How Safe is Too Safe?

A version of this article first appeared in the November 2018 edition of our free newsletter, to subscribe click here

 We have technical input into many aircraft development programs that are flying or intending to fly prototypes of new aircraft or major modifications of existing aircraft.

These aircraft fly under experimental flight certificates and as such the development team have some leeway when it comes to the standards that should be met to demonstrate safety of flight.

Of course, everyone is working towards aircraft that safeguards the life and well being of the pilot and the life and wellbeing of people on the ground.
However, there is a trade off between safety and cost – and the budget is always limited.

So how do you spend your budget to achieve an adequate level of safety? What is an adequate level of safety? What level of documentation is appropriate?

Initial flights of new or modified aircraft always carry an elevated risk. This is why you use a professional test pilot who is critical in helping manage those risks. But how much risk is appropriate? How do assess the risks? How do you mitigate the risks? What about the risks you don’t know about?

Aspects of a program that affect the level of Risk:

    • The uniqueness of the modification – the unique aspects of the configuration of the aircraft or modification?
      • How similar is your design/configuration to other aircraft. Are you developing a multi propeller, canard, Quadraplane?
    • The maturity of the technology utilized
      • Are you using a new design of engine? Trim servo motors? Glass cockpit? New design of Seat? New composite material? New anything?
    • The complexity of the technology utilized
      • Chaining together tried and tested technology is only as reliable as the compounded reliability of the individual components. How carefully have you looked at the reliability of the aircraft critical systems?
    • The experience and competence of the team
      • Aviation history is full of very smart people doing very dumb things. Intelligence is not a guarantee nor an excuse nor is it a substitute for competence.
    • The maturity of the infrastructure and company systems the team is working within
      • Are you working within a set of company systems that guide you through the process of product development and flight safety?
      • Are you developing these systems as you go along?
      • Have you missed anything?
      • How would you know?
    • The experience and competence of the pilot
      • The test pilot is the final gatekeeper of flight safety risk in the input they give at the flight safety reviews, during high speed taxi and flight. They are responsible for making real time risk assessments – real life and death decisions. You need the best possible pilot and you have to give them the best possible information.
    • The reliability of the predictive tools used by the development team
      • What kind of analytical assessments are flight safety based on? Estimates? Empirical analysis? Software simulation? Lab or ground testing? Did you fly a scale model? How does the likely accuracy of the results of the design process affect safety of flight?
      • The flight envelope of the aircraft
  • How do you plan to conduct your flight testing?
    • What test points are you planning to fly?
    • How cautious are you with regard to expectations for first flight and how aggressive are your plans for envelope expansion?
    • How will you communicate the appropriate level of concern to the pilot?
    • How will this level of risk be reflected in the flight test program?
    • Even the best test pilots get into a warm and fuzzy state as their confidence increases with each successful test flight. Are the risks being reiterated on a regular basis? Is the pilot being reminded of the margins of safety of the flight envelope?

I have just spent a week with a well known part 23 OEM and their approach to flying prototypes reminded me of the difference between composite and metal aircraft. This informs the level of confidence in the structure of each.

Composite aircraft are thought to be sized to withstand ultimate load with maximum undetectable damage at 180F when saturated with humidity. In reality the structure is sized to conservative strain limits that prohibit damage growth at maximum barely visible damage at the hot wet condition and so the ultimate strength of the pristine structure at nominal service conditions usually has very high residual strength (buckling notwithstanding).

Metal aircraft are typically sized to real static failure modes at ultimate level – you have the forgiveness of yielding and plastic redistribution but in general metal aircraft have lower overall static residual strength than composite aircraft at the start of their service life.

Note that the systems are generally the same for both metal and composite aircraft and require the same level of caution and anxiety…..

With composite structure there is always the specter of process control, especially of bonded structure. While this field is now relatively mature it is still the victim of a far greater sensitivity and variability than metal sub assembly processes. Careful process development backed up by some testing and simple shop guidelines have a far greater effect on the final aircraft strength than tweaking the material selection or increasing the bond width by 10%.

