August 14, 2014 

Subject: Request for Exemption from Regulation 14 CFR Part 45.13(a)(4) 

Reference: Initial request dated November 7, 2013 

In addition to the information provided in the November 7, 2013 exemption request, we offer the following 

clarification. 

We believe an exemption to 14 CFR Part 45.13(a)(4) will benefit the flying community by avoiding added 

confusion in an already complex industry, and by preventing an added cost to operate an aircraft for an already 

expensive mode of transportation. 

In regard to the topic of confusion, we believe the flying community will experience confusion for several reasons. 

One reason for added confusion concerns the process that has been previously used. It has not been customery 

practice to incorporate a Type Certificate number on the blade butt. Hundreds of thousands of propeller blades are 

currently operating in public service without a Type Certificate number stamped onto the blade butt. Adding a Type 

Certificate number in new production today will introduce confusion regarding the eligibility of previously shipped 

blades. 

Another reason for added confusion stems from our knowledge that the number of eligible Type Certificates 

numbers for a specific blade design will most certainly increase over time as new applications are created. The 

absence of an applicable Type Certificate number on the butt of an existing blade will undoubtedly create confusion 

as to its eligibility. Resolving that confusion will result in wasted time and money and/or result in the purchase of 

unnecessary replacement blades. 

The third reason for added confusion concerns the fact that there will now be three (3) blade butt stamping 

variations that will exist in the field for any given blade design. One version is where the blade butt has no Type 

Certificate number at all (current and past production). A second version is where the list of stamped Type 

Certificate numbers is only partially complete (because of added eligibility that was authorized after shipment of a 

specific blade). The third version is where the blade model contains all of the currently eligible Type Certificate 

numbers. In addition, these variations could easily be contained in the same 3 or more bladed propeller(s). The 

industry will be required to interpret these variations and assess their impact on airworthiness. There will 

undoubtedly be additional instructions necessary to provide to the field, explaining these stamping variations and to 

inform the public how to assess installation approval. With this confusion and added instruction, the cost to the 

flying public will undoubtedly increase. All of this confusion will not add to flight safety or improve the 

airworthiness of the product. 

We are certain this will result in a cost increase to the flying public; not only through the actual practice of 

identifying and then stamping all of the currently eligible Type Certificate numbers on a blade butt, but also to 

address and resolve the added confusion to the field. 

Telephone: 937.778.4200 Fax: 937.778-4365

Page 2 

August 14, 2014 

Hartzell Propeller Inc. 

One Propeller Place 

Piqua, OH 45356-2634 USA 

Tel: +1-937-778-4200 

Fax: +1-937-778-4271 

www.hartzellprop.com
We believe that granting this exemption is consistent with the intent of the Small Aircraft Revitalization Act of 2013 

and further supported by the attached document titled: “Fact Sheet H.R. 1848 – Small Airplane Revitalization Act 

of 2013”. Essentially, the Small Aircraft Revitalization Act acknowledges that the industry has been undergoing 

decline and partially blames that decline on outdated and inappropriate regulations that unnecessarily increase cost. 

We are not aware of any negative effect on flight safety due to the absence of a Type Certificate number being 

stamped on the blade butt. The practice of not marking a propeller Type Certificate number on a blade butt has 

existed for a half-century or more at Hartzell Propeller Inc. and it has never been considered as a flight safety 

concern. 

We believe it is in the public’s best interest to not further burden aviation with this increased confusion and cost. 

Please approve this exemption request. 

Regards,

Richard L. Edinger 

VP Certification and Flight Safety 

Lead ODA administrator 

Hartzell Propeller Inc. 

937-214-6544 (cell) 

Attachment: Fact Sheet: H.R. 1848 – Small Airplane Revitalization Act of of 2013 

Telephone: 937.778.4200 Fax: 937.778-4365
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Fact Sheet: H.R. 1848 – Small Airplane Revitalization Act of 2013

Background Information

General aviation (GA) is all civil aviation operations other than passenger and cargo air 

transport operations for compensation or hire.

The GA industry includes nearly 600,000 pilots, employs roughly 1.3 million people, and 

contributes approximately $150 billion annually to the U.S. economy.

Over the last few decades, the GA industry has experienced unique challenges, including a 

steady decline in new pilots, flight activity, and the sale of new aircraft.

In part, these challenges are due to overly prescriptive and outdated certification processes, 

which often inhibit the availability of modern safety solutions for certificated GA aircraft.

The Federal Aviation Administration (FAA) certification processes are outlined in the Federal 

Aviation Regulations (FAR), which are divided into different parts.

In August 2011, the FAA chartered the Part 23 Reorganization Aviation Rulemaking Committee 

(Part 23 Rulemaking Committee), with the goal of improving the safety and viability of GA.

o FAR Part 23 prescribes FAA airworthiness and safety standards for the issuance of and 

changes to certificates for small airplanes in the “normal, utility, acrobatic, and 

commuter” categories.

o FAR Part 23 generally includes airplanes that weigh 12,500 pounds or less and have a 

seating configuration of 9 seats or less. (The commuter category includes aircraft that 

weigh 19,000 pounds or less and have a seating configuration of 19 or less.)

In June 2013, the Part 23 Rulemaking Committee completed its work and developed 

recommendations to reorganize FAR Part 23 to remove barriers to bringing new, safer airplane 

designs to market.
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o These recommendations include: (1) removing prescriptive methods of compliance, (2) 

ensuring safety objectives address future technologies, (3) utilizing FAA-accepted 

consensus standards, (4) developing globally acceptable regulations, and (5) 

implementing these recommendations as soon as possible.

Summary

H.R. 1848 was introduced on May 7, 2013, by Representatives Mike Pompeo (R-KS), Daniel 

Lipinski (D-IL), Sam Graves (R-MO), Richard Nolan (D-MN), and Todd Rokita (R-IN).

This legislation would require the FAA to issue a final rule based on the Part 23 Rulemaking 

Committee recommendations by December 31, 2015.

The final rule must:

o Create a streamlined regulatory regime for small airplanes that improves safety and 

decreases costs;

o Set safety objectives that will spur innovation and technology adoption;

o Replace the existing prescriptive regulatory regime with new standards for compliance 

and testing; and

o Use FAA-accepted consensus standards to clarify how FAR Part 23 safety objectives may 

be met by specific designs and technologies.

Subcommittee Action

None.

Amendments

A Manager’s amendment is expected and will provide a minor technical change.

Statement of Administration Policy

None.

Staff Contact and Phone Number

Holly Woodruff Lyons, Staff Director, Subcommittee on Aviation, 6-3220.

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