--by John Croft, FAA NextGen Updates and Messaging Branch
When Rosen Sunvisor Systems displayed its wares at the annual Sun ‘N Fun International Fly-In and Expo in April, a new product with an unusual identifier on the label — NORSEE — was on sale. NORSEE refers to the FAA policy statement for Non-Required Safety Enhancing Equipment, part of the required labeling for Rosen’s new visor for the Piper Navajo.
I Can See Clearly Now
The Navajo visor is Rosen’s first NORSEE product and, based on the company’s experience so far, it is the likely forerunner of many similar products. The Oregon-based company is a household name in visors for aircraft, with certified products available for most U.S.-made general aviation aircraft, as well as all Boeing commercial jetliners.
Three years after NORSEE’s debut, the FAA Safety Briefing magazine team caught up with the FAA officials overseeing NORSEE and two manufacturers who are now using the streamlined process to see how the program is progressing. We found success in certain key areas. We also discovered that the FAA is learning a great deal about how to improve the nascent program, which allows non-traditional aviation companies to produce non-essential safety products for certified aircraft. As of the end of February 2019, the FAA had issued about a dozen approvals for safety equipment ranging from USB panel-mounted chargers to iPad mounts to a multi-function display.
About a half-dozen other projects are in the pipeline at any given time, according to John Raspanti, an aerospace engineer in the Chicago Aircraft Certification Office (ACO). The Chicago ACO is currently the focal point for all NORSEE applications. As program manager of NORSEE, Raspanti reviews and disseminates the information to the appropriate FAA lines of business.
Launched in 2016, NORSEE allows a streamlined approval process for certain non-essential equipment that can enhance the safety of general aviation fixed-wing and rotary-wing aircraft. Included are traffic and terrain advisory systems, attitude indicators, weather advisories, crashworthiness improvements and stability augmentation systems.
NORSEE evolved from an earlier policy (AIR100-14-110-PM01) which uses ASTM standards (F3011-13), to make it easier for manufacturers to gain approval for angle-of-attack systems. It is designed to enable a lower-cost, faster route to the type certificated (TC) aircraft market for a broad range of safety equipment that historically have required Technical Standard Orders (TSO) to approve the product and supplemental type certification (STC) to install it. Anthony Vilante, an FAA aerospace engineer in the Certification Procedures Branch, wrote both policies, which were designed to streamline the approval process for owners to install lower cost, non-certified safety equipment.
Companies applying for NORSEE approval can select various industry standards, such as ASTM, that suit their product as long as the equipment meets minimum design requirements established by the FAA. Applicants may also utilize applicable portions of existing FAA Advisory Circulars and TSO standards. The applicant’s paperwork includes manufacturing and quality control information as well as safety analyses proving that the product will not affect primary systems on the aircraft. After the Chicago ACO reviews and finds the application and the supporting documents acceptable, it sends the applicant a letter of approval that provides instructions on their responsibilities as the design approval holder, including how they must maintain quality control of the product. How the product gets installed is up to the manufacturer (per installation instructions approved by the FAA) and the buyer and, in some cases, the buyer’s airframe and powerplant mechanic. The installer is responsible for following the installation instructions, which may require a calibration or pull-test, for example.
“We always say that if you can turn a screwdriver, you can install most of our STC’d sun visors,” said Gary Hanson, field engineer for Rosen Sunvisor Systems. “If you’re not comfortable, have a mechanic do it, with a logbook entry.” Even though owners can install the visors themselves, Hanson recommended that they have their mechanic review the installation and fill out a Form 337 (Major Repair and Alteration) to more thoroughly document the history of changes made to the aircraft. “It can help if you sell (the aircraft),” said Hanson.
Opening the Door
Vilante said NORSEE has opened the door for low-cost safety enhancing equipment to enter the general aviation market, in part from manufacturers who have not previously built certified equipment through the rigorous FAA processes. He added that going forward, NORSEE will be the “umbrella that catches all safety-enhancing add-ons that do not fit into the field approval, STC, Parts Manufacturer Approval or type certificate areas.”
That unfamiliarity has added to the workload. Raspanti, who runs the NORSEE program part-time, has spent a good deal of his time helping new applicants, about half of whom have never worked with the FAA, through the process.
