FEDERAL AVIATION ADMINISTRATION

 SMALL AIRPLANE DIRECTORATE

 PART 23 REORGANIZATION

 NOTICE OF PROPOSED RULEMAKING

 May 3, 2016

 8:02 a.m. 

 Public Hearing

Georgia International Convention Center

 Atlanta, Georgia

 REGENCY-BRENTANO, INC. 

 Certified Court Reporting 

 Suite 140 

 13 Corporate Square 

 Atlanta, Georgia 30329

 (404) 321-3333
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1 Attendees:

2 Bill Schinstock

Lowell Foster

3 Pat Mullen

Jeff Pretz

4 Jim Brady

Mark James

5 Mike Reyer

Paul Pellicano

6

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1 (Tuesday, May 3, 2016 8:02 a.m.)

2 MR. PAT MULLEN: My name is Pat

3 Mullen. I am the acting manager of the

4 Small Airplane Directorate in Kansas City,

5 Missouri, and I welcome you to this public

6 hearing to discuss the part 23

7 reorganization notice of proposed

8 rulemaking.

9 I just wanted to take just one

10 moment before handing it off to our

11 moderators. I just wanted to welcome you to

12 Atlanta and thank you for your participation

13 in this meeting. We were -- this effort was

14 highly dependent upon the energy and the

15 input of the industry, especially during the

16 Aviation Rulemaking Committee phase. And

17 during the Notice of Proposed Rulemaking,

18 our success is equally dependent upon your

19 energy in providing us meaningful comments

20 to the NPRM, so we are very glad to see all

21 of you here at this meeting.

22 At this time I would like to

23 introduce you to one of our key moderators

24 in this meeting, Mr. Bill Schinstock. He is

25 the acting manager of the Small Airplane
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1 Directorate, Standards Office. He is going

2 to have some -- he would like to provide his

3 greetings and then he will go over some of

4 the rules of engagement for this public

5 meeting. As you know, public meetings are

6 actually structured. There are some rules

7 that we do have to abide by, and Bill will

8 provide all of that input and direction to

9 all of us, so thank you and good morning and

10 we look forward to the next two days of

11 meetings.

12 MR. BILL SCHINSTOCK: Thank you,

13 Pat.

14 Good morning, ladies and gentlemen.

15 The formal meeting is called to order at

16 this time. Today is Tuesday, May 3rd, 2016.

17 I would like to welcome you to the public

18 meeting on the part 23 Notice of Proposed

19 Rulemaking. As Pat said, my name is Bill

20 Schinstock. I am a manager in the Small

21 Airplane Directorate for policy and

22 regulations and standards. I am pleased to

23 welcome you to this meeting. The purpose of

24 the meeting is to solicit comments and

25 additional information from the public on
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1 the FAA part 23 Notice of Proposed

2 Rulemaking.

3 Joining me on the panel today for

4 today's public meeting are several members

5 of the staff from the Small Airplane

6 Directorate. Mr. Lowell Foster, who is

7 primarily in flight, flight test and

8 handling qualities. He is also the primary

9 engineer on that project. His name is on

10 the rule. Mr. Lowell Foster.

11 Next to him is Pat Mullen who has

12 introduced himself.

13 And then Jeff Pretz, who is a power

14 plants and propulsion engineer in the small

15 airplane standards staff.

16 Jim Brady, who is a systems

17 engineer.

18 And next to him is Mark James,

19 structures.

20 And next to him is Mike Reyer,

21 loads and structures.

22 And next to him is Paul Pellicano,

23 who is our icing specialist.

24 These panel members are here to

25 facilitate discussions and to provide
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1 clarifying information so that we may

2 develop as complete and useful of record of

3 the proceedings as possible. Any comments,

4 questions or statements made by the panel

5 members during the course of this meeting

6 should not be taken as expressing a final

7 FAA position.

8 A little bit of the format for the

9 proceedings: The FAA will consider comments

10 made at this meeting before making a final

11 decision on issuance of the final rule. We

12 will not make the formal decisions here.

13 In order to develop an orderly and

14 logical record, we have prepared an agenda.

15 As illustrated in the agenda, we will

16 discuss the proposed rule subpart by

17 subpart. The FAA panel will briefly

18 summarize each subpart of the proposed

19 section by section.

20 After each summary, the public will

21 be given an opportunity to ask questions

22 about the proposal or to introduce relevant

23 information on a proposal subpart being

24 discussed.

25 We plan to discuss Subparts A
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1 through D today. We plan to discuss

2 Subparts E through G tomorrow. At the end

3 of each day we will provide time for general

4 comments on the proposal as some of you may

5 not be with us both days. We will also

6 provide time at the end of each day for the

7 public to present material.

8 We request that anyone who wishes

9 to make a presentation to please inform the

10 staff at the registration table in the back

11 of the room and we will accommodate your

12 request as time permits. The proceedings

13 are being transcribed by a Court Reporter.

14 A verbatim transcript of this meeting will

15 be available after May 15th, 2016. Ordering

16 information is available at the registration

17 table outside the room. A copy of the

18 transcript for this meeting will be placed

19 in the public docket.

20 Persons wishing to ask a question

21 or provide a comment must be recognized by

22 the chair. The chair will recognize each

23 person from the floor, will establish the

24 appropriateness of all discussions and

25 questions and will terminate the discussions
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1 that are not fruitful. Issues that do not

2 deal with the part 23 NPRM and associated AC

3 are not under consideration during this

4 meeting and the chair will rule such

5 discussions out of order.

6 If you wish to ask a question or

7 provide a comment, we ask that you please

8 raise your hand for the chair to recognize

9 you. You will then be provided a microphone

10 or you can step up to the mic here. For the

11 benefit of the Court Reporter, each time you

12 take a microphone, please identify yourself

13 and your affiliation for the record. We ask

14 that you limit your comments to issues

15 directly pertaining to the NPRM and the

16 proposed advisory circular associated with

17 this rulemaking.

18 Please be aware that if you provide

19 a comment or presentation, members of the

20 FAA panel may ask you follow-up questions

21 intended to clarify or focus on particular

22 elements or concepts expressed in your

23 comment or presentation. This will offer

24 you an opportunity to elaborate on relevant

25 issues. Our objective here is to make sure
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1 that we have a complete understanding of

2 your concerns.

3 While the proceedings are being

4 transcribed by a Court Reporter, the FAA

5 strongly encourages each person to submit

6 their comments in writing to the docket.

7 Prior to beginning our formal

8 discussions on the proposal, I would like to

9 give you a little background on how we got

10 here. The intent of this rulemaking is to

11 move from prescriptive standards to

12 performance-based standards. To that end,

13 the proposal captures the safety intent of

14 the current regulations while reducing the

15 volume of the text in part 23. In fact, the

16 proposed text constitutes only 10 percent of

17 the current rules. The FAA received

18 recommendations and proposed rule language

19 from an Aviation Rulemaking Committee, or an

20 ARC. The FAA conducted a comprehensive

21 review of the ARC's proposed rule language

22 which took approximately six months. The

23 ARC's recommendations were one of many

24 factors used to develop the NPRM.

25 Now we are at the public comment
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1 stage. After the comment period is closed,

2 the FAA will consider the comments received

3 in developing the final rule.

4 Again, we would appreciate it if

5 you can submit any comments you have in

6 writing to the docket.

7 The ground rules for this public

8 meeting are straightforward. All exchanges

9 should be made on the record. The FAA will

10 not entertain questions or comments

11 regarding the proposal during breaks. Some

12 logistics for the meeting, we will break for

13 lunch at approximately 12:00. We will also

14 take morning and afternoon breaks as

15 indicated in the agenda. For those of you

16 that don't know, restrooms are just out the

17 door and to the left. The emergency exits

18 are out the door and past the lobby outside.

19 If you are not registered yet, please do so

20 at the front at the first break. An

21 attendee list will be prepared and placed in

22 the docket.

23 One other note that I would like to

24 make is that we are on a telecom and a

25 weblink with authorities from foreign CAAs
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1 and so they are on the telephone and they

2 will be listening the comments. They will

3 not have the ability to talk to us but they

4 can hear what we are talking about. The

5 audio is being recorded for our benefit

6 later on in addressing the comments. At

7 this time, we were going to have a

8 presentation by the leader of the ARC, but I

9 don't see Greg here yet.

10 He is a little bit late traveling

11 so when he gets here we will allow him to

12 make his introductory comments. But at this

13 time I think that I will hand the podium

14 over to Lowell Foster and he will begin the

15 proceedings. Thank you.

16 MR. LOWELL FOSTER: So when Greg

17 gets in we will just take a break and let

18 him do his introduction. And we are

19 scheduled for a break at 9:30. Okay. So we

20 are ahead of schedule already. You got to

21 like that.

22 I am going to talk about Subpart A

23 and B and fundamentally, within the

24 constraints of the meeting, I am going to

25 share the language with you, what we -- what
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1 the new rules address and then open the

2 floor for questions or comments. And I

3 really don't want to read everything to you,

4 so maybe I will just share the language on

5 the slide. Part -- the 23.1 added a few

6 definitions, but fundamentally it's the

7 same. Any questions? Comments? Nope.

8 Everybody done?

9 Okay. 23.5, we did make a lot of

10 changes. This is where we went from weight

11 and propulsion to risk and performance, so

12 you will see a lot of changes in 23.5. We

13 also -- we identified levels and those are

14 risk levels which are based on passenger

15 numbers. We have high and low performance

16 which are speed based and then we introduced

17 the concept of "simple".

18 Yes. Question. And I would ask

19 you to step up to the mic for Susan over

20 here.

21 MR. RIC PERI: Hi, Lowell. Ric

22 Peri with Aircraft Electronics Association.

23 MR. LOWELL FOSTER: Good morning,

24 Ric.

25 MR. RIC PERI: Just for
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1 clarification purposes, I have received a

2 number of questions specifically with Level

3 1 with the zero to one. Can you explain the

4 zero, please?

5 MR. LOWELL FOSTER: So I think, as

6 mentioned in the preamble, the idea was it

7 could be a single-seat airplane with a pilot

8 and one passenger, so it was targeting the

9 two place category. It does not necessarily

10 leave out the opportunity for no pilot.

11 Anything else?

12 And this is the second part of the

13 23.5. We will pause right here.

14 Good timing, Greg.

15 MR. GREG BOWLES: Yeah, sorry,

16 guys. You are taking comments piece by

17 piece, is that what you are doing?

18 MR. LOWELL FOSTER: Do you want to

19 comment?

20 MR. GREG BOWLES: Yes.

21 MR. LOWELL FOSTER: And then we can

22 take a break and then if you would like to

23 do a welcome.

24 MR. GREG BOWLES: Okay. Great.

25 Thank you. So in this area, the comment
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1 that we would have, I think that is most

2 important -- and by the way, Greg Bowles

3 with the General Aviation Manufacturers

4 Association.

5 23.5(d) categorizing a category of

6 aircraft called simple, I think that we

7 understand the intent of the FAA doing that

8 to try to make sure that we do have a way to

9 treat simple aircraft appropriately. The

10 concern that we have is by creating a

11 category for that defined like this, it

12 actually breaks out another category like we

13 used to have with commuter categories, so

14 the comments that we would make is to remove

15 the simple category and treat aircraft with

16 that characteristic appropriately throughout

17 the code and also throughout the standards.

18 MR. LOWELL FOSTER: Okay. And I

19 would ask you, along with that comment,

20 hopefully you can make that comment to the

21 docket.

22 MR. GREG BOWLES: Yes.

23 MR. LOWELL FOSTER: Great. Thanks.

24 Tell you what, why don't we finish Subpart A

25 and we will take a break and invite you up.
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1 Is that it for 23.5? One comment.

2 Okay. Steve?

3 MR. STEVEN ROSENFELD: Good morning

4 Lowell. Steve Rosenfeld, National Traffic

5 Control Association. I just want one thing

6 clarified as I go through this rule and I

7 see how aerobatics is treated. Am I correct

8 in saying that if you have a normal airplane

9 and the only additional maneuver it's

10 approved for is to do spins that can be

11 recovered and nothing else, no loops, rolls

12 or anything like that, just spins, that

13 still will end up categorizing that airplane

14 as aerobatic; is that correct?

15 MR. LOWELL FOSTER: That is

16 correct. And there is actually two places

17 in the preamble that we discussed that.

18 MR. STEVE ROSENFELD: Okay. Thank

19 you.

20 MR. LOWELL FOSTER: You bet. If

21 that is it for 23.5 we will move on to

22 23.10.

23 23.10 was new. And when you move

24 to a performance-based rule, the rules are

25 very top level and so we felt the need to
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1 make it a requirement that we agree upon the

2 means of the compliance up front and that is

3 what 23.10 is intended to do.

4 I will mention there is an AC

5 associated with this -- a proposed -- a

6 proposed AC associated with this.

7 MR. GREG BOWLES: Clarification

8 question for 23.10(b). Is this intended to

9 ask that people creating means of compliance

10 for broad use and acceptance by the FAA for

11 all future projects need to request

12 compliance or that methods of compliance

13 which may be put forth through an AC or

14 other acceptable means that the FAA has

15 pointed to need to get approval on a

16 project-by-project basis?

17 MR. LOWELL FOSTER: So I am going

18 to let that go as a comment that we will

19 look into, okay, and actually ask you, maybe

20 to expand on that and submit it to the

21 docket. It's a good question. I appreciate

22 that. We are still having some internal

23 discussions, so I would prefer not to

24 elaborate.

25 Anything else? All right. That
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1 takes us to Subpart B, and it might be a

2 good break point that, Greg, you were on the

3 agenda -- Greg was our ARC coach here for

4 industry and he had wanted to do a little

5 welcoming statement.

6 MR. GREG BOWLES: I do not have

7 slides but I do have some other things. So

8 thank you for giving me a minute here to say

9 some things. And I'm sorry for showing up

10 and speaking so quickly, everybody.

11 So I am Greg Bowles. I am with the

12 General Aviation Manufacturers Association

13 and I was the cochair of the ARC along with

14 Pat Mullen and I am currently chairing the

15 ASTM activity that has been mentioned in

16 this area.

17 So what I would like to say on

18 behalf of a whole bunch of associations, so

19 AEA, AOPA, EAA, HAI, ICAS, ASAO, NATA and

20 NBA. So that basically represents the

21 aircraft maintainers, the modifiers and the

22 operators of pretty much all the aircraft

23 here in the US.

24 This group got together and

25 submitted some high level comments to the
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1 docket, and I want to make sure everyone is

2 aware that that is on there now for review.

3 Some of the things that were

4 thought to be critical going forward, this

5 change is seen as something to revitalize

6 general aviation. Today we are losing

7 10,000 private pilots a year in the US. The

8 average age of the private pilots actually

9 is maybe a more concerning number. We just

10 looked at some data that shows the average

11 age obviously gets a year older every year

12 because we are not bringing lifeblood into

13 aviation today.

