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Four long years ago, I wrote an article in Air Facts Journal titled, “The $20 an hour Cessna 172 Experiment” (November 25, 2020) about our efforts to reduce operating costs for piston aircraft while eliminating the need for leaded gas. Our goal was to demonstrate that there are practical solutions to the challenges facing general aviation (GA), specifically its piston engine segment, which could potentially come from small, passionate entities and even individuals. The main culprit for lowering cost and emissions was the engine, so we began a challenge of finding a practical engine solution for legacy airframes and found a rather “well-traveled” C172 with a tired engine for a test bed.
Our solution involved developing a more affordable, environmentally-friendly, modern engine to directly replace existing piston engines. The focus of our mission was to eliminate the need for leaded fuel, increase the availability of older aircraft in rental fleets that most pilots could afford to rent or buy, and overall reverse the decline in GA participation. This project was self-funded, driven by a small team of passionate and highly qualified engineers and pilots who believed that practical solutions existed for the issues facing GA.
This first article outlined mostly the how and why we took on the project as a challenge to demonstrate that practical solutions exist. At the time, many legacy piston aircraft were being scraped for parts when owners faced the cost of overhauling the engine. As the legacy engine was not only the most expensive part of the ownership and operating cost, it was also why we needed leaded gas, as well as the incompatibility with modern emissions controls.
So, finding a cost-friendly solution to replace the archaic engine would solve many problems that not only keep GA frozen in the 1950’s, but lowering the cost to participate in GA for far more inspiring pilots….which is the real solution for saving GA. Additionally, such a solution with the ability to directly replace the original engine on a legacy aircraft (average GA piston aircraft are almost 50 years old) would increase the GA rental fleets in flying clubs and small operators, and could significantly lower rental rates for the same airframe.
In addition to the first Air Facts article, AOPA and EAA published their own articles on our C172-V8 project, each also generating a tremendous amount of interest and overwhelming our inbox, requiring us to upgrade our website capacity. Most contacts requested information on ordering a firewall forward kit, and/or asking if we had kits for other types of piston aircraft, especially the C182, C210, C206 and Piper PA28 series. As the engine is software controlled like any modern engine, we could efficiently customize the same engine for different airframes rather quickly. We received interest from dozens of potential dealers and shops wanting to sell and install our engines worldwide.
Initially, our idea of offering a non-certified kit to convert older aircraft to experimental category for private owners or equity-based flying clubs ran afoul of a 1950’s FAA policy (not regulation). Many wanted to buy our experimental C172 and C182 firewall forward kit regardless of FAA issues, with many saying the FAA cannot violate you based on just a policy. But we did not want to sell anything that someone potentially could not get an airworthiness certificate for and be left fighting it out with FAA lawyers. We did reach out to an aviation industry attorney, but decided a fight with the $21B budgeted agency would be foolish. So, we decided to seek FAA supplemental type certificate (STC) approval to allow owners to swap their old airframes to our firewall forward engine kit.
We had a flying C172 aircraft that eliminated need for avgas, had modern emissions, and at a price point that would likely accelerate owners to convert to make a tangible difference in the short and long term. Our complete and all-new C172 and C182 firewall forward kit was a direct bolt-on conversion and cost less than a factory overhaul of the original engine, and cost less than half to operate, all while out-performing even the newest Cessna models that perform the same as their fifty-year-older siblings.
It was a logical progression, as there was clearly an interested market, at least based on inquiries. We also believed that others would be encouraged to follow us with more practical solutions, bringing modernization, innovation, and—most importantly—lower acquisition and operating costs necessary to reignite general aviation (GA) worldwide. Moreover, the FAA had long pronounced for alternative solutions to leaded avgas as well as to further reduce emissions. Our claims were not just theoretical as most other solutions the FAA was concentrating on, we had a real flying prototype with real data to prove it, and eager to discuss its potential with FAA departments required for us to continue development.
Unfortunately, it became clear that FAA leadership had no interest in supporting such a solution—whether as an experimental conversion for certified airframes or via a STC (a certification that would allow owners to replace their original engine with ours on certified aircraft)—regardless of the potential benefits. We never proclaimed to be ‘THE’ solution, but potentially a solution that could keep older aircraft economically flying in rental fleets, as well as incite others to follow with even more new and better solutions to reignite GA, and so on…
After years of making no progress with the FAA, and witnessing certain leaders use dubious and outright unethical methods to weaponize their bureaucracy, leaving no avenue for dispute, we were forced to shut the development down. It was evident that FAA leadership was unwilling to support any solutions that might revitalize GA unless such solutions came from a legacy manufacturer, one with FAA or political insider connections, or a company with the financial means to negotiate the FAA’s piston GA gauntlet.
