Review of FAA Commercial Aircraft Certification Process should not Over-react; an Answer may be in Process

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ARTICLE: Dreamliner Prompts New Look at Aircraft Safety Reviews

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One of the most valuable documents issued by the FAA is a Type Certificate. What is required to demonstrate that a commercial aircraft is airworthy is defined in the regulations (14 CFR Part 25). Those rules have been in place for decades and the challenges posed to the agency with the responsibility for and challenges to certificate a transport category aircraft have remained relatively constant over that time.

The B-707 was a technically advanced aircraft in 1954; the FAA had to deal with turbojet engines, swept wings and a variety of advancements in civil aeronautical design then. For example, the first commercial jetliner, the DH Comet, had several mysterious crashes; so the FAA had a full plate of technology challenges to address in that TC application. Every generation of new airplanes has pushed the envelope and the FAA has met the challenge each time.

The FAA has recognized that the private sector is more capable of innovating faster than its resources are capable of regulating. To meet this capability differential, there are classes of recognized, independent experts who have demonstrated their technical knowledge about the design proposal and competence to assess airworthiness (Designated Airworthiness Representatives – DARs) and the engineering in those drawings and data (Designated Engineering Representatives – DERs). These auxiliary talents help the FAA make technical judgments.

A third and larger source of technology capacity is the Organization Designation AuthorizationODA. Under these rules, the collective expertise of duly qualified individuals can supplement the FAA’s oversight of certification. While most of the DARs, DERs and ODAs are independent of any TC applicant, the regulations permit these authorities to be extended to the manufacturer.

This structure is well known to the Congress in that the Hill has specifically reviewed and approved of the FAA’s use of these adjunct resources. The statute was amended to include the designee function.

From a recent Congressional history standpoint, the Hill budgetary powers have consistently looked for ways to reduce the FAA’s staffing. To decide now to increase the spending on internal expertise would represent a radical change in their fiscal trend line. As suggested in the WSJ article, adding experts with exceptional knowledge of emerging technology may not be the wisest response. Note: such talent is likely to be highly priced. Further, the individual with such narrow knowledge will be underutilized by the specific, new technology issues created by one or two TC projects.

The real future promise in the Type Certification arena was defined by an Aviation Regulatory Committee examining Part 23. The potential for this new approach to certificating non-commercial aircraft was the topic of a speech by the Administrator. Relevant to the above article, he said:

Instead of specifying a design – we are specifying a safety outcome that we would like to see.
We are taking a less prescriptive approach which will allow for greater innovation in the marketplace. Our goal, as always, is to enhance safety and to decrease accidents. But we are less wedded to one particular pathway to achieve that goal.

The committee has suggested switching from criteria based on an airplane’s weight and propulsion to criteria that correspond to the aircraft’s performance and its complexity.

The engineering leaders at the companies here in Wichita have been key to the success of the Part 23 rule making committee this year. We are working with governments in other countries and with industry around the world to determine what does this translate to in terms of appropriate standards.

You are really helping us reach this goal of enhancing safety while decreasing the cost associated with certification. Our goal is to improve general aviation safety and to cut certification costs in half.

The transfer of these certification concepts from the rules applicable to smaller GA airplane to those that define the TC standards/processes for the transport category aircraft is not guaranteed. However, if it is successfully implemented in the Part 25 context, FOCUS will improve.

The ARC regulatory innovation is, before the actual tests are defined, to review the proposed design to identify the challenges and to point the available resources at the critical issues. Using the WSJ example, it would be anticipated that the inclusion of the new ion lithium battery would merit such added attention. Under the new Part 23 ARC process, issues concerning a new battery would not require the incredibly slow promulgation of new regulatory standards. Under this new approach, having identified the challenge, the assessment of all aspects of certification of a new material or mechanism or any innovative technology would be referred to the industry experts, the ASTM committee with international, multi-industry experience on the specific issue.

The tumult associated with the B-787 has created a lot of heat, but has not shined much light on the subject. This is not the time to panic and to advocate major, drastic changes. There are resources presently available for the expert review of innovation, but the greatest potential for a solution may lie within the FAA’s existing regulatory innovations.

THE SKY IS NOT FALLING. Yes, there may not be all blue skies above right now, but there is reason to believe that the FAA is evolving – through its own internal reviews – to a regulatory regime which matches the innovation of their TC applicants.

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