Washington Report: FAR Part 23 rewrite

Citation Mustang
Should 172s really be subject to the same certification process as Citations?

One of the major reasons cited for the declining pilot population is the high cost of new airplanes, with a new Cessna 172 costing $300,000 or more. Even Light Sport Aircraft (LSAs), which were supposed to make new airplanes affordable, are often $150,000 or more. Many airframe manufacturers in turn blame the FAA’s Byzantine certification process, which they claim drives up the cost and drives down the utility of new aircraft. Certifying a new aircraft is certainly expensive, with clean sheet piston airplanes costing in the neighborhood of $100 million to develop, by most estimates. This cost is then spread out over an ever smaller number of units.

A key problem is that that light airplanes like the Cessna 172 are lumped together with 400 knot business jets for the purposes of certification. Both are subject to FAR Part 23, which prescribes the certification standards for airplanes under 12,500 lbs. As turboprops and jets have become increasingly sophisticated, the certification process has grown equally complicated. The FAA is, in effect, catering to the highest common denominator.

But a new group hopes to turn back this tide. Last year, the FAA formed a 55-member Part 23 Reorganization Aviation Rulemaking Committee (ARC) to examine the certification process and try to cut costs by 50% and still improve safety. In particular the group, led by the General Aviation Manufacturers Association (GAMA), is looking at establishing a simpler standard for truly light airplanes–removing jets from the mix and focusing on only the important issues for entry-level aircraft. The job is a complex and difficult one, but many members of the ARC have expressed optimism lately.

What do you think? Can this group make positive changes to the aircraft certification process? Will this drive down the cost of new airplanes?


    • There are several forces at play with respect to GA costs. The cost of 100LL is idiotic. The $300,000.00 C172 is both idiotic and beyond any practice human reasoning. So how do we change these constant costs escalations? I’m sure that Government regulations play a major role and ought to be curtailed. Fuels costs need to be cut in half. If low HP GA a/c are lumped in with high performance a/c that’s even more idiotic. Other than the fact they both fly low HP a/c have no relationship to high performance a/c……

    • The $300,000.00 Cessna 172 was certified back in the 50’s.

      One would think that the cost of certification would have expired by now. As a result, while I think revising the cert regs may have a small impact on new designs, it still won’t give a significant cost savings to the bottom line on existing and new designs.

      Someone brought up the fact that a new Ford truck would be much more expensive if it were to be produced in smaller numbers. While this may be true, let’s compare the price of boats. Boats are certainly not produced in the same amounts of units as cars and trucks, but you still see the every day guy being able to afford them because while they may be a bit more expensive than a motor vehicle, they are not OUTRAGEOUSLY more expensive.

      Airplanes are simply too outrageously expensive to create interest and the LSA market has proven this. Even with LSA self certification standards, these airplanes are ridiculously priced at over $100K.

      Therefore,while the proposal for revisal of certification standards is encouraging, it simply won’t do enough to make an airplane affordable for the same guy that can afford a reasonably priced new boat.

      Until someone produces the $50K new airplane (and nobody will considering even a homebuilt will run you $60k or better to build)there is no future in believing that a production airplane can be offered at a reasonable price. Hate to be a wet blanket as I am am an eternal optimist, but above that, I am a realist with hands on experience at the game being a pilot for 41 years, and a 4 time aircarft owner.(all 4 were very used— of course)

      • To say, “The $300,000.00 Cessna 172 was certified back in the 50′s,” isn’t really fair.

        Did it have “Omni-Vision” in the 1950s?

        Did it have a 180 HP Lycoming engine in the 1950s?

        Did it have a 2550 lb. max gross weight in the 1950s?

        Did it have G1000 in the 1950s?

        In an effort to remain competitive, OEMs have to continually update their products. While there are fewer hoops to jump through when a change is made to the aircraft vs. a clean sheet design, recertification is required. Do you have any idea how many man-hours have gone into swapping the -114A PT6 for the -140 PT6 on the Caravan? 3 years in development, tens of millions of dollars spent, and over a year of actual flying and the ENGINE doesn’t even have a happy stamp from the FAA yet, let alone the aircraft as a whole…

        All for a “simple” engine swap in an airframe with over 12 million hours of history.