14 Typically when a pilot hits about

15 70 it's a pretty sharp drop off; they do not

16 continue past that curve. There are

17 exceptions, but the vast majority drop off.

18 Of that bulk, the median number of pilots is

19 about 65 to 68, so what is going to happen

20 over the next four to five years, there is a

21 tremendous number of pilots that will be

22 dropping off the register and dropping off

23 activity.

24 So based on estimates, we think

25 that we will probably see the numbers of
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1 private pilots in the US drop to an all-time

2 low since the time that they were on the

3 rise back in the 1960s. So we will probably

4 settle around instead of what the high was

5 when there were 300,000 or 400,000 private

6 pilots in the US, we will probably settle

7 around 140,000 pilots in the next four

8 years. That is a pretty devastating number.

9 We are currently at 168,000 this year, so

10 the trends have been continuing in that

11 direction.

12 If nothing is done, aviation is

13 only attractive to those of us who have

14 something wrong with us. I guess that we

15 all have an aviation gene. We love it. But

16 the general population is not interested in

17 enduring the difficulties that are in their

18 way. A lot of those difficulties are

19 brought because of a whole number of

20 sources. They are brought because of cost.

21 They are brought because of difficulty in

22 construction. But a lot of them are brought

23 because of the outdated regulations.

24 So it's seen that these changes

25 that are being proposed can address one of
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1 the major problems, being able to put

2 innovation into the existing fleet of

3 aircraft is really important. That is the

4 lifeline to keep things going to attract

5 young people into aviation with the products

6 that are out there. But even as important,

7 and maybe more so, is being able to design

8 new products that are more attractive for

9 folks to pull new young people into

10 aviation.

11 When we look at the alternatives

12 that young people have today, they can go do

13 a lot of things. They can fly aircraft

14 simulators on their iPads and computers at

15 home with a very low burden. So not only is

16 this change necessary, but we also think

17 that a change in the operations and

18 maintenance environment going forward will

19 be critical too. So I think that the

20 association had talked about flight

21 standards improvements as well. As these

22 new products come along, it will be

23 important to be able to utilize those as

24 safely and as efficiently as possible, so we

25 anticipate that that would be something that
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1 we are all interested in looking towards.

2 The proposal, we will submit

3 detailed comments from the GAMA perspective

4 along with the association, so I wouldn't go

5 through those today in detail. I think a

6 couple of the highlighted areas that I would

7 raise for awareness when we look at the

8 global environment, one of the things that

9 is happening very quickly is a change in

10 propulsion. So we are starting to see

11 hybrid and electric propulsion being

12 theorized and being real in the widest end.

13 There is a lot of promise there, but there

14 is a lot of challenges in bringing that kind

15 of thing on board. The rules probably need

16 to be tailored a bit better to address

17 electric and hybrid propulsion in a more

18 straightforward manner, so we anticipate

19 putting detailed comments in that direction.

20 In the area of propulsion source,

21 we also anticipate looking at how other

22 authorities around the world have handled

23 the certification of propulsion sources so

24 we anticipate turning comments in to

25 potentially ask the FAA for certification
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1 for propulsion sources as part of the

2 airframe and that determination will be

3 based on the complexity of the propulsion

4 source, not based on the complexity of the

5 airframe.

6 So for example, a very complex

7 airplane may use a very simple electric

8 motor and that would be a case where that

9 simple electric motor should be certified

10 through the airframe certification, not as a

11 standalone component would be appropriate;

12 however, if a very simple airplane wanted to

13 use a very complex turbine engine, it would

14 probably make sense to certify that turbine

15 engine as a standalone.

16 One of the last really critical

17 things that needs to happen in this effort

18 is a timing issue. So we believe that the

19 FAA has worked really hard to get us here.

20 I know that a lot of you in the room have

21 worked in that effort as well. In Europe,

22 the European Aviation Safety Agency has

23 committed to having their rules on the books

24 by the end of this year. That is really

25 good news. That is really important. And
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1 they have a pretty flexible rulemaking

2 system in Europe. The system here in the US

3 is more difficult. The FAA has to work

4 through the office of management and budget

5 and the DOT to get priority and get through

6 the system to even put out the NPRM and also

7 the final rule.

8 With that said, this issue is so

9 critical that we don't believe it can wait

10 for a future administration. So the worry

11 would be that if the FAA does not reach the

12 end of the year 2016 with their rule, it

13 would get pushed out some amount of time and

14 all of that amount of time would be putting

15 the US industry at a bit of a disadvantage.

16 So it's very important that the FAA does

17 everything possible to prioritize and that

18 the other branches of the executive

19 government do the same and put this rule

20 through. I hope that we will find that it's

21 noncontroversial. So far everybody that we

22 have talked to from the GAMA perspective has

23 found that it's a very positive rule,

24 certainly needs some technical tweaks and

25 some harmonization but we really want to
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1 prioritize that rule.

2 So the last thing I will say is the

3 prioritization is an absolute key here --

4 I'm sorry, harmonization is an absolute key

5 here. We need to make sure that this rule

6 is the set of regulations that is used

7 around the world for the certifications of

8 these kind of vehicles so that manufacturers

9 can plan on designing a vehicle that works

10 optimally and then that vehicle can be sold

11 and exported or imported as it may be

12 because this industry is just too small to

13 have design differences in other markets.

14 And as I get off the stage, I will

15 say that I want to thank the folks at the

16 FAA small aircraft directorate and the folks

17 at the FAA certification and all the

18 supporting branches. I know that there are

19 a lot of folks from the econ office and a

20 lot of other areas that have done a lot of

21 work to get us here. I think that the work

22 is probably not over, but we do appreciate

23 everything that has been done to get us

24 here.

25 The FAA has a lot of challenges and
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1 technical -- challenges and rules and

2 policies that get in its way when it needs

3 to do things and these folks have been

4 really dogged in working to figure out how

5 to work around those issues or work with

6 those issues -- to work with those issues to

7 come towards the best resolution for all of

8 that, so I thank you for that and thank you

9 for letting me say some things.

10 MR. BILL SCHINSTOCK: Thanks, Greg.

11 Thank you, Greg, I appreciate the comments.

12 The one request that I would have for you,

13 if you could please coordinate with our

14 Court Reporter for the list of companies at

15 the beginning of your presentation, I would

16 imagine that that was hard to capture.

17 We will continue with Lowell, but I

18 would like to open the floor now for anybody

19 that has a comment about what we have

20 covered so far, questions about what we have

21 covered so far and then we will jump into

22 Subpart B if there are no questions.

23 Ric?

24 MR. RIC PERI: Just a quick comment

25 on the simple aircraft. In light sport
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1 airplanes, the F-37 ASTM standards for that

2 and the rules that have followed, one of the

3 challenges that the light sport airplane

4 community has struggled with is the VFR-only

5 limitation on that. It seems like we are

6 perpetuating that with that definition of

7 simple. Understand the stall speeds and all

8 of that stuff that goes with it, but adding

9 the VFR seems like we are going to repeat

10 history and create something that is going

11 to become a challenge and the entire

12 industry is going to be petitioning for

13 exemptions and extensions for that, so I

14 would ask that you reconsider that.

15 MR. BILL SCHINSTOCK: Okay. Thank

16 you.

17 All right. Lowell?

18 MR. LOWELL FOSTER: All right. We

19 are back to Subpart B.

20 In Subpart B, you probably saw the

21 most changes because we went from -- it's

22 very heavily based on weight and propulsion

23 and so going to performance-based standards

24 where we move to the risk/performance-based

25 was a challenge so you may see probably a
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1 substantial number of changes here. I am

2 going to again continue where I let you read

3 this. What I want to share is what each of

4 these new or proposed rules address. So for

5 100, this is the weight and center of

6 gravity topic. And current Rule 23.21,

7 23.23, 23.29 and 31 have been basically

8 covered by this rule captured in the new 100

9 rule. Okay. No questions, comments?

10 So proposed Section 105 just

11 covered the performance section in the

12 current Rule 23.45. And as we stated in the

13 preamble, the intent was to maintain the

14 level of safety as much as possible. And in

15 this rule I think that we are at parity.

16 Yes, Greg, comments?

17 MR. GREG BOWLES: So it appears

18 that the temperature charts that were

19 created were more in line with aircraft that

20 suffered performance losses when temperature

21 increases. We think that electric aircraft

22 may suffer performance hits when temperature

23 decreases versus increase or there is

24 potential for that depending on the design.

25 So today going from standard request 30
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1 would maybe not cover that. Is that an area

2 of discussion within the FAA right now?

3 MR. LOWELL FOSTER: I think that

4 that is a very good comment and I appreciate

5 you sharing that and would welcome that on

6 the docket. The history of that is true in

7 terms of based on engine and the attitude.

8 Any other comments, questions?

9 Okay. Moving on, 110 is stall

10 speed. It captures 23.49 in the current

11 rule, and if there are no comments or

12 questions I will move on.

13 MR. GREG BOWLES: So in the stall

14 speed questions which we ask for power set

15 to idle or zero thrust, would the FAA

16 envision power when you say set to idle or

17 zero thrust, would that mean that if power

18 was used for lifting or power was used for

19 some kind of augmentation so if there were

20 some kind of augmentation or lift fans on an

21 aircraft, would zero thrust mean forward

22 direction thrust or would that include all

23 power lift in those other devices?

24 MR. LOWELL FOSTER: So those

25 discussions -- that goes beyond discussions
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1 and we would have to just take that as a

2 comment and under advisement. The intent

3 here was to capture the current rule as we

4 talked about in the preamble. All right,

5 moving on to 23.115.

6 23.115's takeoff performance, this

7 incorporates current 23.51, 53, 55, 57 and

8 61. And I believe that there are two pages

9 to this. No, actually, I fit it all on one.

10 Any comments or questions?

11 All right. Moving on to 120. 120

12 is climb performance. It captures current

13 23.63, 23.65, 67 and 77.

14 MR. GREG BOWLES: It appears from

15 the way that the climb angles are lined out

16 that the FAA is asking for steeper climbs

17 out of smaller and simpler aircraft with

18 fewer people on board. I guess actually

19 it's just based on fewer people. So

20 aircraft with fewer people and low speed are

21 steeper climbs than high speed with more

22 people, is there any background to the

23 philosophy there?

24 MR. LOWELL FOSTER: So the intent

25 here was to maintain the current rule as
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1 best we could. And as I said at the start,

2 this particular rule or this set of climb

3 requirements are heavily weighed to

4 propulsion and weight so we tried to match

5 as best we could with what we have today

6 using performance and the airworthiness

7 levels. It isn't a perfect match so that

8 may be what you see. And if there is

9 something that is a concern or very far off,

10 we would really welcome that comment and

11 have that identified.

12 But the intent was, as much as we

13 could, to maintain parity today with the new

14 system. So this is the second part of it.

15 Greg, for clarity, were you

16 targeting this specific -- any specific

17 paragraph with your comment?

18 MR. GREG BOWLES: Yes. I was

19 curious about the climb requirements for all

20 Level 4 as compared to Level 1, 2 and 3.

21 MR. LOWELL FOSTER: Okay. Thank

22 you.

23 Any other questions or comments?

24 Okay. Climb information captures

25 current 23.66, 69 and 71. And these were
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1 the paragraphs where we were only

2 determining, there was not a minimum climb

3 gradient required as in 120. And again the

4 intent was parity as much as possible.

5 MR. PAT MULLEN: I'm sorry to

6 interrupt. Just real quick, so we are

7 having a little bit of trouble with the

8 sound so if I could ask you to speak up a

9 little bit more and also on that microphone

10 because we are having a -- so there are

11 folks from the foreign CAAs listening and

12 they are having trouble hearing.

13 MR. LOWELL FOSTER: Any other

14 questions on 125 climb information?

15 Comments?

16 Okay. So 130 landing, again,

17 captures existing 23.73 and 23.75.

18 Comments? Questions? Greg?

19 MR. GREG BOWLES: Sorry, I have a

20 question about 3 knots for water operations.

21 Is there a genesis for where that 3 knots

22 came from and would that be 3 knots compared

23 to ground movement, water movement, air

24 movement, rotation of the earth? What would

25 that be compared to?
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1 MR. LOWELL FOSTER: So I don't

2 remember discussions on three, if that comes

3 from existing or not, but it's a valid

4 comment. We appreciate it and I would ask

5 to you submit it so we can review it.

6 If I understand your comment,

7 you're actually wondering why 3 knots versus

8 relative ground or it could be 3 knots maybe

9 GPS; the two could be different; is that --

10 am I understanding your comment?

11 MR. GREG BOWLES: Yes. If you are

12 calling relative ground current so through

13 the tracking, through the water at 3 knots.

14 MR. LOWELL FOSTER: Relative to the

15 comment?

16 MR. GREG BOWLES: Right. Or are

17 you saying -- so there are a number of

18 factors that come into play. Wind drift, it

19 could blow you sideways a bit or you could

20 have -- you could be landing upstream or

21 downstream or in a tide, so those questions,

22 yeah.

23 MR. LOWELL FOSTER: Thank you. Any

24 other questions, comments?

25 Okay. Move on to flight
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1 characteristics, proposed 23.200. This

2 actually captures a lot of current sections.

3 Section 141, 143, 145, 147, 149, 151, 153,

4 155, and 23.157. Again, a substantial

5 number of current rules encapsulated,

6 however, a lot of those rules really were

7 how-to's and we feel that they are better --

8 you are better located in a means of

9 compliance document.

10 There is -- this is one of the

11 areas where we do have an increase in

12 requirements, which is (c) where we require

13 stall before we hit VMC for the Level 1 and

14 2 multiengine. That is a change from today.

15 MR. GREG BOWLES: So I have a

16 clarification question and then also a

17 question about (c). So a clarification

18 about (a)(3). Would you see section (a)(3)

19 as citing a specific system failure criteria

20 so that the more general system criteria for

21 23.1315 does not apply?

22 MR. LOWELL FOSTER: So the intent

23 of this when we drafted it was to maintain

24 parity with the flight rules. I don't

25 recall discussions on systems aspects, so I
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1 would say that that is a good comment and

2 ask you maybe to share that with us in the

3 docket if there are concerns.

4 MR. GREG BOWLES: Yes. Thank you.

5 And then my second question

6 23.200(c), the requirement to have minimum

7 control speed below a stall speed or at

8 stall speed is a prescriptive solution

9 towards making sure aircraft don't lose

10 control. You have a rule coming up shortly

11 that discusses the prevention of unintended

12 loss of control in the normal configuration.

13 I think our comment will be to the FAA in

14 written form and now verbally that we think

15 that the same should be true -- this should

16 be a more broad requirement so that aircraft

17 don't suffer unintended loss of control,

18 unintended inadvertent loss of control with

19 a critical engine failure, but forcing

20 minimum control speed to be at stall speed

21 is but one solution. We can use envelope

22 protection and high awareness through angle

23 of attack, we can bump the stall speed

24 artificially; there is a lot of other

25 solutions so I just wanted to mention that.
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1 MR. LOWELL FOSTER: So I appreciate

2 that. As we stated in the preamble, this

3 was one of the ARC recommendations that we

4 adopted and those comments will be

5 appreciated. Thank you.

