X-Virus-Scanned: clean according to Sophos on Logan.com Return-Path: Sender: To: lml@lancaironline.net Date: Mon, 09 Dec 2013 07:43:19 -0500 Message-ID: X-Original-Return-Path: Received: from mail-qa0-f46.google.com ([209.85.216.46] verified) by logan.com (CommuniGate Pro SMTP 6.0.7) with ESMTPS id 6628812 for lml@lancaironline.net; Fri, 06 Dec 2013 13:31:37 -0500 Received-SPF: pass receiver=logan.com; client-ip=209.85.216.46; envelope-from=pjdmiller@gmail.com Received: by mail-qa0-f46.google.com with SMTP id f11so819476qae.5 for ; Fri, 06 Dec 2013 10:31:02 -0800 (PST) X-Received: by 10.224.55.69 with SMTP id t5mr9159264qag.82.1386354662564; Fri, 06 Dec 2013 10:31:02 -0800 (PST) X-Original-Return-Path: Received: from [192.168.1.144] ([68.202.59.203]) by mx.google.com with ESMTPSA id f10sm21811831qej.1.2013.12.06.10.30.58 for (version=TLSv1 cipher=ECDHE-RSA-RC4-SHA bits=128/128); Fri, 06 Dec 2013 10:31:01 -0800 (PST) Subject: Re: [LML] Re: ERAU Study on Effects of Acft Certification References: From: Paul Miller Content-Type: multipart/alternative; boundary=Apple-Mail-DA5D8297-A38B-4A53-BBE9-39D17F23948F X-Mailer: iPad Mail (10B146) In-Reply-To: X-Original-Message-Id: X-Original-Date: Fri, 6 Dec 2013 13:30:59 -0500 X-Original-To: Lancair Mailing List Content-Transfer-Encoding: 7bit Mime-Version: 1.0 (1.0) --Apple-Mail-DA5D8297-A38B-4A53-BBE9-39D17F23948F Content-Type: text/plain; charset=us-ascii Content-Transfer-Encoding: quoted-printable Absolutely correct. Ask my Canadian friend who recently completed his lanca= ir why he could not receive training in his aircraft. I am a comm pilot wit= h 6000 tt, 500 in Lancairs and was not permitted to fly that airplane becaus= e it has a high wing loading (and therefore requires a specific type rating f= or that specific airframe). The rules that are supposed to enhance safety c= an be barriers to efficient accessible training. Without that, people will= tend to cut corners or go without. Paul On 2013-12-06, at 10:52, Mark Sletten wrote: > I'm not sure I get your point Hamid. No one suggested that individuals sho= uldn't do all they can to improve safety. But its not a secret that even wel= l-intentioned FAA rules can compromise safety. For example, new Lancair buil= ders seeking to improve their chances of surviving their first hundred hours= via training face many regulatory barriers. >=20 > The "industry" the author refers to in regards to Part 23 aircraft (she sp= ecifies older, in-service certified aircraft) is comprised of owners, mainta= iners, flight instructors and technology suppliers. Granted, flight instruct= ors are limited in what they can do by the owners' willingness to engage the= m, but owners are clamoring for safety upgrades. The maintainers and technol= ogy suppliers who want to meet this demand are stymied by certification requ= irements that makes what should be relatively inexpensive safety improvement= s economically unfeasible. >=20 > This is something the FAA acknowledged as long ago as 2009: >=20 > http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/air/d= irectorates_field/small_airplanes/media/CPS_Part_23.pdf >=20 >=20 > "While the existing approach has produced safe airplanes for decades, tech= nological advances have changed the original assumptions of the part 23 divi= sions. The new small turbine engines, composite airframes, and lightweight d= igital electronics offer part 23 airplanes the operational capability and pe= rformance of traditionally larger part 25 airplanes. Part 23 standards have e= volved beyond their original intent to address the increasing performance an= d complexity. Unfortunately, the slow, simple part 23 airplanes have suffere= d as the standards have shifted towards more complex airplanes." >=20 > I believe the study cited in the original article did a good job of verify= ing and quantifying the assumptions made in the FAA's 2009 report. >=20 > Respectfully, >=20 > --Mark >=20 > Hamid wrote: >=20 > Early in the article it states a fact: "...neither the overall accident ra= te nor the fatal rate has budged in more than a decade, despite industry eff= orts to reduce accidents." If the barrier to entry created by certification= were a major factor in this, Experimental aviation would not only continue t= o improve drastically, in pace with the rapid advance in technology, but bec= ome as safe as driving. The fact is that it has not. >=20 > The biggest contributor to accidents, as has been discussed and demonstrat= ed many many times here on LML, is the faulty hardware between the pilot's e= ars, not the hardware that was not installed due to certification. But PhDs a= re granted for blaming the government for certification rules and not for ca= lling out the idiot on his quest for a Darwin award. >=20 > Regards, >=20 > Hamid >=20 > On 12/5/2013 10:57 AM, Mark Sletten wrote: >=20 > Very interesting study regarding the effects of FAA certification requirem= ents on flight safety. >=20 > http://www.avweb.com/avwebflash/news/Research-Study-Aircraft-Certification= -Rules-Dont-Necessarily-Improve-Safety221068-1.html >=20 > --Mark --Apple-Mail-DA5D8297-A38B-4A53-BBE9-39D17F23948F Content-Type: text/html; charset=utf-8 Content-Transfer-Encoding: quoted-printable
Absolutely correct.  Ask my Canad= ian friend who recently completed his lancair why he could not receive train= ing in his aircraft.  I am a comm pilot with 6000 tt, 500 in Lancairs a= nd was not permitted to fly that airplane because it has a high wing loading= (and therefore requires a specific type rating for that specific airframe).=   The rules that are supposed to enhance safety can be barriers to eff= icient accessible training.   Without that, people will tend to cut cor= ners or go without.

