So lets put some data around this. According to http://gama.aero/files/GAMA_2015_Databook_LoRes_for_Web.pdf

Cirrus sold 301 aircraft - 31 SR20, 128 SR22, 142 SR22T

Beech sold 23 G36

Stodgy old Cessna sold 271 SEP aircraft - 142 172S, 33 182T, 51 T206H, 44 TTx.

I would speculate that maybe half are toys. Half or more are working planes going to flight schools, rentals, some 135 outfits for the SR22, business people.

So we have maybe 300 or so people in the entire world who are buying new SEP as toys. Now how many of those have the financial capability to spend 2X - 3X for their toys and trade up to a SF50? The expensive toy market is very small.

Cirrus applied to the FAA for a "special condition" so as not to actually have to test the SF50's parachute system for certification…

that seems a tad strange to me, as that rescue system seems to be highly integrated in the SF 50, even into the avionics, if this report here is correct…

https://www.flightglobal.com/news/articles/cirrus-wins-parachute-test-reprieve-from-faa-423569/

I wouldn't read that as "not going to test it to see if it works" but rather "not a test for certification". Those are very different things

The customers will test it thoroughly, have no doubt.

That article said:

The CAPS is also integrated with the SF50’s avionics software. In the event a pilot commands the CAPS to deploy, the avionics will automatically manoeuvre the aircraft to ensure the parachute is released within an operating speed range between 67-160 KCAS, the FAA says.

That raises all sorts of questions.

If the avionics can put the plane in a good state, do you still need the chute?

What happens if the avionics can't put the plane in a good state? Does it not fire the chute at all? Or try and fail after some seconds? What is the algorithm here?

What about the delay the avionics insert in the chute deployment? That could be the difference between success and failure if near the ground.

Here is the proposal:

https://www.federalregister.gov/article ... ery-system

Essentially, Cirrus is arguing that the parachute is not a required part of the aircraft for safety, and further that the parachute doesn't reduce safety. This is at odds with their marketing.

I think the SC will fail because of one simple fact: occupants EXPECT the parachute to work and bring them to the ground safely. For that reason ALONE, Cirrus MUST test the entire system, on an airplane, in flight. It seems unconscionable to me to expect a customer to be the first to ever deploy the parachute.

Mike C.

Not really.

Everything on the airplane must operate safely, even those things not required for certification.

Consider that the FARs don't require a heater in an airplane. Does that mean you don't have to test a combustion heater like those found in piston twins? Of course not, you have to test it operates safely.

The parachute is the same way. If it is on the airplane, then it must be tested to pass certification.

This argument also suggests that one can get an STC to remove the parachute. Cirrus itself is saying it is not required.

Mike C.

Mike,

Bad example. Most heaters on twins are required equipment to provide defrost services for FIKI aircraft.

Tim

Most piston twins are not FIKI.

Mike C.

Cirrus, on March 11th, said:

Yes, we’re still estimating first customer delivery by mid-year, so no change on the delivery timeline there. Regarding CAPS certification, we’re still in the midst of final testing and will give you all a report as soon as we’re able.

Cirrus, prior to March 18th, filed for the special conditions. Seems "final testing" meant "we'd like to not do it". Based on the CAPS testing done to date, and the VERY late date of this request (past even a recent certification deadline), one has to imagine they have run into unexpected problems with the CAPS test program.

FAA is asking for comments by May 2nd. Then they cogitate. Then they opine. Then Cirrus has to work with that result, which might be that they have to do a full up test on the aircraft. Which will take time. Then results have to get written up. Sent to FAA, they cogitate, ask questions, then they may pass it.

I would say a delivered SF50 by June 30 seems exceedingly unlikely given the certification timeline exposed by this issue. This year might even be in doubt.

Mike C.

I just need more pages of posts on the topic to settle my bet and justify a round of golf.
:-)

Not really.

Everything on the airplane must operate safely, even those things not required for certification.

Consider that the FARs don't require a heater in an airplane. Does that mean you don't have to test a combustion heater like those found in piston twins? Of course not, you have to test it operates safely.

The parachute is the same way. If it is on the airplane, then it must be tested to pass certification.

This argument also suggests that one can get an STC to remove the parachute. Cirrus itself is saying it is not required.

Mike C.

yes, that is all a bit strange..if they advertise their CAPS, as standard on the SF50, there will certainly be quite a number of customers, who , upon having seen that the system basically works as advertised on the small piston Cirrus airplanes, actually base their SF 50 purchase decisions, among other factors, also on the performance of that system..

in the last 10 years there was a bit of an inflation of SCs ( Special Conditions) during certification of new types…as well meant and good the SC system is….too many SCs water down the integrity of the certification system IMHO..

the latest evolution of § 23 (25). 1309 also has been bent a bit far already….I mean .1309 always has been the "make or break switch" in certification..if that is watered down..let's forget certification and certify birds & systems on a hope and a prayer…may work on an LSA but not on a bird costing several Mio $...

touchy….

sure it costs a bit to flight (crash) test the system..maybe three airframes..and OK, the tests could be unmanned, they could RC them..understandable if Exp test pilots would not want to do it..fair enough..but RC'ed..where is the problem? except the costs, but that money would be well spent, because it could show the customers that the CAPS in the SF 50 is not just for show...

Who still has bets on this thing? Crandall v. Ciholas?

I vote it's not gonna happen in 2016.

A bigger question is other than protecting government jobs, do we really need the FAA to have ANY say at all in part 91 aviation? I agree the general public needs protection part 121 but do we really need the FAA's certification of us part 91? I think the market would sort this out on their own. If design XYZ is shedding wings, it won't sell and they will get sued to oblivion. The LSAs don't seem to be falling out of the sky either do the Vans RVs. I don't think the part 23 rewrite will ever happen but perhaps our country can solve this certification dilemma before it sinks GA.

What's the cost of certification, it must be 1/3 of the cost of new design.

A few years back, an FAA certification guy was assigned to Cirrus, and he essentially resided in the Cirrus operation.....watching, measuring, re-checking, etc. He was an important part of the certification process.

If that is still how the process works, then I doubt that Cirrus would have made this request without that FAA guy knowing about it (and likely telling Cirrus that such a request would perhaps achieve a positive result). Perhaps, this is even a reasonable request, as Cirrus has considerable experience -- and presumed expertise -- in all things involving airframe parachutes.

Cirrus should know the risk of not demonstrating something like this. They got an ELOS to avoid having to do a full spin program on the SR line. As a result, there are still people out there who believe that 'a cirrus can't recover from a spin' despite the fact that the plane underwent further spin evaluation as part of the European certification.

Some believe, as I do, they wanted to make sure the chute was required equipment. What better way than to make that official by using it as an ELOS.

It is FAR more expensive to certify a chute than to do a few spins, so the "chute as spin ELOS" argument, especially given the plane recovers from spins fine, seems motivated by something other than the cost of spin testing.

Mike C.