Booz & Company

Booz & Company

This document is confidential and is intended solely for the use and information of the client to whom it is addressed.

General Aviation Implementation Support (GAIS)Airworthiness Module (Revised)

1st Revision: October, 2010

Final Revision: October, 2011

Beijing, 25 September 2009

Prepared for ACPACP GAIS - 3_Airworthiness_Revised Oct 2011_EN_vf.pptBooz & Company 2

Purpose of Document

The intent of this document is to provide a detailed handover of all analysis and materials relating to regulatory gap studies on Airworthiness Module as part of deliverables for General Aviation Implementation Support (GAIS) project funded by the US Trade Development Administration (USTDA)

The study focuses on drawing general aviation (GA) regulatory experience and insights from the U.S. because:

– The U.S. has the most established and successful GA industry with a mature regulatory system that increases GA capacity and efficiency while maintaining safety

– ACP is an U.S. organization with its members consisting of FAA and key GA aircraft and equipment manufacturers with global presence. ACP member firms are best able to share GA regulatory, management, technological and operational experiences from the U.S.

Analysis has been conducted and completed by Booz & Company with active contribution from Civil Aviation Administration of China (CAAC), Development Research Center of the State Council (DRC), Aviation Industry Corporation of China (AVIC), ACP members and other key stakeholders

For further information please contact:

– Mr. Paul Fiduccia ([email protected])

– Mr. Frank Yu ([email protected])

– Mr. Kevin Wu ([email protected])

– Dr. Edward Tse ([email protected])

– Mr. Yang Guang ([email protected])

– Mr. Timothy Wong ([email protected])


This is one of the seven sets of deliverables developed for ACP GAIS project

Safety Module

AirworthinessModule

OperatorsModule

GA Safety Regulation

Safety Oversight Organizational

Structure

Safety Performance Measurement

Type and Production

Certifications

Aircraft Registration and

Certification

Airworthiness Regulations

GA Aircraft Ownership

Regulatory Constraints for

Operators

ACP General Aviation Implementation Support (GAIS) List of Deliverables

Safety culture and promotion

GA Associations

Module

Case Studies

Roles of GA Associations

General Aviation Airport

Module

GA Airport Regulations

GA Airport Planning & Design

GA Airport Funding

Flight Standards

Module

Mechanics

Flight Standards Regulations

PilotsGA Operating

Cost

Ma

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Mo

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leS

ub

- M

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Executive Summary

1 2 3 4 5 6

Prepared for ACPACP GAIS - 3_Airworthiness_Revised Oct 2011_EN_vf.ppt

In China, GA refers to all civil aircrafts activities other than public aircraft transportation activities

Booz & Company 4

General Aviation

Public ServiceEconomic

ConstructionConsumer Aviation

Forestry

Agriculture

Meteorology

Disaster Relief

Others1

Mine Exploration

Aerial Photography

Petroleum Services

Others2

Tourism

Training and Sports

Business Travel

Private Use

Non scheduled commercial operations3

(*) CAAC categorization(1) Others include aircraft seeding, pest control, farming and emergency rescue (2) Others include remote sensing, power line services and industrial associated applications(3) Non scheduled commercial operations include air taxi and air charter operationsSource: Committee of General Aviation Specialist of China Aviation Industrial Base (CAIB), CAAC and Booz Allen analysis

Three Main Categories of General Aviation Flight Activities*NON EXHAUSTIVE

China:

General Aviation refers to all civil aircrafts activities other than public aircraft transportation activities. Including flight operations associated with industrial, agricultural, forestry, fishery and construction, and other purpose operations such as medical and sanitation, emergency rescue, Meteorological sounding, ocean monitoring, scientific experiments, education and training, culture and sports etc.

Definition of General Aviation

FAA:

General aviation (GA) refers to all flights other than military and scheduled airline flights, both private and commercial.

ICAO:

General aviation comprises all aircraft that are not operated by commercial aviation or by the military.


Airworthiness Module aims to identify opportunities to simplify airworthiness management of general aviation aircraft in China The main objective of Airworthiness Module is to conduct regulatory gap analysis to identify

opportunities to simplify airworthiness management of general aviation (GA) aircraft in China

The scope of Airworthiness Module is as follows:

– Review FAA’s regulations in ensuring initial airworthiness of general aviation aircraft

– Review corresponding CAAC’s regulations

– Identify regulatory gaps

– Recommend steps to improve airworthiness management of GA aircraft


Summary of observations and recommendations for Module 3: Airworthiness (1/2)

Module 3: AirworthinessKey Areas U.S. (FAA) Observations China (CAAC) Observations Recommendations

Airworthiness regulations

In the US, FAA has stipulated regulatory requirements for different GA segments, e.g.:– Requirements for experimental

amateur-built aircraft and light sport aircraft

FAA also works closely with industry association to provide necessary guidance and information for:– Amateur build aircraft– The FAA and Industry Guide to

Product Certification (CPI Guide) guide is jointly prepared by FAA, AIA and GAMA

– Plane Sense - introduces aircraft owners and operators, or prospective aircraft owners and operators, to basic information about the requirements involved in acquiring, owning, operating, and maintaining a private aircraft

The VTC process leverages the work from primary airworthiness country to reduce the applicants’ burden - it requires on-site visits to the original aircraft manufacturer

China lacks simple but concise guidance materials in the following areas:– CAAC and industry guide to

product design and production certification

– Summary of requirements involved in acquiring, owning, operating, and maintaining a private aircraft

China does not have clear regulatory requirements for self-built aircraft despite reporting of test flying activities and accidents

Work with GA industry stakeholders to review and streamline VTC requirements

Work with manufacturers and suppliers to produce CAAC-Industry guidance material on aircraft design and production certification

Produce a guidance that summarizes requirements involved in acquiring, owning, operating, and maintaining a private aircraft (similar to Plane Sense)

Draft advisory circular related to airworthiness requirements for experimental amateur-built aircraft

Issue LSA related regulations and rules for inclusion in the aircraft airworthiness requirements


Summary of observations and recommendations for Module 3: Airworthiness (2/2)

Module 3: AirworthinessKey Areas U.S. (FAA) Observations China (CAAC) Observations Recommendations

Aircraft registration and certification process

In the US, it generally takes less than 1 month to register and obtain aircraft certificate for registration and airworthiness

Some of the requirements are either duplicative or inconsistent across different regulations (e.g. CCAR 285)

Work with GA industry to simplify and shorten aircraft registration and certification process


Executive summary


Type and production certifications

Aircraft registration and

certification Appendix


GA stakeholders have highlighted several regulatory and administrative shortcomings related to GA airworthiness

Key Takeaways from Interviews and Questionnaire

Lack of understanding of

regulatory requirements

Most of the potential buyers of aircraft do not understand what exactly needs to be done and where to start

CAAC and the regional bureaus sometimes do not have conformed understanding - some options are approved by regional bureaus, but ruled out by CAAC

There are lack of standards and useful reference or guidance materials provided by CAAC

Onerous approval process

The overall certification process from design, production to registration and airworthiness certification are lengthy

There are unnecessary administrative procedures and processes that require:– Large amount (and at time repetitive) of paperwork– Frequent visits to different CAAC offices

Aircraft purchase processes are taken too long and some of the processes are repetitive

Lack of regulatory guidance

For experimental amateur-built aircraft, it is difficult to get type certification due to lack of necessary regulations and procedures

Source: Booz & Company analysis


We have identified differences in three areas which have impacted the effectiveness of current airworthiness regulatory system


VTC and industry guidelines

Aircraft registration and certification

Key Areas

CAAC needs to review and incorporate provisions of Light Sport Aircraft (as stipulated in AC-21-AA-2009-25) in CCAR Part 21

CAAC does not have clear airworthiness regulatory requirements for amateur built experiment (kit built) aircraft

Key Differences Impact

Current production and test flying of experimental amateur built aircraft cause safety concerns and restrict the growth of amateur built aircraft

The VTC process is complicated and lengthy - it requires on-site visits to the original aircraft manufacturer

China lacks simple but concise guidance materials in the following areas:– CAAC and industry guide to product design and production

certification– Guidance for experimental amateur-built aircraft certification

Resource consuming for applicants

Confusion in interpretation of regulations

Inconsistency in regulatory compliance

Aircraft registration process is complex and restrictive for applicants

China lacks a guidance that summarizes requirements involved in acquiring, owning, operating, and maintaining a private aircraft

Resource (time and cost) consuming for applicants as well as CAAC

Inconsistency in regulatory compliance


1

2

3


China does not have clear regulatory requirements for self-built aircraft despite reporting of test flying activities and accidents