Paul

On 2013-12-06, at 10:52, Mark S= letten <mwsletten@gmail.com>= ; wrote:

I'm not s= ure I get your point Hamid. No one suggested that individuals shouldn't do a= ll they can to improve safety. But its not a secret that even well-intention= ed FAA rules can compromise safety. For example, new Lancair builders seekin= g to improve their chances of surviving their first hundred hours via traini= ng face many regulatory barriers.

The "industry" the author refers to in regards to Part 23 air= craft (she specifies older, in-service certified aircraft) is comprised of o= wners, maintainers, flight instructors and technology suppliers. Granted, fl= ight instructors are limited in what they can do by the owners' willingness t= o engage them, but owners are clamoring for safety upgrades. The maintainers= and technology suppliers who want to meet this demand are stymied by certif= ication requirements that makes what should be relatively inexpensive safety= improvements economically unfeasible.

This is something the FAA acknowledged as long ago as 2009:

http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/ai= r/directorates_field/small_airplanes/media/CPS_Part_23.pdf


"While the existing approach has produced safe airplanes for decades, techno= logical advances have changed the original assumptions of the part 23 divisi= ons. The new small turbine engines, composite airframes, and lightweight dig= ital electronics offer part 23 airplanes the operational capability and perf= ormance of traditionally larger part 25 airplanes. Part 23 standards have ev= olved beyond their original intent to address the increasing performance and= complexity. Unfortunately, the slow, simple part 23 airplanes have suffered= as the standards have shifted towards more complex airplanes."

I believe the study cited in the original article did a good j= ob of verifying and quantifying the assumptions made in the FAA's 2009 repor= t.

Respectfully,

--Mark

Hamid wrote:

Early in the article it states a fact: "...neither the overal= l accident rate nor the fatal rate has budged in more than a decade, despite= industry efforts to reduce accidents."  If the barrier to entry create= d by certification were a major factor in this, Experimental aviation would n= ot only continue to improve drastically, in pace with the rapid advance in t= echnology, but become as safe as driving. The fact is that it has not.

The biggest contributor to accidents, as has been discussed a= nd demonstrated many many times here on LML, is the faulty hardware between t= he pilot's ears, not the hardware that was not installed due to certificatio= n. But PhDs are granted for blaming the government for certification rules a= nd not for calling out the idiot on his quest for a Darwin award.

Regards,

Hamid

On 12/5/2013 10:57 AM, Mark Sletten wrote:

Very interesting study regarding the effects of FAA certifica= tion requirements on flight safety.

http://www.avweb.com/avwebflash/news/Research-Study-Aircraft-Certification-= Rules-Dont-Necessarily-Improve-Safety221068-1.html

--Mark

= --Apple-Mail-DA5D8297-A38B-4A53-BBE9-39D17F23948F--