Non-Commercial Standard Category Aircraft - Would you?

[NotarPilot]

I've read some posts here where members have commented about the advantages of Experimental aircraft owners that allow them to put on non-TSO/non-PMA'd parts on their aircraft.  I copied and pasted a brief overview of the proposed changes to Part 23 by the Reorganization Aviation Rulemaking Committee.  This would allow non-commercial operators of type certificated (TC) aircraft to operate similar to Experimental Amateur Built (AB) operators.  You wouldn't have to comply with ADs if you didn't want to, you wouldn't need to get a 337 or field approval to install some piece or equipment you like, and you know those non-TSO'd LED nav lights you want for $35 bucks a side, have at it!  Your annual could be completed by an A&P who isn't an IA.  

 

Questions are:

 

1. Would you take advantage of it?

 

2. Why would you take advantage of it?

 

3. Do you think it would devalue your airplane being that it could not be used for a commercial purpose unless you converted it back to Standard Category?

 

4. Do you think these changes would make aviation safer?  More affordable?  Better for GA?  More dangerous?

 

I would like to hear other opinions.

 

The owner of any Part 23 aircraft, or heritage Part 23 aircraft (CAR3 etc) regardless of weight, number of engines or

horsepower may elect to redesignate his or her aircraft as a Non-Commercial (TC).

 

Privileges

- Aircraft in this category can be maintained by the owner using the same procedures that have been established for

Experimental AB aircraft.

- Replacement or Alteration Parts should be appropriate for aircraft use, however need not be PMA / TSO authorized.

- Owners can “opt out” of Airworthiness Directives at their discretion.

- Owners can alter their own aircraft without the requirement for a Field Approval or STC. (however, some alterations

may require “phase 1” flight testing similar to Experimental AB requirements)

 

Requirements

- Before conversion, all applicable ADs must be complied with, i.e. it must an airworthy aircraft.

- Airplane owners must affix a “non-commercial” placard readily visible to all passengers

- The aircraft must have a yearly condition inspection by an A&P Mechanic noting the fact that the aircraft is “in

condition for safe operation.” (similar to Experimental AB requirements)

- The above will be codified within Part 23 as a set of “ Operating Rules”

 

Limitations

- Aircraft can not be used to carry persons for hire, this includes aircraft rental for flight instruction.

- Aircraft owners must maintain a list in the aircraft logbook of ALL applicable ADs and their compliance status. This

list would be used to highlight the owners awareness of the ADs existence and document their choice of whether to

comply or not.

- Aircraft owners must maintain a list in the aircraft logbook of ALL alterations performed that are not FAA approved

and ALL non PMAed / TSO parts installed. This list would be used to facilitate the conversion of the aircraft back to

normal category.

 

Conversion back to Normal Category

- Aircraft operated in the Non Commercial (TC) class would be dual certificated in both the standard and non

commercial classes, as is common place for Restricted Category aircraft.

- Aircraft in the Non-Commercial (TC) category can be operated in the Standard category, provided the aircraft

reasonably meets it type design data including compliance with all ADs, removal of all Non PMA / TSO parts and

replacement with certified units and the removal of all non-certified alterations

- The conversion can be accomplished by an IA mechanic with a complete and thorough annual inspection and log

book audit. Upon successful completion the aircraft could be operated under it’s Standard Airworthiness Certificate.

The Procedure is very common with Restricted Category aircraft and has proven both safe and successful.

 

Read the entire PDF off the EAA forums here...

https://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&ved=0CDkQFjAA&url=http%3A%2F%2Feaaforums.org%2Fattachment.php%3Fattachmentid%3D1746%26d%3D1332713559&ei=GbpwUt-vAoSWiQKMpYDoDQ&usg=AFQjCNEGSYeGF_DnT-sEu2FkTA6U1bkwnQ&bvm=bv.55617003,d.cGE

[flight2000]

_{Where do I sign up?}   

 

_{I'm more than happy to convert mine over and have no worries about resale value since this is the one and only aircraft I will ever need/own.}

 