Source: Media reporting, Booz & Company analysis

Airworthiness Regulations1

重庆小伙自制飞机飞上 300 多米天空2008年 10月 26 日来源：新华网 / 华龙网

10月 25 日，彭聪驾驶自制飞机成功起飞　　当日，重庆市江津区电信局员工彭聪在江津长江水面上驾驶自己制造的飞机成功起飞，并飞上了 320 米高空。制造这架飞机，彭聪用时 5 年，耗资 10 多万元，经过无数次试验才最终成功

广东男子 7 万自制飞机视频走红网络 2008-6-30 来源：中国台州网

…. 两年前， 40 岁的陈昭荣正式开始在村里造直升机。从组装开始，他就不停在门前的空地上摆弄，拉去别人家里请人焊接等等。 6 个月前，他组装好直升机，“样子跟任何的一架直升机都不一样，是我自己做的，发动机是买来的一个二手发动机。”造飞机的全部花费，陈昭荣估计是六七万元…

北京市一工人自制小飞机坠毁驾驶员受伤2007年 04月 11 日来源：京华时报

30歲的李賢鋒已住院兩天，他“ ” 是為了自己的飛天夢而受傷。

4月 8日上午，完全沒有駕駛經驗的李賢鋒駕駛一架小飛機衝向天空。兩分鐘後，飛機從 50米的高度墜毀。那是李賢鋒手工制造的飛機，他說用了幾年的時間。自己制造一架飛機並飛起來———以維修保齡球器具為職業

“的李賢鋒，為這樣的夢想癡狂

浙江 64 岁老汉驾自制飞机坠落被调查2008-04-15 来源：天津北方网

上周，浙江一位 64岁的飞行爱好者在驾驶自己组装的超轻型飞机时失去控制，飞机损毁严

…重，所幸人员无恙去年底，他从杭州买来零件，自己组装了一架“小蜜蜂 3C” 超轻型飞机，迫不及待地进行试飞时，结果险象环生

CAAC needs to stipule clearly airworthiness

requirements and guidance for experimental amateur-built

segments

China permit ultralight under Part 103;Aircraft that are above ultralight weight limited could be

permitted under experimental amateur-built-experimental


In the US, FAA has stipulated regulatory requirements for experimental amateur-built aircraft and LSA Categories of FAA Special Airworthiness Certificate

Category Purpose(s)Title 14 CFR

Section

Primary Aircraft flown for pleasure and personal use

21.24 21.184

Restricted Aircraft with a "restricted" category type certificate, including: Agricultural

Forest and wildlife conservation Aerial surveying Patrolling (pipelines, power lines) Weather control Aerial advertising Other operations specified by the

Administrator

21.25 21.185

Multiple Multiple airworthiness certificates 21.187

Limited Aircraft with a "limited" category type certificate (conversion of military aircraft for civilian use)

21.189

Light-Sport Operate a light-sport aircraft, other than a gyroplane, kit-built, or transitioning ultralight like vehicle

21.190

Provisional Aircraft with a "provisional" category type certificate for special operations and operating limitations

part 21 subpart C

part 21 subpart I

section 91.317

Category Purpose(s)Title 14 CFR

Section

Experi-mental

Research and development Showing compliance with regulations Crew training Exhibition Air racing Market surveys Operating amateur-built aircraft Operating kit-built aircraft Operating light-sport aircraft Unmanned Aircraft Systems (UAS)

21.191 21.193 21.195

Special Flight Permit

Special-purpose flight of an aircraft that is capable of safe flight (though may not currently meet applicable airworthiness requirements), for the purposes of :– Flying aircraft to a point for repairs,

alterations, maintenance, or storage. – Delivering new aircraft to the base of a

purchaser or to a storage point. – Conducting production flight tests. – Evacuating an aircraft from impending

danger. – Conducting customer demonstration

flights in new production aircraft that have passed or completed production flight tests.

– Excess weight operations.

21.197

Source: FAA



FAA issues experimental certificates for amateur-built aircraft and LSA to fly

Purpose Explanation Research and

development To conduct aircraft operations as a matter of research or to determine if an idea warrants further development. Typical

uses for this certificate include new equipment installations, operating techniques, or new uses for aircraft

Showing compliance with regulations

To show compliance to the airworthiness regulations when an applicant has revised the type certificate design data or has applied for a supplemental type certificate or field approval

Crew training For training the applicant’s flight crews in experimental aircraft for subsequent operation of aircraft being flight tested in type certificate programs or for production flight testing

Exhibition To exhibit an aircraft’s flight capabilities, performance, or unusual characteristics for air shows, motion pictures, television, and similar productions, and for the maintenance of exhibition flight proficiency

Air racing To operate an aircraft in air races, practice for air races, and to fly to and from racing events

Market surveys To conduct market surveys, sales demonstrations, and customer crew training for U.S. manufacturers of aircraft or engines

Operating amateur-built aircraft

To operate an amateur-built aircraft in which the major portion has been fabricated and assembled by persons for their own recreation or education

Primary category kit To operate a primary category aircraft that was assembled by a person from a kit manufactured by the holder of a production certificate for that kit, without the supervision and quality control of the production certificate holder

Operating light-sport aircraft

Operating a light-sport aircraft that: Has not been issued a U.S. or foreign airworthiness certificate and does not meet the provisions of 14 CFR section

103.1. An experimental certificate will not be issued under this paragraph for these aircraft after January 31, 2008; Has been assembled:

– From an aircraft kit for which the applicant can provide the information required by 14 CFR section 21.193(e); and– In accordance with manufacturer's assembly instructions that meet applicable consensus standard; or

Has been previously issued a special airworthiness certificate in the light-sport category under 14 CFR section 21.190

Experimental Certificates (FAR21.191)

Source: FAA



These experimental certificates provide much more relaxed certification requirements

Type Certificated Aircraft Experimental Amateur-built Aircraft

Basic Requirements An airplane produced in accordance with 14 CFR Part 23 must meet a number of requirements intended to ensure airworthiness in areas such as performance, stability, controllability, and safety mechanisms

An experimental amateur-built aircraft is an aircraft that has not met any minimum performance standards required by 14 CFR Part 23

Marking Requirement No particular marking required if comply with type certificated aircraft category

Need to properly mark the aircraft as “Experimental Aircraft”

Must display a visible placard stating “Passenger Warning: This aircraft is amateur-built and does not comply with Federal safety regulations for standard aircraft.”

Type of Airworthiness Certificate

Mostly Standard Airworthiness Certificate (Standard) Some require Special Airworthiness Certificate

(Special)

Special Airworthiness Certificate

Operating Limitations

No specific operating limitations for Standard Comply with Order 8130.2 for Special

Must comply with Order 8130.2

Comparison between Type Certified and Experimental Aircraft

Source: AC 20-27F, Order 8130.2F, FAA Aviation News



FAA also works closely with industry association to provide necessary guidance and information for amateur build aircraft

Source: AC 20-27F, Order 8130.2F, FAA Aviation News, China news search

Process of Certifying and Operating an Amateur-built Aircraft - FAA Example

Want to build an aircraft

Contact the nearest FAA office for guidance & info

Design and construct the aircraft

Register the aircraft

Identify and mark the aircraft

Apply for airworthiness certificate

Flight test and maintain the aircraft

FAA encourages amateur aircraft builders to ask for help in design and constructing the aircraft in the following ways through Experimental Aircraft Association (EAA) for guidance, other person with expertise or commercial help recommended by the FAA

FAA also provides detailed Advisory Circulars, Orders and publications for amateur builders to learn and digest



China has recently issued an advisory circular on LSA airworthiness but specific requirements on airmen and operations CAAC Advisory Circular on Light Sport Aircraft (LSA)

AC-21-AA-2009-25

Comments

The Advisory Circular concerning airworthiness requirements of Light Sport Aircraft (LSA) category was recently released in May 2009

It provides an official category of GA segment in China

Subsequently, the development of relative regulations, procedures and forms requirements regarding LSA needs to be carried out as soon as possible

CAAC also needs to review the need for special provisions for airmen and operational requirements specific to LSA as practiced in the U.S. (please refer to Flight Standards Module)

This AC include type certification, production

certification and airworthiness

certification for LSA



A validation of type certificate (VTC) needs to be obtained for products (aircraft, aircraft engine and propeller) imported to China

VTC Applicability

According to the Chinese authority law and regulation requirement and Validation Procedure for Import Civil Aviation Products and Parts (AP2101), the Chinese VTC for an import aircraft is a prerequisite to issuance of a Chinese Certificate of Airworthiness

An engine or propeller also should get a Chinese VTC, unless the engine or propeller is validated as part of the aircraft

The detailed procedures for issuance of Chinese Validation Type Certificate are prescribed in CAAC AP2101

Comments

Any import aircraft or aircraft engines or propellers needs to apply for VTC before the Chinese authority to issue a airworthiness certificate

