EASA SC-VTOL-01 Comment Response Document Note: The comments have been grouped by theme or objective and renumbered sequentially. Bookmarks are available to navigate the document. General type of vehicle Explanatory Note 1: type of vehicle The Special Condition (SC) has been developed to cover a new category of person-carrying vertical take-off and landing (VTOL) heavier-than-air aircraft with lift/thrust units used to generate powered lift and control. The vertical take-off and landing capability distinguishes this type of aircraft from aeroplanes. The Special Condition does not intend to cover traditional rotorcraft either but rather aircraft with distributed lift/thrust and it will be clarified that, for the SC to be applicable, more than 2 lift/thrust units should be used to provide lift during vertical take-off or landing. The Special Condition background mentioned “the aircraft may not be able to perform an autorotation or a controlled glide in the event of a loss of lift/thrust” as it is the case for some VTOL aircraft being proposed, however this is not a requirement. Comment Comment summary Suggested resolution Comment is an Comment is EASA EASA response observation or substantive or comment is a is an NR Author Paragraph Page disposition suggestion* objection** 1 1David Loebl, Background/Sc 1 “Although hover flight may be possible, the aircraft Clarify the condition where no glide is possible: Yes No Noted See Explanatory Note 1 AutoFlightX ope may not be able to perform an autorotation or a “…not be able to perform an autorotation or a controlled glide in the event of a loss of lift/thrust.” controlled glide in the event of a loss of lift/thrust implies that the given SC are not applicable for during hover.” transition vehicles that can fly also with aerodynamic lift. 2 3Luftfahrt -Bundesamt VTOL.2005 Certification of small-category VTOL aircraft: Yes Yes Partially The numbering mirrors CS-23 Amendment 5. The applicability is accepted indeed vertical take-off and landing aircraft with distributed lift/thrust This is more or less a definition and should be and will be clarified in the SC. See also Explanatory Note 1. better included in VTOL.2000 as an additional sub-paragraph It is not perfectly clear, to which kind of aircraft this Special Condition shall appliy: Is Vertical Take OFF capability really required? Why is not distributed lift required? Why is not the missing autorotation/glide landing capability required? 3 2ACI EUROPE General General There is no mention in the text of communication It may be the case that these matters are covered in yes no Noted It is agreed that the products that will be certified on the basis of this comment comment between aircraft and between aircraft and the another regulatory instrument, but it is essential for Special Condition will have to carry communication equipment ground/ATC. It is vital for safe operations that small- safe operations that they be treated with primary allowing communication between aircraft and between aircraft and category VTOL aircraft communicate with one importance, whether in the present proposed special the ground/ATC. These aspects are covered as for any other type of another and that ATC can manage their traffic in condition or elsewehere. aircraft outside the SC/CS. proximity to aerodromes. This includes for information on aircraft position/altitude/airspeed, ability to transmit and receive instructions related to traffic information and emergency procedures. VTOL.2310 4 These paragraphs refer to operating rules of an Embraer suggests to EASA for amending the Part-CAT YES YES Noted Not in the scope of the SC Embraer S.A. VTOL.2500(b) "Aircraft". However, there are only definitions for Air Operations rules, Regulation (EU) No 965/2012, to VTOL.2535 "Helicopter" and "Aeroplane" in EASA CS-Definitions include the operations conditions for Aircraft (VTOL). VTOL.2555 document and the Regulation (EU) No 965/2012 does VTOL.2615(b) not have the correspondent subpart for “Aircraft” in Part-CAT of the Air Operations regulations. TE.CERT.00142-001 © European Union Aviation Safety Agency. All rights reserved. ISO9001 Certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet. An agency of the European Union Page 1 of 227 227 EASA SC-VTOL-01 Comment Response Document Comment Comment summary Suggested resolution Comment is an Comment is EASA EASA response observation or substantive or comment is a is an NR Author Paragraph Page disposition suggestion* objection** 5 2Rolls -Royce Scope 1 Existing regulations can impose flight envelope Flight envelope regulation could be a useful tool to Yes Yes Noted This approach can be proposed within the frame of the SC restrictions to ensure safe operation. This does not achieve increased safety levels. appear to be part of the special condition as written. New aerospace companies may not appreciate the importance of this aspect. 