• 11 Nov 2023 03:22 AM
• 0

A Small Step for EHang, a Giant Leap for eVTOL

By Willi Tacke and Xin Gou, Flying Pages GmbH
Vertiflite, Nov/Dec 2023

On Friday, Oct. 13, EHang held a ceremony in Beijing to celebrate: the company had obtained the type certificate (TC) for its two-seat EH216-S Autonomous Air Vehicle (AAV) from the Civil Aviation Administration of China (CAAC). This was a momentous day for EHang and also for the expected future of electric vertical takeoff and landing (eVTOL) aircraft. There has been some debate about what this means, but first let’s run through some facts about this TC:

• It was the first TC issued to an eVTOL in the world.
• This is the first type certificate issued to a passenger-carrying, pilotless aircraft in the world.
• The TC was issued under CCAR-21 category, which is the rule regulating uncrewed aircraft systems (UAS). So, in essence, the EH216-S was certified as an UAS rather than a crewed aircraft.
• It is a Normal Category TC, not as a Restricted Category, nor a Special TC, nor as a Permit to Fly.
• According to the type certificate datasheet (TCDS) for the EH216-S, the TC comes with a list of restrictions for operation, some of which appear to be quite strict and might thus hinder the commercial feasibility and use case of EH216-S.
• It took two years and 10 months for CAAC to issue this TC, from the date of acceptance of EHang’s application (Dec. 28, 2020) to the issuance date on the TC (Oct. 12, 2023).

There are a number of steps that EHang must complete before legal commercial operations can begin, including obtaining the production certificate and the operator certificate. In addition, there are still some regulatory gaps that CAAC needs to fill — especially in the flight standards domain — before eVTOL aircraft can be a real market in China, such as the qualification and licensing for the ground operators, vertiport design, construction specifications, etc. Although there are detractors about CAAC’s lack of transparency and accident reporting, a TC is a TC, no matter what — just the same as the TC issued by CAAC for the RX1E electric light-sport aircraft (LSA) in 2015. You may not have heard of RX1E, but that LSA type certificate indeed made RX1E the first type-certificated electric airplane in the world… and not the Pipistrel Velis Electro, which was certificated by the European Union Aviation Safety Agency (EASA) in 2020.

We can debate the validity and limits of the EH216-S TC, and the intention — and perhaps even the qualification of CAAC — but in the end it’s CAAC’s authority to decide whether to give an aircraft a TC or not. Once the document was signed by CAAC — a legitimate civil aviation regulator recognized by international laws and bodies — it became a legal proof of meeting the Chinese government’s airworthiness requirements.

Nonetheless, the issuance of this TC is symbolic and strongly indicates CAAC’s desire to lead the global eVTOL race. A first is a first, after all.

The effect of this TC could be double edged, however. On one hand, it will likely raise the awareness and interest of investors and the eVTOL market in China, as shown in the popular report of this news in mass media and the financial media in China. According to an unofficial count, there have been about 50 eVTOL designs at different stages in China, including about 10 projects at substantial stages with either a flying prototype or a considerable amount of capital for development.

On the other hand, the doubt on the validity and feasibility of this TC in the professional community may cause a backfire on the intention of CAAC to promote eVTOL and the application of airworthiness of other eVTOL models in China, because CAAC now needs to convince the market and other applicants that it plays by the rule book to create a level field for all players.

The EH216-S was approved with a maximum takeoff weight of 1,367 lb (620 kg), an 18.6-mile (30-km) range, a service ceiling of 394 ft (120 m) above ground level (AGL) and 3,280 ft (1,000 m) above mean sea level (MSL), and a maximum cruising speed of 48.6 kt (90 km/h). The aircraft has a maximum flight duration of 25 minutes with a 25% battery reserve (though the flight conditions were not specified for the reserves). It also requires two ground operators, though it wasn’t stated how many aircraft the two operators can control or monitor at the same time. These performance data — especially the servicing ceiling — certainly make commercial operations tricky and use-case limited.

The glory of the many titles of the “first” of this TC — especially being the first certified passenger-carrying pilotless aircraft — will certainly raise a lot of interest, as well as curiosity and reasonable doubts. After all, extraordinary claims require extraordinary evidence. CAAC needs to provide more transparency of the certification process if it wants to uphold the value of this TC over time.

CAAC officials have stated publicly that the agency wants to take a gradual but steady approach towards full commercialization and operation of eVTOL — with parallel rulemaking in both certification and operation at the same time — which means that CAAC is perhaps willing to take the risk of letting EHang begin operations earlier, rather than later. For this purpose, a TC is a must-have in terms of procedure requirement, while having some restrictions to counterbalance the operational risk. Therefore, it will be more interesting than the TC itself to see the scope and scale of the EH216-S’s commercial operation in the near future, and how soon and what steps CAAC takes to remove those restrictions down the road. After all, a TC with many restrictions even under Normal Category is not good enough for practical commercial operation and to convince the industry of the future market.

Considering the attitude of the EASA and the US Federal Aviation Administration (FAA) towards passenger-carrying autonomous aircraft, it is high unlikely that the EH216-S will find a way to validate its TC outside of China (at least in Europe and North America), so the impact of CAAC’s decision to issue this TC to EHang will likely be limited only in China (and those nations that recognize its certification authority) in the foreseeable future.

Coincidently, just a few days before the issuance of EHang’s TC, Joby announced piloted flight testing of its air taxi (see “Joby Delivers,” Vertiflite, Nov/Dec 2023, with more than 30,000 miles (48,030 km) of remotely piloted flights. These two pieces of news happening almost at the same time clearly show the different mentality of the American and Chinese regulators. However, as the first certified passenger-carrying autonomous aircraft, operation of the EH216-S and the reaction of the market will surely be closely observed by the industry both inside and outside of China (particularly as EHang is listed on the US Nasdaq stock exchange).

With all things considered, this TC may be a small step for EHang at this moment, as the initial restrictions are rather limiting, but it is a giant step for eVTOL as an industry — and as a novel aviation product — because a major regulator issued a TC. The effect of this TC certainly remains to be seen. In this sense, this TC may not be the end of EH216-S’s story, but more likely just the beginning of a bigger story. After all, eVTOL aircraft, just like any product, must prove their economic value in real use for developers, users and investors to be regarded as a success.

Of course, if an aircraft is certified prematurely and it is proven that it is not as safe as it should be, this kind of early commercialization can harm the whole industry as well as the credibility of a Chinese airworthiness certificate.

For example, there have always been concerns about the open propellers low above the ground in an area where there may be people or obstacles. This could potentially harm passengers or bystanders in case of an incident. Or the propellers could be damaged in a not-perfect landing. If this damage is not detected, it could lead to a later accident.

It is hoped that CAAC will (like every authority should) issue strict operation rules that will try to avoid accidents in general, and especially accidents where people might be injured or even killed.

A TC has a lot of chances to bring the development forward, but it also requires a lot of responsibility on the part of the manufacturer, the operator and the regulator.

About the Authors

Flying Pages (www.flying-pages.com) is the publisher of several general aviation magazines in German, English, French and Chinese. Willi Tacke is the CEO and Founder of Flying Pages GmbH, based in Germany, and Xin Gou is the Vice President. Tacke has been working for aviation publications since 1983 as an editor, test flight editor, editor in chief, publisher and presenter. Pioneering advocates for electric aviation, Flying Pages is the founder (2009) and organizer of the annual e-Flight-Expo, the world’s first electric aviation trade show at AERO Friedrichshafen in Germany, as well as the founder (2017) and organizer of the annual e-Flight-Forum in China.