Adopting supplement modifications or improvements to the existing VTC model needs to re-apply for VSTC (S for supplement) before they can come in to China

The process for VSTC are similar to VTC - however project complexity might be reduced

VTC and industry guidelines2


The VTC process is complicated and lengthy - it requires on-site visits to the original aircraft manufacturer

Document Submission

Acceptance of Application

Initial Familiarization Meeting

Noise Requirements

Application form AAC-021 for manufacturer to fill in and pass to FAA then to CAAC

Recommendation letter and general product description from FAA to CAAC

Description of design features and basic specification of product include three-view drawing

A copy of the FAA type certificate and type certificate data sheet

A copy of all FAA special conditions, equivalent safety items and exemptions from the airworthiness, fuel venting and exhaust emission, or noise requirements

A compliance checklist with certification basis

CAAC-AAD issues Notification of Acceptance

Examination fee CAAC establish examination team

Validation Type Certificate (VTC) Process and Requirements

Certification

Establish type validation basis and perform on-site engineering review

Review manufacturer’s quality assurance system

Sign final validation meeting minutes The documents to be provided to

CAAC-ADD project team needs to include over 10 sets of document

Source: FAA, CAAC and industry interviews, Booz & Company analysis

2

Fuel Venting and Exhaust Emission Requirements

Comments CAAC only validate the FAA type certification

from export country, which require less work for both CAAC and the applicant

Feedback from interviewees: “Current VTC process is too time consuming and costly” - this will lead to fewer GA airplanes available in China



Regulations and guidance on experimental amateur built airworthiness certification is lacking

“I will design and build my aircraft first and deal with certification and registration matters

later”

“My project will never materialize if I go through the proper process”

GA Manufacturer Interview Quotes

“The VTC application process is lengthy and costly”

Key Takeaways

General aviation aircraft manufacturer/ entrepreneurs are not clear of CAAC’s approval process for GA aircraft production (e.g. balloons, sports aircraft etc.)

There are no clear standards/ guidelines to ensure an efficient certification review and approval process

Part of these are because China currently does not have a strong aircraft design capability or demand - however, we think that the application procedures should be simplified in order to encourage more individuals or companies to participate in aircraft design and production

Source: Industry interviews

2 VTC and industry guidelines


In the US, it generally takes less than 1 month to register and obtain aircraft certificate for registration and airworthiness

Submit Aircraft Registration

Package

Submit Application to Local FAA Office

FAA DecisionIdentify Type of Airworthiness

Certificate Needed

FAA Aircraft Certification Process

Check Eligibility of Registration

FAA Issue Aircraft Registration Certification

Aircraft Registration

12-16 Days

Airworthiness Certification

7-14 Days

The registration requirements are very clear and easy to follow All process and forms required are easy to find on FAA website FAA also has “Information Aid” document to answer general problems occur during certification process There are also local office contract details for applicant who might have individual enquiries

Source: FAA

3 Aircraft registration and certification


However, in China, there process normally takes 2-6 month to complete

想买进口的私人飞机

Start

Successful Certification

初期申请大约需要 1-2 个月

飞机登记大约半个月

适航审定大约 1-2 个月

手续完成总计 2-6 个月

民航局允许购机许可交付购机申请等待海关报批

航空器国籍登记航空器所有权登记非经营性通航活动登记

特许飞行证标准 / 特殊适航证无线电台执照

After the aircraft registration, the pilot/owner of the aircraft can apply for airspace and filing flight plan

The whole process is time consuming and complex Many private aircraft buyers postpone their

purchasing decision because of this During the down time, the owner of the aircraft still

have to incur depreciation cost

Aircraft Certification Process in ChinaILLUSTRATIVE

Source: CAAC, industry interview



Compare to the FAA, the CAAC has more complex and restrictive administrative requirements for aircraft registration…

Eligibility of Registration

Submit Aircraft Registration Application

Aircraft Registration Branch Process the Application

Aircraft Registered

May need to redo if a form is not filled in properly

Typical Aircraft Registration ProcessFAA

Acquire Credentials

Submit Aircraft Logo Marking Plan

Apply for Aircraft ID Number

Apply for Aircraft Registration

Submit Application

Airworthiness Contact Office Process the Application

Aircraft Registered

Typical Aircraft Registration ProcessCAAC

No Documents Required

Only need to comply with the law, no need to filing any documents

Key forms included Evidence of

ownership Identity number Registration marking

Documents Required

Purchasing purpose ID document Police record Feasibility study Pilot license Intent Contract with

base airport

All included in one package Registration application

Evidence of ownership Applicant ID document Evidence of the aircraft

not registered elsewhere

Other documents required

Aircraft Certification Obtained Applicant to fill in “Non-

Commercial GA Registration Administration”Source: FAA, CAAC, industry interview, Booz & Company analysis



… as well as airworthiness certification (normally completed by the manufacture after registration)

Applicant Registration with Local CAAC Office

Submit Airworthiness Application

Local Airworthiness Certification Office Process the Application

Issuance of Airworthiness Certificate

Apply for Temp Certificate for Testing Flight

Certification Issuance

Typical Airworthiness Certification ProcessFAA (Local-made Aircraft)

Typical Airworthiness Certification ProcessCAAC (Imported Aircraft)

Contact FAA Local Office for Direct Guidance on Airworthiness Certification

FAA Safety Inspectors Assists the Applicant in Conducting Aircraft Inspection


Local Manufacturing Inspection District Office Process the Application


One form required Aircraft Designation Certification Type Owner’s Certification Inspection Agency Verification FAA Representative Certification Production Flight Testing

All included in one package

CAAC has different sequence in this process compare to the FAA

Application content required here is somewhat similar to the FAA - however in different forms

Not directly comparable

Source: FAA, CAAC, industry interview, Booz & Company analysis



Some of the requirements are either duplicative or inconsistent across different regulations

Duplication

Ambiguity

Inconsistency

Some of the documents required are duplicative and should be simplified if possible

E.g. Some of the clauses under Aircraft Purchase Application and Non-Commercial GA Registration Administration are the same

There are requirements in several regulatory document stating “other documents required” which are not clear to the applicant in terms of what exactly is needed to complete the certification process

Minor contradiction exists for Ultralight Aircraft– For example, in CCAR 91, it is not required for this

category aircraft to go through aircraft certification process - however, it is treated the same as all other categories in CCAR 285

Some of the economic regulations does not agree with each other– For example, in CCAR 45 and 49, nowhere it said

that the owner of the aircraft needs to be a pilot in order to register its aircraft, however, CCAR 285 requires it

Issues Identified from CAAC Regulation and Requirements

Adverse Impact on Buyers

To prospective private aircraft owners, these requirements can slow down the application process significantly

Most of these buyers only want to experience flying, however, the complex administrative packages and processes have become a burden and stopped willingness to buy








Aircraft registration and certification

We recommend six initiatives that will improve the effectiveness and efficiency of the current GA regulatory system

Key Areas


Key Recommendations Expected Benefits

Improve safety More appropriate

requirements for recreational GA segments

New technology development


Shortened approval duration and reduce cost


Improved efficiency Reduced cost to GA operators Reduced workload to CAAC


1

2

3

More aircraft available for China GA growth

Reduced cost to CAAC


1.1

1.2

2.1

2.2

3.1

3.2 One stop information for all related regulatory requirements and forms


We have also drawn up high level descriptions of necessary tasks for each of the recommended initiatives (1/6)


Clarify and define approval requirements and process for experimental amateur built aircraft Provide guidelines on design (TC), production requirements and process Define registration and airworthiness certification requirements for these type of aircraft

Key ObjectivesInitiative

Stakeholders to be Consulted Next Steps/Follow-upExpected Benefits

FAA Industry associations and experts Past and existing experimental amateur

aircraft builders

Task 1: Product Definition

Work with FAA specialists and industry experts on definition for experimental amateur-built aircraft

Clarify and define approval requirements and process - this should aim to encourage amateur built aircraft

Document processes and procedures Issue public consultation

Task 3: Registration and CertificationTask 2: Airworthiness Approval

Use the FAA AC 20-27 and Order 8130.2 Section 7 Experimental Amateur Built Airworthiness Certification as a guidance as how to conduct approval and this also maybe used as applicant reference

CAAC needs to be reasonable in getting the information required from the amateur builders - as most case there is only one aircraft involved - hence, production certificate is only required if there are duplications of aircraft

Consult industry experts and past amateur builders on simplifying the process

Improve safety More appropriate requirements for

recreational GA segments Increase use of experimental aircraft for

new technology development

Set up steering committees/work groups for each task

Draft detailed scope and work plan

Initiative (1.1)