_{Not sure many vintage birds would have to worry about resale value for commercial purposes but could easily see a drop in value because it was not maintained by certified mechanics/shops.  Not that big a deal for me since I already have an aircraft, but it will make resale for those that change aircraft often a challenge if they opt into this category.} 

 

_{I have experience working on aircraft and can handle most jobs, so this would be a big benefit for me personnaly.  I do fear the changes could lead to greater short cuts for those that don't care as much as I do and possibly more accidents due to delayed, blown off, or otherwise poor maintenance by said owners.  I put my family in our plane and make damn sure it is kept in great shape to the best of my ability.  Some others are not as caring, to put it nicely, and we all have seen those aircraft that make you wonder how it ever got off the ground.}    

 

_{All of the requirements outlined seem pretty resonably to me.  Hope it comes to fruition and isn't blocked by some deep pocket association because they feel FBO's and small maintenance shops will lose a ton of money.} 

 

_{I love the FAA, but sometimes they are their own worst enemy.  Opinions from FSDO to FSDO can be very different with respect to what is acceptable and what is not for mods, 337's, etc..} 

 

_{Hopefully this will help out the owners and make GA more affordable across the board.  Only time will tell.}

 

_Cheers,

_Brian

 

[gjkirsch]

I would not take advantage of the change if it were to happen.  If I wanted an expermintal airplane, I'd buy one (or build one myslef if I really wanted to crash!).  I would prefer an accelerated program to certify new avionics rather than put non certified products in a certified plane.  Also, as time goes on, with some AD's complied with and some not, some certified avionics and some not in a plane, it will make valuations and comparisions very challenging.  The planes maintained as certified should hold their value better.  I do not look at my plane as the last one I will own (it is number 4 now), so resale is always in the back of my mind.  

[ELT]

Would making the change  to non commercial cause any problems for IFR or limit operation areas?

[Bob_Belville]

Does anyone think this option would become popular enough to affect the value of the certified fleet and the certified panels we've spent certified, inflated(?) dollars to install? E.g. my old E model probably will never be used for hire. I put 50+ AMUs in the panel that would have cost less than half(?) that, including the installation, as experimental. The value of such upgrades take a big hit now, will it be worse under the new choices? 

[chrisk]

This certainly seems like one way to fix the problem.  The other, as mentioned above, is to make the STC, field certification, and normal certification process more reasonable.   I for one, would like the option to convert my 231 to a 252.  There is no reason this needs to be as difficult as it is.

 

As to the value of a plane with a "non-commercial" certification.   I'd prefer a plane with a normal certification, just because I know what is in it.   With non-commercial, I would want to know every part that was swapped out.   I'm fine with LED lights.  I'm not so sure I would be fine with home made fuel bladders.  --Kind of like buying a plane with a damage history.

[1964-M20E]

Would making the change  to non commercial cause any problems for IFR or limit operation areas?

I'd jump at it in a heartbeat.

 

Experimental aircraft fly IFR now so I would think this would not be a problem and it should not be made into a problem if this comes to pass.

 

Resale value.  If GA falters and becomes nonexistent resale value is worthless.  Also I believe anyone with an aircraft that is more than 15 years old this would not hurt resale value might even make them more desirable.

 

I think the aircraft should still be available for rental for flight training assuming no unverified flight handling modifications are made.  I’ve rented some pretty crappy airplanes in the past.

 

I feel that inside the cabin should be fair game for anything that meets a minimum performance spec set forth by the FAA for communication and navigation.  I think most hand held GPS devices today (aviation dedicated or IPAD type) are more than capable of handling in route IFR navigation.  For non-precision approaches I think an aviation dedicated hand held GPS and for precision GPS approaches a panel mount would be the best option. Portable ADS-B in - out devices should be available and usable.

 

Why does an engine monitor or gauge need to be STCed for a particular aircraft.  As long as it can accurately reports the parameters it is monitoring what difference does it make.  The engine will run with or without monitoring it just gives you a warm and fuzzy about the engine.