        • “Do you have any idea how many man-hours have gone into swapping the -114A PT6 for the -140 PT6 on the Caravan? 3 years in development, tens of millions of dollars spent, and over a year of actual flying and the ENGINE doesn’t even have a happy stamp from the FAA yet, let alone the aircraft as a whole…”

          That’s exactly the point. No matter what Piper or the FAA want to tell you, an Archer is nothing more than a Warrior with 20 more horsepower. Both should be produced under a common Type Certificate. The egine installation should be thought of as a factory-installed “option,” with little more significance than the installation of leather-covered seats versus cloth-covered ones. Does the POH have to reflect the performance differences? Sure. But automobile manufacturers publish comprehensive owners’ manuals that account for the differences that are a consequence of a great variety of installed equipment – including engines and transmissions. And radios.

          If an airframe could be certificated with a demonstrated variety of powerplants, etc., the manufacturer could offer that variety to customers, but pay for certification only once. That doesn’t seem other-worldly to me.

          If Piper wants to swap out a Continental for a Lycoming of the same horsepower, the paperwork shouldn’t weigh more than the engine. At what level is this useful? Down to the branding of oil filters and spark plugs? Seriously.

  • For human-occupied aircraft, the current methodology of certification standards based on the gross weight of the vehicle makes no sense – and it hasn’t for a very long time, if it ever did. In the past, I have proposed a system that focusses on two metrics: the maximum number of occupants, and the atmospheric operating environment (essentially, whether or not the vehicle is pressurized). I’ve proposed five certification groups based on maximum occupant count and pressurization:
    • Trainers (2 occupants or fewer)
    • Personal (3 to 8 occupants) non-pressurized
    • Personal (3 to 8 occupants) pressurized
    • Business/commercial (9 to 19 occupants)
    • Transport (20 or more occupants)
    Experimentals still would be permitted.

    The basic approach would be that the first three groups are intended for occupancy by informed volunteers, so airliner standards are inappropriate and unnecessary. Part-135 operations still would be permitted with all except the trainers. Regardless of group, the type of powerplant(s) would be irrelevant. The empty and gross weights would be irrelevant. An instrument rating and a type rating would be required to act as PIC of pressurized personal vehicles, B/C vehicles, and transport vehicles. Those vehicles would have to be equipped with FIKI-quality anti/de-icing apparatus, and would have to meet lightning-strike-tolerance standards. Balanced field length requirements would apply to all operations of B/C and transport vehicles.

    This approach is sensible and safe, and therefore, defensible. That’s one reason why it also is very unlikely to happen. Hopefully, the FAA’s committee can come up with something that makes as much – or more – sense.

  • It hasn’t been my observation that the rules, per se, are the major obstacle. Yes, there are some that could be dispensed with and others that could be simplified, but it is the procedures that one has to go through to show the FAA that the rules have been met that add glue to the process. The original LSA process demonstrated that some oversight is needed as there were apparently some “manufacturer’s” that didn’t know the difference between calibrated and indicated airspeed. I think the process could be significantly speeded if the FAA would create some sort of Master Designated Engineering Rep and allow that person to provide complete oversite from beginning to end, without interference, using a book of standard procedures that applied to everyone. Kind of like the Pilot Test Standards.

  • While I would love to see the process make more sense it cannot be said that it will reduce the cost of the aircraft significantly. The Cessna 172 in the example above at over $300,000 has not incurred the current expense of certification. I think it boils down to low production, and high liability. If you want to achieve a more affordable aircraft it needs to be produced in large numbers and there needs to be tort reform to seriously reduce the liability of the manufacturers.

  • It would be interesting to read a cost analysis of a new C 172 the way tech nerds take apart a new iPhone.