To Summarize:

  • Engineers should not forget that there can be large differences between the CAD model & analysis and the actual aircraft that is built and flown. Not only does the engineering have to be rational and correct but the build process also has to be rational and correct.
  • Many incidents occur because of simple errors in the implementation of a good system design or insufficient pre-flight checking and testing of those simple systems.
  • You need a team of people and everyone needs to keep on top of their game.

And finally:

  • You need leadership capable of understanding all the issues and making the most difficult decision of all: Not to fly.

Competence, Authority and how to get it wrong……

A version of this article first appeared in the October 2018 edition of our free newsletter, to subscribe click here

I would like to thank a trusted contact for asking me to review some paperwork as it provided a great teachable moment for myself and my class – and a good subject for the newsletter. I can’t mention them by name but you know who you are. Thanks.

As part of the course that I teach at UCCI we have just covered some engineering ‘disasters’. Events caused by insufficient understanding, inadequate assessment or generally bad engineering.

It is important for an engineer to understand that things do go wrong. Not often, but they do. Understanding the root cause of failure is the only way to consciously avoid the same situation.

Sometimes even the understanding and knowledge of what you should do cannot overcome the general sunny optimism that both bless and curse humans. The week that I was teaching this important element of engineering reality I was sent a perfect example of optimism overcoming common sense.

Over the years I have ended up with a large network of aircraft developers and operators. One of them called me because of a concern they had with an aircraft that was flown in to their facility to have some work done.

The small composite aircraft had a major change to one of the wing spars at the root (for those of you who are not in the know the spar is the element of the wing that carries the bending load created by the wing lift and the root of the spar – where it meets the fuselage- carries the highest bending load.)

This major modification (or repair, it was not clear what the reason for the change was) carried with it a one page qualification.

To put that in perspective, we are doing a small amount of work for a famous part 23 OEM – writing substantiation reports for equipment going into their flight test aircraft. The oxygen bottle installation report runs to 30 pages.

The one page qualification consisted of 3 paragraphs of prose and a diagram.

  • The first paragraph was a description of the level of competence of the author. He is a professor emeritus at a university, he has written textbooks, he is a lifetime member of an industry body (I never understood that, was he inducted as he passed out of the birth canal?). In his own words he is experienced, competent and respected by his peers.
  • The second paragraph was a verbal description of the change, it contained some vague terms but overall was ‘okay’ as far as it went.
  • There was a diagram of the change.
  • Then there came the all Important qualification: “I have done no analysis of this change but it is many times the strength of the original design. In my opinion this is adequate”. That was the start and the end of the substantive component of the qualification, and marked the end of the document apart from the signature of the author.

Even if it is your opinion that the change was adequate, you still do the analysis, even a simple one. You might even add some qualifications to your assessment. How about “assuming that good practice was followed with regard to material choice, material handling, surface preparation and curing during the implementation of change by the manufacturing team…….”.

There are several problems here:

  1. There is no numerical demonstration that the change is adequate and therefore there is no evidence that the aircraft is safe to fly
  2. The description of the change is inadequate, there is some geometric definition and some generic materials mentioned but nothing specific enough and it is incomplete.
  3. The engineer has used an argumentum ad verecundiam (an appeal to authority without evidence) in order to convince somebody else that the aircraft is safe to fly
  4. The engineer has exposed the occupants of the aircraft to unnecessary risk
  5. The language that the engineer has used demonstrates his own negligence and creates clear liability for the engineer.

Engineers have to be aware that not only are they responsible for the safety of others, but they also have a responsibility to give clear evidence that the appropriate level of safety has been achieved.

This is necessary to safeguard the public – even if the design appears to be strong enough, some level of analysis has to be done especially if the structure is one of the most critical components of the aircraft. The engineer has to be more than sure and has to prove to himself or herself (xerself?) that safety is proven.

It is also necessary to maintain your ethical standards as an engineer. Are you really that clever? Are you really that sure? Is your opinion so valuable that a quick calculation would somehow degrade your authority?

This is also necessary to achieve a level of personal protection against future claims of liability. You work hard for your money and your family. Do you really want to put all of that on the line because you can’t be bothered to spend an extra 15 minutes getting it right?