6 Okay. I thought that I might have

7 a second page of this. Any more questions

8 on the controllability?

9 Okay. 205 trim, and it captures

10 only current 23.161 trim, same title. And,

11 again, the intent was parity. Comments?

12 Questions?

13 All right. Moving on. Stability,

14 proposed 23.210. We captured sections 171,

15 173, 175, 177, 179, and 181 under stability.

16 And, again, the intent here was to maintain

17 the current level of safety today.

18 No comments or questions, we will

19 move on.

20 MR. PAT MULLEN: I do just for the

21 public benefit. This is Pat Mullen.

22 MR. LOWELL FOSTER: Hang on.

23 MR. PAT MULLEN: So we specifically

24 identified airplanes not certified for

25 aerobatics and did we describe in the
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1 preamble why we excluded those based on

2 recent airplane certifications we have gone

3 through?

4 MR. LOWELL FOSTER: We did. There

5 was a discussion in the preamble on

6 splitting normal and acrobatic; however, the

7 way this is proposed, it basically maintains

8 what we do today in the stability

9 requirements for acrobatic. They are

10 essentially exempted because that is not a

11 desirable characteristic.

12 All right. 210, any comments or

13 questions? All right.

14 So let's go to proposed 215, stall

15 characteristics, stall warnings, and spins.

16 This rule captures the low speed

17 characteristics standards of 201, 203, 207

18 and 221. And this is an area where we hope

19 we did raise the level of safety. We hope

20 to see significant safety gains and that is

21 in (b) where the smaller airplanes cannot

22 have a tendency to inadvertently depart.

23 MR. GREG BOWLES: So 23.215(b)

24 applies to Level 1, 2 and 3 single-engine

25 airplanes so it does not apply to
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1 multiengine. So per my previous comment,

2 potentially, we might have to talk about

3 during loss of thrust or something if that

4 is how we are going to deal with the VMC

5 issue. But more to this question, it does

6 not include Level 4.

7 MR. LOWELL FOSTER: Okay, for

8 clarification you did not mean Level 1 and 2

9 multiengine, right? It's all Level 1 and 2.

10 MR. GREG BOWLES: Sorry, yeah,

11 sorry, Level 3.

12 MR. LOWELL FOSTER: I just wanted

13 to be clear.

14 MR. GREG BOWLES: And it does not

15 include any Level 4.

16 MR. LOWELL FOSTER: Right.

17 MR. GREG BOWLES: So my question

18 actually comes to Level 3 single-engines.

19 Does the data show -- and so first question

20 would be did you base that decision not to

21 include Level 4 on the incidence of loss of

22 control in Level 4 airplanes?

23 MR. LOWELL FOSTER: We did.

24 MR. GREG BOWLES: And if you did,

25 was there a large difference between Level 4
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1 and Level 3 single engine?

2 MR. LOWELL FOSTER: There was a

3 small difference. The Level 4 airplanes,

4 which would be commuter category basically,

5 we don't have the data to support requiring

6 this. Level 3, I would have to go back and

7 look. But good comment, thank you.

8 Any other questions, comments?

9 Okay.

10 Proposed 220, ground and water

11 characteristics. These captured current

12 23.231, 233, 235, 237, 239. And again here

13 the intent was parity with the current

14 rules.

15 MR. GREG BOWLES: 23.220(a) seems

16 to encompass the old language that had to do

17 with crosswind landings on regular surfaces

18 on land surfaces.

19 MR. LOWELL FOSTER: Right.

20 MR. GREG BOWLES: And B seems to

21 encompass all water-based operation in more

22 detail than what is now captured for

23 land-based airplanes. So it would seem

24 appropriate that if we are not going to

25 specify how to include the information in
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1 more context for land planes, which is the

2 majority of aircraft, that it would be

3 necessary to do that for seaplane operation

4 or amphibious. It could meet the same level

5 of criteria and be captured in standard.

6 MR. LOWELL FOSTER: Okay. We

7 appreciate that comment. Thank you.

8 Any other comments?

9 Okay. 23.225 vibration, buffeting,

10 and high speed characteristics. This

11 incorporates or it captures current 251, 253

12 and 255. And, again, with this, the intent

13 was the parity with current rules.

14 Comments? Questions? Okay.

15 Great.

16 The next one is icing, so I am

17 actually going to hand this off to our icing

18 expert, Paul Pellicano.

19 MR. PAUL PELLICANO: Can you guys

20 hear me? All right. I will take that as a

21 yes.

22 What we did is we adopted the part

23 23 reorganization ARC and the part 23 icing

24 ARC aviation technical committees to take

25 the performance of flight characteristics
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1 requirements in icing that are currently in

2 23.1419 and we put them in Subpart B. So

3 this is the new 23.230. It only is

4 applicable to airplanes that seek

5 certification for flight in icing. And what

6 we do is we took the current requirement

7 that we have for part 23 airplanes and that

8 is to show in these Subpart B requirements

9 in Part 25, appendix C conditions. We have

10 currently requires that today in 1419 and we

11 carry that over to 230.

12 This is one area where we did

13 increase safety because we are allowing

14 applicants now to either show that they can

15 safely fly in additional icing requirements

16 in Appendix C. Appendix C is really

17 wintertime clouds with small drops.

18 The intent of this rule is to

19 account for freezing drizzle or freezing

20 rain which no airplane today is currently

21 certified for but unfortunately which

22 airplanes encounter. So we are giving

23 applicants the option to certify in those

24 conditions or to not certify. And if they

25 choose not to certify, they have to show
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1 that they can detect and safely exit. And

2 the intent is to show that would be the

3 current move to compliance we have in

4 advisory circular 23.1419.

5 The other thing that we borrowed

6 from the current advisory circular 23.1419

7 is the fact that we do not look at high

8 speed -- it's not necessary to do that -- or

9 to look at spins. And also the most

10 critical thing that we are taking from the

11 advisory circular is that the stall warning

12 and ice conditions be the same in icing as

13 in non-icing. For example, we do not allow

14 buffet today if you have a stall warning

15 system. Our accidents tell us that is the

16 most critical thing to do for flight and

17 icing.

18 Going back to SLD, one of the

19 things that we are doing, too, is besides

20 detecting, we are allowing the option to

21 avoid. That technology currently does not

22 exist but there is work in various areas

23 both ground based and airborne based to do

24 that, so this rule would allow the option.

25 And if an airplane does not seek to fly in
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1 additional icing conditions outside of

2 Appendix C, we require an addendum

3 documentation and that is currently in our

4 guide material which most applicants have

5 been following.

6 Questions? Comments?

7 MR. GREG BOWLES: I applaud the

8 section. It's a good way to summarize a

9 pretty complex subject into one part so that

10 it is really concise and nice.

11 I have a question about (a)(2). So

12 you discussed a second ago that the stall

13 warning for flight in icing conditions and

14 non-icing needs to be the same. You

15 expressed that it needs to be the same in

16 the way that the pilot is notified. But

17 would you clarify that we don't intend for

18 that to be the same actual stall speed?

19 MR. PAUL PELLICANO: Oh, we expect

20 the stall speed to go up in icing.

21 Absolutely. As a matter of fact, if you

22 look at airplanes today, current airplanes

23 certified today, they have a different --

24 stall warning because different stall speed

25 schedules go up, absolutely.
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1 Any more questions or comments?

2 Okay. Thank you very much.

3 MR. LOWELL FOSTER: So we were

4 thinking that we would take a break, but

5 before that I would like to go back to 23.5

6 real quick.

7 So I would like to just reinforce

8 that this is really the heart of the change

9 of 23, the levels, and what we are doing

10 with the safety continuum in proposing Level

11 1 through 4 and just make sure that that

12 magnitude is clear with everyone. Give you

13 a chance, again, to comment or question.

14 MR. BILL BRODEGARD: Bill

15 Brodegard, Aspen Avionics.

16 Related to this is the -- I am

17 interested in the philosophy on the VFR

18 limitation. In other words, what was the --

19 what is the -- what is the driver that

20 creates that VFR limitation?

21 MR. LOWELL FOSTER: For the simple?

22 MR. BILL BRODEGARD: Yes.

23 MR. LOWELL FOSTER: It's simply

24 VLA. CS-VLA and our charter to harmonize

25 with that. The bottom end of 23 was
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1 expanded to include VLA as we discussed in

2 the preamble but that may not have been

3 clear.

4 MR. RIC PERI: Ric Peri, AEA. I

5 appreciate the harmonization concept, but I

6 believe it's to harmonize wherever

7 practical. Our airspace rules, our IFR

8 rules are slightly different than Europe and

9 we want to make sure that we incorporate

10 those aircraft but I would suggest that we

11 do not want to adopt the restrictions that

12 Europe has placed on those aircraft unless

13 there is a purpose for it.

14 In other words, we absolutely want

15 the rules to be able to adopt it, but let's

16 make the rules applicable to our airspace in

17 the US to the maximum extent possible as

18 well.

19 MR. LOWELL FOSTER: Thank you. I

20 appreciate that, Ric.

21 MR. GREG BOWLES: I guess while we

22 are on the subject I will make a quick

23 comment about this topic. From my

24 perspective if you look at the European

25 proposal it does not actually -- it no
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1 longer defines a VLA aircraft and they no

2 longer differentiate an aircraft such as a

3 simple aircraft in this manner. The

4 European approach has now been to use the

5 class as you identified Level 1 through 4,

6 high speed, low speed and then technical

7 considerations within the standards beyond

8 that. VFR/IFR is used in certain cases but

9 not as a lump of a simple aircraft. It's

10 used for different approaches to lightning

11 and herth. So from our perspective we would

12 actually prefer the European approach over

13 defining the simple aircraft as defined

14 here.

15 MR. LOWELL FOSTER: And so if I

16 could clarify, basically, instead of using

17 VFR/IFR as a category differentiator, you

18 are making it a technical differentiator

19 along with other technical differences?

20 MR. GREG BOWLES: Yes.

21 MR. LOWELL FOSTER: Okay. Any --

22 MR. GREG BOWLES: Lowell, before

23 you end, I wanted to ask -- I know that I

24 was late and I apologize -- did you cover

25 Part 21 or do you intend to cover Part 21
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1 comments today?

2 MR. LOWELL FOSTER: We don't. We

3 intend to only cover part 23, however, we

4 have representatives from Part 21 if you

5 have a question or comment.

6 MR. GREG BOWLES: Will there be a

7 period of time to do that on the agenda?

8 MR. LOWELL FOSTER: We are ahead of

9 schedule.

10 MR. GREG BOWLES: Right now?

11 MR. LOWELL FOSTER: Yes. Go for

12 it.

13 MR. GREG BOWLES: So I wanted to

14 comment on 21.9, the FAA has added a

15 provision that would allow other methods of

16 manufacture as acceptable to the

17 administrator so that would be something new

18 alongside of TSO, PMA and production --

19 production certificate and commercial parts.

20 So this new category we would highly

21 endorse. I think the FAA has shown a need

22 for flexibility with safety enhancing

23 equipment specifically, so the recent angle

24 of attack policy is going down a path of

25 standard part production which is a good
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1 path for that part, but there are other

2 classes and parts that could be quite safety

3 enhancing that don't meet standards today

4 such as carbon monoxide detectors. So GAMA

5 would very much be in the favor of allowing

6 as acceptable to the administrative path for

7 production or use intended in aircraft and

8 the development of guidance and policy to

9 control that use.

10 MR. LOWELL FOSTER: Thanks. I

11 appreciate that comment, Greg. And I would

12 ask that you could include that in a written

13 form to the docket. Thank you.

14 So it's a little after 9:00. Let's

15 go ahead and take our first break with the

16 intent to be back at 9:20, 15 minutes, and

17 we will start with Subpart C.

18 (Recess.)

19 MR. PAT MULLEN: All right. Thank

20 you for coming back. I hope you all had an

21 enjoyable break. I had a few questions

22 during the break and for -- Susan, for your

23 benefit, this is Pat Mullen. There has been

24 some questions on the Court Reporter's

25 transcript and its availability and when it
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1 would be available and if it's free of

2 charge and I think that if you -- if I could

3 bring Bill Schinstock up to the microphone

4 to explain. I think that we said that it

5 was going to be placed on the docket, but I

6 think that we also said that it would be

7 available for purchase and I think that we

8 need to clarify that.

9 MR. BILL SCHINSTOCK: Yes, what I

10 said was that it would be put on the docket

11 and there will be instructions for getting a

12 copy of it and it should be available May

13 15th. There may be a little bit of a delay.

14 Once we get it we have to submit it to the

15 government office that puts things on the

16 docket and sometimes there is a short delay

17 while this gets on, but it should be shortly

18 after May 15th. I honestly don't know if

19 there is a charge for the transcript but we

20 can find that out. I will let you know at

21 the next break. Thank you.

22 MR. LOWELL FOSTER: Any other

23 questions or comments?

24 Well, then, I think we will get

25 started with Subpart C with Mike Reyer.
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1 MR. MICHAEL REYER: Good morning.

2 My name is Mike Reyer. I work in the Small

3 Airplane Directorate with everyone else on

4 the panel, but I actually work in the small

5 and continued operational safety branch.

6 And for this project, though, I am working

7 in the loads portions and structural

8 durability.

9 Okay. 23.300 is called the

10 structural design envelope. And this rule

11 captures the intent of several of the rules,

12 321, subparagraphs (b) and (c); 333(a); 337,

13 subparagraphs (a) and (b); and 343,

14 subparagraphs (a) and (b).

15 But what this rule requires is the

16 applicant must determine the structural

17 design envelope, which describes the range

18 and limits of airplane design and

19 operational parameters for which the

20 applicant will show compliance with

21 requirements of this subpart. The applicant

22 must account for all airplane design and

23 operation parameters that affect structural

24 loads, strength, durability,

25 aeroelasticity -- and aeroelasticity,
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1 including: Structural design airspeeds and

2 if the airplane is limited by Mach number

3 you have to consider Mach numbers, design

4 maneuvering speed, VA, which may not be less

5 than the airspeed at which the airplane will

6 stall at the max design load factor --

7 maneuvering load factor, design cruising

8 speed, which may be no less than the maximum

9 speed expected in normal ops, and the design

10 dive airspeed which is the airspeed that

11 will not be exceeded by inadvertent airspeed

12 increases when operating at VC.

13 And then you need to consider any

14 other design airspeed limitations required

15 for the operation of high lift devices,

16 landing gears, any other equipment or

17 devices.

18 For Level 4 airplanes you have to

19 develop a rough air penetration speed. I

20 think that that is all I have on that.

