Published in Aviation Week & Space Technology online, November 1, 2017
Published as Aviation Week & Space Technology magazine “Viewpoint,” November 13, 2017
Republished by permission of Aviation Week & Space Technology
Global commercial aviation certification has challenged airline OEMs and suppliers for decades. While flight safety has improved significantly over the years, the certification process still delays innovation, keeps OEM and airline costs needlessly high, increases ticket prices and encourages bureaucracy.
Just one example tells the story. It used to be that for a new avionics system, 75 cents of each dollar was spent on engineering and 25 cents on certification by global agencies. Today, that ratio has changed significantly. In many cases, it costs more to certify a new avionics system than it does to develop it in the first place. This relationship between engineering and certification costs cannot be sustained if our goal is to deliver high-integrity, cost-effective products to the customer.
At the core of the aviation certification challenge is the lack of global harmonization, a desired end state where certification standards and procedures are similar, and, importantly, mutually recognized and accepted within each of the global certifying authorities, the six biggest being: the U.S. (FAA), Europe (EASA), Canada (TCCA), Brazil (ANAC), Japan (JCAB) and China (CAAC).
While the relationships between these certifying authorities are cordial at the senior executive level, mistrust is common at middle-management levels and below. This lack of trust leads to second-guessing and the demand for duplicative certification—many times on systems that have been flying for years with no safety issues. This is a waste of time and financial resources.
It used to be that for a new avionics system, 75 cents of each dollar was spent on engineering and 25 cents on certification by global agencies. Today, that ratio has changed significantly.
Here’s an example that amplifies this point. After completing a comprehensive FAA certification on one of Rockwell Collins’ integrated avionics systems, it took an additional seven years to get approvals from five international authorities. Tens of millions of dollars were spent with one certification authority alone because it demanded its own redundant engineering and certification tests rather than recognizing the FAA’s approval and validation. Despite jumping through numerous hoops over many years, in the end it resulted in no safety improvements. It was a preposterous experience.
A second big issue in certification is the fee and compensation structure of some foreign certifying authorities, which incentivize duplicative efforts. For example, one certifying authority charges both flat and hourly fees for certain types of certifications. This structural framework is a disincentive to a timely certification process.
Changes are needed. Here are three recommendations that would help:
Affirm Interagency Trust as the Foundation of Certification
The terminology for what civil aviation authorities are required to do once one of them certifies a system is “validate.” Validate does not mean conduct redundant certification activities. Interagency trust is the key requirement. When one of the six big aviation authorities certifies a new system, the default position of the other authorities should be to recognize that certification and expedite validation, absent data or evidence that calls the original certification into question. To achieve this goal, certifying authorities must have an alignment of purpose—aligned roles and responsibilities that they recommit to following.
Slow progress is being made. In February 2016, the FAA and EASA approved a “road map” aimed at reducing the time and costs associated with certification. There are, however, four other big global certifying authorities. This road map must be expanded globally to be truly effective.
Move to a Risk-Based Certification System
According to the FAA’s own website, the aviation environment has reached a level of complexity where it “cannot achieve further safety improvements by following a purely rule-based approach.” Consequently, the FAA’s stated desire is to focus certification resources based on risk rather than solely box-check compliance against all rules.
We applaud and encourage the FAA’s movement to a risk-based certification system. We need to accelerate these efforts in the U.S. and institute a risk-based system globally.
The U.S. Congress must act. Provisions in the pending House and Senate FAA reauthorization and fiscal 2018 appropriations bills would drive important certification reforms at the FAA and require more aggressive engagement by the FAA in foreign markets to expedite the validation of FAA-certified products and safety standards. Not only is certification reform necessary, it should be a national priority. Aviation contributes $1.6 trillion in total U.S. economic activity, supports nearly 11 million jobs and accounts for over 5% of the U.S. GDP. Civil aircraft manufacturing continues to be the top net exporter, generating $53.4 billion in positive impact on the U.S. trade balance.
This is not an appeal for less oversight; it is crucial to the future of the global aviation industry that we have robust certifying authorities. No, this is an appeal for accelerated action—accelerated action between the global certifying authorities and accelerated action by the U.S. Congress to adopt much-needed reforms. These reforms should enable the seamless transfer of certified technological advancements and safety enhancements for commercial aviation across geopolitical boundaries.
Let’s get this done!