This was a particularly poor example and is similar in nature to the Hyatt Regency disaster of the mid 1980’s when over 100 people were killed because of a change in the design of a walkway that the engineer thought was strong enough and failed to do any analysis for.

The irony is, the engineering professor who wrote and signed the substantiation for the wing spar has probably used the Hyatt Regency incident as a subject in one of his classes.

It is also worth noting that on the sketchy substantiation of the wing spar, there was no checking signature. An engineer (or a good engineer) does not trust his own assessment without a second pair of qualified eyes to review, spot errors and validate the work.

Every step of the engineering has to be specific, accurate, comprehensive and clear. Failure to meet these minimum standards endangers people, your own well being and the well being of the organization you work for.

Do it right, do it once and get it checked.

Space Center Houston – The Elephant’s Graveyard

A version of this article first appeared in the October 2018 edition of our free newsletter, to subscribe click here

For our sons sixteenth birthday, we paid a visit to the Houston Space Center. None of us had ever been to any of the NASA sites before so we were really looking forward to it.

The Houston Space Center has one of the decommissioned shuttles (Endeavor) mounted on the converted 747 carrier aircraft, which was super cool.

They have a full, unused (of course) Saturn 5 rocket and many smaller exhibits.

You can also take a guided tour of the Johnson space center and Houston’s famous ‘mission control’.

We saw all of these things and took the tour and it was all large and impressive and slightly sad.

In the spring of 1981 I was a 10 year old in primary school in a small yorkshire village in England. The head teacher (there were only two teachers in the whole school) cancelled classes for the day as we spent the day watching the first space shuttle launch on live broadcast from Florida.

I remember that this took pretty much the whole day as the launch was delayed multiple times and we spent a lot of the waiting looking out of the windows at the unseasonably warm and sunny weather wanting to get out there and play.

That was 37 years ago. The engineering for the shuttle started in 1968 – before I was born.

The Saturn 5 rocket – which is even more physically impressive, originates in a design formulated in 1962 – 56 years ago.

You could buy models of the Northrop T-38’s that NASA use for……well, I’m not sure what, probably training the astronauts but probably more for just hot-dogging and having fun. The first flight of the T-38 (F5) was 1959 – 59 years ago.

These things are very impressive. They are also very old.

To put that in context – when my 10 year old self went to a museum in 1981, exhibits that were 59 years old would have dated from 1922.

The Houston Space Center is a museum and it is full of old artefacts and exhibits. I loved it – this is the technology that inspired me when I was a child and seeing it up close was just great.

The space shuttle and the 747 carrier aircraft were too sanitized and cleaned up to the point where the interiors looked like mock-ups . I had more fun looking up into the landing gear bay of the 747 because is was real – greasy and grimy and full of exposed systems, hydraulics, P-clamps, sheet metal and rivets…….but it was all great.

It is also evident that NASA has much more to say about their past than their future.

If you go the the NASA website it is difficult to find out what they think their mission is. I am not a fan of corporate mission statements but they are useful in providing clarity of purpose when nothing else does.

The front page of the website ( has some things they are doing – but no clue as to what the purpose of the organization is.

The ‘about’ page ( is also unclear on why NASA exists. There is this phrase “NASA’s Vision: We reach for new heights and reveal the unknown for the benefit of humankind.” but you could use this same phrase for a Pentecostal church organization and it would probably be more relevant.

How about “Exploring Space” or “Colonizing the Solar System” or “Making Manned Spaceflight an Everyday Event”. How about something….anything?

The sidebar of the ‘about’ page lists the further web pages you can spend your time visiting that show how compliant they are with US federal requirements and standards: Privacy Program, National Aeronautics and Space Act, Open Government, Plain Writing, Information Quality, Communications Policy.

Experienced university graduates (probably with doctorates) writing web pages filled with prose about internal NASA policies and procedures that demonstrate compliance with federal policies that give an acceptable method of compliance with federal regulations that ensure that NASA are fulfilling their important federal statutory obligations.

