Honda Aircraft Company received from the FAA a provisional type certificate (PTC) for its HondaJet. The company called the action a “tremendous milestone”. What is the significance of this FAA decision and why is Honda Aircraft’s reaction so different than Amazon’s?
What is a PTC? The Federal Aviation Regulations require that the applicant for an as-of-yet unissued full type certificate may be entitled to a provisional TC if (14 CFR Subpart C):
(c) The applicant must certify that—
(1) The aircraft has been designed and constructed in accordance with the airworthiness requirements applicable to the issue of the type or supplemental type certificate applied for;
(2) The aircraft substantially meets the applicable flight characteristic requirements for the type or supplemental type certificate applied for; and
(3) The aircraft can be operated safely under the appropriate operating limitations specified in paragraph (a) of this section.
(d) The applicant must submit a report showing that the aircraft had been flown in all maneuvers necessary to show compliance with the flight requirements for the issue of the type or supplemental type certificate applied for, and to establish that the aircraft can be operated safely in accordance with the limitations contained in this subchapter.
(e) The applicant must establish all limitations required for the issue of the type or supplemental type certificate applied for, including limitations on weights, speeds, flight maneuvers, loading, and operation of controls and equipment unless, for each limitation not so established, appropriate operating restrictions are established for the aircraft.
(f) The applicant must establish an inspection and maintenance program for the continued airworthiness of the aircraft.
(g) The applicant must show that a prototype aircraft has been flown for at least 50 hours under an experimental certificate issued under §§21.191 through 21.195, or under the auspices of an Armed Force of the United States. However, in the case of an amendment to a provisional type certificate, the FAA may reduce the number of required flight hours.
By accepting the applicant’s certificate and reports, the FAA considers the status of the company’s proof of airworthiness to be close to final approval. As the Manager of the Atlanta Aircraft Certification Office (man with a pen in hand in above picture) Melvin Taylor said:
“It is a pleasure for the Atlanta ACO to issue Honda Aircraft Company a provisional type certificate for the Model HA-420. It is a milestone event for a first time aircraft manufacturer to receive its first type certificate. This issuance speaks well to the hard work put forward by all the Honda and FAA staff working in a collaborative manner. The Atlanta ACO takes pride in being part of Honda’s introduction of such an advanced and uniquely designed aircraft to the aviation market. We look forward to continuing our collaboration with Honda as we move to final completion of their HA-420 approval.”
The FARs (14 CFR §91.317(d) ) lists what the holder of a PTC may do once this authority is issued:
(1) In direct conjunction with the type or supplemental type certification of that aircraft;
(2) For training flight crews, including simulated air carrier operations;
(3) Demonstration flight by the manufacturer for prospective purchasers;
(4) Market surveys by the manufacturer;
(5) Flight checking of instruments, accessories, and equipment that do not affect the basic airworthiness of the aircraft; or
(6) Service testing of the aircraft.
These privileges are permitted after the TC applicant defines limitations on the flights as required by 14 CFR§91.317(e). Honda now can put prospective purchasers to fly, can take the new product to show it around the country and continuing testing.
The President and CEO of Honda Aircraft, Michimasa Fujino, gushed about the FAA’s issuance of the PTC:
“Provisional type certification for the HondaJet is a tremendous milestone for the program, and we are pleased to reach this significant step toward customer deliveries and entry into service,… Honda Aircraft has completed nearly all of the testing and reports required by the FAA, and we are very close to achieving final type certification for the world’s most advanced light jet.’
Amazon was not as happy when it received a similar authority from the FAA. Its Logistics Company was established as a separate organization to develop a sUAS delivery system to distribute its inventories to customers within minutes of orders. The FAA, seemingly on its own action, issued an Experimental Aircraft Certificate (very similar to the PTC) to the Washington entrepreneur. Paul Misener, VP for global public policy at Amazon, testified as follows at a House Hearing:
“The good news is that, while the FAA was considering our applications for testing, we innovated so rapidly that the UAS approved last week by the FAA has become obsolete. We don’t test it anymore. We’ve moved on to more advanced designs that we already are testing abroad.”
Why the difference in reactions? Honda Aircraft has a future in the design and approval of aircraft. It has learned the integrity and value of the FAA’s certification of aircraft for safety.
Amazon’s core business is not the manufacturing of aircraft; similarly, the Seattle organization is not in the business of designing trucks to deliver its products. The sUAS aspect is being pursued internally because the company believes that it has and wants to maintain a significant advantage in distribution. Time is of the essence to Amazon and thus it has little tolerance for anything less than warp speed by the FAA. It did not bother to tell the FAA that its current sUAS was different than what was included in its papers. The EAC could be a useful tool for gaining certification for its future UAS certificate.
By ignoring the FAA’s EAC and charging off on its own testing program in Canada, it is possible that Amazon will be adding time before its drones will be able to fly in the United States. Flight testing without the FAA’s being able to review the proving efforts will make whatever “data” suspect when brought to the FAA. By taking their planes elsewhere, Amazon is probably ignoring the data requirements and reports which the FAA regulations, Advisory Circulars and intermittent requests usually develop during the regulator-regulated dialogue.
Honda Aircraft will likely receive its Final Type Certificate soon; Amazon not so fast.
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