We continued to receive too many requests for sales and updates on the projects to keep on top of, so I wrote another Air Facts article explaining why we shut the program down, “The $20/hour Cessna 172 experiment—Update“, October 31, 2022.
To be clear, early on in the regulatory process of obtaining our experimental, multi-purpose airworthiness certificate, we had nothing but encouraging and supportive FAA assistance at the Aircraft Certification Office (ACO), and Manufacturing and Inspection District Office (MIDO), which mostly oversees aircraft manufacturers.
Our experimental C172 proved itself capable of demanding flight training missions, with both private and commercial pilots training and successfully passing their FAA checkrides in our V8-powered C172, at a fraction of the cost compared to using stock C172 aircraft. Our high school student pilot earned her Private pilot wings at a cost of less than $3,800 including aircraft operating cost (fuel, engine reserves for 60 hours), FAA DPE fee, and 30 hours CFI instruction, all without burning a drop of leaded avgas.
We calculated that any C172 with our engine kit operating in a flying club could reasonably rent at less than $60/hour wet (including gas), which would make flight training and rentals more accessible to far more people with average Private pilot training of sixty (60) hours flight time and 30 hours CFI dual cost about $5,000… less than half that of renting same vintage C172 and burning avgas. It would also be a game changer for building time, or simply flying for the joy of flying for recreational pilots.
We felt we proved such practical innovations could be a catalyst for re-igniting GA, and likely ignite other small but passionate entities to follow with other long overdue updates to the piston fleet.
The update article sparked a wave of strong and encouraging comments (which make for great reading in the article’s comments section….maybe even better than the article itself), as well as a fresh influx of emails urging us to continue our efforts. The article was even named an Air Facts “Article of the Year,” and many readers expressed their frustrations with the FAA. Many offered well-meaning suggestions on how to navigate the FAA’s bureaucratic hurdles, some with well thought out potential solutions.
We deeply appreciate the interest so many readers showed for our efforts and passion, so we took the two top (practical and legal) suggestions and again tried getting an audience with FAA leadership to discuss the hurdles facing small entities trying to bring innovation and change in the piston GA sector. Because we couldn’t respond to all your emails, we wanted to share the results of our efforts using your recommendations in this final update for Air Facts readers.
I don’t want to bore readers with the obstacles already outlined in prior articles, but suffice to state that we couldn’t even get a call back from FAA officials over the last four years, or even receive a reply from formal appeal petition that prevented us from even continuing the development.
Our goal was simple: to have a direct meeting with FAA GA leadership to discuss the obstacles they place on small entities striving to make a difference in piston general aviation, and to share our experiences from the past four years. We hoped that such a dialogue could pave the way for others wanting to make a positive impact on piston GA and maybe even be enough to resurrect the Corsair project.
Here are your three suggestions, how we implemented each, and the results.
Our most common suggestion was to ask AOPA and EAA for help in obtaining an audience with FAA leadership to explain how the agency inhibits small companies from advancing GA innovation and modernization.
As long-time members of both organizations, we requested their assistance in securing a meeting with key FAA leaders responsible for small aircraft policy and certification. Both AOPA and EAA connected us with their government affairs liaisons, with whom we engaged through phone calls and emails in January 2024. Both stated they would contact relevant FAA departments to obtain a meeting or some contact.
After months of waiting with no updates, we followed up. Murray Huling, Vice President of Regulatory Affairs at AOPA, informed us he had not received a response from the FAA but would follow up. Weeks later, Mr. Huling relayed that FAA suggested starting our entire petition process over from scratch with a new petition and suggested AOPA provide a letter of support (essentially forget all our work and waiting over last three years and try again from scratch).
EAA’s FAA liaison, Tim Charpentier, got the same response eventually. When we again asked both to help secure a meeting with FAA policy, neither could. Restarting from scratch after four years of waiting was not an option—and we felt it was merely another attempt to delay the process. And again, no offer or desire to even discuss our experience. This was what we have experienced for last four years and it came as no surprise, but we were surprised FAA would do the same to the largest GA advocate organizations. If EAA or AOPA couldn’t get even a meeting, we had no chance…and we moved on.
Both AOPA and EAA had published articles about our project early on, generating considerable interest and inquiries. We reached out to their editors to propose an update article focusing on the challenges small companies face in developing GA solutions which may find the right reader with ability to force a meeting. The AOPA editor declined, while the EAA editor did not respond.
Having exhausted both the AOPA and EAA suggested option, we moved on to the next suggestion.