Wow – I wonder how we ever got into space before we had all this.

So, NASA has lost their way – their budget is not what it used to be and so their role cannot be what it once was. But, what is their role?

NASA has done some great work in recent years – the mars rovers are phenomenal and the data they have sent back from Mars is incredibly exciting and important. To put that in context the mars rover programs have cost $2.5Bn and have been running since 1994. Since 1994 Nasa has received (in 2018 dollars) $460Bn.

The rovers have cost around 0.5% of the total NASA budget.

You can get more information on the NASA budget breakdown here:

Examination of all the goals defined in these documents that the organization is trying to achieve gives clear evidence of diffusion of effort and dilution of achievement.

So what should NASA do?

Should they exist as a research and artefact curating organization and slowly settle back into the role of maintaining the infrastructure from a time when they were funded and focused on their mission?

Should they close down their museums, rationalize their budget and focus solely on getting people into space again?

The Houston Space Center is worth a visit, we had a great day – it is a great reminder of what we can achieve – but not of what we are, or should be, achieving now.

Freedom of Speech, Contrary Opinion and the Engineer

A version of this article first appeared in the August 2018 edition of our free newsletter, to subscribe click here

I always thought the concept of freedom of speech was non political. I thought it was essential for a healthy society in the same way it is essential for a healthy organization.

It is my assessment that the politicization of the concept of freedom of speech is a bid for power in the present that will cause a decline in the long term health of society. Just like a restriction on discussion and communication in an organization will cause a decline in the health of the organization.

I have worked on two programs at two different OEMs where both the organizational chart and the schedule were secret and where meetings were shut down for speaking the truth. These programs both failed. One of the OEMs has gone through at least one bankruptcy and at the other the program was cancelled, the company was reorganized and has since been sold.

I am sure we have all worked in companies where political expediency is valued above commercial or technical excellence. We all know how painful it is to bend your psyche to fit into a warped notion of ‘common sense’ and live that reality every day.
The low cost purchase of expediency in the present for the long term cost of dysfunction, high staff turnover and eventual failure.

Apparently this culture is now deemed a good way forward for society as a whole. Companies that are run along these philosophical lines can go bankrupt and be replaced with a better functioning alternative. What happens when the society you live in elects to follow this path? What kind of philosophical, moral bankruptcy will result? And what will replace the society once it has been broken beyond repair?

It is clearly a better alternative to do what you can to save both the dysfunctional organization and, I would say essential, to save the dysfunctional society.

So what steps can you take to make a positive difference inside a dysfunctional organization and how does this relate to how to improve society?

1. Personal: Never compromise your personal integrity. If it feels wrong, if you are telling a lie or if you are hiding any truth you need to stop. Always tell the truth.  A good project manager once told me “if you are in a meeting and you are not comfortable with everything you discuss being on the front page of tomorrow’s newspaper you are doing something wrong”.

2. Emotional: Never lose your temper. No matter how much pressure you are under or how unpleasant your professional life may be always remain courteous and calm. Shouting does not win arguments and a smile and a shared joke puts people in the frame of mind to compromise and be flexible.

3. Professional: Be the best you can at what you do and share your skills and knowledge as widely as possible. Do not be selfish – share credit and accept blame. When someone corrects you accept it with gratitude – no matter what the intent of criticism is, it can make you better at what you do – use it.

The three points above are the things that I learnt from my own mistakes and missteps and while following them can be hard, not following them will generate a much worse result in the long term, both for yourself and others.

These points are good to apply in any industry. In engineering where bad designs, poor decisions and errors can cost lives I see them as essential. If I catch an engineer in a lie, or trying to hide an unpleasant truth they are a financial and ethical liability and their value as an engineer is effectively zero.

These are the standards that I use to judge myself and the people in my industry.

These personal standards rely on freedom of speech for me and freedom of speech for everyone else, no matter how much I may want to avoid what they have to say.

If we select to live in a culture that allows the suppression of ideas that we do not agree with, that are unpopular or even just wrong, where does that leave the free inquiry and unrestricted comment that are essential to the fields of engineering and science?

