Another update on the Corsair V8 project

[PeterNSteinmetz]

The regulatory barriers just not moving at all. I have to admire their persistence but fear it is really tilting at windmills.

The Corsair C172-V8 Experiment Update #3—Reader’s Suggestions : Air Facts Journal

Unfortunately, it became clear that FAA leadership had no interest in supporting such a solution—whether as an experimental conversion for certified airframes or via a STC (a certification that would allow owners to replace their original engine with ours on certified aircraft)—regardless of the...

airfactsjournal.com

 

[rotorwrench]

The regulatory barriers just not moving at all. I have to admire their persistence but fear it is really tilting at windmills.

For context, which regulatory barriers do you believe exist that prevents this type of modification? For reference, links to CAR 13 and Part 33.

What I find interesting is the current average auto engine built with and by the latest technologies, cannot meet the antiquated requirements from the 40s and its lack of technologies. In reality, its more than just rules that are preventing more auto engines to be TC’d or installed in TC'd airframes. Which has also been proven by the Porche, Toyota, and Hyundai attempts.

 

[PeterNSteinmetz]

For context, which regulatory barriers do you believe exist that prevents this type of modification? For reference, links to CAR 13 and Part 33.

I think in that article they are not complaining about specific wording, but rather about the way the regulatory apparatus is simply not talking to or dealing with them at all. So it is the effective stonewalling by people, not the words on paper.

What I find interesting is the current average auto engine built with and by the latest technologies, cannot meet the antiquated requirements from the 40s and its lack of technologies. In reality, its more than just rules that are preventing more auto engines to be TC’d or installed in TC'd airframes. Which has also been proven by the Porche, Toyota, and Hyundai attempts.

I don’t find that terribly surprising. Do electric light bulbs burn the same way as candles? Would they meet requirements for appropriate flame sizes?

All of these consequences they are complaining about are completely typical results of regulation and regulatory capture. I agree with them that it will likely be the death of GA flying. Just a hobby for me so I just follow the rules, accept the added expense, and don't regard it as my fight. I think they had a lot more invested in the outcome.

 

[rotorwrench]

I think in that article they are not complaining about specific wording, but rather about the way the regulatory apparatus is simply not talking to or dealing with them at all. So it is the effective stonewalling by people, not the words on paper.

What I’ve found interesting in all their articles, narratives, and presentations, is the names and positions of the people they talked to concerning this project. Most of those people are not in a position to directly help them. My take on the “stonewalling” was they wanted those FAA department heads to make an exception to the rules for their project.

The “regulatory apparatus” is pretty simple and straight forward. I’ve been through the STC process a number of times with none of their type problems. But then again, we followed the requirements by working with the Project Managers and Engineers at the ACOs and MIDOs (as they started out) and not talking to the head shed looking for favors and exceptions.

Regardless, in general, their presentation and project generated a number of questions that went unanswered, which in turn made the whole STC project appear a bit suspect from the get-go. Especially to those who were looking to invest in it.

I don’t find that terribly surprising. Do electric light bulbs burn the same way as candles? Would they meet requirements for appropriate flame sizes?

Interesting example. Maybe, if I was flying at 1000 feet and the V8 had an unacceptable fire potential. Ironically, its one of the main reasons auto engines are hard to certify as those road ready engines can’t pass a simple fire prevention test for certification.

Now if you were to take a V8 built for organized car racing it would generally pass the CAR 13 fire prevention tests and probably the Part 33 tests as well. However, now you’re also looking at a V8 that costs more than a Lycoming or Continental. It was a similar route Porche and Toyota took. Except the market was not there to support an engine at that cost level despite both engines receiving a type certificate.

I agree with them that it will likely be the death of GA flying. Just a hobby for me so I just follow the rules, accept the added expense, and don't regard it as my fight. I think they had a lot more invested in the outcome.

Recreational GA has been dying for the past 30 years for the simple reason no one is getting involved. If you want to save the hobby GA side, you need to get new people wanting to fly airplanes and not trying to put V8s in 172s. Simple demographics and economics.

