New ‘Code Number’ for eVTOL: 2117(b)

The ‘G-35’ – SAE International’s standards committee for Modeling, Simulation and Training (MST) for New Emerging Technologies and Concepts – was launched in September 2021 to develop consensus-based standards for implementing advance technologies such as eVTOL while maintaining and enhancing safety.  G - 35 Committee Examining M&S for Emerging Concepts | Halldale Group

CAT’s Robert W. Moorman touched base with Marilyn Pearson, Co-Chair of the G-35, and Global Regulatory Affairs Specialist, Advanced Air Mobility and eVTOL at CAE, on the group’s progress.

CAT: How far along are you on setting standards for eVTOL / eCTOL aircraft?

Pearson: Our goal is to have a draft standard for aircraft certification, FSTD qualification, and pilot training and licensing by the end of 2023.

CAT: Do you recommend these standards be uniform universally? Same for US as Europe and elsewhere?

Pearson: Yes. We have ICAO and five other CAAs participating. The purpose is to ensure that these recommendations can be neutral, not specific to one regulatory agency or another.

CAT: Explain, please, on standards versus regulations. Do regulators take your recommendations and weave them into the regulations? Or do these recommendations remain recommendations?

Pearson: Great question. These organizations - SAE, ASTM, RTCA - all write standards and can write guidance documents. A standard that is written by one of these organizations is intended for regulators to use in developing regulations. Most times, regulators participate as liaisons and advisors to these groups. They’re pretty comfortable the standard is written. The regulators could integrate these recommendations into their policy documents and codified eventually. The recommendations could be a means of compliance. In this case, we’re hoping these recommendations can inform regulations.

CAT: Most of us remember when the FAA changed its certification standards for eVTOL aircraft in mid-May 2022. Which now states that these eVTOL aircraft [must or can] be certified in the “powered-lift” category rather than Part 23. This was a 180-degree change from what we heard from the FAA early on. As a veteran of the agency, I would like to get your opinion on the change. [Pearson retired from the FAA in December 2020.]

Pearson: That’s incorrect. It isn’t a must. The OEMs can opt for certifying under Part 23 as an airplane or helicopter. The recommendation is that they be certificated under 2117(b), the special category. Because these aircraft don’t fit the airplane or helicopter, the FAA noted that it needed too many special conditions and deviations for certification. And that didn’t fit. So they went to 2117(b).

(As a former FAA official, it would be inappropriate to offer an opinion.)

I can only guess from what I’ve heard from FAA sources that under 2117(b), you can take the appropriate components of each. You aren’t limited. The purpose of the shift was so these aircraft could be certified without a burden to the applicant. Most applicants are going 2117(b), I’ve heard. The confusion came because several [eVTOL, eCTOL] OEMs were in the process of certification. And now they had to change course. FAA said you don’t have to change course. We’re just moving your applications to 2117(b).

CAT: With few exceptions, the eVTOL and eCTOL OEMs are not developing training curricula for pilots and AMTs simultaneously. They remain fixated with the aircraft development process. CAE seems to be filling that gap, leading the way, along with FlightSafety. Don’t the OEMs need to pick up the pace as relates to training of pilots and aircraft mechanics?

Pearson: In advance of certifying these aircraft, you’re going to need to think about training. Do you have  appropriate training devices for pilots, aircraft mechanics. That is how I came up with the idea for G-35. Everyone was focused on aircraft certification and no one said anything about pilots. I have always seen pilots in this area [training] as being an afterthought. The last thing you need is for an aircraft to go through type certification and turn around and say, ‘who should we hire?”

CAT: [Pearson is a certified pilot with 50 years flying experience.]