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New "Low Complexity" Aircraft Category in FAA Part 23 CPS

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  • dave santos
    The big news in the FAA Part 23 CPS certifications-overhaul recommendations (that Brian shared) is a proposed easy-track for certification of Low
    Message 1 of 2 , Apr 21, 2012
      The big news in the FAA Part 23 CPS certifications-overhaul recommendations (that Brian shared) is a proposed easy-track for certification of "Low Complexity" aircraft; making this a special streamlined Category. The world's aviation authorities will follow suit with such new policies, for operational and market compatibility.
       
      The key forces behind this deregulatory concession for Low Complexity are the powerful pilots' lobbies like VAA, NBAA, AOPA, and EAA, whose members fly simple old aircraft Types in large numbers, and want certification norms to match. In fact, the AVERAGE age of a General Aviation aircraft is nearly forty years! Its like Cuba up there, these vehicles just won't die. The mostly very old and rich men who fly "WarBirds", actual historic military aircraft, where a particularly powerful political force in this latest result. Low Complexity AWE gets to ride this unstoppable parade. KiteLab Group is a particular tiny voice that has advocated Low Complexity preferences in aviation circles.
       
      On the other hand, Medium Complexity"and "High Complexity" aircraft will be even more closely regulated for high-consequence safety. Aircraft dependent on software, fly-by-wire, high-voltage power, and aerobatic autonomy are clearly headed for the "High Complexity" category. "Low/Medium/High Performance" is being correlated with matching Low/Medium/High.Complexity designation. This is more than just airspeed-based, but also broad operational capabilities like VTOL, and high-altitude designs. The expert presumption is that enhanced performance generally entails added complexity.
       
      This major FAA sponsored report is further confirmation that Low Complexity  AWES aircraft are favored by current and future regulatory frameworks for early certification and lower cost-of-regulatory-compliance. The Part 23 class no longer tops at 12500lbs, but at 19,000lbs flying weight (since the '70s). Thats a lot of potential power for the "rag-flappers" driving groundgens; several megawatts in a good breeze. Flygens net less power within a flight weight limit, needing extra power just to lift electrical systems, as well as flying into the High Complexity trap.
       
      AWES KIS is not just about good design in itself, but is also nicely rewarded by FARs. The pending policy goal is for AWES with a PIC present not to be classed as UAS, as is reasonable.
       
      These issues will be included in TACO 1.1.
       
       
       
       
       
    • blturner3
      I think making an aircraft unmanned, tethered and remote greatly decreases the risk to life and property. Low risk should be the same as low complexity from a
      Message 2 of 2 , Apr 23, 2012
        I think making an aircraft unmanned, tethered and remote greatly decreases the risk to life and property. Low risk should be the same as low complexity from a regulatory point of view. I did notice that they were now considering weight and speed as not being enough to judge the danger an aircraft posed. Perhaps we should add operating height as an important variable in our own risk assessments.

        Brian

        --- In AirborneWindEnergy@yahoogroups.com, dave santos <santos137@...> wrote:
        >
        > The big news in the FAA Part 23 CPS certifications-overhaul recommendations (that Brian shared) is a proposed easy-track for certification of "Low Complexity" aircraft; making this a special streamlined Category. The world's aviation authorities will follow suit with such new policies, for operational and market compatibility.
        >  
        > The key forces behind this deregulatory concession for Low Complexity are the powerful pilots' lobbies like VAA, NBAA, AOPA, and EAA, whose members fly simple old aircraft Types in large numbers, and want certification norms to match. In fact, the AVERAGE age of a General Aviation aircraft is nearly forty years! Its like Cuba up there, these vehicles just won't die. The mostly very old and rich men who fly "WarBirds", actual historic military aircraft, where a particularly powerful political force in this latest result. Low Complexity AWE gets to ride this unstoppable parade. KiteLab Group is a particular tiny voice that has advocated Low Complexity preferences in aviation circles.
        >  
        > On the other hand, Medium Complexity"and "High Complexity" aircraft will be even more closely regulated for high-consequence safety. Aircraft dependent on software, fly-by-wire, high-voltage power, and aerobatic autonomy are clearly headed for the "High Complexity" category. "Low/Medium/High Performance" is being correlated with matching Low/Medium/High.Complexity designation. This is more than just airspeed-based, but also broad operational capabilities like VTOL, and high-altitude designs. The expert presumption is that enhanced performance generally entails added complexity.
        >  
        > This major FAA sponsored report is further confirmation that Low Complexity  AWES aircraft are favored by current and future regulatory frameworks for early certification and lower cost-of-regulatory-compliance. The Part 23 class no longer tops at 12500lbs, but at 19,000lbs flying weight (since the '70s). Thats a lot of potential power for the "rag-flappers" driving groundgens; several megawatts in a good breeze. Flygens net less power within a flight weight limit, needing extra power just to lift electrical systems, as well as flying into the High Complexity trap.
        >  
        > AWES KIS is not just about good design in itself, but is also nicely rewarded by FARs. The pending policy goal is for AWES with a PIC present not to be classed as UAS, as is reasonable.
        >  
        > These issues will be included in TACO 1.1.
        >  
        >  
        >  
        > http://www.faa.gov/about/office_org/headquarters_offices/avs/offices/air/directorates_field/small_airplanes/media/CPS_Part_23.pdf
        >
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