 

Assuming the engine mounts have the same bolt pattern why am I limited to what variant of the Lycoming IO-360 engine I can put on the front of my plane or for that matter any engine that has the same form and fit and performance.  Would I put a PT-6 under the cowl no!  I couldn’t not afford it and besides the HP difference is too much.  However +/-15% of the original designed HP for the plane I feel would be fair game assuming you have carefully considers W&B and other engineering and design issues.

 

For example right now Avidyne could be producing a workable fine GPS NAV COM if it were not for the FAA holding them back.

 

I’ve always wondered why I can do a myriad of maintenance activities like completely remove and replace the cowl on my aircraft, change the tires and tubes but I cannot replace the starter.  This boggles the mind.  I would even take on an engine overhaul with some guidance and sending out certain pats to be reworked.

.

[Sabremech]

I'm in favor of this especially for the vintage aircraft. I've been holding off of installing an autopilot because a certified system is 16K and a comparable non certified system is 3K. I find that owners of experimental aircraft maintain them to a very high standard as they are more involved in the maint than the normal owner of a certified aircraft. It's their baby in most cases because they built it. This is definitely heading in the right direction.

David

[NotarPilot]

I, for one, believe this has the potential to make GA safer and here's an example why. Dynon offers a very sophisticated and reliable glass display with autopilot at a fraction of the cost of say a Garmin G500 or Aspen. Reading the capabilities makes me believe this new technology has the potential to save some people's bacon when they get in a pickle. Here's a brief part of the capabilities I just read.

FEATURES: Every Dynon autopilot can fly magnetic heading, GPS ground track, and horizontal NAV from any connected compatible radio or GPS. Now with new extraordinary IFR capabilities, the autopiltot also includes fully-coupled approaches, coupled VNAV, IAS

Hold, Mode Sequencing, and Flight Director guidance. Additional standard features include emergency 180-degree turn capability and a new LEVEL button to immediately return the aircraft to straight and level flight.

Imagine being able to push a button to level the wings if you went IIMC and got disoriented. Not to mention AFFORDABLE synthetic vision on a screen big enough to see. With greater affordability I think more owner pilots will take advantage of this technology which could ultimately make flying safer.

According to an August 2, 2013 article in AvWeb, "The FAA said its revision of Part 23, which governs the certification of GA aircraft, should be complete in July 2016." So I guess we only need to wait three years.

[aaronk25]

Sign me up.........I'll start running auto gas tomorrow!

[Oscar Avalle]

Sign me up too.  As mentioned by Brian, this is my last plane. I have invested a lot of money and efforts in getting it to where I would like it to be. However, looking into the future, I there is a new and improved autopilot on the horizon. Autogas, engine upgrade you name it.

 

The question I have is about insurance. What would be the impact on the our insurance bill. 

[aviatoreb]

NotarPilot, where is this proposal in terms of its adoption.  Is it already adopted?  Just proposed?  When would we see such a rule in place?

 

Not only do I want cheaper equipment, I want proven safety equipment that is simply not currently available to me.  I.e., top of my list are:

 

1) Airbag seatbelts - http://www.amsafe.com/products-services/commercial-aviation/airbags-restraints/seatbelt-airbag-system/

2) A digital autopilot - with envelope protection/automatic unusual attitude recovery...and possibly someday auto land.  http://www.avidyne.com/products/dfc90/

 

its just plane silly that I cannot have this stuff in the name of a stc process that is so expensive and arduous in the name of safety that it is not economically reasonable to put these and other proven equipment through the process for my airframe.

 

3) Gami Prism, http://www.gami.com/prism/prism.php

[aviatoreb]

.

[Rwsavory]

There is no way that our 45+ year old Mooney will ever be used for commercial purposes, and its value will never be tied to such usage.  I would covert it over immediately if given the chance, if for no other reason than the ability to install lower cost avionics.      

[BigTex]

The question I'd have is when the time comes to sell. Would buyers given a choice of similarly equipped planes, choose the Certified aircraft over the one in this new category? If so, what would be the hit?

