engine manufacturers who live in the real world of FAA certification are just now taking their first tentative steps into the 21st century of internal combustion engine technology -- a place automobile manufacturers not saddled with a "certification process" have lived for nearly three decades. Which begs the question, do you think Lycoming waited this long to join the likes of Chevrolet and Honda in the spirit of safety and reliability?
 
In my opinion, if our FAA certification process worked, it would have DEMANDED such "safety" and "reliability" innovations. Instead, our FAA mandates manufacturers traverse a circumspect and ridiculously Byzantine "certification" process to prove -- only to the FAA, not our courts -- such systems are safe and reliable.
 
If you can think of a better example of "bureaucratic BS" than that, you have my admiration!
 
I learned an interesting statistic in speaking with the management and development team at DeltaHawk engines (currently seeking certification for a heavy-fuel piston aviation engine). They told me that from drawing board to FAA certification, they estimate the development cost for a new-design engine to be $20 million. I know the team had a flyable prototype installed in a Velocity with around $5 million invested (including purchase and build cost for the Velocity kit). That means they are estimating FAA certification costs at somewhere north of $15 million. The ignorant and inquiring among us (me) asks how can it possibly cost SO MUCH to determine an engine meets minimum safety and reliability standards? Where is all that money going? Could it possibly be to keep an aging and voracious bureaucracy alive and well?
 
Can you say "bureaucratic BS?" I knew ya could...
 
Regards,
 
Mark 

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