Backcountry Pilot • Could your airplane be a Primary-Non Commercial (PNC)

Could your airplane be a Primary-Non Commercial (PNC)

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Could your airplane be a Primary-Non Commercial (PNC)

This has been discussed before but here is a new article on the potential new category. PNC could breath a lot of new life into GA and old airplanes. [-o<

http://macsblog.com/2014/03/could-your- ... -be-a-pnc/
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Re: Could your airplane be a Primary-Non Commercial (PNC)

I like the sound of this….
Thanks for posting.

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Re: Could your airplane be a Primary-Non Commercial (PNC)

between this and the medical bill there may, repeat, may be a GA future.
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Re: Could your airplane be a Primary-Non Commercial (PNC)

I would definitely love to see this come to pass
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Re: Could your airplane be a Primary-Non Commercial (PNC)

Kinda like our "owner maintenance category" up here. Kinda.
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Re: Could your airplane be a Primary-Non Commercial (PNC)

Below is a section of the proposed rule making from the FAA work group.

Here is a link to the whole thing, http://www.faa.gov/regulations_policies ... Report.pdf



3.3.5 Primary Non‐Commercial Category
Background
The 14 CFR Part 23 Reorganization ARC was tasked with doubling aircraft safety while reducing certification costs by half. Currently, there are almost 200,000 General Aviation aircraft registered in the United States; however, production of new aircraft averages less than 1 percent of this per year. Consequently, it may be decades before this ARC’s improvements for new aircraft design will yield any measurable safety improvements or cost reductions for the General Aviation Fleet as a whole.
One way to realize the safety and cost goals is by leveraging the concepts this ARC developed for use in new aircraft certification in a manner that would have an immediately felt positive safety effect on the existing General Aviation fleet.
~ 39 ~
This section will summarize the ARC’s recommendation to implement a Primary Non‐Commercial Category (See Appendix G for complete paper) that is similar to the Canadian Owner Maintenance Category, but with some significant safety enhancements to address some concerns with that program. This recommendation is bold, but reflects the challenge posed to industry at the FAA’s ARC kick‐off meeting. At that meeting, the FAA challenged the ARC members to be bold, creative, and non‐ traditional.
The Primary Non‐Commercial Category is intended for the private owner to operate their aircraft in a substantially less burdensome and costly manner by reducing the level of FAA maintenance and alteration requirements to a level appropriate for a privately owned vehicle.
This proposal has two precedents that support the concept. First, this class follows international precedent by leveraging the concepts of the Canadian Owner Maintenance Category, which has a proven safety record over the last decade. For more information on the Canadian system requirements and safety results experience see the complete recommendation in Appendix G. Secondly, this concept uses the maintenance training principles of the highly successful LSA program that has a proven safety record. Incorporation of this new category will offer the FAA a rare opportunity for implementation of sound safety continuum principles paired with international harmonization.
In addition, by allowing a practical and workable path to return Non‐Commercial aircraft to Standard Category through dual airworthiness certificates, owners will have a large financial incentive to keep their aircraft near type design to avoid devaluing their aircraft. This is a significant safety advantage over the Canadian system where it is nearly impossible to return to Standard Category; therefore, affording no incentive for owners to keep aircraft compliant to safety proven type design.
Finally, the principles set forth in the “Primary Non‐Commercial Category” proposal exclusively leverage existing US regulations with proven safety records. The recommendation simply takes successful existing regulatory practices and combines them into the new Primary Non Commercial Category. For example, maintenance training and certification comes from LSA, airworthiness certification comes from dual certificated Standard/Restricted Category aircraft and Non‐Commercial use from Experimental Aircraft. There is nothing new or novel proposed, except for the potential for safety and cost improvements that would be available for users of the Primary Non Commercial class.
3.3.5.1 Primary Non‐Commercial Category Recommendation
Applicability
The owner of a fixed wing, non‐ turbine powered part 23 aircraft or part 23 glider, 20 years or older, may elect to redesignate their aircraft as a Primary Non‐Commercial.
Privileges
1. Aircraft in this category can be maintained by the owner with a repairperson’s certificate, similar to currently established procedures for LSA aircraft repairpersons.
~ 40 ~
2. Replacement or alteration parts should be appropriate for aircraft use; however, such parts need not be PMA/TSO authorized.
3. Owners can alter their own aircraft without the requirement for FAA approved data; however, some alterations may require “phase 1” flight testing similar to Experimental Amateur Built (EAB) requirements.
Limitations
1. Primary Non‐Commercial Category Aircraft are required to observe the FAA Approved Aircraft Flight Manual Operational Limitations and/or required placard limitations established for the Standard Category.
2. Aircraft cannot be used to carry persons for hire, this includes aircraft rental, but allows an owner to receive flight instruction in their own aircraft.
3. Airworthiness Directives are only applicable as currently allowed for EAB.
4. Aircraft owners must maintain a list in the aircraft logbook of all applicable ADs and their compliance status. This list will be used to highlight the owners’ awareness of the ADs existence and document their choice of compliance. This list will also be used to facilitate the conversion of the aircraft back to normal category.
5. Aircraft owners must maintain a list in the aircraft logbook of all alterations performed that are not FAA approved and all non PMA/TSO parts installed. This list will be used to facilitate the aircraft conversion back to normal category.
6. Incomplete or fraudulent maintenance logbook entries result in the revocation of the aircraft’s standard airworthiness certificate.
Requirements
1. Before original conversion, the aircraft must have a current annual inspection – all applicable ADs must be complied with at the current annual inspection.
2. Airplane owners must either add the prefix of “NC” to the aircraft registration number or affix a “Non‐Commercial” placard readily visible to all passengers.
3. The aircraft must have a yearly condition inspection by an A&P mechanic certifying that the aircraft is “in condition for safe operation.”
4. Upon transfer of aircraft ownership, the Non‐Commercial Airworthiness Certificate must be reissued in the new owner’s name.
~ 41 ~
Conversion Back to Normal Category
1. Aircraft operated in the Non‐Commercial type certification class would be dual certificated in both the Normal and Non‐Commercial categories, as is commonplace for Restricted Category aircraft.
2. Aircraft in the Non‐Commercial TC category can be operated in the Standard Category, provided the aircraft meets it type design data including compliance with all ADs, removal of all Non‐ PMA/TSO parts and replacement with certified units and the removal of all non‐certified alterations.
3. The conversion can be accomplished by an Inspection Authority (IA) mechanic with a complete and thorough annual inspection and logbook audit. Upon successful completion, the aircraft could be operated under its Standard Airworthiness Certificate. The procedure is very common with Restricted Category aircraft and proven to be safe and successful.
Regulation and Order Changes
The following regulations would need to be revised to accommodate the Primary Non‐Commercial Category.
1. New Regulation § 21.24 establishing the Primary Non‐Commercial Category
2. Revised Regulation § 21.184 issue of airworthiness certificates for primary category aircraft and primary (non‐commercial) aircraft
3. New Regulation § 91.328 Operating Limitations for Primary Non‐Commercial Aircraft
4. Revised Regulation § 45.22 for markings on Primary Non‐Commercial Aircraft
5. New Regulation § 65.108 establishing Primary Non‐Commercial Repairmen Certificates
6. Revised FAA Order 8130.2 Airworthiness Inspector’s Handbook
7. New Order 800‐ANC‐ARC defining required training for Primary Non‐Commercial Repairman Courses and Evaluation
3.3.5.2 Conclusion
The intent of the Primary Non‐Commercial Category is to reduce the level of FAA maintenance and alteration requirements to a level more appropriate for a privately operated vehicle while simultaneously improving safety and reducing owner costs.
This recommendation follows the international precedent of the Canadian Owner maintenance class. Analysis of a decade of Transport Canada data indicates that this class has been fully successful in maintaining (and in some cases enhancing) the safety of the Canadian GA fleet. It is reasonable to conclude that similar US Primary Non‐Commercial Category would have safety results equivalent to the
~ 42 ~
Canadian success. Thus, incorporation of this new category will offer the FAA a rare opportunity for international harmonization by the application of sound safety continuum principles.
It is important to note that there is absolutely nothing new or novel in this recommendation – the “Primary Non Commercial Category” consists exclusively of regulations and procedures used to certify and operate other categories of aircraft. These “borrowed” regulations are simply recombined in a way that preserves the individual safety checks in a streamlined manner that is substantially less burdensome for a private owner.
In order for general aviation to remain viable in the United States, it is essential that a way be found to both lower costs and improve safety. The Primary Non‐Commercial Category offers the FAA a chance to accomplish both goals, using existing regulatory language, while decreasing oversight requirements and expenditures.
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Re: Could your airplane be a Primary-Non Commercial (PNC)