Organizations that cannot accept these standards of inquiry and criticism are dysfunctional. And if the application of these standards in society are not acceptable then society will become dysfunctional.

The way to reform a dysfunctional organization is the application of these standards, especially when they are the most difficult to apply.

The same is true of society, where the truth, or even just your opinion is least palatable, it is most important that it is spoken.

It is only through the exposure to contrary opinions that you learn to formulate the reason and logic behind your own positions. It is the only way that you find out that you are wrong. Free speech is what keeps us all from living in ignorance.

It is essential that we engineers maintain our ethical standards regardless of the short term consequences. How else do you live with yourself?

UAS Certification and what you can do about it

A version of this article first appeared in the August 2018 edition of our free newsletter, to subscribe click here

We are working with several companies and organizations on regulatory compliance for both designing and operating unmanned aerial vehicles, both above and below the 55lb weight limit.

There are several things that immediately become apparent

  1. If you want to develop a UAS greater than a 55lb gross weight without a military or government customer, forget about it,
  2. There is a lot of demand and many commercial applications for heavier UAVs,
  3. Regulators are not psychic and have problems both formulating the regulations and recognizing the urgency of developing the regulations,
  4. Connecting with the regulators to help develop new regulations for development and operation is difficult. They are as busy as anyone else and have their own priorities. There is a sense of the importance but there is little leadership.

As I wrote in the last new letter, when it comes to government funding, there is a worry that the larger companies may monopolize this regulatory development process as well. Not that they would formulate any regulation with the intention of harming the smaller developers, but they have a certain way of doing things that involve large budgets and they will advocate for what they know. And that will involve large budgets.

From what I have seen first hand and from the experience of other consultants, some of the new companies in this space do not understand the certification process and how the regulations will profoundly affect their design process and the chance of success of their product in the market. We have started to work with a client who is very aware of these issues and have educated themselves well – regulatory issues are a significant focus for the initial phase of the project. If you can’t get the product past the regulator you will have zero sales.

And the companies who do understand the issue have problems getting their voices heard.

There are therefore two critical aspects that the industry has to achieve:

  • Focusing the regulator on the task
  • Getting a seat at the table and your voice heard.

This is a field where the technology is moving forward at an ever increasing pace and the regulator is barely out of the starting blocks.

If we all make more attempts to reach out to our local certification or regulatory body it can only help. There are several things you can do

  1. Find out who the individual responsible for UAS regulations is at local and national levels.
  2. Try and connect with them on linkedin, send them an email.
  3. If there are meetings or discussion schedules on this issue, try and get an invite. If you can’t get an invite make sure you get sent a copy of the minutes.
  4. Be polite, professional, enthusiastic and supportive. The regulator has a heavy responsibility to ensure public safety, but they also need the best information from all the stakeholders and they have to foster an environment conducive to innovation as well.

Give your time and energy for free and help as much as you can.

Brexit, Big Fish and the UK Aircraft Industry

A version of this article first appeared in the July 2018 edition of our free newsletter, to subscribe click here
In the last couple of years there have been a number of new aircraft projects in the UK. I Have been involved with some of them and it has been interesting to see the progress and reactions.
The new startup companies complain that while there is public funding or other types of assistance available (innovation centers co funded by the larger corporations in the industry such as Rolls Royce Aero Engines and Airbus) there is a freezing out of startup companies in favor of internal projects within the two giants in the UK.

Of course you would expect this. Little Billy Startup has little to no political sway compared to the established players. So when it comes down to the final decision it does not matter how good your design or business plan is, you’re just not in with the in-crowd.

You can see this in the UK. Rolls Royce has come up with a VTOL urban mobility design concept. It looks like around 20 other VTOL design concepts and has the same likelihood of success.

Rolls Royce have never proposed an aircraft program before. They have not issued an aircraft concept. Why now? Why are they competing with a bunch of startups in a field with a low probability of eventual success?
Do they plan to be the first to market? Do they see themselves as the post brexit UK aerospace leader? Is this just a case of keeping up with everyone else? Or is it a route through to public money meant for innovative startups?