 

[PeterNSteinmetz]

The “regulatory apparatus” is pretty simple and straight forward.

Good points to think about and nice to hear your input. Overarchingly though, it is a well documented and general result that regulations and the accompanying bureaucracy decrease innovation and increase costs. I see no data and analysis to suggest aviation is any sort of special exception.

Regardless, in general, their presentation and project generated a number of questions that went unanswered, which in turn made the whole STC project appear a bit suspect from the get-go. Especially to those who were looking to invest in it.

Possibly because of the regulatory uncertainty involved. I don’t know why anyone would invest in aviation though. You know the joke about to make a small fortune in aviation…

Interesting example. Maybe, if I was flying at 1000 feet and the V8 had an unacceptable fire potential. Ironically, it’s one of the main reasons auto engines are hard to certify as those road ready engines can’t pass a simple fire prevention test for certification.

True, and I suppose the example would suggest that maybe the fire prevention test requirement is not really justified given the levels of risks involved. There is always going to be a tradeoff between safety and cost. And again it is rather well documented that regulators will normally err very much on the side of caution while downplaying cost.

Recreational GA has been dying for the past 30 years for the simple reason no one is getting involved. If you want to save the hobby GA side, you need to get new people wanting to fly airplanes and not trying to put V8s in 172s. Simple demographics and economics.

It is likely multi factorial. But one often hears from people about the potential sport - “too expensive”. So if that remains I doubt all the Young Eagles flights and encouragement in the world will matter much.

There is also the fact that kids can get their dopamine squirts much more cheaply and safely with video games these days. They have essentially hijacked normal human motivational systems and their is strong competition to make them more and more effective. This may indeed be the main factor and it seems to affect other sports as well as even reproductive drive.

Not my fight because I am fairly confident I will be able to fly until I am not safe to do so anymore. I became interested in flying as a hobby in the late 1960s when things were a lot more robust.

I think these guys had more invested and perhaps should have read von Mises. In that sense I can see why people regard them as tilting at windmills. Only a real revamping of the entire aviation regulatory bureaucracy could change what they are running into.

 

[rotorwrench]

I see no data and analysis to suggest aviation is any sort of special exception.

If that were true, then which regulation prevented Corsair from installing the V8 on the 172 and actually flying it in the NAS legally?

Or, which regulation prevents Corsair from selling an E/E V8 kit to other people so they can install it on their aircraft?

Or which regulation prevents you from doing something similar on your aircraft?

The answer… there are no regulations that prevent that. And a quick look over the past 10 years will also show that innovation is alive and well in the US aviation sector along with its interaction with the FAA. As they say, the proof is in the pudding.

 

[PeterNSteinmetz]

Those sort of anecdotes do not, in my view, argue strongly against the large body of literature which shows that these types of regulation slow down innovation and increase cost. This result is sort of also intuitive, is it not? The whole purpose of such regulations is to keep people from taking certain actions.

In all likelihood, costs would be even lower and much greater innovation would have taken place without these regulations.

The price that may have been paid would be some decrease in safety. I mean the safest thing to do in the limit is clearly eliminate all GA flying. Then there will be a zero GA accident rate.

The appropriate choice in this sort of tradeoff is best determined in a free market. Not made by some bureaucrats who pay no price personally if they get it wrong. This is just standard von Mises and Austrian school. Nothing unusual about this at all.

 

[rotorwrench]

The whole purpose of such regulations is to keep people from taking certain actions.

In part, yes. But those regulations also service international agreements, manage the NAS, provide a mechanism for the industry to grow., etc.

In all likelihood, costs would be even lower and much greater innovation would have taken place without these regulations.

Likelihood? In what way that is not currently available now? Plenty of innovation out there at the current cost structure.

Since I know of no other aviation system that uses a free market approach vs a regulatory approach, perhaps you can offer some specific examples?

 

[PeterNSteinmetz]

In part, yes. But those regulations also service international agreements, manage the NAS, provide a mechanism for the industry to grow., etc.