21 No, 23.300 goes on. Subparagraph

22 (b), you have to determine the design

23 maneuvering load factors not less than

24 those, which service history has shown, may

25 occur within the structural design envelope.
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1 In the preamble we discuss, you

2 know, the load factors you choose. We

3 expect them to be what they are today, but,

4 you know, the load factors you chose has to

5 maintain the current level of safety we see

6 with the current regulations.

7 Subparagraph (c), inertial

8 properties including weight, center of

9 gravity and mass moments of inertia,

10 accounting for all weights from the airplane

11 empty weight to the maximum weight; and the

12 weight and distribution of occupants,

13 payload and fuel.

14 You have to document the range of

15 motion for all control surfaces, high lift

16 devices and other movable surfaces,

17 including tolerances and the maximum

18 altitude.

19 Any questions? No. Okay.

20 Moving on to the next. 305,

21 interaction of systems and structures. For

22 airplanes equipped with systems that affect

23 structural performance, either directly or

24 as a result of failure or malfunction, the

25 applicant must account for the influence and
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1 failure conditions of these systems when

2 showing compliance with the requirements of

3 this subpart.

4 This is a new -- not really a new

5 requirement. We have issued special

6 conditions for these types of systems like

7 load alleviation systems, for example. We

8 have done one in part 23. And in part 25

9 they are commonplace. And like we say in

10 the preamble, we wanted to include this as a

11 rule so that people integrating -- who want

12 to integrate systems like load alleviation,

13 they have something to comply to.

14 Greg?

15 MR. GREG BOWLES: Thank you. Just

16 a clarification question.

17 Mike, a clarification issue on

18 23.305. It would appear that you are

19 discussing systems that might affect the

20 primary structure. You were thinking of

21 primary structural members, you were not

22 thinking of things that could affect

23 brackets and other smaller structures.

24 MR. MICHAEL REYER: It would apply

25 to a system like a flap load alleviation
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1 device. But beyond that, you know, I would

2 have to consider that. If you could, you

3 know, make that a comment.

4 MR. GREG BOWLES: Yeah, I guess the

5 question would be about the envelope of

6 applicability. I think that I would

7 understand your intent here as being large

8 aerodynamic influences on structure as a

9 result of systems, but it would not

10 necessarily include, for example, failure of

11 a rotor, things like that, failure of an

12 engine rotor coming through the structure.

13 That would be a different rule?

14 MR. MICHAEL REYER: That is a

15 different rule. Yeah, thanks for the

16 comment. Any others?

17 MR. DAVID ARMSTRONG: David

18 Armstrong from Garmin.

19 The question I have is this seems

20 very similar to the way that Part 25 deals

21 with 629 -- or 529 rule. The -- do you

22 include or exclude failure conditions of the

23 systems that are shown to be extremely

24 probable? The rule does not say that.

25 MR. MICHAEL REYER: If you read the
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1 special conditions that have been published

2 for like load alleviation systems, it has

3 language in there that discusses that.

4 MR. DAVID ARMSTRONG: Okay. Thank

5 you.

6 MR. MICHAEL REYER: Any more?

7 Okay. I am going to the next.

8 Now we go on to the structural

9 loads portion. Just to kind of -- the

10 introductory regulations of this section,

11 23.310 covers -- let's see here -- 301, 302

12 and 321.

13 The applicant must determine

14 structural design loads resulting from any

15 externally or internally applied pressure,

16 force or moment which may occur in flight,

17 ground and water operations, ground and

18 water handling, and while the airplane is

19 parked or moored.

20 Subparagraph (b), determine the

21 loads required by Paragraph (a) of this

22 section at all critical combinations of

23 parameters, on or within the boundaries of

24 the structural design envelope.

25 So proposed paragraph (c), the
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1 magnitude and distribution of these loads

2 must be based on physical principles and may

3 be no less than service history shows will

4 occur within the structural design envelope.

5 Any questions?

6 315, flight loads, flight load

7 conditions, proposed flight load conditions.

8 It covers a lot of stuff. 333, subparagraph

9 (c); 347; 47; 49; 51; 67; 423; 425; 27; 41

10 and 43.

11 And this paragraph says: The

12 applicant must determine the structural

13 design loads resulting from the following

14 flight conditions: Vertical and horizontal

15 atmospheric gusts where the magnitude and

16 gradient of these gusts are based on

17 measured gust statistics, symmetric and

18 asymmetric maneuvers, for canted lifting

19 surface, vertical and horizontal loads

20 acting simultaneously resulting from gust

21 and maneuver conditions, and for multiengine

22 airplanes, failure of the powerplant unit

23 which results in the most severe structural

24 loads.

25 Any questions? Thank you.
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1 MR. GREG BOWLES: My understanding

2 of the current rule for powerplant failures,

3 structural loads, in multiengine airplanes

4 today we don't necessarily account for a

5 sudden stop of the propeller. Is that true

6 under 23.315? Would that be included in (d)

7 in the future?

8 MR. MICHAEL REYER: I don't want to

9 make a comment on that right now. I would

10 have to get back to you.

11 MR. GREG BOWLES: Okay.

12 MR. MICHAEL REYER: Okay. Any

13 other questions?

14 Going on to 320. 320, ground

15 loads. This covers an entire section of the

16 current rules 470 through 537. The

17 applicant must determine the structural

18 design loads resulting from the following

19 ground and water operations: For airplanes

20 intended for operation on land-taxi,

21 takeoff, landing, and ground handling

22 conditions occurring in normal and adverse

23 attitudes and configurations.

24 Subparagraph (b), for airplanes

25 intended for operation on water-taxi,
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1 takeoff and landing and water handling

2 conditions occurring in normal and adverse

3 attitudes and configurations in the most

4 severe, sea conditions expected in

5 operation. And then finally jacking and

6 towing loads.

7 Nobody? Okay.

8 325. This covers a fair amount of

9 the current rules too. Proposed 325,

10 component loading conditions, covers 345,

11 61, 63, 65 and then 371 through 425, 455 and

12 459.

13 The applicant must determine the

14 structural design loads acting on: Each

15 engine mount and its supporting structure

16 resulting from engine operations combined

17 with gusts and maneuvers.

18 Subparagraph (b), each flight

19 control and high lift surface, their

20 associated system and supporting structure

21 resulting from the inertia of each surface

22 and mass balance attachment; gust and

23 maneuvers; pilot or automated system inputs;

24 system induced conditions, including jamming

25 and friction; and (5) ground operations,
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1 including downwind taxi and ground gusts.

2 Subparagraph (c), for pressurized

3 cabins -- pressurized cabin resulting from

4 the pressurization differential from zero up

5 to the maximum relief valve setting combined

6 with gust and maneuver loads; from zero up

7 to the maximum relief valve setting combined

8 with ground and water loads if the airplane

9 may land with the cabin pressurized; and

10 then finally, at the maximum relief valve

11 setting multiplied by 1.33, acting as a --

12 without other load considerations.

13 Anyone?

14 And 330, just the definitions

15 basically of what limit and ultimate loads

16 are. This covers 301(a) and 303.

17 Unless special or other factors of

18 safety are necessary to meet the

19 requirements of this subpart, the applicant

20 must determine: (a), the limit loads, which

21 are equal to the structural design loads;

22 and, (b), the ultimate loads, which are

23 equal to the limit loads multiplied by one

24 and a half factor of safety.

25 Pretty much a direct translation of
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1 what is in the current rule.

2 Okay. We will go on now to what we

3 call structural performance. These sections

4 are kind of in the end of, you know, what

5 the structure has to be capable of doing,

6 you know, to the loads that we have

7 calculated.

8 Structural strength, this

9 incorporates 305. The applicant must

10 demonstrate that the structure will support

11 limit loads without interference with the

12 operation of the airplane; and (2),

13 detrimental permanent deformation; and

14 ultimate loads.

15 Again, this is largely out of the

16 current wording of the regulations. I don't

17 really have anything too much to say about

18 that. Does anybody have a question? Okay.

19 Well, that is strength in a nutshell.

20 And now 405, which is structural

21 durability, or you might call it fatigue and

22 damage tolerance. The current rules have,

23 you know, the prescriptive methods, safe

24 life, damages or fail safe and we, of

25 course, wanted to leave those options
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1 available to people but, of course, take the

2 prescriptive content out of the current rule

3 as much as possible. So paragraph (a) is

4 really the statement of the intent of the

5 previous fatigue and damage rules which are

6 571 through 575 and 627.

7 Paragraph (a): The applicant must

8 develop and implement procedures to prevent

9 structural failures due to foreseeable

10 causes of strength degradation, which could

11 result in serious or fatal injuries, loss of

12 the airplane, or extended periods of

13 operation with reduced safety margins. The

14 Instructions For Continued Airworthiness

15 must include procedures developed under this

16 section.

17 We did retain a few of the more

18 prescriptive requirements especially in

19 Subpart (c); that came from the jet rule.

20 And that is one place where, you know, an

21 altitude limitation was kept.

22 Subparagraph (b), if a pressurized

23 cabin and two or more compartments separated

24 by bulkheads or a floor, the applicant must

25 design the structure for a sudden release of
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1 pressure in any compartment that has a door

2 or a window, considering failure of the

3 largest door or window opening in the

4 compartment.

5 This is again from the jet rule.

6 For airplanes with maximum operating

7 altitude greater than 41,000 feet, the

8 procedures developed for the compliance to

9 paragraph (a) of this section must be

10 capable of detecting damage to the

11 pressurized cabin structure before the

12 damage could result in rapid decompression

13 that would result in serious or fatal

14 injuries.

15 And finally, the roto-burst: The

16 airplane must be capable of continued safe

17 flight and landing with structural damage

18 caused by high-energy fragments from an

19 uncontained engine or rotating machinery

20 failure.

21 And that last bit is kind of meant

22 to include an electric propulsion system

23 where you might have a rapidly rotating

24 aperture arm or something like that. It

25 could have the same kind of effect that a
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1 rotor blade or something like that could

2 have.

3 And that is it for my section.

4 Does anybody have questions or final

5 questions or comments? No. Okay. Well

6 thank you.

7 Mark James is up next for the rest

8 of the Subpart (c) and D.

9 MR. MARK JAMES: Good morning. I

10 am Mark James. I work in the Small Airplane

11 Directorate for Bill Schinstock on standard

12 staff and I will be covering the rest of the

13 structure section.

14 So the first rule we are proposing,

15 23.410, aeroelasticity. This captures the

16 safety intent of the original 23.629 flutter

17 section along with 677, Paragraph (c), trim

18 systems; 687, spring devices in part.

19 Paragraph (a) says the airplane

20 must be free from flutter, control reversal,

21 and divergence at all speeds within and

22 sufficiently beyond the structural design

23 envelope; for any configuration and

24 condition of operation; accounting for

25 critical degrees of freedom; and accounting
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1 for any critical failures or malfunctions.

2 And in paragraph (b), the applicant

3 must establish and account for tolerances

4 for all quantities that affect flutter. Any

5 questions on that?

6 And now we will move on to design,

7 which was previously Subpart D, design and

8 construction. So we are proposing 23.500,

9 which captures the safety intent of 601,

10 design and construction; 603, materials and

11 workmanship, paragraph (b); 671, control

12 systems-general, and paragraph (a); 683,

13 operational tests; 687, spring devices, in

14 part; and 689, cable systems.

15 We propose, paragraph (a), the

16 applicant must design each part, article,

17 and assembly for the expected operating

18 conditions of the airplane; (b), design data

19 must adequately define the part, article, or

20 assembly configuration, its design features,

21 and any materials and processes used; (c),

22 the applicant must determine the suitability

23 of each design detail and part having an

24 important bearing on safety and operations;

25 (d), the control system must be free from
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1 jamming, excessive friction, and excessive

2 deflection when the control system and its

3 supporting structure are subjected to loads

4 corresponding to the limit airloads; the

5 primary controls are subjected to the lesser

6 of the limit airloads or limit pilot forces;

7 and the secondary controls are subjected to

8 loads not less than those corresponding to

9 maximum pilot effort.

10 Any questions or feedback on that?

11 Moving on. 23.505 is supposed to

12 capture the safety intent of 607, fasteners;

13 609, protection of structure; and 611,

14 accessibility.

15 We propose paragraph (a): The

16 applicant must protect each part of the

17 airplane, including small parts such as

18 fasteners, against deterioration or loss of

19 strength due to any cause likely to occur in

20 the expected operational environment.

21 (b), each part of the airplane must

22 have adequate provisions for ventilation and

23 drainage.

24 And, (c), for each part that

25 requires maintenance, preventative
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1 maintenance, or servicing, the applicant

2 must incorporate a means into the aircraft

3 design to allow such actions to be

4 accomplished.

5 MR. GREG BOWLES: Question:

6 23.505(a), do you anticipate that section

7 would also address corrosion?

8 MR. MARK JAMES: I don't want to

9 comment on that, but I will take that as a

10 comment and we will give you -- address it

11 in the final preamble.

12 Okay. 23.510. We propose to

13 capture the safety intent of the original

14 605, fabrication methods; and 613, material

15 strength properties and design values.

16 This is -- that was the original

17 section that captured what we typically

18 refer to as A- and B-basis allowables.

19 We propose, paragraph (a), the

20 applicant must determine the suitability and

21 durability of materials used for parts,

22 articles, and assemblies, the failure of

23 which could prevent continued safe flight

24 and landing. The applicant must account for

25 the effects of likely environmental
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1 conditions expected in service.

2 The methods and processes of

3 fabrication and assembly used must produce

4 consistently sound structures. If a

5 fabrication process requires close control

6 to reach this objective, the applicant must

7 perform the process under an approved

8 process specification.

9 Except as provided in paragraphs

10 (f) and (g) of this section, the applicant

11 must select design values that ensure

12 material strength with probabilities that

13 account for the criticality of the

14 structural element. Design values must

15 account for the probability of structural

16 failure due to material variability.

17 This was the section that was

18 previously the A- and B-basis Allowables and

19 what was very prescriptive in nature is now

20 a method of compliance.

21 Paragraph (d), if material strength

22 properties are required, a determination of

23 those properties must be based on sufficient

24 tests of material meeting specifications to

25 establish design values on a statistical
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1 basis.

2 If thermal effects are significant

3 on an essential component or structure under

4 normal operating conditions, the applicant

5 must determine those effects on allowable

6 stresses used for design.

7 Design values, greater than the

8 minimum specified by this section, may be

9 used, where only guaranteed minimum values

10 are normally allowed, if a specimen of each

11 individual item is tested before use to

12 determine that the actual strength

13 properties of that particular item will

14 equal or exceed those used in the design.

15 And, paragraph (g) is an additional

16 paragraph that Part 25 has had for years

17 that we have added in: An applicant may use

18 other material design values if approved by

19 the Administrator.

20 So if there is no questions on

21 that, we will move on to 515, special

22 factors of safety, which is meant to capture

23 the safety intent of 619, special factors;

24 621, casting factors; 623, bearing factors;

25 625, fitting factors; 657, hinges; 681,
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1 paragraph (b), limit load and static test,

2 in part; and 693, joints.