1.1




Set up full regulations, rules, administrative procedures and advisory circulars for LSA category



FAA Industry associations and experts Past and existing experimental amateur

aircraft builders

Task: LSA

Recent issuance of Light Sports Aircraft advisory circular has made great impact on the GA industry - the subsequent procedures and forms required needs to be carried out as soon as possible

Consult stakeholders on relevant procedures required - again, this should aim to simplify the administrative processes Consult stakeholders on related importation procedures and processes China can take the lead in setting the electric LSA plane requirement and regulation standard

Improve safety More appropriate requirements for

recreational GA segments Increase use of experimental aircraft for

new technology development



Initiative (1.2)

1.2




Simplify current VTC processes and reduce cost for manufacturers



FAA specialists CASC and CATIC ACP and other non-Chinese

manufacturers

Task: Review and Streamline VTC Requirements

Baseline current VTC requirements Consult stakeholders on current issues - suggest discussions scope limited to GA aircraft only Decide jointly with stakeholders on where to reduce paper work and costs Work with FAA to develop a agreement on VTC and SVTC exemptions - for example, minor modifications to products are exempt for VTC

procedures for certain category of GA aircrafts Document processes and procedures Issue public consultation






Initiative (2.1)

2.1




Provide direct guidance on aircraft design certification Provide direct guidance on aircraft production certification



AVIC FAA GAMA ACP

Task 1: Aircraft Design Certification

Baseline current aircraft type certification process and procedures Get industry input in how to make the process more efficient and

collaborative Document findings and procedures Publish CAAC-Industry guide on design certification Detailed examples can follow FAA CPI

Task 2: Aircraft Production Certification

Baseline current aircraft production certification process and procedures

Get industry input in how to make the process more efficient and collaborative

Document findings and procedures Publish CAAC-Industry guide on production certification






Initiative (2.2)

2.2




This is aim to help individual purchase and importation of GA aircraft in China through simplifying aircraft registration and certification process



AVIC FAA GAMA ACP

Task 1: Aircraft Registration

Baseline current aircraft registration certification process and procedures

Review especially on individual aircraft purchase documentation required - simplify or delete the “ 购机申请“ (aircraft purchasing credentials)

Compare with the FAA aircraft registration process and compile all necessary documents into one package rather than let the applicant going back and forth to acquire different piece of paper

Modify existing requirements according to above findings

Task 2: Airworthiness Certification

Baseline current aircraft airworthiness certification process and procedures

Compare with the FAA airworthiness certification process and study the possibility of involving safety inspectors at the right beginning of the certification process

Simply paper work and documentations processes for airworthiness certification and compile all necessary documents into one package

Modify existing requirements according to above findings Also, study possibilities of simplify or delete CCAR 285 as it appears

redundant and unnecessary

Improved efficiency Reduced cost to GA operators Reduced workload to CAAC



Initiative (3.1)

3.1




Develop a easy-understanding industry guidance to ease aircraft owning process for individuals



Industry associations GA enthusiasts / individual aircraft buyers

One stop information for all related regulatory requirements and forms



Initiative (3.2)

Task: Provide Guidance for Individuals

CAAC can ask industry associations to draft this guidance from an individual point of view - develop the guidance from the process of acquiring, owning, operating and maintaining a private aircraft

Use the FAA Plane Sense as a reference in each step CAAC to review the draft guidance and make recommendations Circulate for consultation and feedbacks

3.2


Executive summary


Type and production certification


certification Appendix


ICAO requires its member states to ensure airworthiness of aircraft throughout their life cycle

Type Certification Production

It defines the design of an aircraft type and to certify that this design meets the appropriate airworthiness requirements under the anticipated operation conditions

Aircraft manufacturer normally submit a request for Type Certificate before serial production

It requires proof of compliance with the appropriate airworthiness requirements (such as documentary evidence, inspections and ground and flight tests)

This ensures that each aircraft, including parts manufactured by sub-contractors, conforms to the approved design

Proof of production control and traceability of production records are critical considering factors

Certificate of Airworthiness

A Certificate of Airworthiness shall be issued on the basis of satisfactory evidence that the aircraft complies with the design aspects of the appropriate airworthiness requirements and fit to fly

It shall be renewed or shall remain valid provided continuing airworthiness of the aircraft is demonstrated through a system of inspection

Continued Airworthiness of Aircraft

This is ensured through proper maintenance of aircraft

Maintenance can include any one or combination of overhaul, inspection, replacement, defect rectification and the embodiment of a modification or repair

ICAO Annex 8 Part II Recommended Procedures for Certification and Continuing Airworthiness

Source: ICAO Annex 8 to the Convention on International Civil Aviation - Airworthiness of aircraft, Booz & Company analysis

Original Airworthiness Recurrent Airworthiness


“AIRWORTHY"

United States Code and Federal Aviation Regulation do not define “airworthy” but FAA Order 8130.2F states two conditions that must be met

+“The aircraft must conform to its TC”Paragraph 9.b. of 8130.2F:

“The aircraft must be in a condition for safe operation”

=

Paragraph 9.a. of 8130.2F Conformity to type design is

considered attained when the aircraft configuration and the components installed are consistent with the drawings, specifications, and other data that are part of the Type Certification (TC)

This includes any supplemental type certificate (STC) and field approved alterations incorporated into the aircraft

Paragraph 9.b. of 8130.2F It refers to the condition of the

aircraft with relation to wear and deterioration

For example, skin corrosion, window delamination/crazing, fluid leaks, and tire wear

If one or both of these conditions are not met, the aircraft would be considered unairworthy

Aircraft that have not been issued a TC must meet the requirements of paragraph 9b above

FAA ORDER 8130.2F CHG 3 Airworthiness Certification of Aircraft and Related ProductsDefinition of “Airworthy”

Note:1) The term “airworthy” is not defined in Title 49, United States Code (49 U.S.C.), or in 14 CFR2) FAA ORDER 8130.2F CHG 3 Airworthiness Certification of Aircraft and Related Products - It establishes procedures for accomplishing original and recurrent airworthiness certification of aircraft

and related products. The procedures contained in this order apply to Federal Aviation Administration (FAA) manufacturing aviation safety inspectors (ASI), to FAA airworthiness ASIs, and to private persons or organizations delegated authority to issue airworthiness certificates and related approvalsSource: FAA Order 8130.2F, Booz & Company analysis


Three primary Federal Aviation Regulations govern the airworthiness of an aircraft in the U.S.

14 CFR Part 21Certification Procedures for Products

and Parts

This regulation identifies the requirements of and the procedures for obtaining type certificates, supplemental type certificates, production certificates, airworthiness certificates, and import and export approvals

14 CFR Part 43Maintenance, Preventive

Maintenance, Rebuilding, and Alterations

14 CFR Part 91General Operating and Flight Rules

It prescribes rules governing the maintenance, preventive maintenance, rebuilding, and alteration of aircraft having U.S. airworthiness certificates

It also applies to airframe, aircraft engines, propellers, appliances, and component parts of such aircraft

It does not apply to any aircraft with experimental certificate

It is an operational regulation that is focused toward the owner, operator, and/or pilot of the aircraft

Clause 91.7(a) states “no person may operate a civil aircraft unless it is in an airworthy condition.”

Subpart E — Maintenance, Preventive Maintenance,and Alterations describes in general the rules regarding maintenance, preventive maintenance and alteration

Source: Federal Aviation Regulations, Booz & Company analysis

Airworthiness standards for airplane, rotorcraft and manned balloons (Parts 23, 25, 27, 29 and 31)

Airworthiness standards for aircraft engines and propellers (Parts 33, 35)

Airworthiness Directives (Parts 39) Emission requirements (Parts 34, 36) FAA Orders 8110.4 Type certification and

8120.2 Production Approvals

Operating requirements (Parts 91, 121, 125, 135)

Repair station

Other interlinked regulations Certification of pilots, airmen (Parts 61,

65) Certification of commercial operators

(Parts 119) Operating requirements (Parts 91, 121,

125, 135) Repair station (Part 145) FAA Orders 8900.1 Flight Standards

Information Management System (FSIMS)

Three Primary Regulations Governing the Airworthiness of An Aircraft in the U.S.