I would submit that the evidence in other industries is that such regulation actually inhibits growth.

Since I know of no other aviation system that uses a free market approach vs a regulatory approach, perhaps you can offer some specific examples?

I am not sure what sort of examples you are requesting. The last time we discussed this, IIRC, there was no evidence specifically studying the effects of these regulations generally in aviation. Lots of statements of intended effects, but no real data or analysis at the general level.

Again IIRC they were mostly generally enacted at an earlier time when they had no real data and potentially no way to analyze it. There were enacted on the basis of intentions and guesswork. This was also a time of a lot of progressive legislation under FDR so there was a tendency to think like “there is a problem here - the government should do something about this”.

But perhaps you have something else in mind?

 

[rotorwrench]

I would submit that the evidence in other industries is that such regulation actually inhibits growth.

And I would resubmit aviation is a unique industry with no peer. So any comparison to "other industries" is moot on numerous levels. Perhaps you can offer some evidence examples from those other industries, and we can compare notes?

I am not sure what sort of examples you are requesting.

Simple. You stated: ".... costs would be even lower and much greater innovation would have taken place without these regulations."

Looking for specific examples of innovative aircraft you believe could be developed with less regulation ... but could not be developed with the current level of regulation. Make sense? I can think of a dozen or so new design or innovative aircraft off the top that have been developed in the last 7 years under the current regulatory structure and cost basis. What more am I missing and by who?

Again IIRC they were mostly generally enacted at an earlier time when they had no real data and potentially no way to analyze it. There were enacted on the basis of intentions and guesswork.

Not really. If you study the background of each regulation, you'll find there are specific reasons behind each regulation. However, prior to the Administrative Procedure Act (APA) in the 1940s, finding those reasons required researching the individual Federal Registry entries and other obscure documents. With the APA and its NPRMs, you can now track those specific detailed reasons much easier.

Fortunately, there have been a number of articles and books written on the development of the original Air Commerce Regulations (ACR) and the initial CARs that provide the general reasons behind those early aviation regulations. But in general terms, most aviation regulations come from requests by the flying public via their representatives, requests by the industry players, and to service international agreements. And the data was provided by real world actions and facts. For example, even though the aviation accident was abhorrent at the time, it took the Knute Rockne accident to implement changes that finally started the decline in aircraft accident rates. Which in turn raised the public's confidence in commercial flight and the market started its exponential growth.

 

[Ron Wanttaja]

Simple. You stated: ".... costs would be even lower and much greater innovation would have taken place without these regulations."

That sort of freedom actually resulted in homebuilt airplanes being banned in 47 states by 1940. There was such a casualty rate among homebuilt airplane owners that the state governments took action.

Ron Wanttaja

P.S. The answer is, "Oregon"

 

[PeterNSteinmetz]

That sort of freedom actually resulted in homebuilt airplanes being banned in 47 states by 1940. There was such a casualty rate among homebuilt airplane owners that the state governments took action.

Ron Wanttaja

Ron, do you have a reference for this? Very interesting,

 

[Ron Wanttaja]

Ron, do you have a reference for this? Very interesting,

George Bogardus, the Oregon Outlaws, and the American Airmen's Association.

Barnstorming the Beltway

How a homebuilder's determination won liberty and experimental licenses for all.

www.smithsonianmag.com

Sport Aviation, page 36, February 2018.

Basically, the CAA allowed homebuilts to fly only for 30 days, while the Outlaws claimed their Oregon aircrafet registrations were sufficient to let them fly.

Ron Wanttaja

 

[PeterNSteinmetz]

George Bogardus, the Oregon Outlaws, and the American Airmen's Association.

Barnstorming the Beltway

How a homebuilder's determination won liberty and experimental licenses for all.

www.smithsonianmag.com

Sport Aviation, page 36, February 2018.

Fun story Ron, thanks for sharing it. Perhaps I misunderstood your prior post. It seemed to me you were saying that states had outlawed homebuilts and then the CAA stepped in. But this story seems to imply homebuilding was fine until the CAA came up with overly restrictive or ambiguous regulations.

