• A modernization of Part 27 and 29 would allow for new and innovative products from all of rotorcraft OEMs to enter the marketplace, The rotorcraft industry needs a regulatory framework that can quickly adapt and respond to new technologies without the need to overhaul regulations every few years and without the need to resort to special conditions or exemptions.
• Passenger capacity, not weight, should define Part 27. Weight – which is no longer a direct indication of complexity – has created a product gap at the light end of Part 29. A mere change in weight without a change in passenger capacity generally doesn’t change the overall risk, so passenger capacity is a more accurate defining point from safety/risk standpoint.
• There are currently only 2 certification bases – normal and transport – but the variety and complexity of modern rotorcraft demands a better classification scheme.
• The current system encourages manufacturers to amend old type certificates instead of certifying new “clean sheet” models.
• Engine technology, structural materials, and electronic technology in particular are advancing so rapidly that in some cases current regulations may be impeding the introduction of better and safer products.
• Streamlining the regulations is of great benefit to all stakeholders – operators, regulators, and manufacturers. For operators, revisions would lower costs as new capabilities and safety features are incorporated into current and future aircraft. And for manufacturers, having clear, adaptable methods of compliance would drive more innovation and free them up to reinvest in new products more often.
Aztec Aviation Inc.
This is comment on Proposed Rule
Interest in Restructure of Rotorcraft Airworthiness Standards
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