A horizontal comparison of EASA’ VTOL special conditions vs. FAA’s silence

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EASA VTOL Special Conditions for Type Certification

Vertical Take Off and Landing aircraft 

European Aviation Authority 1st with standard for this Urban Mobility air vehicle

 

 

 

 

 

 

On July 2, the European Aviation Safety Agency (EASA) published a 31-page document: “SPECIAL CONDITION Vertical Take-Off and Landing (VTOL) Aircraft”, which follows a proposed Special Condition (SC) published in October 2018. Several points can be made from these two documents.

First: The final SC definition of a “small-category VTOL” differs significantly from the 2018 proposal by nearly doubling the passenger capacity from 5 to 9, and increasing the certified take-off mass of 2000 kg or less to 3175 kg or less.

(Proposed) VTOL.2005 Certification of small-category VTOL aircraft

Certification with this small category Special Condition applies to an aircraft with a passenger seating configuration of 5 or less and a maximum certified take-off mass of 2000 kg or less.

(Final) VTOL.2005 Certification of small-category VTOL aircraft

Certification with this small category Special Condition applies to an aircraft with a passenger seating configuration of 9 or less and a maximum certified take-off mass of 3,175 kg (7000 lbs) or less.

►The reasoning is as follows:

“EASA has decided to set the scope of the VTOL Special Condition up to the CS-27 small rotorcraft limits, with a passenger seating configuration of 9 or less and a maximum certified take-off mass of 3,175 kg (7000 lbs) or less. This decision has been motivated by several comments received and provides the possibility to align with the CS-23 aeroplane certification levels 1 to 3 and potentially the future UAS Safety Continuum.”

 

 

 

 

 

Second: EASA beat the FAA to the starting line by publishing these Special Conditions as common standards for broad use, but the FAA appears to be negotiating certification criteria with individual applicants, which may lead to variability

From the final SC notice, “The establishment of a common set of conditions will enable a fair competition and clarity for future potential applicants. In addition, it will enable EASA to consider all vehicles with a Certification Basis based on the VTOL Special Condition as “Special Category” aircraft.”

Third: EASA issued a Press Release that declares, in part “The establishment of a common set of conditions for the certification of these new concepts of vehicles will enable a fair competition on the European market as well as clarity for future manufacturers and their investors.”

It is notable that the statement is very specific to fair competition in Europe.

 

 

 

 

 

Fourth: EASA has split VTOL certification into two certification categories, “Basic” and “Enhanced”, Category Enhanced is intended for protection of third parties when flying over congested areas and when conducting commercial air transport of passengers.

Some aspects of the Special Conditions are very interesting to those of us who are engaged in VTOL certification:

Although the word “hybrid” does not appear in the Special Conditions, the document does envision auxiliary power units (APU), which are typically used to generate power, and the word “fuels” is used as well, which clearly implies hybrid systems.

From the final document, “The special condition is intended to be compatible with a remote piloting capability or different levels of autonomy, however these aspects are not currently addressed by this special condition. Flight crew references will be considered “as applicable” when material for remote piloting and autonomy is added.”

 

 

 

 

Although it appears most commercial VTOL aircraft will be piloted for a variety of reasons, these Special Conditions are obviously looking strategically to the future because autonomy is inherent in nearly all VTOL industry strategies.

It’s interesting to note, from the introductory section, “ . . . EASA developed this VTOL Special Condition extensively based on CS-23 Amendment 5, which is also largely harmonised with the FAAs Part 23, integrating elements of CS-27 and new elements where deemed appropriate.”, which offers some hope that these EASA Special Conditions can be proposed to the FAA with a possibility of success.

Conclusion:

It appears EASA has recognized that the regulatory role is critical to VTOL global competitiveness, and it has stepped up to provide a framework for European VTOL manufacturers to market their aircraft anywhere in the world as fully certificated products. This is critical for a new industry, because the “Gold Standard” for type certification may be considered EITHER FAA or EASA regulations. If a forward-leaning VTOL potential client such as Dubai or Singapore is considering selecting between two competitors from either Europe or the United States, and one offers a fully Type Certificated product but the other is “in work”, which way is the selection likely to go? “First to market” in this case may lead to global dominance.

Further, the professional look and feel of the EASA Press Release informs us that they have a sophisticated public relations organization.

From the certification and safety perspective, the Special Conditions also appear to be well developed and thorough.

As for the FAA:

Was the FAA caught flat-footed by this Press Release?

We must ask, will the FAA embrace these Special Conditions or at least accept them in an applicant’s proposed certification plan?

Will the FAA step up and release something similar for all industry to use as a common certification standard? If so, WHEN?

Does EASA have a better public relations strategy?

EASA Press release: https://www.easa.europa.eu/newsroom-and-events/press-releases/first-building-block-enable-safe-vtol-operation-and-new-air

 

 

 

 

 

 

 



 

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1 Comment on "A horizontal comparison of EASA’ VTOL special conditions vs. FAA’s silence"

  1. Mike,

    The FAA is moving forward in certification of E-VTOL in a manner the industry has requested. We do not want to certify these aircraft under special conditions because of the problems we will encounter with operational rules. Please contact my head of certification Lowell Foster lfoster@gama.aero to understand where Industry is on this issue. Pete Bunce, President and CEO GAMA

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