Government and industry have come together to form an international aviation rulemaking committee (ARC) similar to the recently concluded Part 23 ARC to consider changes to the FAA Part 27/29 EASA CS27/29 rules governing civil helicopters.
While similar in structure to the Part 23 ARC, the rotorcraft equivalent will be more targeted and limited in scope and therefore should proceed at a faster pace, according to Walter Desrosier, vice president of engineering and maintenance at the General Aviation Manufacturers Association. Stakeholders should get a preliminary view of the committee's work within a year, and FAA/EASA proposed rulemaking could come within four years, he said.
“Right now it will not be what a lot of folks have seen in the CS23 and Part 23, a pretty significant rewrite and reorganization, because there were so many areas that were outdated and so many areas that would benefit from some change,” Desrosier said. “In 27 and 29 I don’t think it will be nearly as extensive as a proposed change. It will be very targeted in certain subparts and certain areas where we have seen a lot of technological development of rotorcraft, where the rules have not kept up.”
Equivalent Levels
Desrosier said the committee is looking at areas already granted exemptions or compliance through equivalent level of safety (ELOS) determinations. “The analysis that our working group is conducting is not mature enough to say that we’ve reached conclusions on anything specific. There are many areas [where] there is going to be a specific opportunity for potential improvements and enhancements.”
A fundamental objective, he explained, is addressing what have become detailed methods of compliance for a particular rule, which in turn spawn special conditions or exemptions because of the limiting and inefficient nature of complying with the rule in later applications. “So that is one of the first areas in the analysis,” he explained. “We are taking a look at where we see a lot of exemptions, special conditions, equivalent levels of safety in some of the existing designs. Where do we expect to see some of these in future designs and that indicate areas of the rules that just are not up to date with the current technology, methods and materials?”
The next step is to look at other prescriptive areas not involved exemptions, special conditions and ELOSes, but that could be subject to those later. “We want to make sure that the airworthiness design standards, the rules we have to meet, do not become overly prescriptive in a means of compliance,” Desrosier said. “Instead they should identify the safety objective. That allows for a lot more accommodating different methods of compliance for different features that we might get in for the future.”
Stakeholder Input
The committee will be seeking input from stakeholders, he said, and has already engaged in some industry forums. “We’re planning to take some of the more specific areas we’re planning to identify and initial recommendations to those same forums to make sure we can bring in the perspectives and the views of the broader rotorcraft industry. Not just the manufacturers but also the operators and the maintenance community, in terms of identifying how can we better improve the structure of the regulations to support our current needs, but more important our future needs, to be more efficient and effective in addressing the ability to address future technology and future products.”
Desrosier said the 27/29 committee is not a panacea, that there are areas that need more immediate and tactical attention from industry, particularly in the areas of avionics, ADS-B and mission equipment.
“We realize this is a long-term effort to get a major rulemaking,” he said. “There are many other areas today not related to the 27/29 review that are more tactical. There are issues we need to address as an industry and work with the authorities today. Avionics is a big area of attention.”
Key avionics issues include addressing a more efficient approach to certification of new avionics and retrofits, and the 2020 ADS-B out mandate. “We’ve identified unique challenges and obstacles with respect to equipage and approvals for rotorcraft,” Desrosier said. “A lot of that is progressing very well. It comes down to policies, procedures, training and awareness. [And] making sure we have the appropriate standards, methods of compliance and certification processes to do it in an efficient way. These are all short term. This is not rulemaking. This is all stuff that is needed now, and that is why this is such a focused effort. We are running out of time, and we have to make sure we can identify any obstacles and roadblocks now and remove those so that operators can equip and manufacturers can provide the equipment and the services necessary to support equipage by 2020.”