6 FNAM Background/Sc 1 FNAM does not understand the differences between In order to ensure efficient understanding of the Suggestion Substantive Accepted Scope of the SC will be clarified. See Explanatory Note 1. ope VTOL and rotorcraft or (e)VTOL and certified drones. SCVTOL context, FNAM suggests to add a context Indeed, this kind of ‘aircraft may not be able to paragraph presenting the differences between: perform an autorotation’, this means that some VTOL rotorcraft, certified drones and VTOL. It could be may be able to perform an autorotation. operational and physical characteristics. Some rotorcraft operations may therefore be covered FNAM suggests EASA to ensure that current aircraft by several different regulations: VTOL and helicopter models such as R22, R44 and Cabri G2 helicopters are rules. For example, it could be the case of R22, R44 not covered by this proposed VTOL regulation. If they and Cabri G2 helicopters which are lighter than are, FNAM requests for an economic impact 2000kg. FNAM wonders what will be the regulation assessment which covers manufacturers, operators applicable when two different regulations are and maintenance organisations. applicable for the same model of aircraft. It may lead to different implementations of European rules. This will impact the European level playing field objective. If the proposed VTOL regulation becomes mandatory for current aircraft model, a significant retrofit work will be mandatory for manufacturers. FNAM fears economic impacts on operators, manufacturers and maintenance organisations will be important for this retrofit. 7 1Volocopter VTOL.2000(a) OBJECTION: Proposed to delete the term “person-carrying”. No Yes Not accepted “person-carrying” distinguishes this class of aircraft from remotely Person carrying is considered the more demanding piloted or autonomous aircraft (drones) with no person on board. Section (a) relates to person-carrying VTOL aircraft, operation, requirements for luggage compartments Cargo-only aircraft are within scope if the pilot is on board. while on the other hand already including provisions are adequately included and would require for remotely piloted or autonomous operation. consideration for cargo applications. Comparable CS do not differentiate between purpose as person- or cargo carrying aircraft; either use just makes specific requirements applicable, or not. SAFRAN Background/Sc 1/26 YES 8 2 It is precised in this document that a VTOL is an …with powerplant sytems/units units used to Not accepted Some VTOL configurations will have much tighter integration of ope 3/26 aircraft where the powerplant is now mixed with the generate powered lift and specifically controlled to engines/motors and flight controls than other types of aircraft and VTOL.2000(a) control system of the aircraft “…with lift/thrust units obtain flight characteristics. Aircraft subject to this the specificity needs to be addressed. Definitions of lift/thrust unit, used to generate powered lift and control. Aircraft Special Condition are not pressurized. lift/thrust system and flight control system will be clarified in the subject to this Special Condition are not pressurized.” Accepted Means of Compliance (AMC). For the rest of the document it is proposed to change This term used is unclear. The propulsion of the “Thurst/Lift” with “Powerplant systems” aircraft is a dedicated function and should not mixed with the lift system if the lift system is understood as to be part of the flight control. It is up to the aircraft manufacturer to use the propulsive system for the control of the aircraft. In addition Safran highlights the case of hybrid/tiltrotor configuration : Powered Lift in T/O and Landing, Classical configuration (fixed wing) for Cruise, for which this definition is only partially applicable. TE.CERT.00142-001 © European Union Aviation Safety Agency. All rights reserved. ISO9001 Certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA-Internet/Intranet. An agency of the European Union Page 2 of 227 227 EASA SC-VTOL-01 Comment Response Document Comment Comment summary Suggested resolution Comment is an Comment is EASA EASA response observation or substantive or comment is a is an NR Author Paragraph Page disposition suggestion* objection** SAFRAN Background/Sc 3/26 Yes 9 5 Question for Stakeholders : N/A Noted Autonomy is not currently in the SC. See Explanatory Note 3. ope VTOL.2000 Can passenger involvement be envisonned in “Safe flight and Landing” capability of an Autonomous Air taxi in Enhanced category? (For example choice of landing area). More generaly how is considered “Passenger interface”(for choosing Air taxi destination for example)?Is it considered as cockpit/flight control item, and therefore Passenger as a “unqualified flight crew” with limited flight management capability? SAFRAN Background/Sc 3/26 Yes 10 6 Question for Stakeholders : N/A Noted The VTOL projects that have been brought to the attention of the ope Agency for possible certification do not foresee aerobatics.