The public should be worried as traditionally the market monopoly position of companies is used as a boogeyman to justify blocking mergers and acquisitions. An equal problem, but one that is largely ignored is the monopoly over public money. The more new companies depend on public money to get off the ground and overcome the unavoidable statutory product and corporate costs the more critical this becomes.

Mergers and corporate consolidation create this problem, as public money that is meant to promote innovation and technical risk ends up covering the day to day expenses of inefficient industry giants.

One of the most egregious cases of this is Bombardier in Canada (although I am sure you all have your own favorite). No one is really sure how much public money that they have received at the federal and provincial level in the form of cash gifts, grants, loans and subsidies. But the ones that I have counted in recent years come to over $1bn per year. I am sure it is impossible to calculate the total amount but it is significantly over this number.

This keeps a lot of people employed – which is a good thing. But what is the opportunity cost?

For the same money you could give 1000 technology startups a grant of $1m each. Imagine the innovation you would be fostering if you did that? How many ‘Bombardiers’ could Canada create with that approach? Well, hopefully not ‘Bombardiers’ that need $1Bn per year just to get by – but you know what I mean
Right now Canada has one – and it is very expensive.

So the UK as a newly independent nation (Theresa May notwithstanding) has a choice to make with it’s public funds. It can follow the Canadian model, it can reward inefficiency and established corporations or it can actually help cover the downside risk of innovative start up companies.

From what I have seen from my contacts and clients in the UK, it looks like it is business as usual. Just the process of applying for funding from these pots of public money is so onerous that many companies do not even try.

A project run by a good friend of mine was all ready to get approval for a substantial government grant. They had got top marks from all of the adjudicators and had ticked every box. Two days before the formal announcement of the award they got a call that things weren’t actually so cut and dried and that they should not assume that the grant will be awarded.

Another project we are working with are looking at getting space in an innovation center funded by Government and large industry partners. But this is in doubt because they may be judged as competing with one of the giant industry partners involved in the funding.

In a society where taxes are high and success, in a large part, depends on getting some of those taxes back in the form of a government grant, the monopoly that we allow large companies over this process is just as negative as a monopoly over the market. Maybe more so, as the only way the market can be bought is by providing additional value to the actual customers. In order to monopolize government grants you just have to lean on your local or national politician – a much simpler and less expensive process.

So with the large players being a big fish in a much smaller post-brexit pond where does that leave the little fish?

Lost in Sweden

A version of this article first appeared in the July 2018 edition of our free newsletter, to subscribe click here

One of my favourite aircraft is the Saab 35 Draken which was a groundbreaking Swedish aircraft manufactured in the 1950’s and 60’s. It remained in service until the late 90’s with the Danish and Swedish air forces.

We have spent the last week of June with my wife’s parents in beautiful Sweden in a small town called Simrishamn. By chance there is a small museum just 5 minutes away from Simrishamn with a collection of Draken aircraft ( . The owner is an ‘amateur’ collector of aircraft (he has a real job during the week) and takes people on tours of his collection on Sundays by appointment.

Saab 35 Draken

He is far from being amateurish though, and his knowledge of Saab military aircraft programs is comprehensive. For any aircraft aficionado visiting the South East of Sweden I can recommend this as a great way to spend a Sunday afternoon.
He has about 10 Saab Drakens, 2 Saab Lansens, a Saab Viggen a De Havilland Dove, a Bell Huey many different vintage jet engines, aircraft ejection seats, flight suits, helmets and an astonishing array of aircraft miscellania. His collection is better than many established museums and his enthusiasm is infectious.

You can call the museum to make an appointment: 0701-122689. Remember to make a generous voluntary contribution, there is no set charge for viewing the collection and he is self supporting.

The Abbott Aerospace SEZC Ltd Scholarship Fund

A version of this article first appeared in the July 2018 edition of our free newsletter, to subscribe click here

We have formally established our scholarship fund with the University College of the Cayman Islands.

The fund is targeted at students who have not qualified for any other award, who have enthusiasm and ability but may struggle academically.