3 We propose paragraph (a): The

4 applicant must determine a special factor of

5 safety for any critical design value that is

6 uncertain; used for a part, article, or

7 assembly that is likely to deteriorate in

8 service before normal replacement; or

9 subject to appreciable variability because

10 of uncertainties in manufacturing processes

11 or inspection methods.

12 Paragraph (b), the applicant must

13 determine a special factor of safety using

14 quality controls and specifications that

15 account for each structural application;

16 inspection method; structural test

17 requirement; sampling percentage; and

18 process and material control.

19 Paragraph (c), the applicant must

20 apply any special factor of safety in the

21 design for each part of the structure by

22 multiplying each limit load and ultimate

23 load by the special factor of safety.

24 Yes, Greg?

25 MR. GREG BOWLES: Another
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1 clarification, 23.515(c) under today's

2 amendment do we apply factors of safety to

3 limit load as well as ultimate load?

4 MR. MARK JAMES: Yes.

5 MR. GREG BOWLES: Okay. Thank you.

6 And then we will move on to 23.600,

7 emergency conditions. And this is one where

8 we had hoped to see the industry take the

9 lead in coming with some holistic

10 approaches. This is meant to capture the

11 safety intent of 23.561, emergency landing

12 conditions, general; 23.562, emergency

13 landing dynamic conditions; 23.785, seats,

14 berths, litters, safety belts, and shoulder

15 harnesses; and 23.787, baggage and cargo

16 compartment.

17 We propose paragraph (a), the

18 airplane, even when damaged in an emergency

19 landing, must protect each occupant against

20 injury that would preclude egress when

21 properly using safety equipment and features

22 provided for in the design; the occupant

23 experiences ultimate static inertia loads

24 likely to occur in an emergency landing; and

25 items of mass, including engines or
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1 auxiliary power units, within or aft of the

2 cabin, that could injure an occupant,

3 experience ultimate static inertia loads

4 likely to occur in an emergency landing.

5 Paragraph (b), the emergency

6 landing conditions specified in paragraph

7 (a) of this section, must include dynamic

8 conditions that are likely to occur with an

9 impact at stall speed, accounting for

10 variations in aircraft mass, flight path

11 angle, flight pitch angle, and yaw and

12 airplane configuration, including likely

13 failure conditions at impact; and not exceed

14 established human injury criteria for human

15 tolerance due to restraint or contact with

16 objects in the airplane.

17 The airplane must have seating and

18 restraints for all occupants. The airplane

19 seating, restraints, and cabin interior must

20 account for likely flight and emergency

21 landing conditions.

22 And it continues on to paragraph

23 (d), each occupant restraint system must

24 consist of a seat, a method to restrain the

25 occupant's pelvis and torso, and a single
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1 action restraint release. For all flight

2 and ground loads during normal operation and

3 any emergency landing conditions, the

4 restraint system must perform its intended

5 function and not create a hazard that could

6 cause a secondary injury to an occupant.

7 The restraint system must not prevent

8 occupant egress or interfere with the

9 operation of the airplane when not in use.

10 Paragraph (e), each baggage and

11 cargo compartment must be designed for its

12 maximum weight of contents and for the

13 critical load distributions at the maximum

14 load factors corresponding to the flight and

15 ground load conditions determined under this

16 part: Have a means to prevent the contents

17 of the compartment from becoming a hazard by

18 impacting occupants or shifting; and protect

19 any controls, wiring, lines, equipment, or

20 accessories whose damage or failure would

21 affect operations.

22 That covers what was originally

23 referred to as the dynamic seat rule. Any

24 comments or questions on this? Okay.

25 That finishes up the section on
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1 structures. So I don't know -- what do we

2 have up next? Do you want to do it?

3 MR. BILL SCHINSTOCK: So we are

4 well ahead of schedule, as you can tell. We

5 are scrambling a little bit trying to decide

6 how to handle it, but since we are so far

7 ahead of schedule, I will give you one more

8 chance if anybody has anything that we have

9 not covered if they would like to comment on

10 or ask questions about that, otherwise, we

11 will take a short break and chart our course

12 for the remainder of the day.

13 MR. BILL BRODEGARD: This is Bill

14 Brodegard from Aspen Avionics. I have just

15 one other structures question. I apologize,

16 it had to sit in my head for a moment. But

17 there was that one section where it said

18 that the structure has to be established by

19 tests. And from an article manufacturer

20 like myself, the -- does that mean every

21 applicant has to demonstrate by test all the

22 structural aspects or are there going to be

23 some kind of standards that we can show

24 that, okay, our equipment meets this

25 particular standard? And there was another
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1 question I had about it must be approved and

2 I did not know who approved it.

3 MR. MARK JAMES: I think that I

4 know what section you are referring to. I

5 will try to get back to it here. Thank you.

6 MR. BILL BRODEGARD: Thank you,

7 just -- I think that it was just before that

8 one.

9 MR. MARK JAMES: Just before this

10 one?

11 MR. BILL BRODEGARD: No, it was a

12 longer one. Continued safe flight and

13 landing, I think, had it.

14 MR. MARK JAMES: You are talking

15 about paragraph (a)?

16 MR. BILL BRODEGARD: Let's see,

17 the -- yeah, let's see. It says: (d), if

18 the material strength properties are

19 required, a determination of those

20 properties must be based on sufficient tests

21 of material meeting the specifications -- I

22 am not sure what that -- you know, I think

23 about them, you know, mounting my equipment

24 on a shelf that has been prepared for

25 accepting my equipment. Does the applicant,
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1 me, have to go through testing in order to

2 verify that that is okay or do we use the --

3 you know, the statements from the

4 manufacturer, you know, that it's adequate

5 or, you know, those kind of things? I am

6 just -- I don't want get into dynamic

7 testing.

8 MR. MARK JAMES: I understand. I

9 appreciate the comment and so what I am

10 hearing you say, if I can try to phrase it

11 differently, is that we need to clarify when

12 and who has to do what testing for the

13 materials and whether it's primary structure

14 or secondary structure or tertiary

15 structure --

16 MR. BILL BRODEGARD: Right.

17 MR. MARK JAMES: Is that kind of

18 exactly what you are getting it at?

19 MR. BILL BRODEGARD: Yes. And then

20 on (b) there, it says perform the process

21 under an approval process specification. Is

22 that an FAA approved process specification?

23 Is that an accepted industry standard or how

24 is that approved?

25 MR. MARK JAMES: So your comment is
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1 that we would like -- you would like to

2 clarify what we mean by who approves the

3 specification?

4 MR. BILL BRODEGARD: Yes.

5 MR. MARK JAMES: If you would

6 please put those in a comment on the docket

7 we appreciate it and we will address that.

8 MR. BILL BRODEGARD: Okay.

9 MR. MARK JAMES: Thank you.

10 MR. RIC PERI: I appreciate the

11 fact that we started this evolution ten

12 years ago by highlighting the fact that, you

13 know, my car is, you know, more advanced

14 than my airplane. In paragraph (d), in

15 particular, you're perpetuating a criteria

16 that, in fact, was revised in the automotive

17 standards in 1972 in that they revised the

18 1968 standard by allowing for a complete

19 passive protection system, and yet we are

20 still locked into the, you know, seat belts

21 and pelvis and torso. I would suggest that

22 you take a look at the Department of

23 Transportation automotive standards with

24 regards to restraint systems for passengers

25 and see if we can't modernize this beyond
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1 1960.

2 MR. BILL SCHINSTOCK: Thank you,

3 Ric. We will take that under advisement and

4 address it in the final preamble.

5 MR. PAT MULLEN: So, Ric, could you

6 describe a little bit what DOT's passive

7 restraining system is and what it comprises

8 of?

9 MR. RIC PERI: They don't define

10 it. Okay. What they say is that under the

11 standard 208 of NHTSA, which is the National

12 Highway Transportation Safety, occupy crash

13 protection -- this standard originally

14 specified the type of occupant restraint;

15 i.e., seat belts required. It was amended

16 to specify performance requirements for

17 anthropomorphic test dummies seated in the

18 front outboard seats of passenger cars and

19 of certain multi-purpose vehicles including

20 the active and passive restraint systems

21 identified below. The purpose of the

22 standard is to reduce the number of

23 fatalities and the number and severity of

24 injuries of occupants involved in frontal

25 crashes.
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1 There has been a number of reports

2 of the damage of legacy seat belts in

3 accidents, which is why they basically said,

4 hey, if you can create, you know, the

5 ultimate bean bag chair and protect

6 somebody, you are free to do that. And so

7 while the technology and the availability

8 may not be readily there, we are locking

9 ourselves into a standard that reality is

10 that we may have automotive standards that

11 we can't put into aircraft because of that.

12 And so what I would suggest is that we marry

13 them to make sure that we have those same

14 opportunities.

15 MR. MARK JAMES: Thank you. That

16 is a very good comment. I appreciate that.

17 MR. BILL SCHINSTOCK: Anybody else?

18 All right. Let's take a 15-minute break and

19 we will get together up here and chart our

20 course for the rest of the day. Thank you.

21 (Recess.)

22 MR. PAT MULLEN: Okay. Thank you

23 everybody and good morning again.

24 Obviously, as you know, we are pretty far

25 ahead on the agenda and that is a good thing
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1 but it also presents some challenges and we

2 think that we have a game plan that we want

3 to go over with you, and Bill is going to go

4 over that with you.

5 The one thing that I wanted to

6 mention is this is a public meeting and I

7 don't know if -- I appreciate -- there has

8 been some good dialogue that we have heard

9 from GAMA and AEA and we appreciate that

10 input, but don't be afraid to tell us

11 exactly what is on your mind. I mean, we

12 are not sitting here pretending that we have

13 done the perfect job and that our rule is

14 perfect. If you think that we are missing

15 something, if you think that we missed the

16 point or are not as clear or are too -- or

17 we are too ambiguous on a proposed rule, let

18 us know. It's okay. I really -- please

19 don't be shy. I know that we have a Court

20 Reporter and everything is going to be

21 recorded and placed in the docket, but I

22 just encourage your input and your feedback,

23 so I just wanted to mention that so, thank

24 you, and if I can present -- hand it back

25 over to Bill.
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1 MR. BILL SCHINSTOCK: Okay. A

2 little bit of old business, first, I was

3 asked about the copy of the transcript. The

4 plan is to put the transcript in the docket

5 and it would be available there for anybody

6 who wants to make a copy of or print it out

7 or whatever, but it would be in the docket.

8 It does say that you can order it directly

9 but that information will be in the docket

10 on how to do that. I don't know the answer

11 to that, but it will be available in the

12 docket to the public.

13 So for the rest of the day, as Pat

14 said, we are well ahead of schedule. Our

15 plan is to present Subpart (d) next. And

16 when we get through that we will take a look

17 at it. If we have time before lunch we will

18 go through Subpart (g) and finish that and

19 then we will open the floor to anybody that

20 has comments that wants to make a

21 presentation or anything along those lines.

22 And then if -- when we run out of topics to

23 discuss today, we will break for the day --

24 the remainder of the day and then start up

25 tomorrow as planned.
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1 Tomorrow we will cover Subparts E

2 and (f) and then again, once again, open the

3 door for any public comment or presentation

4 and leave the floor open as long as

5 necessary to let everybody speak their

6 peace. But as Pat said, please, feel free

7 to provide us with the comments here today

8 and tomorrow. We would appreciate it.

9 Thank you.

10 Mark?

11 MR. MARK JAMES: Thank you, Bill.

12 You will have to excuse me. We had a

13 retirement in our ranks and our mechanical

14 systems engineer is gone and we have someone

15 replacing him but he was not on the team so

16 I am going to try to go through the

17 mechanical systems rules in Subpart (d) and

18 I will try not to bore you further with me

19 reading the rule to you. I will just let

20 you read the new proposed rule language for

21 this 23.700, flight control systems. But

22 what I will read to you is from the preamble

23 and what the rule is meant to capture in the

24 way of the safety intent from the original

25 language. This was meant to capture the
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1 current Rule 23.677, trim systems,

2 paragraphs, (a), (b) and (d); 689, cable

3 systems, (a) and (f); 697, artificial stall

4 barrier systems; Paragraphs (a), (b), (d),

5 (e) and (f); 23.691, wing flap controls,

6 paragraphs (a); and 703, takeoff warning

7 systems, paragraphs (a) and (b).

8 And I will give you just a minute

9 to read that, and if everybody has -- oh,

10 there is somebody waiting right there.

11 MR. GREG BOWLES: Greg with GAMA.

12 23,700(a)(1)(iii), flutter, it appears to me

13 that flutter was already addressed in an

14 aeroelasticity section so it might make more

15 sense to not call it a specific hazard like

16 this, but to deal with it in its own way.

17 Also we had a question about, okay,

18 the stall barrier issue. Where was that?

19 That is on the next page; is that right?

20 MR. MARK JAMES: Do you want me to

21 go forward one?

22 MR. GREG BOWLES: No, that is okay.

23 That is -- I will ask that question in a

24 second. On this one, it's only a flutter

25 issue and I think that that should be only
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1 addressed under aeroelasticity.

2 MR. MARK JAMES: So if there is no

3 more questions or comments, we will go on.

4 Oh, it looks like 700 continues. I will

5 give you a chance to read that.

6 MR. GREG BOWLES: So Greg, again,

7 from GAMA. 23.700(c)and (c)(1), (c)(2), so

8 a stall barrier system is eventually a

9 fly-by-wire and an unlimited point of use.

10 It's basically a very simple type of fly

11 wire or a pitch -- a pitch command

12 typically. We would see that only applying

13 those two conditions to stall barriers, may

14 not be the best path and the stall barriers

15 are a pretty prescriptive approach, so

16 potentially the rule as written also

17 addresses this limited stall barrier issue

18 and fly-by wire and this may be better

19 fodder for the standards.

20 MR. MARK JAMES: For the

21 standards -- oh, okay.

22 MR. GREG BOWLES: For the method of

23 compliance.

24 MR. MARK JAMES: You mean more of

25 compliance?
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1 MR. GREG BOWLES: Yes.

2 MR. MARK JAMES: For ease of

3 compliance, yes.

4 MR. GREG BOWLES: Right.

5 MR. MARK JAMES: I see.

6 MR. GREG BOWLES: (C)(1) and (2)

7 dealing with stall barriers is a detailed

8 kind of solution for one condition and it's

9 a good one, and those are certainly checks.

10 There are potentially more things that you

11 want to check with the stall barrier system.

12 Just because it does those two things does

13 not necessarily mean that that is the one

14 that you want on your airplane, so I would

15 suggest that that would be better in a means

16 of compliance.