Vilante said most of the applications received have been for “relatively generic” safety equipment, like carbon monoxide detectors and outside air temperature gauges, equipment that normally would cost a little more to purchase and install. Some complex applications — like multi-axis autopilots which use servos to control primary flight controls — were considered a major change to type design that require an STC, and therefore did not qualify as NORSEE. Others did not address the primary goal, boosting safety. “NORSEE approval is based on the premise that it offers safety benefits that outweigh the potential risks of devices with a minor failure effect,” said Vilante, adding that any failures of the equipment should not result in a reduction in safety.
As the intricacy in operation, functionality, and installation increases, the potential safety risks stemming from the failure of integrated and complex systems also increases and the FAA has to focus more intently on the relationship between safety benefits and potential risks. As a result, more complex equipment generally requires more time and resources to evaluate.
In the avionics area, some applications have pushed the limits of the NORSEE policy. Devices approved so far include small, multi-function gauges that provide information on attitude, angle-of-attack, G loads, and other information.
Is It Working?
Manufacturers who have tried the new process said it can drastically cut the cost and effort to get a product to market, and in some cases, the time it takes to get to market.
“Our first approval took one and a half months from start to finish,” said Rosen’s Hanson of the company’s NORSEE applications. “STCs typically take one and a half to two years to complete.”
Along with the reduced approval time, the NORSEE certification itself is less expensive. “An STC costs a couple of thousand dollars to process, primarily because we’re required to use FAA designees to perform and review analyses,” said Hanson. Manufacturing costs are equivalent to the company’s certified products as all parts are made the same way. Will Rosen be able to pass lower costs along to customers? “We don’t know yet,” said Hanson.
What is certain is that Rosen has more NORSEE applications in the pipeline. “We have another one in right now and we plan to do two more in the next three months or so,” he said. “I have high hopes that NORSEE is going to be a good way for us to go,” said Hanson, “because we have fairly simple products that pilots love and want.”
Jeff Bethel, owner and founder of avionics company, AeroVonics, said the cost of creating and getting a product to market will be about 90-percent less for NORSEE than for the traditional STC route, although he could not say the same about the time it takes to complete the process. AeroVonics, which gained NORSEE approval for its multifunction display in October 2018, has arguably the most complex device approved under the policy to date. The AV-20 provides angle-of-attack, G-meter, attitude, airspeed, and other information on a 2-inch display.
As the complexity of a NORSEE component increases, the review and approval time also increases. The time to complete a NORSEE approval is also dependent on the applicant’s previous knowledge and experience with FAA certification processes. Each NORSEE project requires one-on-one help and guidance to develop the NORSEE documentation. “There is a learning curve, but after the applicant has demonstrated the ability to provide the required documentation needed for NORSEE, we expect the approval times to decrease,” Raspanti said. “For Rosen Sun Visors, we worked together on the NORSEE documents for the initial approval.” If future NORSEE applications mirror the same format, Raspanti said he expects approvals for similar sun visors on other aircraft to achieve more timely approvals.
One improvement that has been implemented is the help and guidance provided by Raspanti to inexperienced NORSEE applicants. “It was apparent they needed help in preparing the letters, design standards, and installation documentation for a NORSEE device,” he said. We provide guidance to help those applicants with little to no engineering experience develop NORSEE documentation that will be acceptable to the FAA.
“What John is doing is building a basis for a general template to go along with these approvals,” said Vilante. “He’s developing a common denominator on what everyone should have in their data package. The approvals will occur on a case-by-case basis.”
The NORSEE policy envisions other ACO branches “eventually” joining the program so that applicants can apply through their local offices. For now, though, everything is being routed through the Chicago ACO branch to ensure consistency in evaluating the applications and to develop a documentation process that will mature “as we get more exposure to various NORSEE products coming to the market,” said Vilante.
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John Croft is an FAA flight instructor and a writer/editor in the NextGen Updates and Messaging Branch. Croft uses ADS-B in the Piper Archer he co-owns with two other pilots, and he regularly flies a small team of FAA communicators to talk to pilots and other stakeholders about ADS-B.