The FAA Didn’t Do It

A reader commented on a recent blog that if the FAA required less safety equipment the price of new airplanes would be a lot lower. At first that makes some sense, but when I thought a moment, it just isn’t the case. The FAA really hasn’t added many safety requirements for light airplanes, and certainly nothing on the order of automobile safety equipment changes in the last 30 years.

The writer cited the ELT requirement as one of the FAA required cost drivers for new airplanes. But ELTs have been required for more than 40 years, and were required during the golden age of GA production in the second half of the 1970s when annual production reached nearly 18,000 airplanes. Clearly the cost of ELTs wasn’t anything that bothered new airplane customers then.

The only two specific FAA required safety equipment changes that come to my mind since the 1970s are for seats and restraints, and Mode C transponders.

In the 1970s the FAA began requiring shoulder harnesses in at least the front seats of new airplanes. An added cost for sure, but one we all welcome. And again, airplane production was booming at the time so the added cost didn’t harm sales.

The crashworthy seat rules came later in the late 1980s and 90s and applied only to newly certified airplanes, not those continuously in production. The seat and the restraint system in new design airplanes has to protect a calibrated crash dummy from spinal injury in a 21, or in some cases higher, G load impact. At first seat design was a big challenge, but engineers worked with seat foams and seat pan designs to meet the rule without a lot of complicated seat support structure. Again, some new cost, but by then airplane prices had already soared so it was not a significant addition.

The transponder requirements that evolved from the 1970s on were safety additions, but primarily aimed at the safety of airline passengers. The public simply would no longer tolerate collisions between GA airplanes and airliners and requiring transponders in all airplanes flying near airline airports was a solution. And it has worked. Mode C transponders allow the TCAS collision warning systems in airliners to function effectively, and since the requirements for transponders and TCAS there hasn’t been a midair involving an airliner in the U.S.

GA airplane owners and pilots also benefited from the transponder rules because controllers can provide effective flight following that is not possible without Mode C. Almost universal equipage of Mode C transponders also allows the traffic warning systems in thousands of GA airplanes to “see” and warn of nearby traffic. Transponders were an added cost, a big controversy, but now something we learned to live with and are not, overall, a huge factor in airplane prices.

What did add to airplane cost over the years were the changes manufacturers made to make a better airplane even though it wasn’t an FAA requirement. For example, when Cessna put its piston singles back in production it changed to entirely fuel injected engines. Carbureted engines are perfectly FAA legal, but they can lose power because of carb ice. Cessna wanted to eliminate the chance of carb ice so the Skyhawk returned with a fuel injected engine. The 182, too. An extra cost, a nice benefit, but nothing to do with the FAA.

Nearly all airplane manufacturers transitioned from vacuum pumps and spinning rotor gyros to electronic flight instruments, not because the FAA required it, but because electronics are more reliable and pilots want it. More safety potential, more cost, but not the FAA’s fault.

Consider the Beech A36 Bonanza. It has been in continuous production for more than 45 years and the last FAA “required” airframe safety change was made in 1984 when Beech redesigned the cockpit flight controls. Because the system changed from a central column with throw-over yoke to a standard dual control wheel Beech had to conduct the full range of flight tests to be sure the control mechanism change didn’t impact handling qualities.

The flight test revealed the A36 didn’t meet every FAA requirement for low speed and stall behavior in all configurations so a wedge shaped vortex generator was added to the leading edge just ahead of each aileron. The wedge solved the flying qualities issues and the A36 has flown on for the last 30 years without additional FAA required changes. But the price of an A36 has raced ahead of inflation like all other new piston airplane prices.

We can all assemble our own very long lists of why airplane prices have risen faster than other manufactured products such as automobiles or consumer electronics, but when you look closely, the FAA really doesn’t get much of the blame for changing requirements, particularly for airplanes in production.

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18 Responses to The FAA Didn’t Do It

  1. steve carter says:

    lawyers, litigation and product liability laws are the reason for Aircraft prices being so high.

  2. Buzz Baxter says:

    Can you spell insurance? That and material compliance.

  3. Glade Montgomery says:

    Good comments Mac.

    Though I consider myself largely Libertarian, I very much dislike the common conservative assumption that regulation equals bad, and is the root of all evil. Your analysis shows how especially un-thinking is that assumption in this context.

  4. Ron Rapp says:

    The FAA isn’t solely to blame for the increasing cost of *existing* airplanes, but it does an awful lot to keep new ones out of the market. Many have tried, and many have run out of money when attempting to bring airplanes and aviation products to us. Liability costs add to the burden. And so does the small size of the industry. The smaller it gets, the more each piece costs. Sounds a lot like what’s happening right now, doesn’t it?

