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Abstract

The dark adage "regulations are written in blood" can be constructively viewed as the FAA's commitment to continuously improving and regulating aircrafts to promote aviation safety. The Changed Product Rule defines specifically when the newest regulations are applicable to the certification of a derivative aircraft, and when old regulations can be legacied into a certification plan. After the tragic Boeing MA4X crashes, industry experts called for a reassessment: is the Changed Product Rule doing its job of ensuring safe design and certification of derivative aircraft? This Comment addresses this question, and advocates for targeted and practical changes to three areas of the Changed Product Rule, with the goals of ensuring a satisfactory scope of certification review, addressing issues with the use of the Impracticality Exception, and minimalizing variation creep. The modifications proposed to address these issues demonstrate how certification requirement differences could have impacted aircraft design and the likelihood of the previous tragedies.

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