 

[PeterNSteinmetz]

…

Looking for specific examples of innovative aircraft you believe could be developed with less regulation ... but could not be developed with the current level of regulation. Make sense? I can think of a dozen or so new design or innovative aircraft off the top that have been developed in the last 7 years under the current regulatory structure and cost basis. What more am I missing and by who?

…

Certainly a number of interesting points there. For now let’s discuss this V8 project by way of example and since it was the OP.

To start with let’s just review the basic facts. As I understand it these guys have worked out a way to use a V8 aluminum marine engine on a C172. They state it provided operation at $20/hour on unleaded auto fuel.

Is this basically correct?

Now my question - can they presently legally set up shop to sell this conversion , performed by them, to any owner of a C172, including flight schools and FBOs, who can then legally use or rent this aircraft to others?

 

[Ron Wanttaja]

Fun story Ron, thanks for sharing it. Perhaps I misunderstood your prior post. It seemed to me you were saying that states had outlawed homebuilts and then the CAA stepped in. But this story seems to imply homebuilding was fine until the CAA came up with overly restrictive or ambiguous regulations.

I'd originally heard the story as the states having done it....

 

[rotorwrench]

Is this basically correct?

Yes.

can they presently legally set up shop to sell this conversion

Yes.

performed by them

Yes.

to any owner of a C172, including flight schools and FBOs

Yes.

who can then legally use [it]

Yes.

rent this aircraft to others?

I think so. But I believe it will take an additional FAA LODA to rent them….

 

[PeterNSteinmetz]

…

Yes.


I think so. But I believe it will take an additional FAA LODA to rent them….

So just to be clear - these guys could advertise saying it is a excellent and efficient engine conversion, perform this on customers planes without any additional approvals from the FAA and it would be legal and comply with regulations?

However their customers could not rent out or use such an aircraft commercially without a LODA?

What would obtaining such a LODA entail? Would every operator need one for each aircraft so modified?

Could a private owner fly it themselves with no additional approvals?

 

[Ron Wanttaja]

Now my question - can they presently legally set up shop to sell this conversion , performed by them, to any owner of a C172, including flight schools and FBOs, who can then legally use or rent this aircraft to others?

In the US, the IA's job during the annual inspection is to verify that the airplane still complies with its Type Certificate. If the installed engine is not in accordance with the Type Certificate or a Supplemental Type Certificate, the IA is not supposed to sign off on the annual.

Ron Wanttaja

 

[rotorwrench]

So just to be clear - these guys could advertise saying it is a excellent and efficient engine conversion, perform this on customers planes without any additional approvals from the FAA and it would be legal and comply with regulations?

They already have advertised that on their website and other literature. They offer/offered a firewall forward kit for the 172 and similar aircraft (Alpha 1) and a kit for E/AB aircraft (Alpha X2).

However, I doubt they would perform the work themselves as they seem to have a bit of an aversion for liability issues.

But keep in mind we are talking about Special AWCs and experimental category aircraft with the V8. So a number of regulations are not applicable. The only FAA involvement with the V8 kit would be for the owner to apply for the Special AWC under Experimental Exhibition and receive their certificate and operating limitations. Which is exactly what Corsair did and how they flew it.

However their customers could not rent out or use such an aircraft commercially without a LODA?

I believe so for rental, but do not follow this specific topic much. However, it is the same process used for E/AB or other Special AWC aircraft when rental, training, and other type ops are performed. For example, Corsair provided the V8 to a student to get their PPC to include the FAA check ride, but don’t know how they provided that aircraft to them. That event is also contained in their literature.

But no on standard commercial ops. Now how the LODA fits into that I don’t know so it might provide some limited “commercial” ops like a tow aircraft or something. Perhaps review Part 91 for more details?

What would obtaining such a LODA entail?

I think you just send a request to your local FSDO.

Would every operator need one for each aircraft so modified?

No.

Could a private owner fly it themselves with no additional approvals?

Yes, except for obtaining a Special AWC and ops limits as mentioned above.