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The commenter recommended changing proposed AM1.2713 to specify that no single failure may lead to a catastrophic event and to exclude the criteria for critical parts. The FAA does not find the level of safety outlined in SC-VTOL for “Category Enhanced” to be applicable to the Model M001 engine failure classifications, which could be minor, major, or hazardous, but not catastrophic. The FAA will apply failure classifications that are consistent with those established in part 33 to provide the equivalent level of safety required by § 21.17(b).
§ 23.2305 Landing Gear Systems
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- The applicant must show that systems and components that cannot be adequately substantiated in accordance with the endurance demonstration or other demonstrations will perform their intended functions in all declared environmental and operating conditions.
- If the design allows any of the engine main rotating systems to continue to rotate after the engine is shut down while in-flight, this continued rotation must not result in hazardous engine effects, as specified in AM1.2717(d)(2).
- (a) Flight controls, engine mounts, and other flight structures within or adjacent to fire zones must be capable of withstanding the effects of a fire.
- Commenters requested the FAA clarify “where the exposure to lightning is likely” in AM1.2430(a)(2), which they believe could be interpreted in different ways.
AM1.2215 Flight Load Conditions
The FAA received a comment to add a requirement to AM1.2335 to minimize the risk of electrical shock to the crew, passengers, and service and maintenance personnel, similar to the requirement in § 27.610(d)(2). This concern is adequately addressed by proposed AM1.2335(b), which requires the appropriate protection against hazardous effects caused by accumulation of electrostatic charge. The FAA received a comment stating that 14 CFR part 23 amendment 23-64’s requirements for flight controls should be sufficient for the Model M001 and the FAA should use those requirements.
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AM1.2120 Climb Requirements
It does not prohibit procedures or control logic that would restrict engine restart under certain conditions. The FAA will address the requirements of appropriate shutdown and restart procedures through the aircraft flight manual limitations and operating procedures. The FAA received comments asking the FAA to provide specific likely failure cases to be considered in addition to more detailed control feel requirements in proposed AM1.2145(a). The intent of AM1.2145(a) is for the applicant to identify likely failures that may be encountered in service that are not addressed by system safety analysis; those could include mechanical or other single point failures. The FAA has revised the language in AM1.2145(a) to improve clarity but did not concur with the commenters’ request to identify specific failure conditions, including detailed control feel requirements.
Any system or device that provides, uses, conditions, or distributes electrical power, and is part of the engine type design, must provide for the continued airworthiness of the engine and maintain electric engine ratings. The engine must be subjected to a durability demonstration to show that each part of the engine has been designed and constructed to minimize any unsafe condition of the system between overhaul periods or between engine replacement intervals if the overhaul is not defined. This test must simulate the conditions in which the engine is expected to operate in service, including typical propeller accounting start-stop cycles, to establish when the initial maintenance is required. If the design allows any of the engine main rotating systems to continue to rotate after the engine is shut down while in-flight, this continued rotation must not result in hazardous engine effects, as specified in AM1.2717(d)(2). (b) High-voltage electrical wiring interconnect systems must be protected against arc faults that can lead to hazardous engine effects as defined in AM1.2717(d)(2). Non-protected electrical wiring interconnects must be analyzed to show that arc faults do not cause a hazardous engine effect.
§ 35.37 Fatigue Limits and Evaluation
(b) There must be no vibration or buffeting severe enough to result in structural damage, at any speed up to dive speed, within the structural design envelope, in any configuration and power setting. (b) The applicant must develop an operating limitation to prohibit intentional flight, including takeoff and landing, into icing conditions for which the aircraft is not certified to operate. (b) The applicant must determine critical control parameters, such as limited control power margins, and if applicable, account for those parameters in appropriate operating limitations. (c) The procedures used for determining takeoff and landing performance must be executable consistently by pilots of average skill in atmospheric conditions expected to be encountered in service. (a) Unless otherwise prescribed, the aircraft must meet the performance requirements of this subpart in still air and standard atmospheric conditions.
- One commenter asked why the functional test in proposed AM1.2840 is limited to forward pitch and not to the entire pitch range.
- The details of this satisfactory functioning must be published in the appropriate manual.
- (2) Verification of the satisfactory functioning of safety or other devices at pre-flight or other stated periods.
- (d) Ingestion sources described in paragraph (b) of this section that are not evaluated must be declared in the engine installation manual.
- Another commenter proposed to use performance-based aircraft requirements that consign the engines and propellers to aircraft equipment or systems and relegate engine and propeller certification requirements to a means of compliance to an aircraft requirement.
- The FAA does not concur with the suggestion to not make the propellers critical parts.
Electric Engines
Several commenters identified that these criteria do not include specific failure condition probability targets or required development assurance level criteria and requested that they be included with appropriate rationale. The FAA does not agree, as existing aircraft airworthiness standards (parts 23, 25, 27, and 29) also do not prescribe specific failure condition probability targets or development assurance level criteria. This guidance may be found in advisory circulars or industry consensus standards, which provide one means, but not the only means, for showing compliance with the regulatory requirements. These means will likely need to be modified to consider powered-lift designs such as the Model M001. The FAA received a comment to distinguish between airplane and engine hazards in AM1.2000(e). The requirement in AM1.2400(e) addresses powerplant components at the aircraft level.
- The airworthiness criteria have been revised to exclude paragraph (f) from the requirement to comply with certain paragraphs of § 33.29.
- This document sets forth the airworthiness criteria the FAA finds to be appropriate and applicable for the powered-lift design.
- Electric engines can create torque much faster than combustion engines, and sudden changes in torque could present a hazard to the aircraft installation.
- The revised definition specifies that life-limited parts may involve rotors or major structural static parts, among other parts with failure potentially leading to hazardous engine effects due to LCF mechanisms.
- This will allow Archer to seek a standard that reflects their operating limitations and specifics of their design.
- AM1.2715(c) applies to an electric engine regardless of whether the engine is torque limited.