    What is the cost of the materials, parts, labor etc.?
    Obviously would take expert guesstimation but quite doable.

    • I would challenge you to build Ford F-150 pickups at the rate of 100-200 units per year for less than $300,000 each. For that matter try to build 100-200 iphones per year at a “reasonable” cost. The retail price of any commodity has little to do with the cost of materials, parts or labor. It has everything to do with what you can get for it; which has to be equal to or greater than the sum of the design, manufacturing, marketing, overhead, liability and product support costs; or you go broke. A lot of airplane companies have gone broke, but not because they charged too much.

    • There are many variables, other than the F.A.A. and probably one of the biggest is “liability.” As long as courts can go after the manufacturer, basically in perpetuity, and those same courts are awarding unrealistic dollar values to a “loss,” nothing is going to change. The manufacturers, as much as I hate to defend them, have to protect themselves against these ridiculous awards, and the only way to do that is to hire, and keep on hand, a bevy of lawyers and insurance carriers, (extremely expensive,)that actually produce nothing of value to the true production of new, INEXPENSIVE, aircraft.

      • Since the General Aviation Revitalization Act passed in 1994 liability was capped at 18 years from date of first delivery.

        Manufacturers at the time lobbying for the Act claimed that liability added anywhere from 70k to 100k to the price of an airplane.

        • Do those numbers seem credible?
          Current LSA manufacturers sell (many) models at or below $100 K.
          That price suggests that the manufacturers are all fools and selling way below cost. No?

          • That was the figure given by Cessna / Piper / Beech at the time (Early 90s.)

            From a pretty interesting article called “The rise and fall of general aviation: product liability, market structure, and technological innovation”

    • I think the real challenge is the cost of producing a limited number of units. There is a well-known and documented learning curve that shows the labor cost will decrease very rapidly over the first few hundred units. This is true for automobiles as well as airplanes. The aviation industry (other than for large transport manufacturers) has been reluctant to make an estimate of average cost over a production life. Many years ago, I proposed a light airplane design which projected the cost of ship one of the order of a million dollars and the cost of ship 300 at about 40,000. I was told the problem was to get the first customer to pay the million dollars (plus a mark up) and subsequently the cost would rapidly come down. I suggested a model where we would predict the market based on, say $60,000, and figured a breakeven of 300 units — similar to the automobile industry where they breakeven about ten months into the model year. I was told this was much too simplistic.

      I wonder how many B-787’s Boeing would have sold if the launch customer had to pony up the cost of ship number one.

      Dick Newman

      • We design and build airplanes the same way we design and build houses – one at a time, by hand. But (excepting experimentals) each design is accompanied by a certification process that treats it like it was the first aerial vehicle ever conceived.

        From a certification perspective, that bright line between homebuilts and production vehicles has become absurd. We need far fewer designs, far far fewer manufacturers, and a certification process that countenances the fact that non-transport-category aircraft, flown by amateur pilots (or fully automated), simply don’t need to possess every state-of-the-art feature that exists. Personal transportation vehicles aren’t airliners – and they don’t need to be.

        This industry produces at least 20 times as many business jet models as can be justified, and there’s probably twice that over-abundance of light aircraft models available – in theory, at least (since many catalogue models have an annual production rate of zero).

        And though I’m loathe to piss off my many mechanic friends, if we’re going to open up Part 23, we might as well revisit the idea of annual inspections for light aircraft that fly on an infrequent basis. I won’t argue in favor of letting planes rot in the weeds, then fly away. But there’s nothing magical about a 12-month calendar. Some planes need to be inspected more often; most, less-frequently. That $3,000-per-year ritual is causing pilots to park many planes – they (barely) can afford to fly enough to stay current, or they can afford to annual their bird, but they no longer can afford to do both. So they wind up doing neither. Truth.

  • I am lucky in that I fly for a living, but I really miss general aviation flying. I would love to own an airplane, but the cost is pretty high for someone my age trying to accumulate retirement money as well as dream of aircraft ownership. I believe my only possible way to get back into general aviation is a flying club, or someone with an airplane they don’t use much letting me fly it a little. Other than that, I’ll just go back to being an airport bum.

