Does gyroplane community really want S-LSA?

[fara]

I ask this question because I am just finishing up an engineering consulting project taking a kit built airplane company through ASTM design, flight, and production and QA standard compliance and compliance with newest FAA order for SLSA.

FAA is no longer accepting self-certification by manufacturers as is. When a new first make/model comes out and the manufacturer fills out Statement Of Compliance, the DAR or FSDO inspector is supposed to notify AIR-200 Certification branch in Washington D.C and they contact the manufacturer and tell them they are coming over in usually 30 days to do what they term as First Article Audit for compliance to ASTM standards and rules and regs etc.

I will be taking this said company through such an audit first week of November and have gone through such line of audit before with FAA as a manufacturer. Its 3 to 5 people from FAA who are auditors and they sit there and grill you for 3 to 4 days. They check your documentation but also your implementation on the factory floor and Quality Assurance Record per serial number and read and blast your engineering design and structural reports. Basically put you through the ringer.
Its not hard if you are doing what you should be doing but for example to take this company who has been making kits for 20 years for airplanes through ASTM compliance and setting up a compliant production system took, 6 months, 10 people, 8000 man hours, $273k (us and their team expenditure combined per man hours) and that was the good guy price
This system would work for a type certificate like Primary Category just the same. There is no difference.

So is gyroplane community really want to go certified gyros that are ASTM compliant? Are gyroplane manufacturers ready for such scrutiny. If some factories in Europe have type certificate and Production certificate (TC and PC), they would not have much problem but if they are under microlight rules similar to DULV etc., that will not cut the mustard with FAA.

Would like to know people's general thoughts on the subject.

[Vance]

“Does gyroplane community really want S-LSA?”

Originally Posted by fara

I ask this question because I am just finishing up an engineering consulting project taking a kit built airplane company through ASTM design, flight, and production and QA standard compliance and compliance with newest FAA order for SLSA.

FAA is no longer accepting self-certification by manufacturers as is. When a new first make/model comes out and the manufacturer fills out Statement Of Compliance, the DAR or FSDO inspector is supposed to notify AIR-200 Certification branch in Washington D.C and they contact the manufacturer and tell them they are coming over in usually 30 days to do what they term as First Article Audit for compliance to ASTM standards and rules and regs etc.

I will be taking this said company through such an audit first week of November and have gone through such line of audit before with FAA as a manufacturer. Its 3 to 5 people from FAA who are auditors and they sit there and grill you for 3 to 4 days. They check your documentation but also your implementation on the factory floor and Quality Assurance Record per serial number and read and blast your engineering design and structural reports. Basically put you through the ringer.
Its not hard if you are doing what you should be doing but for example to take this company who has been making kits for 20 years for airplanes through ASTM compliance and setting up a compliant production system took, 6 months, 10 people, 8000 man hours, $273k (us and their team expenditure combined per man hours) and that was the good guy price
This system would work for a type certificate like Primary Category just the same. There is no difference.

So is gyroplane community really want to go certified gyros that are ASTM compliant? Are gyroplane manufacturers ready for such scrutiny. If some factories in Europe have type certificate and Production certificate (TC and PC), they would not have much problem but if they are under microlight rules similar to DULV etc., that will not cut the mustard with FAA.

Would like to know people's general thoughts on the subject.

Hello Abid,

What exactly does that entail?

How much would that add to the price of a gyroplane?

How much would the coast of liability insurance for the manufacturer add to each gyroplane?

I am not a viable customer for an SLSA; how would having SLSA affect my participation in the hobby of flying experimental gyroplanes?

I suspect you know that SLSA and Certified are two very different things; which are you asking about?

Thank you, Vance

[HobbyCAD]

Good Day Adib,

I know exactly what you are talking about. So you were able to show to your FAA, compliance against the air worthiness regulations and conformity against the approved design data in just 6 months? Count yourself lucky !!!

I am in my last laps of our program, managing a complete Part-23 TC of a new aircraft. It has been 2 years, and a couple of million dollars.

...and halfway through the program, just when I thought it was going well, the FAA comes and visits Australia. To maintain the bilateral aviation agreement between our 2 countries, the requirement grew, another year of work got added.

I'd love to see your certification process flowchart.

Count yourself so damn lucky if your first article inspections, ground type inspections and conformity verification inspections are only 5 days.

Regards,

Francois

[HydroGyroNut]

The cost of beauracracy...Just for a freaking hobby... so much unnecessary cost... Hey, count me out. I will fly based on a good history alone and sound engineering principles. I dont need the extra cost of the beureaucrats adding to already high cost of certified gyros out of europe. Heck no...No certified ASTM compliant gyro for me.. Will go with 51% amateur built at a lower cost.