17 MR. MARK JAMES: Okay. Thank you.

18 If there is no other comments we will move

19 on to 23.705, landing gear systems. This is

20 meant to capture the safety intent of the

21 current 23.729, landing gear extension and

22 retraction systems, paragraphs (a), (b), (c)

23 and (d); 23.731, wheels; 733, tires,

24 paragraph (a); 735, brakes, paragraphs (a),

25 (b) and (e); 737, skis. And that is it on
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1 that one.

2 Yes, Greg?

3 MR. GREG BOWLES: Greg with GAMA.

4 23.705(c), it talks about a reliable means

5 of stopping the airplane must provide

6 kinetic energy absorption with the

7 airplane's design specifications for

8 landing.

9 Would you envision this would be

10 addressed by friction when you look at

11 things like skis and flow planes?

12 MR. MARK JAMES: Okay. Thank you.

13 We will take that and address it in the

14 preamble.

15 No other questions. We will move

16 on to 710, buoyancy for seaplanes and

17 amphibians. This was meant to capture the

18 original safety intent of 751(a), main float

19 buoyancy; 755, hulls; and 757, auxiliary

20 floats. Pretty straightforward.

21 MR. GREG BOWLES: On 23.710(b),

22 specifying that if any two compartments of a

23 main hull are flooded the aircraft needs to

24 remain afloat is relatively restrictive.

25 There could be solutions like using
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1 expandable foam and closed cell foam that do

2 not have compartments. You might have open

3 two compartments. You might have many,

4 many, many compartments, so it would be

5 better to just discuss that under any likely

6 failure condition or puncture that could

7 occur in the environment or landing service,

8 it would be better to meet this condition.

9 MR. MARK JAMES: Are you saying,

10 though, that if it did have the compartments

11 that you could address it by saying if you

12 have this design, you could do this or

13 something else? Is that what you are --

14 MR. GREG BOWLES: So --

15 MR. MARK JAMES: -- proposing?

16 MR. GREG BOWLES: Yes. So I think

17 that this could be a great solution, so

18 23.710(b) could be a great solution in means

19 of compliance.

20 MR. MARK JAMES: Thank you.

21 MR. GREG BOWLES: But the

22 performance-based rule might be better

23 worded if it were to address the condition

24 of likely puncture or likely failure or leak

25 and making sure that it does not capsize in
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1 calm water.

2 MR. MARK JAMES: Okay. Thank you.

3 So moving on to proposed Rule 750,

4 means of egress and emergency exits. This

5 captures a rather lengthy list of items:

6 783, doors, paragraphs (a), (b), (c) and

7 (d); 791; 803, emergency evacuation,

8 paragraph (a); 805, flight crew emergency

9 exits; 807, emergency exits, except for

10 Paragraphs (a)(3), (b)(1), (c), (d)(1) and

11 (d)(4); paragraph -- or Rule 811, emergency

12 exit marking; 812, emergency lighting; 813,

13 emergency exit access, paragraph (a); and

14 815, width of aisles; and CS-VLA-783(a),

15 exits.

16 MR. GREG BOWLES: I have another

17 question, 23.750(a), this is a question --

18 actually, a clarification question.

19 MR. MARK JAMES: Okay.

20 MR. GREG BOWLES: It specifies that

21 the evacuation of the aircraft needs to

22 occur within 90 seconds. In the past the

23 rule has -- the preamble -- the current rule

24 indicated that smaller part 23 aircraft

25 don't have capacities that would require --
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1 that would necessitate the testing to show

2 that they could get out in 90 seconds and,

3 therefore, 90 seconds has not been held as a

4 standard.

5 I don't have a concern that we use

6 this as a threshold, but does the FAA

7 envision having to do a 90-second evacuation

8 test on all designs or would means of

9 compliance accept a reasonable number of

10 exits per passenger density or solutions

11 like this?

12 MR. MARK JAMES: Okay. Thank you.

13 Moving on to 755, occupant physical

14 environment. There is the proposed rule

15 language and this is intended to capture the

16 safety intent of portions of some of the

17 following rules: 771, 775, 831, 841, 843,

18 1441, 1443, 1445, 1447, 1449 and 1461. So

19 it's a rather lengthy -- it covers two

20 slides here. The titles for those rules I

21 just mentioned are in the preamble for the

22 NPRM. Any comments or questions on that?

23 Okay. Moving on. Fire and high

24 energy protection. Proposed Rule 23.800

25 fire protection outside designated fire
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1 zones. Again, rather lengthy list of rules,

2 this captures the safety intent for 851,

3 853, 855, 856, 859, 863, 1359, 1365, 1383,

4 1385, and CS-VLA-853. Again, if you want to

5 know the titles of those sections, it's

6 published in the preamble. Also this one

7 continues on to the next slide. Any

8 questions or comments on this one?

9 Let's move on to 805, fire

10 protection in designated fire zones. This

11 is intended to capture the safety intent of

12 the original rule language in 865, 1359, and

13 that is it. Seeing no -- oh, yes, Ric.

14 MR. RIC PERI: Can you elaborate a

15 little bit more on the electrical cables

16 used during emergency procedures only in

17 that the -- pretty much the entire cockpit

18 has emergency procedures to it and I could

19 interpret that to be the entire avionics

20 suite at given applications, so could you

21 elaborate on what you are talking about

22 here?

23 MR. MARK JAMES: I will have to

24 elaborate in the preamble when we respond to

25 the comment. Thank you. Or someone will.
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1 MR. LOWELL FOSTER: If the original

2 author was here I think that we could

3 elaborate on it but Les Taylor retired but

4 as a rulemaking team we are still getting up

5 to speed on that section.

6 MR. RIC PERI: And I would offer

7 it -- I would interpret that to be emergency

8 procedures, that is, in egress; but the fact

9 is that we have a whole lot of emergency

10 procedures in there, you know, such as, you

11 know, limited electronics and stuff like

12 that, which all could kind of touch that and

13 so it's just the clarification.

14 MR. JIM BRADY: Just one

15 clarification. This is Jim Brady. This is

16 inside designated fire zones, so it's not

17 necessarily the entire avionics suite and

18 such. It would be more things like your

19 fuel control cables inside in a cell, those

20 type of things.

21 MR. MARK JAMES: Okay. Moving on

22 to 810, lightening protection of structure.

23 This is meant to capture the safety

24 intent of 867(a) and (c). And seeing no

25 questions or -- okay, here is one.
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1 MR. GREG BOWLES: Some of the

2 policies that have been out recently related

3 to non-required safety enhancing equipment

4 and some other things have discussed that

5 part 23 airplanes are less likely for

6 lightning strike whether or not they are VFR

7 or IFR capable based on the size of the

8 aircraft and also based on the things that

9 they avoid, the type of weather that they

10 avoid. So my question would be, is

11 instrument versus visual the right

12 discriminator for this?

13 MR. MARK JAMES: Would you have a

14 proposal for other --

15 MR. GREG BOWLES: The other

16 proposal that I will put on the floor, and

17 we will submit this in written comments as

18 well, would be it would have to be a

19 measured -- a more risk-based proposal based

20 on history and scale of the aircraft. I

21 guess scale and type of operation because

22 this is what seems to be avoiding of

23 lightning.

24 MR. MARK JAMES: Do you think that

25 the existing levels that we prescribed, the
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1 Level 1 2, 3 and 4, would work for those?

2 MR. GREG BOWLES: Conceivably we

3 could pick a level, yeah, where we are

4 finding that it does and does not occur

5 based on data, past data, yeah.

6 MR. MARK JAMES: Okay. Thank you.

7 So if there is no other questions or

8 comments on that, that concludes this

9 section and so I think that we wanted to

10 have a break, is that right? No. Okay.

11 MR. LOWELL FOSTER: So we will

12 continue on with (g).

13 Yes, Ric?

14 MR. RIC PERI: And I don't know

15 that this is not outside the scope of this

16 rulemaking, so I will start by saying that.

17 But, you know, as we look at

18 performance-based rules -- and, again, going

19 back to some of the challenges that the

20 light sport aircraft community has had in

21 this process, you know, we focus on IFR and

22 VFR, but there is an FAA legal

23 interpretation that says I can fly IFR in a

24 VFR aircraft. I cannot fly IMC. Okay.

25 Is it possible to make that
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1 distinction here to where, you know -- and

2 this is a classic example. I believe what

3 you are trying to say is that where I am IMC

4 and have the possibly of unanticipated

5 lightning strike that I protect for it. But

6 the reality is if I am flying IFR in VMC, I

7 have no hazard. And so from a

8 performance-based perspective, it might be

9 good to make this transition from the

10 IFR/VFR concept into the IMC/VMC concept,

11 which is really what we are talking about.

12 MR. LOWELL FOSTER: Thank you. I

13 would agree I think that that is within the

14 scope and I definitely encourage you to

15 follow up with a written comment.

16 So we will jump ahead to Subpart

17 (g) and we will try to finish that up so

18 that we have time if anybody wants to make

19 comments before we adjourn for lunch, so

20 give me just a second and I will reset the

21 presentation.

22 So proposed 1500 actually is a

23 little bit new but incorporates a lot of --

24 it incorporates anything that the pilot

25 would have monitored or controlled. That
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1 was the intent of 1500. That means it's

2 capturing sections 23.699, 23.745, 1303,

3 1321, 1311, 771, 773, 777, 779 and 23.781.

4 So it's a substantial number of sections

5 from the current rule, however, all of those

6 relate to some aspect of the pilot or the

7 flightcrew and what they need to do to

8 control the airplane, hence, flightcrew

9 interface.

10 This rule, by the way, isn't

11 intended to add any burden so it's a parity

12 rule but the language should allow us to

13 really open the door to a lot of new

14 technologies so this is one of those rules

15 that I think will have a lot of merit on

16 safety.

17 MR. BILL BRODEGARD: It says, so

18 qualified flightcrew can monitor and perform

19 all tasks. The "all" is kind of scary, but

20 does that preclude systems from monitoring

21 things that the flightcrew would not

22 necessarily have to monitor all the time?

23 MR. LOWELL FOSTER: The intent was

24 that it did not limit anything so I would --

25 I appreciate that comment.
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1 MR. BILL BRODEGARD: Yes, because

2 it says flightcrew can monitor but there is

3 other things that they might --

4 MR. LOWELL FOSTER: So if the

5 language is limiting in a respect that we

6 may not be aware of, we would, please,

7 welcome your comment.

8 MR. BILL BRODEGARD: Right.

9 MR. LOWELL FOSTER: Anyone else?

10 Comments? Questions?

11 MR. BERNIE NEWMAN: Bernie Newman,

12 Astronautics. That last sentence which

13 talks about the possibility for a flightcrew

14 error resulting in a catastrophic event to

15 be highly unlikely. When I see catastrophic

16 and I see highly unlikely, traditionally I

17 view catastrophic to be associated with a

18 likelihood of extremely improbable. What is

19 this new phrasing here? What does it mean?

20 MR. LOWELL FOSTER: So that is a

21 very important comment and I appreciate you

22 pointing that out. Hopefully, you will

23 follow-up with a written comment, too, on

24 that.

25 Anyone else?
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1 All right. 1505, instrument

2 markings, control markings, and placards.

3 This captured a very large range of the

4 existing sections; however, most of the

5 sections in the current rule were basically

6 addressing one item, and it was a laundry

7 list. And in those cases they really were

8 details that were better or more appropriate

9 for means of compliance and so this has been

10 summed up.

11 So 1505 captures current 1505

12 through 1527 and 1541 through 1567.

13 All right. Any questions?

14 MR. NICK BOGNER: Actually, I am a

15 little slow. I would like to make a comment

16 on the 1500 from the prior slide.

17 MR. LOWELL FOSTER: No problem. Go

18 ahead. Can you speak up?

19 MR. NICK BOGNER: Nick Bogner. So

20 the question that that last sentence also

21 made me think of something and so it

22 addresses catastrophic and other language

23 and other sections of the new issue. We

24 talk about catastrophic hazardous and major.

25 So in the sake of being consistent, are we
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1 only concerned with catastrophic here

2 without the other levels or not? So maybe

3 address it either more generally or more

4 specifically by covering all of the, you

5 know, important classifications that might

6 be a good consistency to have.

7 MR. LOWELL FOSTER: Okay. I

8 appreciate that. The -- if I -- so we have

9 had two comments on this. If I might, just

10 for clarification, try to understand that

11 perhaps the language used here could be

12 confusing because of how it's used in

13 traditional systems areas. Does that

14 capture some of the concerns that I have

15 heard?

16 MR. NICK BOGNER: A follow-up

17 question that I would say is depending on

18 what the intent here is. Do we want -- do

19 we meaningfully not include the other levels

20 of classification for a specific reason? If

21 there is a good reason, maybe the preamble

22 could address that. But if it really is

23 more general, which I assume it is, but

24 maybe that is the wrong assumption then, you

25 know, let's call that out --
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1 MR. LOWELL FOSTER: Okay.

2 MR. NICK BOGNER: -- would be the

3 thought.

4 MR. LOWELL FOSTER: Yes, I

5 appreciate that. So we will be able to

6 expand on that on the preamble final rule

7 preamble.

8 Anyone else? All right. 1510,

9 airplane flight manual. And this captures

10 the existing 1581 through 1589, which was

11 very presumptive language dealing with the

12 flight manual.

13 Yes, Ric?

14 MR. RIC PERI: So in the current

15 regulations, 1581(b)(2), I think, or

16 something like that, discusses the fact that

17 only the limitation section actually has to

18 be approved and that the remainder of the

19 flight manual could be acceptable to the

20 administrator. What are you going to do

21 with that language? And are you making a

22 distinction between the approved flight

23 manual or the acceptability of the flight

24 manual, because it has a lot to do with

25 retrofit and how flight manual supplements
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1 are addressed in that same light? So that

2 language in there, there is a very specific

3 thing in there for aircraft under 6000

4 pounds and some relief that was put into the

5 rule in multiple rule makings ago that looks

6 like it has been lost here.

7 MR. LOWELL FOSTER: Okay. Very

8 good comment. I appreciate that. Thank

9 you.

10 Any other comments on the flight

11 manual?

12 MR. BILL BRODEGARD: I won't like

13 it if I don't say something. It says: Any

14 information necessary for the operation of

15 the airplane. What is meant by necessary?

16 MR. LOWELL FOSTER: Okay.

17 MR. BILL BRODEGARD: I don't know.

18 MR. LOWELL FOSTER: That is a good

19 comment. Thank you.

20 Let's move on to the last rule,

21 which is instructions for continued air

22 worthiness. And I believe the language that

23 is here is verbatim from the current rule.

24 The only change is the number.

25 Any comments, questions?
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1 Okay. So that finishes that. And

2 I think we are way ahead of schedule.

3 Obviously, we planned for a lot of

4 discussion and that is fine. That is great.

5 We have some time now before we adjourn for

6 today if anybody wants to make a general

7 comment or has any general questions or you

8 remembered something from one of the

9 subparts discussed this morning that maybe

10 you want to revisit. I think that we have

11 the time to look at that if you would like

12 or any other information that you would like

13 to present. Not completely open-ended

14 however.

