Certification and commercial aviation outside the west?

[AdamFrisch]

I've often wondered how this works in most of the countries in the world outside of Europe or North America. It seems like you see a lot of mixed fleets and "anything goes" in, for example, Africa. An example you might see a lot of Let turboprops and Antonovs and Russian gear flying commercially, types that have never been certified in EASA or FAA land. How does this technically work - do these countries have no request that commercial aviation has the be with certified aircraft, or have these manufacturers simply gone to every little country in the world and certified their product?

Hungarian Malev, LOT and many others regularly flew Tupolevs to western cities in their network although they were never certified there. Can a country block another countries aircraft if they're not certified?

Anyone know?

I mean, would it be possible to start an aircraft manufacturing business, not FAA and EASA certify them as it's a pain in the a**, and then still be able to sell them to most countries in Africa, Asia and South America?

[Mad (Flt) Scientist]

I think its pretty much covered by the ICAO documentation. The ICAO member states all agree to accept (to one degree or another) each other's type certificates, but also have to own up to any deficiencies in their own regulations compared to ICAO minimums. If your notional offshore manufacturer wasn't in an ICAO state, I don't think anyone would let you fly into their airspace, so you have to play by ICAO rules.

That would impose some minimum standards on you, though if the overseeing authority were weak you'd undoubtedly be able to pull a fast one or two during the certification process. It's pretty common for "less advanced" aerospace countries to just adopt the FARs or JARs pretty much wholesale and slap a coversheet on them. So it's only in trying to exploit their less experienced oversight personnel you'd get any traction.

And bear in mind that the way the rules are written, if you're dealing with someone with less experience they may apply it strictly as written, not as it was intended - so you may actually be worse off with a less expoerienced, and hence more pedantic, authority.

Finally, if you did end up with an aircraft that couldn't be used in the "first world", many leasing/finance companies probably wouldn't touch it, for fear of poor resale options.

[AdamFrisch]

But if they're ICAO compliant and transparent, how come manufacturers have to certify aircraft separately in FAA land if they're EASA and vice versa? Why don't they just accept one certification to rule them all?

[Mad (Flt) Scientist]

Well, they usually are not distinct certifications. The various authorities have bilateral agreements as to the equivalency of each others' certification standards - based on both the underlying ICAo standards and also commonality of the specific standards themselves, so usually the additional effort to certify in the second or third jurisdiction is minimal. For example, my own company certifies with Transport Canada as lead authority, because they are our national authority. But EASA and FAA certification usually follows just a month or two later, and the incremental work is less than 10% in terms of flight testing; the other authorities do a spot check validation rather than a full certification exercise. TCCA reciprocate for FAA and EASA certified aiurcraft.

Why do it? Well, if I want to register an aircraft in country X, then it has to be approved for a Cof A by that country. That means passing that country's certification rules. And why do i want to register locally? Sometimes tax reasons, sometimes a requirement that I register locally. It even applies to the smaller countries. if I want to register in Bermuda for tax reasons, the Bermudan authorities need to be able to give me a C of A, and at least tick the boxes toi say I have met some kind of requirement.

Again, at my company, we usually have one or more exercises every year to 'validate' a certification for a new country that has its own wrinkles on the basic FAR/CS/TC rules, because enough customers exist in that country to make it worth getting the approval.

One single certification and hence one single set of rules is the holy grail of "harmonization" of cert requirements. But cert requirements are ultimately laws, and laws are made by politicians. So until you get all the politicians to agree, there'll always be some rule that is important to one country that the others don't want. (For example, Canada has some specific concerns about cold weather operations, not surprisingly; FAA and EASA don't put the same emphasis on these concerns)

[AdamFrisch]

Thanks.

It seems like the costs of certification are a huge hurdle to overcome for even established manufacturers let alone a new one. What would a normal category GA aircraft cost to certify, ballpark?