CAAC’s overall airworthiness regulations align closely with the FAA

Category FAA CAAC Differences

Airworthiness management

14 CFR Part 21 - Certification Procedures for Products and Parts CCAR-21-R2 & R3 民用航空产品和零部件合格审定规定

Nil

Airworthiness standards for aircraft

14 CFR Part 23 - Airworthiness Standards: Normal, Utility, Acrobatic, and Commuter Category Airplanes

14 CFR Part 25 - Airworthiness Standards: Transport Category Airplanes

14 CFR Part 27 - Airworthiness Standards: Normal Category Rotorcraft 14 CFR Part 29 - Airworthiness Standards: Transport Category

Rotorcraft 14 CFR Part 31 - Airworthiness Standards: Manned Free Balloons

CCAR-23-R3 正常类、实用类、特技类和通勤类飞机适航规定

CCAR-25-R2 & R3 运输类飞机适航标准 CCAR-27-R1 正常类旋翼航空器适航规定 CCAR-29-R1 运输类旋翼航空器适航规定 CCAR-31 民航总局第 181 号令载人自由气

球适航规定

Nil

Airworthiness for engines and propellers

14 CFR Part 33 - Airworthiness Standards: Aircraft Engines 14 CFR Part 35 - Airworthiness Standards: Propellers

CCAR-33-R1 中国民用航空总局关于修订《航空发动机适航标准》的决定

CCAR-35AA 螺旋桨适航标准

Nil

Other airborne equipment

Nil CCAR-37AA 民用航空材料、零部件和机载设备技术标准规定

CCAR-37AA

Emission requirements

14 CFR Part 34 - Fuel Venting and Exhaust Emission Requirements for Turbine Engine Powered Airplanes

14 CFR Part 36 - Noise Standards: Aircraft Type and Airworthiness Certification

CCAR-34 涡轮发动机飞机燃油排泄和排气排出物规定

CCAR-36 & R1 航空器型号和适航合格审定噪声规定

Nil

Airworthiness directives

14 CFR Part 39 - Airworthiness Directives CCAR-39AA 民用航空器适航指令规定 Nil

Registration 14 CFR Part 47 - Aircraft Registration CCAR-45-R1 民用航空器国籍登记规定 Nil

Comparison of the Airworthiness Regulations



In addition the States Council also promulgated regulations for the administration of the airworthiness of civil aircraft The States Council promulgated Regulations of the Peoples Republic of China for the

Administration of the airworthiness of Civil Aircraft in May 1987

The regulations stipulate that airworthiness requirements shall be followed by:

– All units and individuals engaged in the designing, manufacturing, use and maintenance of civil aircraft

– All units or individuals that export civil aircraft to the People's Republic of China

– All units or individuals that perform outside the People's Republic of China maintenance services to aircraft registered in the People's Republic of China

It also states that the Civil Aviation Administration of China shall be responsible for the administration of the airworthiness of civil aircraft


However, there appear to be a regulatory difference between the State Council one and CCAR 21

第六条任何单位或者个人设计民用航空器，应当持航空工业部对该设计项目的审核批准文件，向民航局申请型号合格证。民航局接受型号合格证申请后，应当按照规定进行型号合格审定；审定合格的，颁发型号合格证

Details of “Design” procedures are not clear as how to file for application to the “Ministry of Aviation Industry” ( 航空工业部 ) - at least this is not found in CCAR 21 related regulation procedures and advisory circulars

第七条任何单位或者个人生产民用航空器，应当具有必要的生产能力，并应当持本条例第六条规定的型号合格证，经航空工业部同意后，向民航局申请生产许可证。民航局接受生产许可证申请后，应当按照规定进行生产许可审定；审定合格的，颁发生产许可证，并按照规定颁发适航证。任何单位或者个人未按照前款规定取得生产许可证的，均不得生产民用航空器。但本条例第八条规定的除外

CCAR-21 ( 民用航空产品和零部件合格审定规定 ) does not require the approval from other states agency prior to the application of production approval

Details of “Production” filing procedures are not clearly mentioned

We recommend that “Regulations of the Airworthiness of Civil Aircraft of the People’s Republic of China (1987)” be reviewed and the role of “Ministry of

Aviation Industry” to be clearly defined

Regulations of the Airworthiness of Civil Aircraft of the People’s Republic of China

Civil Aviation Products and Parts Certification Requirements (CCAR 21)


Executive summary


Type and production

certification


certification

Appendix


FAA issues type certification when the design of civil aircraft, engine, or propeller complies with applicable regulations

Design Approvals Regulation and Policies Issuer

Original Design Approval– An original FAA design approval is

a five-phase process in which an applicant applies for, and the FAA may issue, a type certificate or design approval of a product or a major design change to a product

14 CFR Part 21 subpart B (sections 21.11 through 21.53)

Predecessor Regulations to 14 CFR– Aeronautical Bulletins – Civil Air Regulations (CARs) – Regulations of the Administrator

Advisory Circular 21-23 Orders 8110.4

Aircraft Certification Offices (ACOs) Certificate Management Offices (CMOs)

Field Approval– A field approval is one of the

means used by the FAA to approve technical data used to accomplish a major repair or major alteration

14 CFR Part 1, 43 Advisory Circular 43.9-1, 43.13-1, 43.13-2,

43-10 Orders

– FSIMS (Flight Standards Information Management System), Volume 4, Chapter 9, Section 1

Administrator, through Aviation Safety Inspector (airworthiness)

Parts Manufacture Approval (design)– The PMA certifies that a

replacement or modification part complies with the airworthiness standards of eligible products (aircraft, engine or propeller)

14 CFR Part 21, Part 43, Part 45 Subpart B

Advisory Circular 43-18 Orders 8110.42

Manufacturing Inspection District Offices (MIDOs)– If the applicant is applying for a PMA

based on an STC or identicality by a licensing agreement

Aircraft Certification Offices (ACOs) – If the design approval basis is identically

without a license agreement or test and computation

Major Design Approvals (Type Certification)

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Type Certification

Source: FAA


FAA issues Orders that prescribe the responsibilities and procedures the FAA must follow to certify new aircraft, engines and propellers

Orders 8110.4C Type Certification

Order 8110.4, Type Certification, is primarily written for internal use by the FAA, its designees, and delegated organizations

The order provides procedures and policy for the type certification of products

It describes the process for U.S. applicants to obtain a U.S. TC for their product under 14 CFR § 21.21

It focuses on the design approval process conducted by Aircraft Certification Offices (ACO)

It also addresses other aspects of safety, such as airworthiness (airworthiness certificates), manufacturing (production approval), maintenance, and operations (continued airworthiness) as they relate to design approval (type certification)

Order 8110.52 Type Validation and Post-Type Validation Procedures applies to U.S. applicants who seek foreign TCs and when non U.S. applicants seek U.S. TCs

Before manufacturing a product, an applicant must have a design approval (that is, TC, STC, amended TC, amended STC) and a PC or other FAA production approval

Similarly, before manufacturing a component or spare part (for sale) the applicant must have a PMA or a TSO authorization

Note: TC = Type certification; STC = Supplemental type certificate (i.e. a type certificate for achange to an aircraft, engine, propeller, or appliance); Amended TC = an approval for a change to a TC, made by the TC holder; Amended STC = an approval for a change to a STCSource: FAA, Booz & Company analysis

14 CFR Part 21 Certification Procedures for Products And Parts

Summary of Requirements on Product Certification

Type Certification


The CPI Guide provides clear guidance on processes to reduce the certification cycle time while ensuring regulatory compliance

Comments

The FAA and Industry Guide to Product Certification (CPI Guide) guide is jointly prepared by FAA, AIA and GAMA

It aims to improve certification process, referred to as Certification Process Improvement to reduce cycle time of reduce the cycle time to certify products, while ensuring regulatory compliance

This guide describes how to plan, manage, and document an effective, efficient product certification process and working relationship between the Federal Aviation Administration (FAA) and an Applicant

It is a compilation and enhancement of the best business and certification practices and is compatible with FAA Orders 8110.4, “Type Certification” and 8100.5, “Aircraft Certification Service - Mission, Responsibilities, Relationships, and Programs”

The FAA and Industry Guide to Product Certification (CPI Guide)

Jointly prepared by:

Type Certification

Source: FAA


These Orders and Industry Guide define clearly processes and roles and responsibilities of FAA and applicants during the five phases

Conceptual Design PhaseRequirements

Definition PhaseCompliance Planning

PhaseImplementation Phase

Post Certification Phase

This Phase is initiated when the Applicant begins design concept for a product that may lead to a viable certification project.

