Quadrilateral Aviation Certification Agreement
FAA, ANAC, EASA & TCCA
The Federal Aviation Administration (FAA), Agência Nacional de Aviação Civil (ANAC) of Brazil, European Aviation SafetyAgency (EASA), and Transport Canada Civil Aviation (TCCA) have announced a strategy (PDF) to develop and implement policies that streamline certification. The Certification Management Team (CMT), that group of 4 Civil Aviation Authorities, issued a Validation Improvement Roadmap (PDF) (VIR) that defines the specific multilateral initiatives. The timeline defined in that document is aggressive, but if successful, could lead to a dramatic acceleration of the introduction of new aviation products BASED ON THE REDUCTION IN THE REPETITION IN EACH’S CAA’S SEPARATE CERTIFICATION TIME.
At a distance, it would appear that the work of the CMT may well have been a tremendous spinoff of the collaboration between CAAs about a radically different certification process/standards for Part 23 aircraft.
As demonstrated by these charts, the aerospace industry is global with air frame, powerplant, avionics and various subsystem OEMs headquartered in many countries plus manufacturing sites in a longer list of nations. Each Civil Aviation Authority around the world holds as a highly guarded sovereign right the power to approve or disapprove the certification of aircraft to be flown in their airspaces.
In reality, the primary airworthiness judgment, followed by most CAAs, is exercised by a few CAAs which have the expertise necessary to make such safety approvals.
In the past, when a company considered the development of a new aeronautical product, the timeline starting with first drawings and ending with global introduction had to include long blocks for CAA-by-CAA approvals. CMT’s VIR program could reduce the repetitive certification delays.
The statement of the CMT’s strategy best articulates their approach to this project:
“The CMT will oversee and manage collaboration efforts to permit the development and implementation of regulatory and policy solutions common to certification issues and support greater harmonization of our systems. The CMT vision is to use active confidence building initiatives and risk-based validation principles to accept partner certification activities with limited or no technical involvement. The CMT understands that maximizing the use of existing bilateral partnerships to accept approvals and findings made by our partners is essential to reducing the resources currently expended on validation programs.
In May 2016, the CMT signed their Collaboration Strategy identifying four high-level strategic focus areas to realize the CMT vision. These focus areas are
- Partnership Leveraging,
- Continued Confidence Building,
- Global Leadership, and
- Certification Policy Alignment.
The CMT is working in a quadrilateral fashion to address these focus areas with the understanding that the scope of the bilateral agreements are not always aligned. In light of this, the CMT recognizes partners may develop bilateral validation improvement roadmaps to address the four strategic focus areas more efficiently in the near term.
We believe the CMT Collaboration Strategy will produce significant progress towards our bilateral goals and the CMT’s vision to use active confidence building initiatives and risk based validation principles to accept partner certification activities with limited or no technical involvement
The CMT has focused its work on the major TC groups, which are listed as follows:
- Certification Authorities for Bilateral Agreement (CABA) and Certification Policy
- Certification Authorities for General Aviation Products (CAGP)
- Certification Authorities for Transport Airplane (CATA)
- Certification Authorities for Rotorcraft Products (CARP)
- Certification Authorities for Propulsion Products (CAPP)
That is a huge statement. CMT, if fully implemented, would replicate the multilateral structure of the unification of the European Nations into EASA or the North American Free Trade Agreement. While EASA has had some initial successes, there has been some resistance as the Brussels organization seeks to extend its direct authority into the individual sovereign soils. While not directed at EASA directly, one might make the case that BREXIT was a sign of pushback by that Island Nation to Pan European standards.
Much of the VIR agenda shows a very tight deadline; is this an indication that the quadrilateral comity is already at a very high level or just a high level of euphoric optimism? Here are some of those goals:
You read over these and make your own judgment as to whether/when they are achievable?
Here are some other questions not fully explained in the documents:
- A major policy issue, not addressed in the press release, is why other countries are not included in CMT, like:
- The United Kingdom (if it is no longer a Member of EASA?)
- If a country is not part of the CMT, their aeronautical products will be at a significant disadvantage.
- Does CMT expect any repercussions from such exclusions?
- Why is there no explanation for exclusion?
- Is there some sense that the non CMTs are incapable of some of the technical assessments requisite to making such judgments?
- If true, are diplomatic considerations the reasons why there was no explanation?
- If a non-CMT CAA follows the VIR standards, will CMT accept such a certification with a higher level of comity?
- Will other countries be able to join CMT and what might be the admission standards?
- How will ICAO view this transnational aviation safety standard setting and implementing organization as a threat?
- Will CMT include ICAO in its proceedings?
- Will CMT directly or through its members or through ICAO share its advances with other CAAs?
- Will CMT include reciprocal site surveillance?
- Will, for example, the FAA be expected to watch the Brazilian Embraer OEM operations in the US?
- Would EASA review the operations of a GE, for example, plant in Germany?
- How will the four parties assure consistency within CTM –
- For example, if OEM A claims that OEM B was treated differently, how will such a conflict be resolved?
- Will there be any mechanism for auditing within CMT?
- Will there be any centralized resource for one CAA to resolve ambiguity before setting its TC design parameters?
- The FAA has a high level BASA with, for example, Israel that sets the basis for an FAA acceptance.
- Will EASA, within this hypothetical question, accept this 3rd country BASA approved product
The Administrator’s FAA’s Global Leadership Initiative prioritizes and targets resources to engage with the international aviation community to improve safety, efficiency, and environmental sustainability through regulatory harmonization and partnerships. CMT’s implementation will result in an even competitive field on certification.
It is not 100% clear that EASA’s strategic plan to spread its aviation safety standards among the CAAs of the world will be diminished by this collaborative effort? In other words, will the CMT harmonization reduce the need for planting flags around the world?
The CMY initiative is a most promising quadrilateral effort which could stimulate aeronautical innovation timeline. Its promise and possible perils remind one of Robert Frost’s famous poem, Stopping by Woods on a Snowy Evening.
Whose woods these are I think I know.
His house is in the village, though;
He will not see me stopping here
To watch his woods fill up with snow.
My little horse must think it queer
To stop without a farmhouse near
Between the woods and frozen lake
The darkest evening of the year.
He gives his harness bells a shake
To ask if there’s some mistake.
The only other sound’s the sweep
Of easy wind and downy flake.
The woods are lovely, dark and deep,
But I have promises to keep,
And miles to go before I sleep,
And miles to go before I sleep.
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