For many technically minded people the classroom is not the best environment to shine and we want to support those students. We will be making multiple awards each semester and successful students will be awarded with a credit to their university account that can be redeemed against textbooks at the university bookstore. For more information or to get an application form you can contact me at

Boeing and Embraer – The cost of doing business where you want to live

A version of this article first appeared in the July 2018 edition of our free newsletter, to subscribe click here

I was asked this question this month “Where would you certify an aircraft if you had a choice?”. My answer was instinctively “Brazil”.

We have done studies to determine what factors make aircraft programs successful. In order to do this you have to define your measure of success and then you have to go hunting for metrics that inform your method and reveal the truth.

We use project level profitability as a measure of success. I.e. does a project manage to payback all of the costs of development and all the ongoing costs of unit production – project break-even. Beyond break-even does the project generate a profit and how does that profit relate to the investment required to bring the product to market.

To the outsider this can all be dreadfully boring, but to those of us wrapped up in the industry it can reveal some intriguing insights why programs succeed or fail. This information then may then give us the knowledge to help significantly increase the chance of success of a program.

The success of a program affects thousands of people – everyone working on the program and all of their families. Supplier companies, their employees and their families. When a program gets it very wrong not only are the investors out of pocket but the lives of thousands of people can be negatively affected.

There is no malice in programs that fail, there is also usually no lack of technical competence but there is a lack of asking the right questions and recognizing the right answers

So – how does all this relate to the original question “Where would you certify an aircraft if you had a choice?”.

This is an example of a project asking exactly the right question.

We categorize risks into 3 categories – technological, certification and market. There are other risks, supply chain, liability, etc, but all of those can be managed. Technology, certification and the market are the areas of an aircraft program that can present intractable problems that may be impossible to solve.

Of these ‘Big Three’, certification and the market at the two risks outside of the companies direct control. By that, I mean that the company can choose a technological basis for their product and once chosen that technology will not stop working – the technology is going to work in the same manner that it worked when you selected and developed it. Physics is reliable.

The market is fickle. Designs and product features can fall in and out of fashion. Focus groups may not represent the wider market trends and the economy and the buying power of your potential customers is in constant flux.

Certification regulations are subject to change, they can become less onerous or more onerous. The people responsible for interpreting the regulations change, some are good and some are ‘less good’. This is out of the control of the company.

It is reasonable to say that a company has no control of the market or the economy. You just have to do your best, hedge your bets the best you can and appeal to the largest market possible.

What can the company do to influence and minimize the risks and costs of the certification process?

In our study we examined 25 ‘high end’ part 23 aircraft projects from the last 30 years. We found that when their development costs are normalized for inflation the yearly ‘burn rate’ in development and certification has a surprisingly small scatter.

There are some outliers – the Eclipse 500 program had an average yearly burn rate over 5 times the average burn rate and 4 times the standard deviation.

In 2018 US dollars the average yearly development and certification spending rate of these 25 programs was US$50M.

(when two outliers of the 25 projects examined are removed the average yearly spend drops to US$35M per year)

Ignoring outliers it is accurate to state that the yearly spend rate of a program does not affect the success of the program.

When you examine program duration the critical metric for success is clearer (although not universal).

The program duration for the 25 programs examined range from 4 to 16 years. Using the limited data I have quoted so far this reveals that the lower limit program cost in 2018 US Dollars is going to be around US$200M and the higher limit will be US$800M.

This factor 4 difference can be influenced by a number of factors – one of the factors that significantly influence program duration is certification. The program duration is also influenced by the certification interface and process management competence of the company. This specific competence of the company and the attitude of the certification authority can combine into a perfect storm of schedule extensions.

In a perfect world where the regulations are universal and harmonized across international boundaries it should not matter where you choose to certify your aircraft.

The world is not perfect and even within national borders there are large differences in how regional offices approach certification and this can significantly influence the success of a program.

Everyone has a comfort zone – including the staff at the FAA (and every other certification authority in the world). You create very high financial risk trying to certify a part 29 rotorcraft using a local ACO (Aircraft Certification Office) that has predominantly worked with fixed wing LSA aircraft.

