For as long as I can remember pilots have been blaming unnecessarily complicated FAA certification rules for the high cost of personal airplanes and for the slow pace of technological development. The FAA has formed a committee to study FAR Part 23—the rules that govern certification of airplanes weighing less than 12,500 pounds for takeoff—to search for ways to simplify approval of piston singles and other light airplanes.
But I don’t think there is a lot to be gained by overhauling the certification standards for basic airframe structural strength and flying qualities. The real benefits in cost savings and performance improvements can come from a new look at how electronics can be used in piston airplanes.
Every pilot I know is frustrated by the capability of consumer electronics that is available for a few hundred bucks and can do more than FAA approved avionics costing many thousands. I know an iPad doesn’t have the same level of testing and software documentation as the primary flight display (PFD) flat glass system certified for a piston airplane. But the iPad cost $300 to $500 and the PFD $10,000 for entry level. The cost gap, in this case, really can be blamed on FAA certification.
It’s easy to see the extra cost burden of certification when you look at the Garmin flat glass lineup. The G600 and G500 combined PFD/MFD systems look exactly the same, and with the same list of options, have the same capabilities. But the G600 costs more because some of its software is FAA approved to a higher level than in the G500. The FAA requires the higher level of software security and testing in airplanes weighing more than 6,000 pounds so Garmin has to charge more for the G600 to perform the same functions the as the G500.
And Garmin makes a PFD for experimental airplanes that requires no FAA certification and costs a fraction of the price of the certified systems. So from one company you can trace the cost of certification without really seeing a benefit in performance and features, and I don’t think much, if any, improvement in overall reliability.
The cost difference is very dramatic when you look at avionics such as systems from Dynon, Grand Rapids Technologies, Advanced Flight Systems and others that are uncertified and intended for amateur built aircraft. These systems have amazing capabilities for a fraction of the price of an FAA certified system.
The price of avionics is a valid measure of certification costs because basic electronic components like glass displays, circuit boards, transistors and whatever come from the same pool of suppliers used to make consumer electronics like phones and computers. To certify a piece of avionics equipment these essentially standard off-the-shelf components have to be tracked and tested at a very high level. Software to operate the FAA certified system needs much more documentation and segregation than may be used in consumer electronics. And the certified system must be tested using standards and techniques that may not make all that much difference in terms of reliability, but does add cost.
Strict avionics certification standards make sense to me in larger airplanes, particularly turbine powered airplanes. These airplanes have multiple levels of power and system redundancy so you want the avionics to be as reliable and predictable as possible. Essential avionics in a transport airplane should be held to the highest possible standard.
But in piston airplanes we accept a much lower level of redundancy and basic performance in exchange for keeping cost in check. Most piston airplanes only have one electrical system, for example, and the big majority have only one engine. Demanding a higher level of testing, redundancy and performance of avionics—as certification standards typically do—than the entire airplane offers makes no sense.
Really big avionics gains are waiting to be made in autopilots if the FAA will just modify the rules. Right now an autopilot is costly and time consuming to certify, and a certification is only good for a specific airplane type. However, a “smart” autopilot could be built right now that would learn how to fly each airplane on its own and store that information in its memory without requirement for many hours of flight testing.
An autothrottle that could maintain target airspeed as well as cruise control does in our cars would be easy and inexpensive to make without complicated certification rules. Think how much safer it would be if the autothrottle maintained the ideal airspeed on landing approach.
How about automatic flight to the nearest airport in an emergency? The electronic capability is available right now for an autopilot and navigation system to jump in and automatically fly the airplane to the nearest suitable runway in an emergency such as engine failure. In fact, Vertical Power is selling such a system for experimental airplanes. But certification of this type of automated safety device under today’s rules is almost impossible.
Just look at what electronics are doing for us in all aspects of our lives. And think what could be done in our airplanes. In this case, it is out-of-date certification standards and attitudes that are keeping the potential safety and utility of modern electronics out of the cockpit, or adding so much cost that most pilots can’t afford to buy them.