Second most suggestion: contact the FAA’s Policy and Innovation Division and the Small Aircraft Directorate (AIR-600). The division’s mission is to build partnerships with private companies and assist with regulatory issues in developing innovation. This actually seemed to us as a great recommendation and we were eager to see results, or at least secure a meeting.
I reached out via email directly to Pat Mullen, Manager of the Small Airplane Standards Branch (AIR-620), and Victor Wickland, Director of Policy and Innovation (AIR-601). I summarized our four-year experience navigating FAA challenges and formally requested a meeting to discuss the difficulties small companies face when attempting to innovate in the piston GA segment.
I promptly received an email from Mr. Wickland, which he copied to other department directors, stating that someone would contact me. As expected—consistent with my past experiences—no one ever did. After seven months, I sent a follow-up email. This time, I received a response to schedule a call. Mr. Wickland’s email included Casper Wang, Product Policy Manager for Emerging Aircraft, GA, and Rotorcraft. I later received an email from James Folz, Deputy Director of Compliance & Airworthiness (AIR-620), stating that someone from emerging technologies would reach out.
Shortly after, I spoke with James Clary, Program Manager for Emerging Technologies (AIR-611). He expressed interest in addressing our challenges and promised to get back to us with potential solutions and not to blow us off. Unfortunately, but true to form, we never heard from him again. After another four months, now about a year after my initial request, I sent another email with all directors on prior emails included, as well as copying FAA head leadership and the administrator, stating I never heard back and how amazed we are in FAA’s leadership ‘ignore policy’ when it comes to GA.
The only response was from Mr. Clary, who advised me to contact my local FSDO for help—despite the fact that FSDOs have no involvement in innovation or certification policy—but no information on what we discussed four months earlier. None of the FAA executives who were copied on the emails, from the administrator or his executive staff down, offered any assistance or reply.
In my follow-up and final email, I reminded Mr. Wickland and his colleagues that my request was merely to share our experiences, believing it would help the FAA understand the challenges small entities encounter trying to bring innovation and modernization to GA….the very purpose of the FAA innovation office efforts. I was not asking for special treatment, just a chance to highlight the systemic challenges within the FAA we and others face. This is that email:
In my email to you and Mr. Mullin a year ago, I asked only of you and related departments for the opportunity to share our experience as we believed it would be helpful to understand reasons that piston GA innovation is more likely to come from small entities as ours, and the FAA induced challenges such entities face. I was not asking for or demanding anything of you, Mr. Mullin or Mr. Clary, other than to merely share our challenges trying to work through a bias and arguably corrupt FAA culture when it comes to piston GA and small business trying to innovate a stale legacy segment of GA. I would suggest the mission in your FAA innovation efforts start with the leadership culture.
You win. As many before us, we gave up.
Again, no response. As a proponent for GA, I continue to remain woefully disappointed in FAA’s leadership’s culture when it comes to GA. As a tax payer, I get a bit irritated accepting that without the inside contacts or financial resources to obtain even a meeting with FAA public servants, most cannot regardless of the merits of what they may bring. As a moderate environmentalist, I felt outrage that such a large government agency continues to systemically protect the dismal status quo while protecting legacy engine manufacturers from competition, decades after all other engine segments have long evolved, especially considering proven technologies readily exist that could have made a significant difference in health, commerce, and a vital industry to our nation.
Unfortunately, the FAA ‘ignore’ policy has additional negative effects for small companies attempting to obtain investment to develop solutions. Potential investors for our project were more than concerned of FAA’s lack of interest and refusal to even return our calls. This was considered a significant risk factor by them, and understandably. The FAA’s innovation section was also developed to assist bringing innovation and investment to US programs. However, their lack, and I would say willful dereliction, further makes investing in GA seem even more risky beyond the civil liability risk and certification costs the segment is infamous for, not to mention the shrinking GA market size to produce worthwhile return on investment.
With no further replies from any of the many FAA officials we reached out to, including those we have formally requested responses from over last four years, we had no other options left. We considered this suggested solution a failure as well.
We do not like being someone that criticizes without at least offering potential solutions worth considering. So, I reached out and spoke with many in the GA sphere, from flight schools to repair shops, and asked what they believed piston GA needed to reverse its course. Most long time GA participants, myself included, believe for GA to survive there must be an industry and FAA meaningful effort in:
- Significantly reducing cost to fly legacy aircraft. The average age of the GA piston fleet is approaching 50 years. Legacy aircraft will remain the majority of the worldwide piston fleet for decades to come, and practical efforts must focus on reinventing the fleet. This is the path of least resistance for developing an affordable rental fleet. Focus must be to find methods to significantly lower ownership and operating cost to keep them economically viable, less expensive to maintain in replacement parts/components, especially obsolete parts; and less expensive methods to ‘certify’ non-critical replacement parts. The goal must be to keep the aging fleet flying at costs the majority of new GA pilots can afford with wider availability of flying clubs and other rental sources, as well as reduce the number of good planes parted-out solely for economic reasons.