15 MR. ANDY SAPINI: Andy Sapini with

16 Textron Aviation.

17 I would just like to thank FAA for

18 undertaking this massive effort. We have a

19 shared interest in seeing it be successful

20 for our industry. I just wanted to make a

21 couple of general comments, not specifically

22 about this subpart or any other subpart. I

23 don't intend to get into a lot of detail. I

24 don't want to duplicate anything that GAMA

25 has already stated, but some high-level
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1 issues that are very important to us at

2 Textron Aviation.

3 First and foremost is

4 harmonization. Harmonization with global

5 authorities has obvious certification cost

6 implications and that is very, very

7 important to us, so our hope is that FAA

8 continues to move in the direction of

9 harmonization with other global authorities.

10 We are seeing good movement in that area.

11 We would like to see that continue.

12 A second item that is important is

13 maintaining a path to future technology.

14 You know, as we look through the rules --

15 and there have been a number of comments

16 made this morning already. I am sure that

17 there will be some more tomorrow as we get

18 into the other subparts. When the rule

19 language contains references to legacy

20 technology and legacy configurations, to me

21 that is an indicator that as we go forward

22 and introduce new technologies there will be

23 many times when special conditions and other

24 avenues will be required and those are

25 specifically the kinds of things that we are
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1 trying to get away from in the new rule

2 languages; getting away from special

3 conditions and such. So whenever we see

4 legacy technologies and configurations in

5 rule language, I think that is a bit of a

6 signal that maybe we have missed the mark on

7 seeing the future.

8 Now, don't get me wrong. We have

9 done a lot of good work and there is a lot

10 of future technology accommodation here, but

11 I think that there are some elements left to

12 go. You know, we all know that this rule

13 must stand the test of time. We don't want

14 to do this again. We can't do this again,

15 most likely, in the next, you know, decade,

16 so the rule has to stand the test of time.

17 And the third item that I would

18 like to hit on is safety-intent-based

19 language. I think, again, we have come a

20 long way in expressing safety intent. That

21 gives the applicant the opportunity to find

22 new innovative ways to meet that safety

23 intent. Innovation almost always brings

24 along new, exciting products and that is

25 obviously very important to our industry is
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1 to have new, exciting products. So moving

2 away from prescriptive language and moving

3 towards safety intent language, I think that

4 that will go a long way towards allowing

5 innovation and exciting new products to

6 reinvigorate rate the industry.

7 And Textron Aviation has generated

8 a plethora of written comments which will be

9 submitted before the closing date. I do not

10 have any intent to reiterate what all these

11 detailed technical comments are right now,

12 but I just wanted to hit on those high

13 points.

14 MR. LOWELL FOSTER: I appreciate

15 it, Andy. Thank you. All good points.

16 MR. WELDON WAINRIGHT: I am Weldon

17 Wainright. I am a consultant at powerplant

18 BER. Just one question, since we have

19 renumbered all the regulations in there,

20 what will happen with all the advisory

21 circulars, say, 238(c), 2316, all the ones

22 that we are using right now for guidance?

23 How will that tie to the new regs? Do you

24 go back and rewrite some of this or how will

25 this happen?
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1 MR. LOWELL FOSTER: I am getting a

2 sign just to ask you to speak up.

3 MR. WELDON WAINRIGHT: I am sorry.

4 Let me repeat it again. Since we renumbered

5 all the regulations and we changed some of

6 that prescriptive language and we have

7 gotten rid of it, so tying back to the

8 advisory circulars right now, which is

9 really the minutia of how you meet the

10 regulations, will 238(c), some of these,

11 will these be rewritten to reflect all the

12 new regulations and capture some of the

13 testing requirements that we currently have?

14 MR. LOWELL FOSTER: So that is a

15 really good question and the answer is that

16 is an extensive list. Our plan is to use

17 the cross-reference table that is in the

18 rule, near term. And those ACs are still

19 active and in play. The long-term view or

20 the long-term goal is to kind of restructure

21 or rebuild and replace them. But currently

22 they are still active and you will just use

23 the cross-reference table.

24 MR. JEFF WILLIAMS: Jeff Williams

25 from Astronautics. I had one -- I had one
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1 question.

2 MR. LOWELL FOSTER: Speak up.

3 There you go.

4 MR. JEFF WILLIAMS: A couple of

5 slides ago, it was 23.1505 on this from the

6 marking. It says the applicant must clearly

7 mark each cockpit control as to function and

8 method of operation.

9 So we are an article manufacturer

10 and we mark all of this stuff. Is the

11 applicant supposed to mark all of these

12 things or is that something that comes

13 from -- that's already in an article?

14 The other thing is as to function

15 and operation of -- method of operation. So

16 if you have a punch button or a knob, this

17 would seem to say that you would have to

18 mark it, clearly mark it as turn left, right

19 or something. I mean, I am not sure how you

20 can do that. If it's a push button, you

21 push it. Just a comment.

22 MR. LOWELL FOSTER: Good comments.

23 On your first comment relating to the

24 applicant in that language, what I think I

25 heard you say or the scenario you gave was
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1 perhaps a vendor has a product that will be

2 installed by the applicant. The vendor will

3 label those things, those functions. And so

4 how does that fit with the rule that says

5 the applicant shall, correct?

6 MR. JEFF WILLIAMS: Yes.

7 MR. LOWELL FOSTER: Anyone else?

8 It's open mic.

9 All right. Well, all right. Since

10 we don't have any other comments, I tell you

11 what, we will plan on reconvening tomorrow

12 at 8:00 a.m. and we will go through Subparts

13 (e) and (f) and then again have a chance to

14 revisit anything that we have talked about

15 today or tomorrow for the folks that may

16 only be attending tomorrow's meeting and

17 then we will also give you another chance if

18 you have comments or concerns that you want

19 to share with the mic.

20 All right. Well, thank you. We

21 really appreciate your attendance and

22 participation. Thank you.

23 (Proceedings concluded at 11:20 a.m.)

24

25
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1 CERTIFICATE

2 COUNTY OF FULTON

3 STATE OF GEORGIA

4 I, Susan DeCarlo, Notary Public and

5 Certified Court Reporter, do hereby certify that

6 I reported in machine shorthand foregoing

7 proceedings on May 3, 2016, that the foregoing

8 pages, numbered from 1 to 105 inclusive, were

9 prepared under my personal supervision and

10 constitutes a true and correct record of the

11 proceedings.

12 This the 23rd of May 2016.

13

____________________________

14 Susan DeCarlo, Notary Public

and Certified Court Reporter

15 Commission Expires 10-12-2016

Certificate number 2125

16

17

18

19

20

21

22

23

24

25
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A

abide 4:7

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44:15 97:5

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44:14

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77:3

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101:10

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63:3 65:24 66:13

66:15 68:15 70:20

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62:24,25 70:9

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67:15

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76:3

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41:6,11 102:20

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35:25

aerodynamic 53:8

aeroelasticity 49:25

49:25 62:15 81:14

82:1

affect 49:23 51:22

52:19,22 63:4

71:21

affiliation 8:13

afloat 84:24

afraid 78:10

aft 70:1

afternoon 10:14

age 18:8,11

Agency 22:22

agenda 6:14,15

10:15 17:3 46:7

77:25

ago 42:12 75:12

98:5 104:5

agree 16:1 92:13

ahead 11:20 46:8

47:15 72:4,7

77:25 79:14 92:16

95:18 99:2

air 31:23 50:19

98:21

airborne 41:23

aircraft 12:22 14:6

14:9,15 17:21,22

20:3,13 24:16

25:25 27:19,21

28:21 29:17,20

34:9,16 39:2

44:10,12 45:1,2,3

45:9,13 47:7 65:2

70:10 77:11 84:23

86:21,24 90:8,20

91:20,24 98:3

airframe 22:2,5,10

airloads 64:4,6

airplane 1:2 3:4,25

4:21 5:5,15 13:7

15:8,13 22:7,12

26:3 36:2 40:20

41:25 49:3,18,22

50:2,5 51:10

54:18 58:8 59:12

60:12 61:16 62:10

62:19 63:18 64:17

64:21 69:18 70:12

70:16,17,18 71:9

75:14 83:14 84:5

93:8 97:9 98:15

airplanes 26:1

35:24 36:21,25

37:22 38:3,23

40:4,7,22 42:22

42:22 50:18 51:22

55:22 56:3,19,24

61:6 90:5

airplane's 84:7

airspace 44:7,16

airspeed 50:5,10,10

50:11,14

airspeeds 50:1

airworthiness 30:6

60:14

aisles 86:14

alleviation 52:7,12

52:25 54:2

allow 11:11 41:13

41:24 46:15 65:3

93:12

allowable 67:5

allowables 65:18

66:18

allowed 67:10

allowing 40:13

41:20 47:5 75:18

102:4

all-time 19:1

alongside 46:18

alternatives 20:11

altitude 51:18

60:21 61:7

ambiguous 78:17

amended 76:15

amendment 69:2

amount 23:13,14

57:8

amphibians 84:17

amphibious 39:4

Andy 99:15,15

102:15

angle 34:22 46:23

70:11,11

angles 29:15

answer 79:10

103:15

anthropomorphic

76:17

anticipate 20:25

21:18,21,24 65:6

anybody 25:18

59:18 62:4 72:8

77:17 79:5,19

92:18 99:6

AOPA 17:19

aperture 61:24

apologize 45:24

72:15

appear 52:18

appears 27:17

29:14 81:12

appendix 40:9,16

40:16 42:2

applaud 42:7

applicability 53:6

applicable 40:4

44:16

applicant 49:16,20

49:21 51:25 54:13

55:12 56:17 57:13

58:19 59:9 60:7

60:24 63:2,16,22

64:16 65:1,20,24

66:6,10 67:4,17

68:4,12,19 72:21

73:25 101:21

104:6,11,24 105:2

105:5

applicants 40:14,23

42:4

application 68:15

applications 88:20

applied 54:15

applies 36:24

apply 33:21 36:25

52:24 68:20 69:2

applying 82:12

appreciable 68:9

appreciate 10:4

16:21 24:22 25:11

28:4 32:4 35:1

39:7 44:5,20

47:11 74:9 75:7

75:10 77:16 78:7

78:9 80:8 93:25

94:21 96:8 97:5

98:8 102:14

105:21

appreciated 35:5

approach 45:4,12

82:15

approaches 45:10

69:10

appropriate 22:11

38:24 95:8

appropriately 14:9

14:16

appropriateness

7:24

approval 16:15

74:21

approved 15:10

66:7 67:18 73:1,2

74:22,24 97:18,22

approves 75:2

approximately 9:22

10:13

ARC 9:20 11:8 17:3

17:13 35:3 39:23

39:24

ARC's 9:21,23

area 13:25 17:16

21:20 28:1 36:18

40:12 100:10

areas 21:6 24:20

33:11 41:22 96:13

arm 61:24

Armstrong 53:17

53:18 54:4

article 63:16,19

68:6 72:19 104:9

104:13

articles 65:22

artificial 81:3

artificially 34:24

ASAO 17:19

asked 79:3

asking 29:16

aspect 93:6

aspects 33:25 72:22

Aspen 43:15 72:14

assemblies 65:22
Page 2

May 3, 2016

REGENCY-BRENTANO, INC.