[jebthereb]

As long as there is still an EAB category I ok with seeing some ASTM compliant Gyro's. It is good that the Gyro is seeing some use with the Law Enforcement community but I would like to see it get more use in the GA community also. I love my helicopter but there are obviously some things that a Gyro can do at a lower cost to operator and customer alike.

[Fly Army]

Part 23 certification is rightfully more involved and expensive. I was involved in LSA ASTM for a fixed wing aircraft from the Czech Republic and even back then I knew this "self-certification" wasn't going to last. It was only a matter of time before someone abused it and thus we have the hoopla that we now have.

We're never going to grow the gyroplane movement without the S-LSA blessing IMHO. I recall reading a post from an enthusiast in the UK that pointed out how the growth of the factory built gyros in his country resulted in a lot of rich "Dilberts" coming into the fold and that is unfortunately inevitable if and when we get S-LSA gyros here. But if we follow the example of the AOPA we can see that these Dilberts can have their uses in growing a support base and building influence in a very positive way.

[fara]

Originally Posted by HobbyCAD

Good Day Adib,

I know exactly what you are talking about. So you were able to show to your FAA, compliance against the air worthiness regulations and conformity against the approved design data in just 6 months? Count yourself lucky !!!

I am in my last laps of our program, managing a complete Part-23 TC of a new aircraft. It has been 2 years, and a couple of million dollars.

...and halfway through the program, just when I thought it was going well, the FAA comes and visits Australia. To maintain the bilateral aviation agreement between our 2 countries, the requirement grew, another year of work got added.

I'd love to see your certification process flowchart.

Count yourself so damn lucky if your first article inspections, ground type inspections and conformity verification inspections are only 5 days.

Regards,

Francois

Francois:
Yeah I was able to do that but you have to know the whole story. Some other consulting company was working on doing that before mine for 18 months for the same model.

So if you want to count the total time spent on the project it was 2 years.
Also remember this company has over 600 of this model flying around already as Exp-AB and we did not do a new design just analyzed the design, did structural, performance and design testing and changed certain things to comply and most importantly set up a compliant production system.

The 5 day thing is an audit. Its not inspection of the design and a through approval of design working with ACO and DERs as in Part 23.
Part 23 GA is moving towards self compliance also now. They just formed a GA sub-committee called F44 in ASTM and I just joined it. Its first meeting is in Atlanta this week. Same place where ASTM F37 committee meeting is. If you are into this stuff you should join F44 committee. It will determine your industry's future and it will cut out a lot of red tape.

[fara]

Vance:
To be very honest. ASTM compliance to design for airplanes for example is absolutely no different than design compliance for Part 23 Appendix A. In some areas ASTM standard more than Part 23 does. Structural tests, design criteria and number of things you ahve to do engineering wise for structural design compliance are quite identical.

The major difference is in QA standard which essentially defines the PC or production system. ASTM standard is much less demanding than Part 23 or PC would require. A typical Type Certificate for a small airplane (TC) in Part 23 would probably be a 2 year $2 million project. Getting a production certificate to produce the same airplane in a factory costs around $10 to $15 million. Those are the going rates.

Compare that to ASTM design compliance not including the design and prototype itself will probably end you costing you $250k and probably $100k to $200k to set up a compliant production system. Same thing if you opened a McDonalds franchise.

I am talking about S-LSA

[Vance]

Originally Posted by fara

Vance:
To be very honest. ASTM compliance to design for airplanes for example is absolutely no different than design compliance for Part 23 Appendix A. In some areas ASTM standard more than Part 23 does. Structural tests, design criteria and number of things you ahve to do engineering wise for structural design compliance are quite identical.

The major difference is in QA standard which essentially defines the PC or production system. ASTM standard is much less demanding than Part 23 or PC would require. A typical Type Certificate for a small airplane (TC) in Part 23 would probably be a 2 year $2 million project. Getting a production certificate to produce the same airplane in a factory costs around $10 to $15 million. Those are the going rates.

Compare that to ASTM design compliance not including the design and prototype itself will probably end you costing you $250k and probably $100k to $200k to set up a compliant production system. Same thing if you opened a McDonalds franchise.

I am talking about S-LSA

Hello Abid,

I don’t agree but now that you are clear that you are asking about only SLSA I feel it would make the discussion more informed if you gave an idea of what you imagine a compliant SLSA gyroplane would cost.

What it costs the factory is not relevant to anyone I know on the forum.

I suspect if the price of the compliant gyroplane was high there would not be a lot of units to amortize the compliance costs over.

I suspect the increased liability would also drive up the unit cost.

