FARs not the Problem
I have been a designated engineering representative (DER) for U.S. Federal Aviation Regulations (FAR) Part 27 and 29 (mechanical systems and powerplant) since 1980. In my experiences, I have seen many of the problems you described in your August editorial (“Getting the Rules Right,” R&WI, August 2015, page 4).
For instance, you write of modified aircraft kept out of service for long periods because of “disputes or confusions over the standards and procedures to be used.“ I have been asked to perform a test that was dangerous. Fortunately, the test was cancelled after the DER pilot I was working with informed the FAA project pilot.
You also speak of outfits forgoing safety improvements because “relatively minor changes would require the entire aircraft element” to be recertified under more stringent amendment. It is ridiculous to have to certify a change to a helicopter that was type certificated under the old Civil Aeronautics Regulation 6 (which predated the FAA) to the latest FAR Part 27 standard. This is usually taken care of in the Certification Program Plan, but the haranguing over this point to get the less-stringent requirement approved with inexperienced Aircraft Certification Office (ACO) personnel is maddening.
Lastly, you cite one engineer’s suggestion that certification standards should lay out performance-based functional objectives, “leaving the accepted means of meeting those objectives to advisory material.“ This would be as bad as requiring the latest amendment to the FAR. I approved a slight modification to a supplemental type certificate using the previously accepted approval requirements. The ACO then said the change needed to show how it met the latest amendment and the latest advisory circular update.
What irritates me the most is the inconsistency among ACOs and even their engineers. I once had an Electrical DER friend whose advisor said that he could not approve an electrical requirement because it fell under a structural section of the regulations. The advisors of one of my client’s company Electrical DER also said he could not approve an electrical requirement that fell under a powerplant section and that I had to do it. I do not have that authority.
It is troubling to have advisors change so often that you can never get to know them. Also, some have absolutely no work experience. In my opinion, FARs are not the problem. The problem with many (but I must admit, not with all) the ACO personnel. I have worked with some good ones.
James V. Hickey
Degrees of Separation
Mike Hangge’s essay “Six Degrees of Army Aviation” is the best I have ever read (R&WI, September 2015, page 50). Although I have never served in the armed forces (I flew for the U.S. Forest Service), I am still proud to call myself the patriarch of a military family. My grandfather, father and son were or are all career officers.
Mike’s advice is applicable to all aviators. As a professional airshow pilot, I have seen how arrogance, hastiness and inconsideration by a few of my colleagues have turned off spectators to not only airshows, but all of aviation.
Treating fans with respect and consideration always results in making even the most lukewarm of spectators into aviation enthusiasts. I can’t count the number of fans who have written to say how my wife/announcer and I have inspired them to take up flying or get an aviation-related job.
Keep up the good work, Mike! And thanks!
Robin T. Harrison
President, Murphy & Harrison, Inc.
Lake Arrowhead, California
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