assembly 63:17,20

66:3 68:7

associated 8:2,16

16:5,6 57:20

94:17

association 12:22

14:4 15:5 17:12

20:20 21:4

associations 17:18

assume 96:23

assumption 96:24

ASTM 17:15 26:1

Astronautics 94:12

103:25

asymmetric 55:18

Atlanta 1:14,24

3:12

atmospheric 55:15

attachment 57:22

attack 34:23 46:24

attendance 105:21

attendee 10:21

Attendees 2:1

attending 105:16

attitude 28:7

attitudes 56:23 57:3

attract 20:4

attractive 19:13

20:8

audio 11:5

augmentation

28:19,20

author 89:2

authorities 10:25

21:22 100:5,9

automated 57:23

automotive 75:16

75:23 77:10

auxiliary 70:1

84:19

availability 47:25

77:7

available 7:15,16

48:1,7,12 60:1

79:5,11

avenues 100:24

average 18:8,10

aviation 1:1 3:16

9:19 14:3 17:12

18:6,13 19:12,15

20:5,10 22:22

39:24 99:16 100:2

102:7

avionics 43:15

72:14 88:19 89:17

avoid 41:21 90:9,10

avoiding 90:22

aware 8:18 18:2

94:6

awareness 21:7

34:22

a.m 1:10 3:1 105:12

105:23

B

b 11:23 17:1 25:22

26:19,20 36:21

38:20 40:2,8

49:12,13,14 50:22

54:20 56:24 57:18

58:22 60:22 63:2

63:11,18 64:21

68:1,12 70:5

74:20 81:2,4,7

83:22,25 86:6,10

back 7:10 19:3

26:19 38:6 41:18

43:5 47:16,20

56:10 73:5 78:24

91:19 102:24

103:7

background 9:9

29:22

bag 77:5

baggage 69:15

71:10

balance 57:22

barrier 81:4,18

82:8,17 83:11

barriers 82:13,14

83:7

base 37:20

based 12:14,16

18:24 22:3,4

26:22 28:7 29:19

36:1 41:23,23

55:2,16 66:23

73:20 90:7,8,19

91:5

basically 17:20 27:7

36:7 38:4 45:16

58:15 77:3 82:10

95:5

basis 16:16 67:1

bean 77:5

bearing 63:24

67:24

becoming 71:17

beginning 9:7 25:15

behalf 17:18

believe 22:18 23:9

29:8 44:6 92:2

98:22

belts 69:14 75:20

76:15 77:2

benefit 8:11 11:5

35:21 47:23

BER 102:18

Bernie 94:11,11

berths 69:14

best 25:7 30:1,5

82:14

bet 15:20

better 21:16 33:7,8

82:18 83:15 85:5

85:8,22 95:8

beyond 28:25 45:7

53:1 62:22 75:25

Bill 2:2 3:24 4:7,12

4:19 25:10 26:15

43:14,14,22 48:3

48:9 62:11 72:3

72:13,13 73:6,11

73:16 74:16,19

75:4,8 76:2 77:17

78:3,25 79:1

80:11 93:17 94:1

94:8 98:12,17

bit 6:8 11:10 21:16

23:15 31:7,9

32:19 48:13 61:21

72:5 76:6 79:2

88:15 92:23 101:5

blade 62:1

blow 32:19

board 21:15 29:18

Bogner 95:14,19,19

96:16 97:2

books 22:23

bore 80:18

borrowed 41:5

bottom 43:25

boundaries 54:23

Bowles 13:15,20,24

14:2,22 16:7 17:6

17:11 27:17 28:13

29:14 30:18 31:19

32:11,16 33:15

34:4 36:23 37:10

37:14,17,24 38:15

38:20 42:7 44:21

45:20,22 46:6,10

46:13 52:15 53:4

56:1,11 65:5

68:25 69:5 81:11

81:22 82:6,22

83:1,4,6 84:3,21

85:14,16,21 86:16

86:20 90:1,15

91:2

brackets 52:23

Brady 2:4 5:16

89:14,15

brakes 83:24

branch 49:5

branches 23:18

24:18

break 10:12,20

11:17,19 13:22

14:25 17:2 43:4

47:15,21,22 48:21

72:11 77:18 79:23

91:10

breaks 10:11,14

14:12

briefly 6:17

bring 48:3

bringing 18:12

21:14

brings 101:23

broad 16:10 34:16

Brodegard 43:14

43:15,22 72:13,14

73:6,11,16 74:16

74:19 75:4,8

93:17 94:1,8

98:12,17

brought 19:19,20

19:21,22

budget 23:4

buffet 41:14

buffeting 39:9

bulk 18:18

bulkheads 60:24

bump 34:23

bunch 17:18

buoyancy 84:16,19

burden 20:15 93:11

business 79:2

button 104:16,20

B-basis 65:18 66:18

C

c 33:12,17 40:9,16

40:16 42:2 47:17

48:25 49:12 51:7

54:25 55:9 58:2

60:19 62:8,17

63:21 64:24 68:19

82:7,7 83:6,22

86:6,10 89:24

CAAs 10:25 31:11

cabin 58:3,9 60:23

61:11 70:2,19

cabins 58:3

cable 63:14 81:2

cables 88:15 89:19

calculated 59:7

call 59:3,21 81:15

96:25

called 4:15 14:6

49:9

calling 32:12

calm 86:1

canted 55:18

capable 59:5 61:10

61:16 90:7

capacities 86:25

capsize 85:25

capture 25:16 29:3

64:12 65:13 67:22

69:10 80:23,25

83:20 84:17 87:15

88:11 89:23 96:14

103:12

captured 27:8

35:14 38:11,22

39:5 65:17 95:3

captures 9:13 28:10

29:12 30:24 31:17

33:2 35:9 36:16

39:11 49:11 62:15

63:9 86:5 88:2

95:11 97:9

capturing 93:2

car 75:13

carbon 47:4

cargo 69:15 71:11

carry 40:11

cars 76:18

case 22:8

cases 45:8 95:7

casting 67:24

catastrophic 94:14

94:15,17 95:22,24

96:1

categories 14:13

categorizing 14:5

15:13

category 13:9 14:5

14:11,12,15 38:4

45:17 46:20

cause 64:19 71:6

caused 61:18

causes 60:10

cell 85:1 89:19

center 1:13 27:5

51:8

certain 45:8 76:19

certainly 23:24
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May 3, 2016

REGENCY-BRENTANO, INC.

83:9

certificate 46:19

106:1,15

certification 21:23

21:25 22:10 24:17

40:5 100:5

certifications 24:7

36:2

certified 1:21 22:9

35:24 40:21 42:23

106:5,14

certify 22:14 40:23

40:24,25 106:5

chair 7:22,22 8:4,8

77:5

chairing 17:14

challenge 26:11,25

challenges 21:14

24:25 25:1 26:3

78:1 91:19

chance 43:13 72:8

82:5 105:13,17

change 18:5 20:16

20:17 21:9 33:14

43:8 98:24

changed 103:5

changes 12:10,12

19:24 26:21 27:1

characteristic

14:16 36:11

characteristics 33:1

36:15,17 38:11

39:10,25

charge 48:2,19

chart 72:11 77:19

charter 43:24

charts 27:18

check 83:11

checks 83:9

choose 40:25 51:2

chose 51:4

circular 8:16 41:4,6

41:11

circulars 102:21

103:8

citing 33:19

City 3:4

clarification 13:1

16:7 33:16,17

37:8 52:16,17

69:1 86:18 89:13

89:15 96:10

clarified 15:6

clarify 8:21 42:17

45:16 48:8 74:11

75:2

clarifying 6:1

clarity 30:15

class 45:5

classes 47:2

classic 92:2

classification 96:20

classifications 96:5

clear 37:13 43:12

44:3 78:16

clearly 104:6,18

climb 29:12,15 30:2

30:19,24 31:2,14

climbs 29:16,21

close 66:5

closed 10:1 85:1

closing 102:9

clouds 40:17

coach 17:3

cochair 17:13

cockpit 88:17 104:7

code 14:17

combinations 54:22

combined 57:16

58:5,7

come 20:22 25:7

32:18 101:19

comes 32:2 37:18

104:12

coming 34:10 47:20

53:12 69:9

command 82:11

comment 7:21 8:7

8:19,23 9:25 10:1

13:19,25 14:19,20

15:1 16:18 25:19

25:24 28:4 29:2

30:10,17 32:4,6

32:10,15 34:1,13

37:1 38:7 39:7

43:13 44:23 46:5

46:14 47:11 53:3

53:16 56:9 65:9

65:10 72:9 74:9

74:25 75:6 77:16

80:3 88:25 92:15

93:25 94:7,21,23

95:15 98:8,19

99:7 104:21,23

comments 3:19

4:24 6:3,9 7:4

8:14 9:6 10:2,5,10

11:2,6,12 12:2,7

13:16 14:14 17:25

21:3,19,24 25:11

27:9,16 28:8,11

29:10 30:23 31:15

31:18 32:24 35:4

35:11,18 36:12

38:8 39:8,14 42:6

43:1 46:1 48:23

62:5 71:24 79:20

80:7 82:3 83:18

87:22 88:8 90:17

91:8 92:19 94:10

96:9 98:10,25

99:21 100:15

102:8,11 104:22

105:10,18

commercial 46:19

Commission 106:15

committed 22:23

Committee 3:16

9:19

committees 39:24

commonplace 52:9

community 26:4

91:20

commuter 14:13

38:4

companies 25:14

compared 30:20

31:22,25

compartment 61:1

61:4 69:16 71:11

71:17

compartments

60:23 84:22 85:2

85:3,4,10

complete 6:2 9:1

75:18

completely 99:13

complex 22:6,13

42:9

complexity 22:3,4

compliance 16:2,9

16:12,12 33:9

41:3 49:20 52:2

61:8 66:20 82:23

82:25 83:3,16

85:19 87:9 95:9

comply 52:13

component 22:11

57:10 67:3

comprehensive

9:20

comprises 76:7

computers 20:14

Conceivably 91:2

concept 12:17 44:5

92:10,10

concepts 8:22

concern 14:10 30:9

87:5

concerned 96:1

concerning 18:9

concerns 9:2 34:3

96:14 105:18

concise 42:10

concluded 105:23

concludes 91:8

condition 62:24

83:8 85:6,8,23

conditions 40:9,24

41:12 42:1,13

52:1,6 53:22 54:1

55:7,7,14,21

56:22 57:2,4,10

57:24 63:18 66:1

67:4 69:7,12,13

70:6,8,13,21 71:3

71:15 82:13

100:23 101:3

conducted 9:20

configuration 34:12

62:23 63:20 70:12

configurations

56:23 57:3 100:20

101:4

confusing 96:12

consider 6:9 10:2

50:3,13 53:2

consideration 8:3

considerations 45:7

58:12

considering 61:2

consist 70:24

consistency 96:6

consistent 95:25

consistently 66:4

constitutes 9:16

106:10

constraints 11:24

construction 19:22

63:8,10

consultant 102:17

contact 70:15

contains 100:19

content 60:2

contents 71:12,16

context 39:1

continue 18:16

25:17 27:2 91:12

100:11

continued 49:5

60:14 61:16 65:23

73:12 98:21

continues 70:22

82:4 88:7 100:8

continuing 19:10

continuum 43:10

control 15:5 34:7

34:10,12,17,18,20

37:22 47:9 51:15

57:19 62:20 63:11

63:25 64:2 66:5

68:18 80:21 89:19

93:8 95:2 104:7

controllability 35:8

controlled 92:25

controls 64:5,7

68:14 71:19 81:5

Convention 1:13

coordinate 25:13

copy 7:17 48:12

79:3,6

Corporate 1:23

correct 15:7,14,16

105:5 106:10

corresponding 64:4

64:8 71:14

corrosion 65:7

cost 19:20 100:5

COUNTY 106:2

couple 21:6 99:21

104:4

course 6:5 59:25

60:1 72:11 77:20

Court 1:21 7:13

8:11 9:4 25:14

47:24 78:19 106:5

106:14

cover 28:1 45:24,25

46:3 80:1

covered 25:20,21

27:8,11 72:9

covering 62:12 96:4

covers 54:11 55:8

56:15 57:8,10

58:16 71:22 87:19

crash 76:12

crashes 76:25

create 26:10 71:5

77:4

created 27:19

creates 43:20

creating 14:10 16:9

crew 86:8

criteria 33:19,20

39:5 70:14 75:15

critical 18:4 20:19

22:16 23:9 34:19

41:10,16 54:22

62:25 63:1 68:5

71:13
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May 3, 2016

REGENCY-BRENTANO, INC.

criticality 66:13

crosswind 38:17

cross-reference

103:17,23

cruising 50:7

CS-VLA 43:24

CS-VLA-783(a)

86:14

CS-VLA-853 88:4

curious 30:19

current 9:14,17

27:6,12 28:10

29:3,7,12,25

30:25 32:12 33:2

33:5 35:10,17

38:11,13 39:11,13

40:6 41:3,6 42:22

51:5,6 56:2,16

57:9 59:1,16,22

60:2 81:1 83:21

86:23 93:5 95:5

95:11 97:14 98:23

currently 17:14

19:9 40:1,10,20

41:21 42:3 103:13

103:21

curve 18:16

D

d 7:1 56:6 62:8 63:7

63:25 66:21 70:23

73:17 75:14 79:15

80:17 81:2,4

83:23 86:7,10,11

damage 59:22 60:5

61:10,12,17 71:20

77:2

damaged 69:18

damages 59:24

data 18:10 37:19

38:5 63:18 91:5,5

date 102:9

David 53:17,17

54:4

day 7:3,6 72:12

77:20 79:13,23,24

days 4:10 7:5

deal 8:2 37:4 81:16

dealing 83:7 97:11

deals 53:20

decade 101:15

DeCarlo 106:4,14

decide 72:5

decision 6:11 37:20

decisions 6:12

decompression

61:12

decreases 27:23

define 63:19 76:9

defined 14:11 45:13

defines 45:1

defining 45:13

definitely 92:14

definition 26:6

definitions 12:6

58:14

deflection 64:2

deformation 59:13

degradation 60:10

degrees 62:25

delay 48:13,16

demonstrate 59:10

72:21

density 87:10

depart 36:22

Department 75:22

dependent 3:14,18

depending 27:24

96:17

describe 35:25 76:6

describes 49:17

design 20:7 24:13

27:24 49:10,17,18

49:22 50:1,3,6,7,9

50:14,22,25 54:14

54:24 55:4,13

56:18 57:14 58:21

60:25 62:22 63:6

63:7,10,16,18,20

63:23 65:3,15

66:11,14,25 67:6

67:7,14,18 68:5

68:21 69:22 84:7

85:12

designated 87:25

88:10 89:16

designed 71:11

designing 24:9

designs 87:8

desirable 36:11

detail 21:5 38:22

63:23 99:23

detailed 21:3,19

83:7 102:11

details 95:8

detect 41:1

detecting 41:20

61:10

detectors 47:4

deteriorate 68:7

deterioration 64:18

determination 22:2

66:22 73:19

determine 49:16

50:22 54:13,20

55:12 56:17 57:13

58:20 63:22 65:20

67:5,12 68:4,13

determined 71:15

determining 31:2

detrimental 59:13

devastating 19:8

develop 6:2,13 9:24

50:19 60:8

developed 60:15

61:8

developing 10:3

development 47:8

device 53:1

devices 28:23 50:15

50:17 51:16 62:18

63:13

dialogue 78:8

difference 37:25

38:3

differences 24:13

45:19

different 32:9 42:23

42:24 44:8 45:10

53:13,15

differential 58:4

differentiate 45:2

differentiator 45:17

45:18

differently 74:11

difficult 23:3

difficulties 19:17,18

difficulty 19:21

direct 58:25

direction 4:8 19:11

21:19 28:22 100:8

directly 8:15 51:23

79:8

directorate 1:2 3:4

4:1,21 5:6 24:16

49:3 62:11

disadvantage 23:15

discriminator

90:12

discuss 3:6 6:16,25

7:1 51:1 79:23

85:5

discussed 6:24

15:17 42:12 44:1

90:4 99:9

discusses 34:11

54:3 97:16

discussing 52:19

discussion 28:2

36:5 99:4

discussions 5:25

7:24,25 8:5 9:8

16:23 28:25,25

32:2 33:25

distinction 92:1

97:22

distribution 51:12

55:1

distributions 71:13

dive 50:10

divergence 62:21

docket 7:19 9:6

10:6,22 14:21

16:21 18:1 28:6

34:3 47:13 48:5

48:10,16 75:6

78:21 79:4,7,9,12

document 33:9

51:14

documentation

42:3

dogged 25:4

doing 13:17 14:7

41:19 43:9 59:5

door 10:17,18 61:1

61:3 80:3 93:13

doors 86:6

DOT 23:5

DOT's 76:6

downstream 32:21

downwind 58:1

drafted 33:23

drainage 64:23

drift 32:18

driver 43:19

drizzle 40:19

drop 18:15,17 19:1

dropping 18:22,22

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multiplied 58:11,23

multiplying 68:22

multi-purpose

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name 3:2 4:19 5:9

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96:16 97:2

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policies 25:2 90:2

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process 66:5,7,8

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project-by-project

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recall 33:25

received 9:17 10:2

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registration 7:10,16

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regular 38:17

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replacement 68:8

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restrictions 44:11

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result 51:24 53:9

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revitalize 18:5

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risk/performance...

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rolls 15:11

room 7:11,17 22:20

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rotating 61:19,23

rotation 31:24

rotor 53:11,12 62:1

roto-burst 61:15

rough 50:19

rule 5:10 6:11,16

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23:19,23 24:1,5

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44:7,8,15,16

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safe 59:23,24 61:16

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sake 95:25

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saw 26:20

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says 55:11 62:19

73:17 74:20 91:23

93:17 94:2 98:13

104:6 105:4

scale 90:20,21

scary 93:19

scenario 104:25

schedule 11:20 46:9

72:4,7 79:14 99:2

scheduled 11:19

schedules 42:25

Schinstock 2:2 3:24

4:12,20 25:10

26:15 48:3,9

62:11 72:3 76:2

77:17 79:1

scope 91:15 92:14

scrambling 72:5

sea 57:4

seaplane 39:3

seaplanes 84:16

seat 70:24 71:23

75:20 76:15 77:2

seated 76:17

seating 70:17,19

seats 69:13 76:18

second 13:12 30:14

34:5 35:7 42:12

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100:12

secondary 64:7

71:6 74:14

seconds 86:22 87:2

87:3

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