FAA letter on flight into known icing

"Bill Zaleski" wrote in message
...
John: The original topic and the subject of this whole tread is/was
ice certification. Those certification rules, and the basis for
certification are contained within FAR 23. That is the whole subject
of this thread.

Non-sequitur.

Part 21 deals with PRODUCTION BASIS and has nothing
whatsoever to do with the criteria for determining whether an aircraft
has icing approval. You chose to go off on a tangent. The FSDO guy
is still correct.

The only part of the letter I corrected has to do with what section of CFR
14 an aircraft's type Certificate is issued under, where the FSDO guy is
wrong. The fact that you have now caught on to haw rediculess you have
been, is a good reason for you to wish to change the subject, but also
irrelevent.

On Wed, 17 Dec 2003 19:22:21 -0800, "Tarver Engineering"
wrote:


"Bill Zaleski" wrote in message
.. .
Sure, a newsgroup is a much better way to prove the point, instead of
FAR's and other documentation, which proves my position.

If we were to use CFR 14 Part 23 as a starting point, the title itself
gives
all but the most egtotistical a clue. Then, if we look for Type
Certificate, we will find it in Part 21.

Simple enough for you Bill, give those FARs a read.

Hi guys,

Let me jump into the middle of this with both feet, and hope to escape without
too many flames...

14 CFR part 21 contains the procedural rules for obtaining a type certificate
and approval for changes to a type certificate (i.e., a Supplemental Type
Certificate), and airworthiness requirements for "unique" kinds of aircraft.
An applicant who applies for a Type Certificate or Supplemental Type Certifcate
under this part, is granted approval under part 21 if the FAA finds that the
design or change to a design shows compliance to the applicable airworthiness
requirements.

The airworthiness requirements to which the design, or change to a design, must
show compliance may be in part 21 (for example, primary category aircraft or
foreign aircraft accepted under a bilateral airworthiness agreement), or in one
of the airworthiness standards such as part 23 for normal, utility, acrobatic,
and commuter category airplanes.

The Type Certificate Data Sheet for an aircraft shows the Certification Basis.
The Certification Basis is the set of airworthiness standards to which
compliance was shown. For example, U.S. manufactured normal and utility
category airplanes are certificated to airworthiness standards contained in
part 23 or its predecessor, CAR 3. Primary Category aircraft are certificated
to airworthiness requirements listed in part 21, so part 21 would be listed in
the Type Certificate Data Sheet. However, procedural rules of part 21 are not
shown in the Data Sheet.

So, in following this thread, my impression is that you're both right. The
design approvals are issued under part 21, and the airworthiness requirements
to which compliance must be shown are listed in the Type Certificate Data
Sheet.

Nothin' like muddying the waters....

Cheers,

Gordon.

"CivetOne" wrote in message
...
Hi guys,

Let me jump into the middle of this with both feet, and hope to escape
without
too many flames...

14 CFR part 21 contains the procedural rules for obtaining a type
certificate
and approval for changes to a type certificate

Yes.

(i.e., a Supplemental Type
Certificate),

No, that is Part 23 for under 12,500 lbs.

snip of rest without reading

Let me be fair to the FSDO guy and agree that the icing capability is
usually added after the Part 21 Type Certificate is issued. Therefore, if
you have anti-icing capability for your small airplane, it is probably a
Part 23 STC change.

14 CFR part 21 contains the procedural rules for obtaining a type
certificate
and approval for changes to a type certificate

Yes.

(i.e., a Supplemental Type
Certificate),

No, that is Part 23 for under 12,500 lbs.

snip of rest without reading

Let me be fair to the FSDO guy and agree that the icing capability is
usually added after the Part 21 Type Certificate is issued. Therefore, if
you have anti-icing capability for your small airplane, it is probably a
Part 23 STC change.

Please allow me to delve into administrative minutia for a second.

I agree that, in our example, anti-icing capability added to a small airplane
after manufacture is a change to the type design, and that the airworthiness
rules to which the anti-icing equipment must be certificated are in part 23.
In addition to the equipment, the Kinds of Operations (23.1525) would need to
be changed to include flight in icing conditions.

However, the procedural rules governing the approval of a Supplemental Type
Certificate are in part 21. Subpart D of part 21 talks about changes to a type
certificate, and subpart E deals specifically with Supplemental Type
Certificates. Subpart E defines the applicable airworthiness requirements for
the STC in a similar fashion to subpart B for type certificates. In our icing
example, the applicable airworthiness requirements would be contained in part
23.

