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EAA Government Advocacy

January 2013

Government Relations Briefings

Government Relations Archive

EAA continues to work hard on these issues and others of importance to EAA members and other aviators. There is strength in numbers, not only in EAA member participation but also in joining with other aviation groups and important allies such as the general aviation caucuses in the House and Senate.


Safety Efforts Aim to Lower GA Accident Rate

EAA is continuing to lead and collaborate on a variety of programs focused on lowering the general aviation accident rate, with efforts that range from aircraft construction to pilot decision-making.

These EAA initiatives, both long-standing programs and new partnerships with other aviation organizations and industry members, are aimed at a single goal: enhancing GA safety. It shows the continuing work of the GA community to raise awareness as the NTSB studies aviation safety. The NTSB in November released its annual "Most Wanted List" that included general aviation in a report that also included safety issues in automobiles, buses, trains, and pipelines.

Everyone agrees that safety is a never-ending priority. That's why EAA has been active in working with other organizations such as AOPA, as well as type clubs, pilot groups, manufacturers, and government agencies. We maintain that education is a far better way to improve safety than regulation. Many accidents are from common avoidable factors. EAA's recent participation in safety initiatives includes:

  • Co-founding the Type Club Coalition, which represents aviators in a variety of aircraft types who are seeking best practices in flight operations.
  • Leadership within the FAA's Loss of Control Working Group, part of the General Aviation Joint Steering Committee, which is studying accident factors and possible ways to minimize those risk areas.
  • Participation in the FAA's Part 23 committee that is studying aircraft certification.

These efforts reinforce some of EAA's longstanding programs that have proven to enhance safety for EAA member builders and pilots who participate in them. Those include the Technical Counselor program that offers guidance for aircraft builders and the Flight Advisor program, which allows pilots who are transitioning to new or unfamiliar aircraft to evaluate their piloting skills and seek additional training, so they are fully prepared when initially flying that aircraft.

EAA Tells FAA: Abandon Proposed Repair Station Rules

EAA has joined several aviation organizations in criticizing the FAA's new proposal for aviation repair stations, stating that the new rules create such cost and regulatory burden that many small repair shops could be forced to shut down.

In comments submitted to the FAA, EAA wrote that the added burdens vastly exceed the minimal safety benefit the rules would provide. EAA also noted that the FAA's cost-benefit analysis used as the foundation for the rule change was flawed, underestimating the industry's labor costs and time necessary to rewrite manuals and apply for recertification.

Instead of creating flexibility and the ability to adapt to new technology in the marketplace, the costs and administrative burdens within the new rules would put many smaller repair shops out of business.

EAA's comments mirror those of the National Air Transportation Association (NATA), General Aviation Manufacturers Association (GAMA), Aircraft Electronics Association (AEA), and Aeronautical Repair Station Association (ARSA), which have also strongly criticized the proposal.

Under the new proposal all of the nation's nearly 5,000 aviation repair stations would be required to apply for recertification within a 24-month period after the new rules took effect. The FAA currently experiences certification delays for new repair stations due to a lack of staff and other resources, so recertifying 5,000 such businesses would be impossible for the agency to accomplish.

Online Resources Improve Safety

This month you can find two new pages on our website that will serve to provide pilots and builders information they need to be safer and smarter in the air.

The Type Club Coalition (TCC) launched its initial website. At www.eaa.org/typeclubs, you will find information on this initiative to bring the owners of different types of aircraft, from type-certificated to homebuilts to warbirds, together for the common purpose of enhancing safety. The TCC's purpose is to facilitate an exchange of ideas between aircraft operators. This expands the knowledge base in the general aviation community with regard to best operating practices and procedures.

EAA has also published the list of Letter of Deviation Authority (LODA) holders for experimental aircraft. These CFIs are authorized by the FAA to offer certain types of instruction for hire in their experimentals (normally a prohibited practice) and are an invaluable resource for those seeking quality transition training.

Sean Elliott

The Final Word - Sean Elliott, EAA Vice President of Advocacy and Safety

Keeping the 'Experiment' In Experimental

It was 86 years ago when Congress passed the Air Commerce Act of 1926 that included Section 25 governing the "Licensing of Special Classes of Airplanes." Within this section the first use of "experimental" as an aircraft certification classification is described. The Air Commerce Act also described the very beginning of what we now know as operating limitations.

While the intent of the experimental class way back then was to allow manufacturers to develop, fly, and prove a prototype aircraft, it was also clear that Congress intended to allow for imagination and innovation in aircraft design. The Act even goes so far as to lump in racing airplanes and "airplanes of an unusual design" to be considered part of the experimental category.

We have come a long way since those early days. Nowadays there are eight different designations under FAR 21.191, entitled "Experimental Certificates." Every kind of experimental aircraft from research and development, to exhibition (warbirds), to air racing, and of course, amateur-built designations are clearly listed and defined. The one common thread among all eight modern day designations, and even the 1926 ACA, is that they are all some form of an "experiment." That means that there is no production type certificate to conform to, and we have been granted the freedom to dream, explore, and innovate. In so many ways, that is the magic of EAA and what our community brings to aviation. The freedom to design, build, and fly is infectious and to varying degrees we all have the bug!

It is all too easy to fall into the trap of becoming more restrictive in an attempt to solve safety challenges in experimental aircraft operation of all types. Safety is, and will always be, a top priority for EAA. Can we do better? We absolutely can! However, we must do so with a continued acknowledgment and preservation of the intent of our activity being understood as an "experiment."

But, not every aspect of an experimental airplane needs to be an experiment. Over the decades since Congress wrote that Air Commerce Act airplane designers, pilots, and amateur-builders have learned much about what works and what doesn't. At EAA we are dedicated to helping builders improve their aircraft and understanding mistakes that have been made by others so they can be avoided in the future. Education, not regulation, is the way to preserve the freedom to innovate while at the same time avoiding unnecessary risk.

From time to time the FAA, NTSB, and other parts of the government need to be reminded of this. It is this "essence of freedom" in our culture that makes the United States the greatest aviation country in the world and EAA the heart of general aviation. Keep 'em flying and keep 'em safe!

EAA's Government Relations department works to preserve the freedom of flight and reduce the regulatory barriers affecting affordability and access to EAA members’ participation in aviation. Protecting the freedom to fly is the foundation on which all of the organization’s advocacy initiatives are built. EAA fights to preserve this freedom by providing clear solutions and practical alternatives backed by hard work and dedication. EAA’s history of success is a testament to that philosophy.

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