You speak as though you know the answers to unit costs.

Would you please quantify the question with a unit retail sales price?

Thank you, Vance

[Ronnie328]

i imagine any company that would go through the process of making an S-LSA gyro, would have an instant market advantage over any kit builders. It would definitely be a deep investment, but i think it would pay off in the long run.

[Vance]

Originally Posted by Ronnie328

i imagine any company that would go through the process of making an S-LSA gyro, would have an instant market advantage over any kit builders. It would definitely be a deep investment, but i think it would pay off in the long run.

Hello Ronnie,

The company that has an SLSA gyroplane is taking a huge risk that there is a market.

They are at a disadvantage with experimental armature built because now they are the manufacturer instead of the builder being the manufacturer so they have taken on a huge liability. Experimental adds a layer of legal protection to the kit manufactures.

In my opinion much of the cost of an SLSA airplane is about liability or they would mostly be in the $50,000 range. I am not a lawyer so I may be in error.

In my opinion building something in a factory doesn’t cost a lot more than building a kit.

That is why I am asking Abid what he feels the additional cost will be.

I would expect a factory built SLSA gyroplane to cost around $100,000 in the USA to amortize the cost to comply and the added liability.

I suspect Abid has a much clearer picture than I do.

Thank you, Vance

[Fly Army]

Vance I agree with your assessment of the liability issue but I think that would only really apply to U.S. made gyroplanes. Which is one of the sad reasons that the U.S. general aviation industry is in the state that it's in - we have only lawyers to thank for that. Bringing suit against a foreign company while not impossible is quite a bit more difficult and costly.

One of the key reasons I'm in favor of S-LSA Gyroplanes is that it makes them legitimate to RENT. Being able to go down and get checked out on a gyroplane and then being able to rent one is something we have never really had save for a few times back when there were J-2's and 18As, which was quite a long time ago. If people could get into gyroplanes in the same manner that people can fixed wing aviation I think we would really have a real jump in our numbers to include more CFI's and more schools too.
Randy

[PW_Plack]

Originally Posted by Fly Army

Vance I agree with your assessment of the liability issue...we have only lawyers to thank for that...

Randy, I used to think that, but lawyers are just facilitators for a greedy society. If we got rid of lawyers, or had "tort reform" to limit awards, it would also hurt people who are legitimately harmed by manufacturers.

I'm generally a fan of "loser pays" to discourage frivolous lawsuits, too, but must admit that it would mean only the rich could seek justice in some cases.

The real problem is that most Americans have been taught for generations now to view businesses as evil entities that steal wealth which should rightfully belong to customers and employees. There is a disconnect from the reality that a lawsuit award comes out of the pockets of all future customers (and, if insured, past ones) and not the pockets of faceless rich people somewhere, and that most people hurt in lawsuits are not to blame for the misfortune of the plaintiffs.

[PW_Plack]

Originally Posted by fara

Does gyroplane community really want S-LSA?

This is what pollsters call "a loaded question." It's a little like asking people in Michigan, "Do Americans really want imported cars?"

The existing gyroplane community in the US is primarily a group of recreational fliers, most of whom would not be in the community if gyros weren't cheap. It also includes instructors who fear that if S-LSA gyros were to exist, training in EAB gyros might be shut down, and they'd have to leave instruction or buy an S-LSA two-place.

I believe that within the larger general aviation community, $100K sport gyroplanes would be at least as popular as they are in Europe, if only because general aviation flying is much less costly and restrictive here.

The widespread availability of factory-built gyros would change the nature of the gyroplane "community," or create an entirely separate community. But instruction in S-LSAs would likely be less expensive for students than the current training in EAB, and available to those who currently can't train for lack of their own machines in which to solo.

The existing EAB community would have better access to training, we'd be safer, and the overall sport would benefit from more awareness, with S-LSA.

Unfortunately, our FAA doesn't seem to feel its mission includes any of those outcomes.

[Fly Army]

Originally Posted by PW_Plack

I'm generally a fan of "loser pays" to discourage frivolous lawsuits, too, but must admit that it would mean only the rich could seek justice in some cases.

Paul,
I too am a HUGE fan of "loser pays" but do not agree with your observation. If that were true than only wealthy inventors/entrepreneurs could bring a product or service to market. If something has real merit there will always be REAL attorneys that are not afraid of ACTUALLY going to court and fighting for a cause. Just like venture capital is used now for products and ideas that appear promising.

One idea to help with this would be to stop electing lawyers to run government ! I've also noticed that when I'm in Utah they seem to have a large amount of TV commercials for ambulance chaser lawyers which I find to be strange given the otherwise conservative culture there.
Randy