It might be like when you do a sell by owner for your house, they know you don't have to pay the 6% commission so they try to deduct that as part of the negotiations. Would we see the same thing with buyers knowing you didn't pay the TSO/PMA prices so offers would be adjusted accordingly?

[jlunseth]

I have looked through the Nall Report for a few years now.  EXP accidents dropped dramatically in the last report that came out.  However, mechanical accidents in EXP are as common as landing and takeoff accidents in type certificated aircraft.  If you know the Report, that is pretty bad.

 

No thanks.

[N601RX]

There is also some language in the new category that could be interpreted to mean in order to sell it you would have to remove all the changes you have made.  This needs to be removed or clarified.

[Marauder]

I actually think if this comes to fruition, it would be a good thing. I certainly won't be cutting any corners in the maintenance of my plane. In fact, I probably would add more safety features because they became more affordable. The only reason I never went the home built route is that as a kid I sucked at building things with Legos or Lincoln Logs -- and I would never trust myself flying something I built!

 

Having a certified airframe, with greater access to reasonably priced upgrades makes sense to me.

[Rwsavory]

The question I'd have is when the time comes to sell. Would buyers given a choice of similarly equipped planes, choose the Certified aircraft over the one in this new category? If so, what would be the hit?

It might be like when you do a sell by owner for your house, they know you don't have to pay the 6% commission so they try to deduct that as part of the negotiations. Would we see the same thing with buyers knowing you didn't pay the TSO/PMA prices so offers would be adjusted accordingly?

 

I am sure buyers will take this into account, just as they do now with engine time, etc.  If I can save $25,000 or so in hard cash when upgrading avionics I would be happy to pass the savings on to the next owner.  

[BigTex]

I've been eyeing a Stinson 108-3 project where it would need a full up restoration. Does anyone know if something like this allow me to perform the restoration without the watchful eyes of an IA? If so, I can see how this would really help get some old birds flying again.

[aviatoreb]

I am sure buyers will take this into account, just as they do now with engine time, etc.  If I can save $25,000 or so in hard cash when upgrading avionics I would be happy to pass the savings on to the next owner.  

 

Thing is one takes a major hit in the cost of upgrades.  I.e., $15k for a GPS upgrade does not net $15k increase in sales price.  More like its worth $5 or $7k in sales price.  So I figure if we install a $5k Dynon, and it looses 30-50% of its value and I net $1.5-3k in increase in sales cost, I figure I have lost less versus the current certified version of the same. 

 

For this reason I would not hesitate to install whatever equipment I see fit for safety and convenience of my particular owner-run operation and as allowed by the law at the time of the install.  So if I am allowed to install a Dynon, or Gami Prism, or an Amsafe seatbelt by rules in a few years, then by all means I would do so and at the cheaper semi-certified rules to come.

[piperpainter]

In a heartbeat I would make this change. Along with just about every other pilot I personally know that doesn't use their airplane for hire. There is so much that could be done at a much smaller cost. This would boost aviation because you would be able to afford those experimental options that are 1/4 cost of certified stuff. I am drooling at the thought of this!

[mike_elliott]

You guys are making a good point about auto fuel.  Ethanol free premium unleaded is readily available for the marine market here where I live in Florida.  I would retard my timing from 25 to 20 degrees and use it in a minute if I could do so legally.  I would make the transition methodically to make sure that it was safe, but I'm almost certain that it would be with no further modifications.  That would save 2 bucks a gallon, and eliminate the pending 100LL crisis that I have been reading about for years now. 

 

With 100 LL at 4.25/ gal at x25, and Unleaded 93 ethanol free gas at 3.99 gal here, I am not so sure I would change much.

[aviatoreb]

With 100 LL at 4.25/ gal at x25, and Unleaded 93 ethanol free gas at 3.99 gal here, I am not so sure I would change much.

 

$4.25?!!!  I have avgas envy....  I am paying $5.99 at my homefield and generally from $5.75-$7.00 regionally.

[aaronk25]

With 100 LL at 4.25/ gal at x25, and Unleaded 93 ethanol free gas at 3.99 gal here, I am not so sure I would change much.

I would as the lead sludge is bad stuff!