The intent is to ensure early, value added, joint involvement with an expectation to surface critical areas and the related regulatory issues, and begin formulating a preliminary Project Specific Certification Plan (PSCP)

Efforts in this Phase clarify the product definition and the associated risks, and conclude with a mutual commitment to move forward with product certification

Specific regulatory requirements and methods of compliance or critical issues are formulated

A more formal PSCP is developed

During this Phase a PSCP is completed

The plan is a tool to which the responsible parties commit and use to manage the product certification project

During this Phase the Applicant and FAA work closely in managing, refining, and achieving their agreed PSCP to ensure that all agreed upon product specific certification requirements are met

During this Phase close-out activities provide the foundation for continued airworthiness activities and certificate management for the remainder of the product’s life cycle

CPI’s Product Certification Process Roadmap (for US Manufactured Product)

Source: The FAA and Industry Guide to Product Certification (CPI)

Type Certification


For foreign manufactured products FAA only issues design approval to an applicant in a country with U.S. bilateral agreement The FAA will only issue product design approvals to an applicant in a country with which the

United States has concluded a bilateral agreement for the export and import airworthiness certification of such products

Additionally, the FAA does not normally issue a type design approval for a product manufactured outside the United States (in other words, the State of Design is a country other than the United States), unless the product is intended for use under the U.S. Registry or for operation by a U.S. operator under lease or charter

Foreign applicants for U.S. design approval must provide the FAA with evidence that the product will be imported into the United States, or will be installed in a U.S. registered or U.S. manufactured product

Original Design Approval (for Foreign Manufactured Product)

Source: FAA

Type Certification

This is in principle similar to CCAR 21 Paragraph 21.319


For parts import, FAA and CAAC have reached an agreement for FAA certified PMA to be used in China

Type Certification

In March 2003, the CAAC and the FAA have signed agreement on certification exemptions for FAA-certified parts under Parts Manufacturer Approval

However, for major replacement and modifications, the applicant is still required to apply the MDA and VSTC

Also, for parts that’s sensitive to ETOPS, FAA PMA are not allowed to use

Procedures of Replacement or Modification of FAA Certified PMA Product to China Registered Aircraft

AC-20-01

Comments

This has helped greatly in simplifying the approval process for FAA-certified parts

However, due to lack of aircraft technical knowledge and certification capability, the application of this AC is limited - as it is difficult for the CAAC to evaluate whether the PMA parts are indeed qualify for “safe operation”

The CAAC may need to invest resources to put together detailed guidance and procedures on PMA and related certification process and regulations


Production certificate approves the manufacturing of duplicate products under an FAA-approved type design

Production Approvals Regulations and Policies Issuer

Production Certificate– An approval (document) to manufacture duplicate

products under an FAA-approved type design (i.e., type certificate or supplemental type certificate)

14 CFR Part 21, subpart F, Part 21 subpart G, Part 45

Advisory Circulars 21-1, 21-6 Orders 8100.7, 8110.42, 8120.2, 8120.15,

8150.1

Manufacturing Inspection District Offices (MIDOs)

Approved Production Inspection System (APIS)– An approved production inspection system is an

FAA-approved inspection process applicable to products manufactured more than 6 months after the date of issue of the type certificate, supplemental type certificate, or licensing agreement

– The approved production inspection system is used most frequently by low-volume manufacturers

14 CFR Part 21, subpart F, Part 21 subpart G, Part 45

Advisory Circulars 21-1, 21-6 Orders 8100.7, 8110.42, 8120.2, 8120.15,

8150.1


Parts Manufacturer Approval– PMA production approval allows you to produce

and sell FAA approved aircraft parts that are eligible for installation on FAA type certificated aircraft

14 CFR Part 21, Part 43, Part 45 Subpart B Advisory Circular 43-18 Orders 8110.42


Aircraft Certification Offices (ACOs)

Technical standard order authorization– A TSO is a minimum performance standard for

specified materials, parts, and appliances used on civil aircraft

14 CFR Part 21, sections 21.3, 21.502 and subpart O

Advisory Circulars 20-110, 20-41 Orders 8110.43, 8120.2, 8150.1

Local FAA office

Major Production Approvals

Production


It takes three-step process to get a production certificate

Submit ApplicationFAA Evaluate quality control

or production inspection system

Issue Production Approval

For a production certificate, submit Form 8110-12 (PDF) , Application for Type Certificate, Production Certificate, or Supplemental Type Certificate, to your local Manufacturing Inspection District Office (MIDO)

For an APIS, a formal application is not required. However, Form 8110-12, Application for Type Certificate, Production Certificate, or Supplement Type Certificate, may be used

Determine that proposed manufacturing facilities located outside the United States place no undue burden on the FAA in administering the applicable Regulations

Conduct a quality system audit to determine compliance with the applicable requirements of 14 CFR part 21. This audit evaluates the applicant's organization, production facility, quality control or inspection system, and approved quality control and design data for compliance with applicable requirements

Notify the applicant in writing of any corrective actions required

Conduct any additional audits, corrective actions, or meetings with the applicant if needed to support the application process

If the applicant's quality control or inspection system, organization, and facilities are in compliance with 14 CFR part 21, subpart F or subpart G, the FAA will issue: An approval letter for an approved production inspection system

A Production Certificate, FAA Form 8120-4, and a Production Limitation Record, FAA Form 8120-3. The Production Limitation Record identifies which products or parts are authorized for production

Production Certificate Process

Source: FAA, Booz & Company analysis

Production


In China CCAR 21 and associated administrative procedures regulate the type certification and production process

Type Certification and Production

CCAR 21 Certification Procedures for Products and Parts

Similar to the FAA, this is the major regulation issued by the CAAC to regulate aircraft type certification and production process in China

Other administrative procedures and advisory circulars on this include

– AP-21-03R3 型号合格审定程序– AP-21-04R3 生产许可审定和监督程序– AC-20-01 关于在中国注册的航空器上使用经 FAA 批准的 PMA 产品实施更换或改装的管理办法– AC-21-AA-2007-14 航空器内、外部标记和标牌– AC-21-02 机载系统和设备合格审定中的软件审查方法– AC-21-05 初级类航空器适航标准—甚轻型飞机– AC-21-06 初级类航空器适航标准—超轻型飞机– AC-21-07 初级类航空器适航标准—滑翔机与动力滑翔机– AC-21-09 飞艇适航标准

Source: CAAC


Executive summary




certification

Appendix


An aircraft owner must register his/her aircraft upon purchase

Aircraft Registration Application*

Evidence of Ownership**

US$ 5 Registration Fee

*) This form (AC Form 8050-1) must be original and can be obtained from the “Aircraft Registration Branch”

**) Need to fill in AC Form 8050-2 - Bill of Sale

Source: FAA

An Eligible Plane for Registration14 CFR Part 47

An aircraft is eligible for U.S. Registration if it is not registered in another country and it is owned by: – a U.S. citizen as defined in 14 CFR

Part 47.2. – a Resident Alien (foreign individual

lawfully admitted for permanent U.S. residence

– a U.S. governmental unit or subdivision

– a non-citizen corporation lawfully organized and doing business under the laws of the U.S. or one of the States as long as the aircraft is based and primarily used in the U.S. (60% of all flight hours must be from flights starting and ending within the U.S.)

It generally takes Aircraft Registration Branch of the FAA 12 - 16 working days to process the registration upon receiving the application package

Different types of registration include:– Individual– Co-owners– Partnership– Corporation– Government

Documents Required Registration

Aircraft Registration Process



After an aircraft is registered, the owner then informs the manufacturer to apply for airworthiness certification

Aircraft RegistrationSubmit Application to Local FAA Office

FAA Decision

Airworthiness Certification Process

Standard Airworthiness Certificate Special Airworthiness Certificate

Normal Utility Acrobatic Commuter Transport Manned free balloons Special classes

Primary Restricted

– Agricultural – Forest and wildlife conservation – Aerial surveying – Patrolling (pipelines, power lines) – Weather control – Aerial advertising – Other operations specified by the

Administrator Multiple Limited Light-Sport Experimental Special flight permit Provisional

Identify Type of Airworthiness

Certificate Needed

Local FAA Field Offices

Aircraft Certification Offices (ACO) Flight Standards District Offices

(FSDO) Manufacturing Inspection District

Offices (MIDO) - FAA Aviation Safety Inspectors

Manufacturing Inspection Office (MIO)



Depending on the classification aircraft owners need to get different airworthiness certifications

Airworthiness Certification Regulations and Policies Issuer

Standard Airworthiness Certification

Regulations– Airworthiness Directives Listing– 14 CFR Part 21 Section 21.17, Part

21, subpart H, Part 23, Part 25, Part 27, Part 29, Part 31, Part 39,Part 43, Appendix D, Part 45 subpart C, Part 47, Part 91

Orders 8130.2 Advisory Circulars 21-12, 45-2

FAA Aviation Safety Inspectors Representatives of the Administrator

(i.e. Designees)

Special Airworthiness Certification 14 CFR Part 21, Part 21 subpart H, Part 45 Section 91.313, Part 91 subpart D, Part 375

Orders 8130.2, 8300.10 Advisory Circulars 20-27, 20-139, 21-4, 21-12,

43.13-1, 45-2, 90-89


(i.e. Designees)

Export Airworthiness Approval 14 CFR Subpart L Orders 8130.2, 8130.21F Advisory Circulars 21-2


(i.e. Designees)

