James W. Gregory

Introduction to Flight Testing


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compliance with safety standards.

      In the United States, the regulatory authority for the FAA to certify the airworthiness of light aircraft is Title 14 of the Code of Federal Regulations (“Aeronautics and Space”), Chapter I (“Federal Aviation Administration, Department of Transportation”), Subchapter C (“Aircraft”), Part 23 (“Airworthiness Standards: Normal Category Airplanes”) – we'll refer to this as 14 CFR §23 or simply part 23 (U.S. Code of Federal Regulations 2021). Part 23 covers the certification standards for general aviation aircraft, which have a maximum takeoff weight of 19,000 lb or less and carry 19 or fewer passengers. Since the scope of this book focuses on light aircraft, Part 23 is most relevant for our purposes. The subpart that is most relevant for flight testing is Subpart B (14 CFR §23.2100 through §23.2165), which defines the requirements for flight testing of aircraft for airworthiness certification.

      Source: Based on FAA (2011).

Airplane certification levels Airplane performance levels
Level 1 Maximum seating configuration of 0–1 passengers Low speed Airplanes with a VNO and VMO ≤ 250 KCAS (and MMO ≤ 0.6)
Level 2 Maximum seating configuration of 2–6 passengers
Level 3 Maximum seating configuration of 7–9 passengers High speed Airplanes with a VNO or VMO > 250 KCAS (and MMO > 0.6)
Level 4 Maximum seating configuration of 10–19 passengers

      VNO = maximum structural cruising speed, VMO = maximum operating limit speed, MMO = maximum operating Mach number, and KCAS represents the units for knots calibrated airspeed.

      While the regulatory framework and overall safety criteria are defined in Part 23, the regulations are intentionally sparse on details on how to actually demonstrate compliance for certification. Instead, means of compliance (§23.2010) can be determined by the applicant, subject to approval by the FAA. Typically, the means of compliance is established by a consensus standard. A type certificate applicant for a new light aircraft could demonstrate compliance with a consensus‐based industry standard, which has been approved by the FAA. This compliance mechanism is a dynamic and flexible approach (compared to explicitly defining the compliance mechanisms in part 23), since consensus‐forming bodies can quickly respond to new technologies and develop consensus standards. One key example of such a body is ASTM International. The ASTM convenes a number of committees, which are populated by representatives from various industry groups, and also includes government (FAA) representatives. The key ASTM committee that covers certification standards for light aircraft is the F44 committee on General Aviation Aircraft and specifically the F44.20 subcommittee on Flight. At the time of writing this book, ASTM F44.20 had published standard specifications for flight test demonstration of aircraft weight and center of gravity, operating limitations, aircraft handling characteristics, performance, and low‐speed flight characteristics (ASTM 2017, 2018a, 2018b, 2019a, 2019b). Historical guidance from the FAA is also available for means of compliance with 14 CFR part 23 through nonregulatory advisory circulars (FAA 2003, 2011).

      It's important to also be familiar with the historical approaches to airworthiness certification, since there are many aircraft flying today that were certified under older versions of the regulations. Predating certification of general aviation aircraft under part 23, certification was granted under the Civil Air Regulations (from the late 1930s until 1965). Kimberlin (2003, chapter 1) provides a good synopsis of these older regulations and how antique aircraft are still flying under airworthiness certificates granted under the older regulations.

      For decades, certification of light general aviation aircraft followed regimented flight testing protocols that were explicitly defined in part 23. Over the years, the part grew more complex as additional safety measures and compliance protocols were codified. The resulting regulation was a rigid document that could not easily accommodate new technologies. For example, part 23 was strictly written to document how a type applicant must demonstrate the performance of internal combustion engines and the associated fuel system. This strict delineation of a compliance pathway was fine when all general aviation aircraft were powered by internal combustion engines running off Avgas. However, there are new propulsion system concepts emerging such as electric motors driven by fuel cells, batteries, or hybrid battery‐generator systems, but these could not be certified under the former regimented structure of part 23. Type certificate applicants would have had to demonstrate an equivalent level of safety and obtain waivers, but there was no established and agreed‐upon process for doing so. Thus, certification of new technologies such as electric propulsion would have been costly, with an uncertain outcome.