Eno Transportation Weekly
Op-Ed: Eno’s Certification Recommendations in Final FAA Bill
October 3, 2018
The Federal Aviation Administration Reauthorization Act overwhelmingly passed the Senate this week and is on its way to the President’s desk for this signature. The new law will address weighty issues like unmanned aircraft systems (UAS), security, consumer protection, and airport and airline operations.
Of course, establishing, implementing, and overseeing the standards for design, production, operation, and maintenance of aircraft, personnel, and safety systems is the FAA’s most important mission. The reauthorization directly addresses this critical role of the FAA—certification—in order to ensure public confidence in the safety of the system for business and leisure travel. With the industry changing rapidly as new technologies come online, the federal certification process needs to be more flexible and agile.
That was the main driver behind the recent work from Eno’s Aviation Working Group. In 2017, we released a comprehensive new report—Safer, Faster, Cheaper: Aviation Certification for the 21st Century—that made the case for an updated, streamlined federal process. The overarching goal is to shift the FAA’s focus from simply complying with prescriptive government mandates (outputs), to the impacts of the requirements (outcomes). We are pleased that many of these performance-based recommendations are part of the final legislation.
Importantly, our report urges the FAA to develop better metrics in order to measure the impact of the certification process. We called for the creation of a body to provide advice and recommendations to the Transportation Secretary on issues of safety certification. The law creates a Safety Oversight and Certification Advisory Committee (SOCAC) and directs it to, among other things, apply and track performance metrics. Related is our call for standardized education and testing of certification engineers and the law’s requirement for a procedures manual and centralized office at the FAA to ensure consistency.
Looking ahead, the Eno report also recommended that, when inevitably certifying new airspace products or users like drones, the FAA should not let itself fall into the tradition of mandating designs. Instead, it should work with the industry to develop performance standards that allow drones and space vehicles to safely operate and integrate into the national airspace, while allowing innovative solutions that account for technological advances. Here again, the focus should be on the outcomes and the law directs the FAA to develop a process for accepting risk-informed safety standards for UAS. How the FAA develops this process is critically important.
Updating the certification processes at the FAA poses a variety of challenges. The agency must cope with rapidly changing technologies while maintaining standards of safety. This is not an easy task for the FAA, as uncertain government resources might not keep pace with a growing and evolving aviation industry.
Yet the certification system needs to allow rule changes to be done quicker and focus not on administrative processes, but on collaboration and engineering safety analysis and oversight. The rules must be clear and when doubts on application or interpretation arise, there should be mechanisms for swift resolution. The goal should be to move towards the implementation of risk-informed, performance-based standards for both new and existing users in the nation’s airspace.
The new law is a step in that direction.