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 Novemb er 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 preventi ng an added cost to operate an aircraft for an already expensive mode of transportation.

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

One reason for added confusion concerns the process that h as been previously used. It has not been customery practice to incorporate a Type Certificate number on the bl ade 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 toda y will introduce confusion regarding th e eligibility of previously shipped

blades.

Another reason for added confusion stems from our knowle dge that the number of eligible Type Certificates numbers for a specific blade design will most certainly in crease 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 blad e 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 interp ret these variations and assess their impact on airworthiness. There will undoubtedly be additional instructions n ecessary 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 conf usion 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 th e 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.comWe 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: “F act 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 safet y 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 fu rther 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: 937.778-4365Page 1



### 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, t he GA industry has experienced unique challenges, including a steady decline in new pi lots, flight activity, and the sale of new aircraft.

In part, t hese 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

com muter ” 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 c ommuter 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, saf er airplane designs to mark et.Page 2

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 recomm endations as soon as p ossible.

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 sa fety 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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