Major Airworthiness Certification Approvals



There are three major regulatory requirements in China for applicant to comply with towards successful certification

CCAR 49 PRC Aircraft Ownership Registration

中华人民共和国民用航空器权利登记条例

Whether an aircraft is owned, operated, or leased, the owner, operator or leaser needs to compile with this regulation in order to register an aircraft

Forms and materials required are included in this document

The FAA has included this part of the regulation in the Aircraft Registration Application - there is no separate regulation regarding this in FAR

CCAR 45 PRC Aircraft Nationality Registration

中华人民共和国民用航空器国籍登记规定

This regulation has listed requirements for aircraft owners or operators when registering their aircraft


This regulation in principle is similar to FAR 47, however, it also includes identification and registration marking related issues

CCAR 285 Non-Commercial GA Registration Administration

非经营性通用航空登记管理规定

This rule is applied to anyone who wish to use GA aircraft for non-commercial purpose

The applicant must obtain aircraft registration certificate and airworthiness certificate beforehand


FAA does not have equivalent of this rule

Three Major Regulatory Requirements for Aircraft Registration

Source: CAAC

Aircraft Registration and Airworthiness Certification


In each aircraft registration step, the applicant is required to submit relevant documents

Acquire Credentials




Submit Application


Aircraft Certification Obtained

Re-apply if documents are not comply with requirement

Typical Aircraft Registration ProcessIndividual Purchase

Purchasing purpose ID document Police record Feasibility study Pilot license Intent Contract with base airport

Documents Required for RegistrationIndividual Purchase

Aircraft nationality registration application

ID document Purchase/lease approval document Purchase/lease contract

ID document Purchase/lease approval document Purchase/lease contract Logo and registration marking application

Aircraft nationality registration application Proof of aircraft ownership ID document Evidence of the aircraft not registered elsewhere Other documents required


CAAC PRACTICE


Compare to the FAA, the CAAC aircraft registration process is more complex and restrictive for applicants

Eligibility of Registration

Submit Aircraft Registration Application

Aircraft Registration Branch Process the Application

Aircraft Registered

May need to redo if a form is not filled in properly

Typical Aircraft Registration ProcessFAA

Acquire Credentials




Submit Application


Aircraft Registered

Typical Aircraft Registration ProcessCAAC

No Documents Required

Only need to comply with the law, no need to filing any documents

Key forms included Evidence of

ownership Identity number Registration marking

Documents Required

Purchasing purpose ID document Police record Feasibility study Pilot license Intent Contract with

base airport

All included in one package Registration application

Evidence of ownership Applicant ID document Evidence of the aircraft

not registered elsewhere

Other documents required

Aircraft Certification Obtained Applicant to fill in “Non-

Commercial GA Registration Administration”Source: FAA, CAAC, industry interview, Booz & Company analysis



This is similar for airworthiness certification

Airworthiness Certification ProcessImported Aircraft




30 days before aircraft delivery, the applicant need to hand in the aircraft delivery plan and technical terms in the contract

Aircraft delivered must comply with CAAC Type Design and is qualified for safe operation

Airworthiness Certification application Difference description of aircraft structures compare to

TC or VTC Other documents required


Apply for Temp Certificate (Special Permit) for Testing Flight

Special permit application Suggested limitations Manufacturer’s “Manufacturer Accordance” (if any) Aircraft technical evaluation


Documents Required for Airworthiness CertificationImported Aircraft

Special Permit

对于尚未取得有效适航证或目前可能不符合有关适航要求，但在一定限制条件下能安全飞行的航空器可申请特许飞行证

申请特许飞行证的航空器应满足 CCAR-45 的要求 , 尚未取得国籍登记的航空器应当首先申请临时登记标志并获得临时登记证书

民用航空器的所有人或占有人可以申请该航空器的特许飞行证


CAAC PRACTICE


Compared with FAA, the CAAC airworthiness certification process is more difficult to comply





Apply for Temp Certificate for Testing Flight


Typical Airworthiness Certification ProcessFAA (Local-made Aircraft)

Typical Airworthiness Certification ProcessCAAC (Imported Aircraft)

Contact FAA Local Office for Direct Guidance on Airworthiness Certification

FAA Safety Inspectors Assists the Applicant in Conducting Aircraft Inspection


Local Manufacturing Inspection District Office Process the Application


One form required Aircraft Designation Certification Type Owner’s Certification Inspection Agency Verification FAA Representative Certification Production Flight Testing

All included in one package

CAAC has different sequence in this process compare to the FAA

Application content required here is somewhat similar to the FAA - however in different forms

Not directly comparable




We have identified the following issues in aircraft registration processes that can be improved

Duplication

Ambiguity

Inconsistency

Some of the documents required are duplicative and should be simplified if possible

E.g. Some of the clauses under Aircraft Purchase Application and Non-Commercial GA Registration Administration are the same

There are requirements in several regulatory document stating “other documents required” which are not clear to the applicant in terms of what exactly is needed to complete the certification process

Minor contradiction exists for Ultralight Aircraft– For example, in CCAR 91, it is not required for this

category aircraft to go through aircraft certification process - however, it is treated the same as all other categories in CCAR 285

Some of the economic regulations does not agree with each other– For example, in CCAR 45 and 49, nowhere it said

that the owner of the aircraft needs to be a pilot in order to register its aircraft, however, CCAR 285 requires it

Issues Identified from CAAC Regulation and Requirements

Adverse Impact on Buyers

To prospective private aircraft owners, these requirements can slow down the application process significantly

Most of these buyers only want to experience flying, however, the complex administrative packages and processes have become a burden and stopped willingness to buy

Summary


1

2

3


For example some of the requirements related to aircraft registration are duplicative

Purchasing purpose ID document Police record Feasibility study

– Intention to use the aircraft, funding capability, declaration of compliance with law

Pilot license or intention to hire a pilot Intent contract with airport

Aircraft Purchase Credential ProofsAdministrative Requirement

Chapter 2 Nationality Registration– Rule 10 …the applicant must provide

the following document to the CAAC

Aircraft Nationality RegistrationCCAR 45-R1

1) Applicant’s identity approval document

2) …

3) …

4) Other documents that may required by the CAAC

Signed application ID document Living address Personal CV and police record Activity purpose and source of funding

and insurance documents (copy) Aircraft registration certificate,

airworthiness certificate and radio license

Pilot license or intention to hire a pilot Intent contract with airport Aircraft management company contract,

activity scale and length of time and other necessary proceedings

Non-Commercial GA Registration Administration

CCAR 285

Documents Required for Aircraft Registration

The wordings highlighted are duplicative and should be

eliminated


Summary 1


Documents submission requirements for aircraft certification process are ambiguous





2) …

3) …


This is not very clear in informing exactly what is required from the applicant Many of these “other documents” are for administrative purpose which can slow down the certification process

significantly

Chapter 2 Registration Administration– Rule 8 The applicant must meet the

following requirement to register


CCAR 285

1) …has aircraft registration and airworthiness certification…

2) …

3) …

4) Other documents that are required by Law and Administrative Rules

Examples of Ambiguity in the Aircraft Certification Requirement


Summary 2


CCAR 285 requirements also create inconsistency with other aircraft registration regulations…





2) …

3) …


Chapter 2 Registration Administration– Rule 11 For individuals applicants, the

following document needs to be provided (3 copies of each)


CCAR 285

Examples of Incompliance in Economic Regulations



the following document to the CAAC in order to register


2) Purchasing/leasing contract

3) Proof of aircraft not registered elsewhere

4) Other documents required

1) …

…

8) …require pilot certificate…

9) …airport usage proposal…

Nowhere it said in CCAR 45 that “pilot certificate” and “airport usage proposal” are needed One might argue that the above are included in “Other documents required” in CCAR 45 - however, as rigorous

as regulations can be, the requirements should be listed clearly in the first place


Summary 3


… and general operating rules

Chapter O Ultralight Aircraft– Rule 91.1305 Certification and

Registration

General Operating and Flight RulesCCAR 91

a) …does not require aircraft registration or airworthiness certification…

b) …does not require pilot certificate or flying experience…

c) …does not require any identity marking…





2) …

3) …


Chapter 1 General– Rule 3 This registration applies to all

non-commercial activities conducted by either an organization or an individual


CCAR 285

Examples of Minor Contradictions in the Aircraft Certification Requirement

Ultralight aircraft as stated in CCAR 91 does not require any form of formal documentation to register or obtain any type of certificate, however, pilots who fly these type of aircraft still needs to register and comply with CCAR 285 and provide numerous documents (e.g. police documents, airport usage, source of funding etc) which appears to be unworthy for flying such type of aircraft

CAAC needs to check the possibility of exclude “ultralight” from CCAR 285 or further simplify the process