    • Bill P. says:

      “[B]ut it does an awful lot to keep new ones out of the market. Many have tried, and many have run out of money when attempting to bring airplanes and aviation products to us.”

      Good point. To the extent that newer and better aircraft — which hopefully employ improved design and production technology and efficiencies — can be brought to market, one would expect that the demand for, and consequently the prices of, older technology aircraft would tend to diminish.

      If, however, we see that in fact the old technology designs are maintaining their places, and their high prices, in the marketplace for an extended period of time (as is the case in aviation), that may be an indication that they are not being subjected to competition from new designs.

      So the question becomes “why?”. Is it the existing regulatory regime that is keeping newer and better designs out of the marketplace? With the exception of a few newer production designs, like the expensive Cirrus and Diamond, the real competition technology-wise seems to be coming from experimentals, which obviously don’t have to live under the regulatory regime that applies to production aircraft.

      Many people make the mistake of thinking businesses are always opposed to government regulation, but those more in the know realize that dominant, established industry-players often lobby to keep onerous regulatory regimes in place for the express purpose of making it difficult for newcomers with less capital to get into the game and compete against them. In the recent healthcare debates, this problem was cited often cited as a reason why a relatively low number of massive insurance companies dominate the marketplace for health insurance, leading to high prices for insurance.

      • Bill P. says:

        I’m not implying that GA aircraft manufacturers have actively lobbied to keep in place regulations and regulatory practices that make it very difficult for new manufacturers to bring new, competing products to market, but it looks like they have benefited from them.

  5. Bill Berson says:

    But the Cessna 172 and Beechcraft mentioned was certified well before the FAA was even created in 1958. If anyone invented a modern, safer, low cost sport airplane. the current FAA burdens would block it from the market with prohibitive certification costs and delays.
    So for sport aviation ( with minimal profit margin), the only option is uncertified Kitplanes.
    Imagine this country if every new affordable car had to be assembled from a 49% kit and the only fully assembled cars were expensive warmed over designs from 1946.

    • Mac says:

      Actually, Bill, Cessna recertified the 172 when it went back into production. That’s why it has the high-G seats and a few other changes, but not many to the basic airframe. Airplanes like the 172 that have good basic flying qualities and a sound airframe that were certified under the old CAR 3 rules can meet essentially all of the new rules except for a few things like the crashworthy seats. Even the 50 foot per second gust loading of Part 23 is not very different from the 30 fps gust of CAR 3 because there is an onset time in Part 23 but in CAR 3 the gust was calculated to be instantaneous. I don’t think Mom Nature knows how to create an instant gust, but if she could, both a CAR 3 and FAR 23 airplane are ready for it.
      Mac Mc

      • Bill Berson says:

        I checked the FAA Type Certificate Data Sheet for Cessna 172. All of the Cessna 172’s from 1955 to the present are listed on the original Type Certificate # 3A12.
        Sure they made upgrades every few years but kept the old Type certificate to save the cost. That was my point.
        New companies can’t compete with Cessna when starting from scratch. I guess even Cessna can’t afford a new Type Certificate made from scratch now.
        That’s why no sport plane (like the 1940 Mooney Mite) has ever been certified in my lifetime.
        I think it is ridiculous for any EAA representative to argue that the FAA has had little or no effect on sport aircraft production for these past 50 years. As I said before, there is no affordable certified sport aircraft production because of the cost to certify.

        • Bob says:

          Bill is right on about “cost to certify”. The biggest FAA-driven cost isn’t “safety equipment”, but the cost of all of the paperwork and of satisfying the FAA with every single detail of your airplane, and the absolutely stunningly massive paper trail associated with every individual airframe that rolls off the production line.
          The FAA does not need to personally inspect every installation of every part of the airplane for “conformity” when the manufacturer’s records already track what was installed versus what was designed.
          The FAA does not need to be involved in decisions about how to lay out the shop floor, and it certainly doesn’t need to be informed every time the company makes a change to that layout to improve efficiency.
          The FAA does not need to send a flesh-and-blood person to witness every certification test of every component, when those tests are already extensively documented and can be easily recorded from any angle desired using commercial digital HD cameras for anyone who really wants to watch them.
          The FAA does not need to dictate how a company runs its quality assurance program when other safety-critical industries like pharmaceuticals and automobiles can turn out much higher volumes at lower defect rates using established industry-standard practices and *without* the pervasive, obsessive government oversight. Ford produces more F-150 trucks ( that is, vehicles of comparable complexity to light airplanes) in one shift than the entire GA piston industry produced last year, and they’re doing it with better quality control and a lower defect rate. And that’s *without* a federal regulator standing over their shoulder at every step of the process.