- Developing methods to update legacy aircraft that not only lower cost, but increase safety and incorporates innovation. For example, replacing original mechanical instruments/gauges that are expensive to maintain or replace with just basic flat panel EFIS systems that are well proven in the experimental world. EAA was able to certify some non-certified/experimental EFIS systems for common certified aircraft types by working with FAA to obtain STC’s. This could eliminate antique vacuum systems and increase safety with larger sized attitude indicators, display of traffic; nearby airport depiction with glide radius; AoA warnings, more accurate fuel sensors and warnings; and weather orientation. Such non-certified systems could have additional limitation for use only for VFR operations, and/or IFR in VMC.
- Fast track needed safety enhancements for use in certified aircraft. Simple and proven solutions, such as low fuel warning alert, could make a real difference. Over 50% of fuel-related accidents are caused by simply running tanks dry and legacy fuel gauges are notorious for inaccuracy. Fuel exhaustion has been an FAA focus for decades, yet there has been no FAA outreach or encouragement to industry to develop practical solutions, or to ‘fast-track’ simple solutions for certification. Cars have had such “idiot” lights for decades that could easily be installed on aircraft (simply a float switch that grounds a bulb). Likewise, larger size attitude indicators significantly decrease spatial orientation compared to the 1940’s 3” vacuum gyros. Such simple, practical and long-proven solutions exist in mass and could have prevented many accidents and fatalities over the last few decades, as well as reduce insurance risk and rates which lowers ownership cost. A win-win for all.
- Legacy piston aircraft must be more environmentally friendly, and finally eliminate need for leaded fuel. However, any new fuel must be less expensive and widely available. I don’t see this happening with any new approved AVGAS substitutes. We chose a flex-fuel engine for our C172-V8 because it can burn different fuel types, including regular automotive gas with ethanol, which further reduces emissions and allows for modern emissions controls. STC’s for approving use of automotive non-ethanol gas should be expanded to more aircraft types and fuel be made available at more airports. Many airports have automotive gas on site for ground equipment and vehicles, but not always convenient for direct fueling of aircraft.
- The industry and FAA must focus on increasing number of student pilots starting flight training, and not just those training for airline careers. This starts with campaigns to attract new pilots, encourage and develop policies to start flying clubs and increasing rental fleet size, push for federal tax incentives which was a considerable factor in GA’s heydays, working with insurance carriers to find ways to lower cost, and exploring experimental aircraft flying club regulations that mostly restrict experimental aircraft from rental.
- The inability of even the greatest advocates we have, such as AOPA, to facilitate meaningful change in what’s needed for piston GA to begin a recovery suggests a change in tactics. Many suggested we, as well as AOPA and EAA, take a more aggressive approach on hot topics as certification restrictions, harmful emissions and insufficient number of pilot examiners by filing law suits to force change. Small entities simply don’t have the resources to do this. Much regulatory headway in other industries have come as a result of legal actions that forced change when government entities refused to act in the publics best interest on their own.
- Last, but most important, end FAA anti-GA piston culture evident by lack of evolution over the last four decades. This culture not only discourages innovation, but, as in our case, prevents it. And we are not alone. Appoint FAA leaders that want to find real solutions and strategies to work with all stake holders to develop meaningful and safe solutions that lower costs and increase the appeal to new comers. Including:
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- Fast-track and encourage practical safety components and devices that are fail-passive (their failure would not leave the aircraft in less safe of a condition than if not installed) for the legacy piston fleet. Basic autopilots significantly increase safety, especially in small aircraft single pilot operations. Larger attitude indicators and better fuel level indications and warnings could have prevented many accidents. If the FAA encouraged such experimental or new technologies to migrate to older certified aircraft, with practical and affordable path ways to a STC or even field approval, small companies would follow the call with devices that make economic sense for the aging aircraft which will likely be in the GA fleet for decades to come considering the high cost and relatively low volume of newer aircraft deliveries. Even complex complete autopilot systems in the experimental/non-certified world cost about 1/3 of comparable certified units, a cost more feasible for the typical 40+ year old piston aircraft.