    • I am curious about the economics of small group ownership of a plane.

      Suppose 4 people buy a new or late-model LSA for $100 k.
      (No debt –all cash.)

      They each fly 150 hours per year (which I gather is a typical amount for a recreational flyer.)

      What would be the cost per hour? Or year? Or whatever else is a rational way to figure the cost of the pleasure of flying.

      Put aside depreciation –i t’s a sunk cost, a toy, pure pleasure.

      So what are the operating expenses including fuel, hanger, maintenance and repairs? Obviously more repairs in later years. but just to get a handle.

      (Obviously I am a non-plane owner, not even a pilot.)

      • David:

        These days, a typical recreational flyer logs 30 hours per year or less. But to your question, this little band of aviators could expect to pay $300 to $600 per month for a T-hanger (depending upon location); about $2,400 per year for insurance; about $3,000 per year for scheduled maintenance (annual inspections, mostly). That’s $9,000 a year for “overhead,” assuming that the costs of capital are ignored. With four pilots at 30 hours per year each, that would work out to $75 per flight hour. Over time, the annual maintenance costs will be twice that amount, as you account for equipment costs and government-mandated “upgrades.”

        Your four souls would be better off if they found six others; formed a corporation to act as aircraft owner; created a “floating fee” flying club (monthly expenses divided evenly among shareholder members); hired an accountant and a lawyer; billed for flight time on a wet rate based on tach time, rather than “clock” time (encourages economical operations) plus an hourly reserve for engine overhaul. Ten non-student members would fly a yearly total of about 300 hours (adding students to the mix would increase usage by about 50 hours per year per active student pilot. Assuming 6 gallons per hour at $6 per gallon; a 2,000 TBO on a $24,000 engine; hourly operating costs would work out to $48. Add in the $9,000 of overhead, and divide that by 10 members; then amortize each member’s fixed costs on the basis of 30 hours worth of flying, and you get $30 per hour. Add that to the hourly operating cost calculated above, and you come up with an “hourly” cost of $78. Ignored in all of this is the typical tachometer hour / clock hour ratio of 0.82 in mixed operations. That can mean an 18% reduction in your hourly costs – but only if you “fly off” the bonus time.

        Is it better than renting an airplane on a spot basis? Maybe. You’ll have excellent access to a well-maintained, hangared vehicle. You’ll be able to take it away from base for more than a few hours at a time, without financial penalty (something that you typically can’t do with an FBO-supplied rental bird). The plane will age at a reasonable rate.

        On the downside, there’s no fleet mix – your one bird is the only bird in your “fleet,” so you’d better pick a make and model that’s a good match for the needs of the membership. Members will want to move on, and non-members will want to join the group. Managing and scheduling are best done by an experienced (if not necessarily professional) soul.

        On the personal side, each pilot is responsible for his/her own training/currency costs, supplies, flight reviews, medical certification, etc. None of this is cheap, but it does cost less than an annual membership at a mid-level country club in suburbia.

          • Edd:

            It is indeed “often quoted.” My own use of it comes from conversations with FAA personnel and from “anecdotal” evidence such as examining the logbook records of pilots I give flight reviews to, and from conversations with “casual” pilots and with mechanics, at events of all kinds.

            The only direct evidence that the Feds can get ahold of comes from three sources: Pilot medical certificate applications, Pilot certificate applications, and various investigations that involve examination of logbook records.

            If anything, I’d say that for recent years, the 30-hours-per-year figure is an over-estimate. I talk with mechanics who report doing a lot of annuals on airplanes that fly less than 20 hours per year. Even where those vehicles are flown by a single pilot, that’s not helping the oft-cited 30-hours-per-year figure.

  • Just an observation or two, not to disagree with decrying the high cost of light, piston, GA airplanes such as the Cessna 172. How will revising Part 23 Certification requirements, or put light piston planes in a different certification category, lower the price, for instance, of a Cessna 172?