So, my bottom line is that the procedural requirements for obtaining design
approval of either a new design or changes to an existing design are contained
in part 21. The design approval, either a TC or an STC, is issued in
accordance with the procedures in part 21. The airworthiness requirements to
which the design or design change must comply are contained in the
airworthiness standards (e.g., part 23 for small airplanes), or part 21 for
unique aircraft (e.g., primary category).

Like I said at the beginning, "administrative minutia."

Cheers,

Gordon.

"CivetOne" wrote in message
...

snip
So, my bottom line is that the procedural requirements for obtaining
design
approval of either a new design or changes to an existing design are
contained
in part 21.

For the aircraft's manufacturer.

The design approval, either a TC or an STC, is issued in
accordance with the procedures in part 21.

No, the procedures contained in Part 23 are intended to enable a third party
to receive STC Aproval, for a change to a small airplane. From the STC,
with a licensing agreement in place, the parts used to make that change can
get PMA aproval.

The airworthiness requirements to
which the design or design change must comply are contained in the
airworthiness standards (e.g., part 23 for small airplanes), or part 21
for
unique aircraft (e.g., primary category).

"Matthew S. Whiting" wrote in message
...

|
| You might be legal, but you'd also be a test pilot. They might throw
| the book at you for impersonating a test pilot ... unless, that is, you
| ARE a test pilot. :-)
|

What FAR spells out the requirements for certification of a test pilot?

"Steven P. McNicoll" wrote in message
ink.net...

"James L. Freeman" wrote in message
om...

Maybe not "illegal" with respect to a known icing FAR, but probably at
risk of a violation under the infamous 91.13 "careless and reckless"
FAR.


FAR 91.13 applies only if the life or property of another is endangered.

I guess if you're renting the plane, it does apply.

-- David Brooks

Parts produced under an STC do not need PMA approval. Chew on that
one, Tarver.



On Wed, 17 Dec 2003 21:56:07 -0800, "Tarver Engineering"
wrote:


"CivetOne" wrote in message
...

snip
So, my bottom line is that the procedural requirements for obtaining
design
approval of either a new design or changes to an existing design are
contained
in part 21.

For the aircraft's manufacturer.

The design approval, either a TC or an STC, is issued in
accordance with the procedures in part 21.

No, the procedures contained in Part 23 are intended to enable a third party
to receive STC Aproval, for a change to a small airplane. From the STC,
with a licensing agreement in place, the parts used to make that change can
get PMA aproval.

The airworthiness requirements to
which the design or design change must comply are contained in the
airworthiness standards (e.g., part 23 for small airplanes), or part 21
for
unique aircraft (e.g., primary category).

Gary Drescher wrote:
"Matthew S. Whiting" wrote in message
...

I think the issue is one of what constitutes known icing. Is it from a
pirep, weather balloon, etc., that has actually seen/encountered the
icing or is a forecast from some weather guy on the ground who thinks
ice might occur sufficient to constitute known icing. Most pilots of
light aircraft know it is both dumb and illegal to fly into a location
where icing is REALLY know to exist. However, to me, a forecast isn't
"known", it is "possible", maybe even "likely", but hardly known.


Are there really any AOMs that refer to "known icing"? The Cessna 152/172
AOMs I've seen prohibit flight in "known icing conditions". That's most
plausibly parsed as known icing-conditions, that is, known conditions that
are conducive to icing. So the icing itself doesn't have to be known, just
the conditions. And a forecast tells you of those conditions.

Well, I have no idea what Cessna was thinking or intending when they
wrote that, but, I'd interpret it as known - icing conditions. I don't
think parsing it your way is at all the most plausible. It is like
saying not to land if it conditions exist that might cause a crosswind
in excess of the demonstrated crosswind. We worry about the actual
crosswind, not what might exist. To me, it is much more plausible that
they would be consistent with all such limitations and apply them to
actual prevailing circumstances, not based on conditions which might
lead to such circumstances. Just my opinion though, as I said I don't
claim to know what Cessna intended.


Matt

Steven P. McNicoll wrote:
"Matthew S. Whiting" wrote in message
...

You might be legal, but you'd also be a test pilot. They might throw
the book at you for impersonating a test pilot ...



What FAR prohibits impersonating a test pilot?

It's called "tongue in cheek", Steven.


Matt