- FAA’s own studies long concluded such components make a significant increase in safety in small aircraft; FAA concluded, “ that inclusion of an integrated autopilot into small aircraft would provide and/or facilitate a significant increase in safety for this type of airplane. Autopilots can be found on some new small aircraft; however, due to current certification costs, the business case is not favorable for development of low cost autopilots for the small aircraft retrofit market and many new lower cost aircraft”. (FAA CASE NUMBER 88ABW-2015-4093 2). Essentially admitting certification cost being the primary factor why such safety enhancements are not produced, yet doing nothing to effect change.
- Fast-track and encourage practical safety components and devices that are fail-passive (their failure would not leave the aircraft in less safe of a condition than if not installed) for the legacy piston fleet. Basic autopilots significantly increase safety, especially in small aircraft single pilot operations. Larger attitude indicators and better fuel level indications and warnings could have prevented many accidents. If the FAA encouraged such experimental or new technologies to migrate to older certified aircraft, with practical and affordable path ways to a STC or even field approval, small companies would follow the call with devices that make economic sense for the aging aircraft which will likely be in the GA fleet for decades to come considering the high cost and relatively low volume of newer aircraft deliveries. Even complex complete autopilot systems in the experimental/non-certified world cost about 1/3 of comparable certified units, a cost more feasible for the typical 40+ year old piston aircraft.
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- Encourage exploring methods to lower emissions and noise. It’s not that difficult or rocket science with decades of inexpensive, proven technologies from other engine segments readily and economically available.
- Develop broader policies that lower the cost of keeping vintage aircraft airworthy and expanding field approvals that is now only on individual aircraft basis (essentially, allow others to use prior identical field approvals without having to repeat the same bureaucratic process).
- Allow owners of older certified aircraft to convert to experimental which could significantly lower costs for private ownership or equity based flying clubs (there is current program for converting to primary category, but FAA policy requires formal certification process for any meaningful modifications which is the reason few have done it. In our case, FAA required us to perform the same DO-178 certification basis on our C172 as a new design of a passenger wide body passenger jet!). This would save many aircraft from being parted out or scrapped, and add to an affordable rental fleet or privately owned aircraft that are cleaner and quieter to operate than its original configuration.
- Appoint more pilot examiners (DPE’s). Another example of FAA’s war on piston GA, making training take even longer and costing even more. This has been a long focus for organizations as AOPA, but with little to no results. There are plenty of DPE applicant volunteers that directly cost the FAA nothing. The DPE’s I know are bombarded with requests for checkrides and getting burned out trying to help as many candidates possible while juggling their own airline job. Others are making a full-time job of it with checkrides costing well over $1,000, often cash, in some areas now. My last three students had to rent a plane and fly out of state to get a checkride in a reasonable time, further incurring rental and hotel costs adding to the final sum of the license.
- In 2011, there were 944 DPEs that conducted 60,621 check rides; compare that to 12 years later in 2023 with 969 DPE’s to conduct 140,954 check rides (adding 120,000 annual check rides but only 25 DPEs….. again, DPEs cost the FAA nothing other than staff for oversight. FAA needs to find leadership to either find the funding or find more efficient methods of oversight). Waiting even longer for FAA to solve proclaimed oversight as an excuse cannot continue to be FAA’s perpetual excuse at GA pilot’s expense. Well-funded airlines, or expensive jet and turboprop training facilities suffer no such shortage.
“The longer you are in a spin, the more difficult it is to recover’, said one of my CFIs long ago. As GA continues its downward trajectory, it becomes more difficult to recover. More small airports close for development into condos or commercial industrial centers; aviation fuel production curtails which further increases cost and shuts down refinery production; insurance carriers continue to leave the dwindling market; more older parts become harder to source and salvage yards dry up; repair/service shops close or now only work on turboprop or jets. All such pressures resulting in fewer new participants that can afford to fly even if they have local access to rental aircraft, and GA becomes even more of a rich man’s sport than it needs to be.
Some argue that GA is recovering based on increasing new piston aircraft deliveries over the last few years. But most new aircraft will be utilized for career flight training schools at considerable cost, and most pilots will never return to GA after starting their airline career. GA’s long-term success really depends on private aircraft ownership, rental aircraft fleet availability, having local airports and training facilities, and the staple recreational pilots seeking the now elusive $100 burger, renting a plane to visit family or friends, or just practicing touch & go’s on a sunny weekend. Essentially, it’s all about end user economics.
Thanks again for all that encouraged our experiment over the last four years and taking the time to reach out.
- The Corsair C172-V8 Experiment Update #3—Reader’s Suggestions - November 4, 2024
- The $20/hour Cessna 172 experiment—Update - October 31, 2022
- The $20 an hour Cessna 172 experiment - November 25, 2020
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