    It won’t. That price reflects sunk costs, including certification, on the part of Cessna, which have to be recovered. For future airplanes, or future 172 models, maybe. But, I doubt it. I believe a complete rethink of certification, licensing requirements, and so forth, for light piston aircraft is necessary. Fiddling around the edges isn’t going to do it.

    That said, I really can’t blame FAA personnel for being careful about this. They personally have everything to lose, and almost nothing to gain, or at least nothing definitive, for solving the problem, especially if it turns out bad. Unfortunately, they will need political and media cover to relax or rethink requirements. I would want that, in their shoes. Wouldn’t you?

  • “….A key problem is that that light airplanes like the Cessna 172 are lumped together with 400 knot business jets for the purposes of certification. Both are subject to FAR Part 23, which prescribes the certification standards for airplanes under 12,500 lbs. As turboprops and jets have become increasingly sophisticated, the certification process has grown equally complicated….”

    This statement is somewhat mis-leading. While Part 23 is applicable to a “new” 172 and light jets, they are not required to meet the same requirements. In the case of a “new” 172, there will be a significant portion of the requirements that will simply be responded to as N/A, Not Applicable. And the opposite obtains for a light jet for some of the other requirements.

    My cynical side agrees with Patrick. This exercise for the ~50 FAA employees will provide a 10 year coast towards retirement. If I recall correctly, it took more than 10 years to accept the LSA ASTM Standards.

  • Its not just the airplane that is subject to the FAA approval process. It’s every other component like a simple GPS or radio or other basic instruments.

  • Steve Phoenix had the most telling comment….the small number of units produced is the main reason for the seemingly out of proportion pricing. With the cost of materials,labor,physical plant and government regulatory compliance being what they are, I doubt that a streamlined certification process for small GA aircraft would result in enough savings for the manufacturer to make a significent difference in the pricing.

    The potential aircraft owner/renter is still faced with the high costs of training,fuel,service,parking/hangar,insurance and service. This combination continues to stifle the light aircraft industry.

    • What you say in your second paragraph about cost has been true during my continuous presence in GA since 1956.

      In 1956 through 1958 I worked at a small airport in CT. Every week-end, guys who were military pilots during WWII, who loved flying, but were now employed as a beer delivery truck driver, carpentry, or something similar, could not afford to own or rent something like an Aeronca 7AC. Owning and flying your own plane needed a higher rung on the ladder. A dentist owned a new Ercoupe that he hangared and would drive up with his Muntz Jet convertible. Some Yale students would show up sometimes to rent 7ACs for parachute jumping.

      The people that tie-down near me at KLGB now are certainly not your ‘average Joe’ either.

      • Is the cost of owning a small plane a great deal higher than owning a boat?

        You get my drift. There are literally millions of Americans who can afford to buy and maintain a boat.

        So I don’t think that cost alone could be the reason for decline in Flying small planes. No?

        For that matter as to the capital cost of a ton of airplane versus a ton of boat, (sail or power, take your pick) I’d like to hear the analysis.

        • David, up here where I live, boats are only useful in the summer. Lakes, streams, and ponds are frozen over. Most light planes have heated cabins, (except for some of the LSA’s,) and are useable even during the winter. A note to this, I’d rather fly in a straight line to my destination, over the mountains, over the forests, and over the communities, than wander around in circles avoiding those obstacles.
          I’m not very good at describing the sheer joy of flying for the sheer pleasure of it, versus your “boats,” though my youngest brother thinks along your lines.
          Saying the above though, has me totally discouraged, as I can no longer afford that pleasure, as too many groups have put too many obstacles in my path, not the least is the outrageous cost of flying for the sheer joy of it.

        • I’ve owned several boats and the cost of purchase, ownership and operation is significantly less than aircraft ownership.

          The boats all had a lower purchase price. Probably a lot more competition and no certification or manufacturer liability insurance needed. Also, probably a lot more made.

