Avionics News June 2013 - 15

approach to general aviation aircraft. In many cases, especially
for the lighter recreational aircraft, this relegated aircraft design,
certification and manufacturing to either the safety standards of
1964 or building a simple single-engine trainer to the standards
of a business jet.
The solution? Put Part 23 on a diet. Trim the regulations by
keeping the lean safety standards and move unneeded guidance
and policy, like criteria (the fat) to, well, guidance and policy.
Remove it from the regulations so they are “one means, but not
the only means” to show conformity to the safety standards.
This single step will encourage the industry to develop new
safety technologies without the time and administrative burden
of special conditions for most safety enhancements.
The second major piece of the evolution of Part 23 is the
migration of guidance and policy into public consensus standards. As we know, there is a huge administrative burden for

about the ARC’s proposal, think of a different brand – ASTM –
rather than those more common in commercial aviation.
The biggest difference will be in the size of guidance
documents and the speed the standards can adapt to a changing
industry. Where we currently might have a 300-page advisory
circular, you likely will see three 100-page standards, or possibly 30 10-page standards or some combination based on a
logical breakdown of technologies.
When it comes to the speed of change, ASTM will have
it all over any Federal agency, especially the FAA. Earlier
this year, the AEA identified a technical error in the agency’s
field approval job aid. The job aid was developed to facilitate
“rapid” changes. To date, the Rotorcraft Directorate cannot
corral five individuals to “approve” the technical correction.
There is no such thing as a consensus standard within the
agency these days. On the other hand, if a technical error is
identified in an ASTM standard, it can,
and often is, corrected within 90 days.
Trim the regulations by keeping the lean safety standards
This will be a great benefit to a dynamic,
fast-moving industry, such as aircraft
and move unneeded guidance and policy, like criteria
electronics.
(the fat) to, well, guidance and policy. Remove it from
The final area of recommendation is
the regulations so they are ‘one means, but not the only
probably the most difficult and the least
likely to see the light of day: continued
means’ to show conformity to the safety standards.
airworthiness. To understand the likelihood of change in continued airworthithe FAA to manage changes to advisory circulars. As a result,
ness, you simply must look toward the regulatory structure
many of the ACs are locked in time. To address needed timely
as well as the FAA organization. The design, certification and
changes, the agency will issue special conditions and policy
manufacturing of light general aviation aircraft is managed
notices; clearly a “Band-Aid” solution for a dated process. From
under Parts 21 and 23. The continued airworthiness of aircraft
a timeline perspective, an AC takes anywhere from three to four
(i.e. maintenance and alterations) is managed under Part 43 –
years or even decades to develop, open for public comment and
separate regulations managed by two separate divisions of an
publish for public use.
extremely siloed agency. So while the Part 23 ARC will make
Enter ASTM Committee F44 on General Aviation Aircraft.
a number of recommendations to facilitate better, faster and
This committee addresses issues related to design and construcmore efficient retrofit installations of safety-enhancing techtion, systems and performance, quality acceptance tests and
nologies, it will simply be an “unsolicited” recommendation
safety monitoring for aircraft weighing less than 19,000 pounds.
that will likely be ignored.
Essentially, this committee will develop parallel standards to
Christopher Freeman, an English economist, once said,
advisory circulars and policy. Once accepted by the FAA, con“Not to innovate is to die.” We know the recreational
sensus standards have the same validity as advisory circulars,
aviation marketplace has been locked in time. Maybe, just
notices, memorandums and policies.
maybe, the innovation of putting the regulations on a diet,
This is not a new concept. For avionics, we have been using
developing dynamic guidance and advancing continued airASTM consensus standards for years. The standard for electriworthiness is just the innovation needed to breathe new life
cal load analysis (F-2450: Standard Guide for Aircraft Electrical
into a 90-year-old industry. q
Load and Power Source Capacity Analysis) on general aviation
aircraft was published by ASTM, accepted by the FAA and used
by the industry more than five years ago. And when considering
Editor’s Note: See “United States News & Regulatory Updates”
consensus standards in the broad application, RTCA and SAE
on page 16 for more information on this subject and the
also produce public consensus standards. So when thinking
introduction of the Small Aircraft Revitalization Act of 2013.
avionics news

•

june

2013

Avionics News June 2013

Table of Contents for the Digital Edition of Avionics News June 2013