ULTRALIGHT AIRCRAFT


Summary 3


In summary, the GA industry lacks a structured guidance materials for prospective aircraft owners and operators

FAA Plane Sense CoverPublished by FAA Flight Standards Service

Hand Book for Potential Aircraft Owners

Plane Sense introduces aircraft owners and operators, or prospective aircraft owners and operators, to basic information about the requirements involved in acquiring, owning, operating, and maintaining a private aircraft

This handbook highlights regulations and regulatory guidance material, as well as providing advice regarding where to locate answers to possible questions

Though this hand book cannot cover every issue faced by aircraft owners and operators, it is intended to be a useful guide and will help potential aircraft buyers to locate the resources to assist the process

FAA EXAMPLE

Summary


Executive summary




certification

Appendix

Regulation and forms for

aircraft registration

Issues related to import and

export


Regulations related to Airworthiness (FAA)

Type 14 CFR Subchapter C Part

Certification Procedures 21/ Certification Procedures For Products and Parts

Airworthiness Standards 23/ Normal, Utility, Acrobatic, and Commuter Category Airplanes 27/ Normal Category Rotorcraft 31/ Manned Free Balloons 33/ Aircraft Engines 35/ Propellers

Noise Standards 36/ Aircraft Type and Airworthiness Certification

Airworthiness Directives 39/ Airworthiness Directives

Aircraft Registration 47/ Aircraft Registration

Others 34/ Fuel Venting And Exhaust Emission Requirements for Turbine Engine Powered Airplanes 43/ Maintenance, Preventive Maintenance, Rebuilding, and Alteration 45/ Identification and Registration Marking 49/ Recording of Aircraft Titles and Security Documents

General Aviation Related Airworthiness Regulations (FAA)

The 14 CFR Subchapter C - Aircraft (Part 21- 59) includes all regulations related to “Aircraft“ - all of these parts are airworthiness relatedSource: FAA


There is no major gap in aircraft certification related regulation between the FAA and the CAAC

Type CCAR Part # Compatibility to the US Part # (FAR) Certification Procedures CCAR 21-R3 21/ Certification Procedures For Products and Parts

Airworthiness Standards CCAR 23-R3 23/ Normal, Utility, Acrobatic, and Commuter Category Airplanes

CCAR 27-R1 27/ Normal Category Rotorcraft

CCAR 31 31/ Manned Free Balloons

CCAR 33 33/ Aircraft Engines

CCAR 35AA 35/ Propellers

CCAR 53 53/ 民用航空化学产品适航规定CCAR 55 55/ 民用航空油料适航规定

Noise Standards CCAR 36-R1 36/ Aircraft Type and Airworthiness Certification

Airworthiness Directives CCAR 39AA 39/ Airworthiness Directives

Aircraft Registration CCAR 45-R1 Aircraft Nationality Registration ( 民用航空器国籍登记规定 )

CCAR 49 49/ 中华人民共和国民用航空器权利登记条例实施办法 47/ Aircraft Registration

Others CCAR 34 34/ Fuel Venting and Exhaust Emission Requirements for Turbine Engine Powered Airplanes

CCAR 43 43/ Maintenance, Preventive Maintenance, Rebuilding, and Alteration

45/ Identification and Registration Marking

CCAR 285 285/ 非经营性通用航空登记管理规定

General Aviation Related Airworthiness Regulations (CAAC)

Source: FAA CCAR currently doesn’t have compare to the FAR CCAR has but FAR hasn’t

Overview


FAA requires the submission of a series of Aircraft Registration Forms

Form Title

8050-1 Aircraft Registration Application

8050-88 Affidavit of Ownership

8050-88A Affidavit of Ownership for Light-Sport Aircraft

8050-98 Aircraft Security Agreement

8050-2 Bill of Sale

8050-4 Certificate of Repossession

8050-5 Dealer's Application

AFS-750-93 Information in Recording of Aircraft Ownership and Security Documents

AFS-750-124E

Information to Aid in the Cancellation for Export of United States Registered Aircraft

AFS-750-124I Information to Aid in the Registration of Imported Aircraft

AFS-750-94 Information to Aid in the Registration of U.S. Civil Aircraft

8050-135 International Registry Entry Form

8050-88A Light-Sport Aircraft Manufacturer‘s Affidavit

AFS-750-55 List of Title Search Companies

Aircraft Owner Change of Address Notification Form

HEIR-AT-LAW

Declaration of International Operations Form

Limited Liability Company Registration Information Sheet

Aircraft Registration Forms

All applications must be mailed to FAA Aircraft Registration Branch in Oklahoma City

The application is centrally processed and approved for 12-16 days



FAA requires the submission of a series of Airworthiness Certification Forms for processing

Type Form Title

Standard 8130-6 Application for U.S. Airworthiness Certificate

8130-9 Statement of Conformity

Special 8130-6 Application for U.S. Airworthiness

8130-12 Eligibility Statement, Amateur-Built Aircraft

8130-15 Light-Sport Aircraft Statement of Compliance

Export 8130-1 Application for Export Certificate of Airworthiness

8130-3 Authorized Release Certificate

8130-4 Export Certificate of Airworthiness

8130-9 Statement of Conformity

Aircraft Certification Forms

Applications can be dealt with relevant local FAA field offices



Aircraft certification and registration processes are managed by various FAA offices

Aircraft Registration Branch

Aircraft Certification Offices (ACO)

Flight Standards District Offices

(FSDO)

Manufacturing Inspection District

Offices (MIDO)

Manufacturing Inspection Office

(MIO)

Roles Receive and process the aircraft registration application located in Oklahoma City

Answer aircraft registration enquires

Provide registration related information

FAA Safety Engineers

Design approvals and certificate management

U.S. production approvals

Engineering and analyses questions

Investigating and reporting aircraft accidents, incidents, and service difficulties

Designated Engineering Representatives (DER) oversight

Airmen certification (licensing), to include pilots, mechanics, I.A.s, repairmen, dispatchers, and parachute riggers

Aircraft permits and other certification issues

Air carrier certification and operations

Accident investigations

Enforcement and investigation issues

FAA Aviation Safety Inspectors

Manufacturing and production certification

Airworthiness certification

Manufacturing facilities approval holder issues

Manufacturing Designated Airworthiness Representatives (DAR-F) oversight

Oversight of Manufacturing Inspection District Offices (MIDO)

Management of geographically located production facilities and designees

FAA Aircraft Certification Local Offices

Source: FAA


Executive summary




certification

Appendix

Regulation and forms for

aircraft registration

Issues related to import

and export


Both import and export aircraft registration cases are handled with high priority

Export (Deregistration)

A complete description of the aircraft, including manufacturer name, model designation, serial number and registration number

The reason for cancellation (export to foreign country)

The name of the country to which the aircraft is being exported

The signature and appropriate title of requester A release, or consent to export for all outstanding

security instruments and unexpired leases with a term of six months or more that were executed on or before February 28, 2006

The resolution of outstanding interests in the aircraft executed on or after March 1, 2006

Import Documents Required

A statement by the official having jurisdiction over the National Aircraft Registry of the foreign country of export indicating that registration has ended or that the aircraft was never registered

Evidence of ownership, such as a Bill of Sale, signed in ink, from the foreign seller to the U. S. applicant/owner

A completed Aircraft Registration Application, AC Form 8050-1

A check or money order made payable to the Federal Aviation Administration in the amount of $5 (U.S. funds)

Both Import and Export Cases are treated with

High Priority



FAA can issue airworthiness approvals for import and export only if the country of manufacture has bilateral agreement with the US

Export Airworthiness Approval

Prior to issuance of an export airworthiness approval, a determination is made that these items conform to their FAA-approved design, are in a condition for safe operation, and meet all special requirements established by the importing country's Civil Aviation Authority

The exporting manufacturer or individuals must follow the Export Airworthiness Approval Procedures and guidance for special requirements for importing countries (these can be found in Advisory Circular 21-2

Import Airworthiness Approval

Import an aircraft, aircraft engine, or propeller The owner of the aircraft needs an export airworthiness

approval (or equivalent certifying statement) from the Civil Aviation Authority (CAA) of the country of manufacture

This export airworthiness approval from the country of manufacture certifies that:– the product conforms to its U.S. type certificate– is in a condition for safe operation– and has been subjected to a final operational check by

the manufacturerImport accompany materials, parts or appliances The owner of the aircraft needs an export airworthiness

approval from the Civil Aviation Authority (CAA) of the country of manufacture for materials, parts and appliances

The export airworthiness approval certifies that the applicable requirements have been met and the materials, parts and appliances are eligible for installation on a product for which the U.S. has issued a design approval


Booz & Company

Documents

Transcript of Booz & Company