Wow.

I don't think I've ever been as excited about a potential rule change as I am right now. Who do I call/write/telegraph in the FAA to help push this along?

The comments section of the link in the first post are very interesting, and one of the posters was a member of the ARC.

Being able to install a G3X or Dynon would be a HUGE game changer for many in the GA fleet. Unfortunately, my expectations are that this makes far too much sense for it to be taken seriously by the FAA.
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Re: Could your airplane be a Primary-Non Commercial (PNC)

If that goes through hopefully Canada follows suit. Our owner maintained category is similar but only allows 4 seat aircraft up to 200HP, and fixed pitch props only, no constant speed props. And we also can't fly into the US if thebplanes are in that category. If the FAA pushes this through, maybe Canada will follow suit and TC and the FAA can get together and allow border crossings...
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Re: Could your airplane be a Primary-Non Commercial (PNC)

Wow! That would open up a lot of possibilities for me and our 205!
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Re: Could your airplane be a Primary-Non Commercial (PNC)

I could get some bushwheels!!! haha jk! But I would get some legit avionics for a lot less money. It's amazing how many things you could do when you start thinking about this. I am working to get an extended baggage in the Mooney that's been approved before, but with this I could just do it. Which, really doesn't require much of a change!
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Re: Could your airplane be a Primary-Non Commercial (PNC)

piperpainter wrote:I could get some bushwheels!!! haha jk! But I would get some legit avionics for a lot less money. It's amazing how many things you could do when you start thinking about this. I am working to get an extended baggage in the Mooney that's been approved before, but with this I could just do it. Which, really doesn't require much of a change!


Exactly what I'm thinking too!
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