          The ASTM production process already for LSAs is more than sufficient for other light airplanes. It’s high time we implemented it for other airplanes.

          • Thomas Boyle says:

            When I suggest that sport aviation could be almost entirely deregulated, I hear cries of “oh, what death traps would appear on the market!” – from people who seem to be blissfully unaware that no government agency certificates car safety. (Crash testing is done by the insurance industry.)

            Sport aviation could be almost entirely deregulated. And it probably should.

  6. I think the costs are mostly driven by two things. The most important is the low production rate of airplanes. The other thing is all the legal issues, including the cost of certification, which has been mentioned by several other posts.

    The reasons for the low demand and production rate are many but I pick up on the perception of the expense and the difficulty. One big misconception on the cost is that it is $100 per hour PLUS fuel, whereas the $100 wet Hobbs rate includes the fuel, which is about half the cost.

    The other misconception is that you can’t really do anything until you get your license, $5000–$10,000 later. The reality that we pilots know is that learning to fly is the most intensive flying that most of us do, and that a student pilots does most of the flying on the first few lessons, and essentially does ALL the flying from then on. So it is a few hundred dollars per week or month and that is time where you are flying the planes.

  7. Douglas Drummond says:

    Another misconception about being able to fly is the vision and other medical requirements. I have people tell me “I can’t see well enough; I’m near-sighted with minus seven diopter glasses.” I was certified with -16 diopters at one time — I was correctable to 20/40 for a 3rd class medical. I tell people “If you can drive at night, no problem.”

    I suspect these people are not motivated enough just like the people who can afford the country club but not an airplane. I’m in a club myself, which is why I mentioned $100 per hour for a 172 or Warrior.

  8. Harold Bickford says:

    I remember well that in the late 70s/early 80s liability insurance (resulting from high settlements from litigation in mishaps) for manufacturers, i.e. Cessna had grown to about $100k per aircraft on an average basis. Ultimately that lead to higher unit costs along with the very high inflation and interest rates of the time. In such an economic setting aircraft production numbers dropped enormously and never recovered as cost had gotten way beyond what the market could bear on the lower end of the price spectrum.
    Regulatory requirements add to cost certainly as do product improvements yet the lower end of the price spectrum actually is filled largely by kit aircraft. In my view folks do well to understand that the goal of lower cost (effective or real) can be satisfied by earning a higher income, some form of fractional ownership, settling for a used aircraft or in the spirit of EAA, building one.

  9. Bob Johnson says:

    Regulation, liability insurance, etc. all play a part, of course, but from a business perspective the high cost of aircraft is primarily due to volume, materials and labor. Why is a Tesla expensive compared to most other cars? Because it is built in much lower volume, with sophisticated materials, with more hand labor, and marketed to a high-end consumer. Why are smart phones 1000x less expensive and 1000x more powerful than supercomputers of the ’70s? Much higher volume, significant improvements in technology and material, and almost complete automation.

    Until you can progress on at least one of those three factors, you’re pushing on a rope in aviation cost-reduction. Enough volume to make a difference is unlikely to ever be achieved in aviation unless flying cars take the world by storm. Hence, material and labor are the only real cost modifiers available. Wood, steel, aluminum and fiberglass have not gotten any less expensive over the past four decades. Homebuilts have the same material issues (see Aircraft Spruce catalog prices) but sorta solve the problem using a huge amount of ‘zero-cost’ builder labor. Until we can 3-D print airplanes using a super-strong low-cost material like Unobtainium, it is unlikely the cost curve is going to bend very much. Mac’s right: increased FAA safety requirements over the years are a red herring.

  10. Thomas says:

    Have to agree – the FAA has, at least, not mandated a whole lot more safety equipment. With the cost of certificated equipment, that could have been VERY expensive – just look at what certificated ADS-B Out is costing.

    On the other hand, I suspect that if the FAA didn’t exist, or took a much more hands-off approach to regulation, we would have a lot MORE safety equipment in our aircraft than we do.

  11. Roger Halstead says:

    All I can do is agree. The FAA is not responsible except for the slow advancement and price of advanced avionics in production aircraft. Homebuilts ave been far ahead on many fronts. There is a local RV that had the ability to program the entire flight including the instrument approach with highway in the sky. The pilot had to do the landing.

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