          The boats sat in my driveway on a trailer when not being used.

          There was no required maintenance. The engines are cheap, derived from high quantity auto engines in my case. Outboard engines are not expensive either. Must be built in larger numbers v aircraft engines.

          So, overall, I suggest a boat can be owned by an average Joe, but an airplane cannot.

          • Obtaining and maintaining a PPL isn’t chump change either, to say nothing of obtaining and maintaining something to use it in.

  • Folks, the bottom line is that aviation is no longer a “fun” recreation..it is now a huge investment. I am working on my CFI and do not see any real young pilot growth regarding GA. How many young people do we know tell you they are looking to become a pilot let alone buying or renting an airplane. The cost of 100LL, rental fees, insurance and let’s not even touch buying a new (outragiously priced)or used airframe. GA is just another byproduct of our screwed up overpriced society. How many older pilots have you seen or heard about leaving GA due to the costs? Could someone please explain to me why there is so much emphasis on multi-million dollar jets being produced..(faster, bigger, ungodly expensive)and a major manufacturer closing it’s doors??? The price of admission (PPL), operating an airplane and enjoying aviation again, what needs to be done? I have a clue, but my ideas would be squashed by the government, crooked investors and overpaid CEO’s…Now I am depressed just thinking about it…I am heading to the airfield to rent the Arrow for $127.00/hr(plus fuel) and relax…yeh right!!!

  • One thing I find interesting is the cost or Certified Avionics like a EFD1000 and “experimental” devices like Dynon. Probably the clearest example of the certification costs since they are very comparable.

  • More than anything, the cost of an airplane reflects the near total loss of value in a United States Dollar. The dollar is approaching 1 cent compared to a 1910 USD. Gold was difficult to find and mine, today gold is certainly more easily found and recovered with modern machinery and chemistry.
    WWII cost the USA ONE Trillion dollars, today one trillion is the yearly deficit.
    The government profits from a weak dollar, it taxes on the number of dollars not the value of commerce.
    The United States has re-elected a communist to the White House, nothing good can come from that.

    I just hope that Congress and the Supreme Court preserve and protect the Constitution and that even the dumbest voters understand that free government handouts cost far too much.

  • The high cost of everything involving aviation is why I’ve let my medical expire and am planning to only fly under sport pilot rules and buy or build something I can actually afford to fly. Seems many are going the experimental amature built route not only for unique aircraft, but because they can be aquired and maintained for less $$, which leaves more $ to actually fly. Some even have removable or folding wings so the plane can be trailered instead of hangared. Yes, I know that’s not as convenient, but when costs are a factor it can make a big difference.

  • As someone who flew purely for fun all over the United States, Alaska, Canada, and the tropics in the 80’s and 90’s, i wish more than anything to jump in an airplane again and take it whereever i please. On one of my last trips I was able to take a 2002-model C172 for a six day trip exploring the Pacific Northwest, and the total bill for the airplane, including fuel reimbursement, was $1600. Or $800 each between my friend and I.
    $135 pp/pd.
    Prices like that will never happen again.
    The strange thing is that we are the only, the ONLY, society (USA) in known history where the middle class was able to enjoy flight as a pure recreation. (I’m qualifying this as fixed-wing, manufacturer-based 2+ place aircraft. You can still buy a chute and strap a fan to your back for pretty cheap!) From WWII until the end of the century, in the USA, normal people could get a license, purchase an aircraft, and fly a reasonable number of hours per year solely for fun. There are a thousand different regulatory, political, petroleum, and liability reasons why we enjoyed that unique position for as long as we did.
    There are also a thousand different regulatory, political, petroleum, and liability reasons that explain why we’ve finally “caught up” to the rest of the world, but the cost of flight will never, EVER, go down, certainly not from rewriting 23. And I’m sorry, but that fact hurts. I sincerely miss flying as much as anyone here who’s been forced to stay terrestrial, but expecting any “improvement” is just wishful thinking.

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