When an FAA/EASA/CAA (fill in the blank…) employee is operating outside their personal/professional comfort zone are they more or less likely to make a finding of compliance for your project? You know the answer to that question.

From our study, based on our criteria and the assumptions we have made, there are four successful part 23 companies that produce high performance aircraft. Cessna, Cirrus, Embraer and Pilatus and for all of 25 projects reviewed only 4 were found to meet our criteria of success.

Note: We omitted some companies and projects from the study due to lack of data, among these omitted companies and projects were Beech and Diamond Aircraft.

These companies are successful because of a number of critical factors. They design and develop great aircraft and they work with their local certification representatives to minimize the duration of the certification program.

So within the US, for larger part 23 programs, considering only certification cost as a critical factor, you would select the Wichita or the Chicago ACO to work with.

Internationally you would consider Brazil or Switzerland.

As Embraer are the only company of all companies examined with two projects that display good success indices (the Phenom 100 and the Phenom 300), ignoring all other factors, Brazil would be our certification jurisdiction of choice.

Both of the Phenom jet projects took less than 3 years to complete, the shortest programs out of all the programs we studied. This is due to the high level of competence of the development program management and the relatively small additional burden imposed by local certification authority.

Most aircraft projects are located where the initial development team is located or where a region offers the most financial incentive to locate the manufacturing.

Our advice is to locate the organization in a jurisdiction where the certification authority has a track record of enabling a return on investment.

This brings us back around to the title of the article. Boeing and Embraer.

Boeing’s ‘partnership’ with Embraer may partly be one-upmanship on Airbus and Bombardier. It may be sensible consolidation and a way to protect the market share they have of the larger aircraft sizes. It may be to save on manufacturing cost by outsourcing to a supplier/partner with clearly demonstrated competence.

Or it just may be a path for Boeing to certify new aircraft programs through a different certification authority. A certification authority that have facilitated Embraers extraordinary growth while maintaining appropriate product safety levels.

What do you think? Will Boeing take the plunge and conduct a type certification program outside of the US?

On a related note. Many of the new Aerial Urban Mobility projects are based in California. The Los Angeles ACO do not have favorable history of assisting and supporting companies certify new types of civil aircraft. We would advise all of these projects to seek new locations and plan on working with FAA ACOs that will maximise their chance of success by minimizing program duration and therefore program cost.

How I Stopped Worrying and Learned to Love the Process

A version of this article first appeared in the January 2018 edition of our free newsletter, to subscribe click here

I have been working with a company just getting to the end of their prototype design phase. They have yet to fly one of the prototypes and their engineering team is working very hard to release the final engineering definition to support the prototype build to flight program.

Once this has been done the expectation is that they will be able to move immediately into certification design, release and manufacture.

  • The company has not developed a certifiable production design before.
  • Most of the managers come from large companies.

These two aspects can combine to cause significant problems.

Most engineers and managers who are accustomed to a large company environment are not fully aware of all of the processes that have been devised and implemented that contribute to the smooth running of engineering, manufacturing, procurement, quality, etc.

Most of them are aware of some of the processes, but like everybody – you don’t know what you don’t know.

What almost all of them are unaware of is the problem that arise when you go through the development and certification processes of an aircraft product with insufficient, immature or non-existent engineering standards and processes.

Engineering processes have an image problem. What kind of engineer would want to work on dull process issues when you can be devising cool looking things that fly?

Imagine a modern car engine if you turned off the software control system, or a computer without an operating system.

It looks like it should work but is doesn’t. Many startup companies spend a vast amount of money discovering this over a number of years.

To Quote Sun Tzu – “Tactics without strategy is the noise before defeat”.

Returning to our startup company in this example. They have a great engineering team and experienced engineering leadership.

They have almost no engineering standards or processes and those that they have are not implemented or enforced.

Standards and Processes are an important component of engineering management strategy. They are tools that channel engineers efforts into products that are certifiable, manufacturable, affordable and sensible.

In the absence of Standards and Processes it is only by chance that you will end up with a good product. In a product as complex as an aircraft there is practically zero chance that the integrated product will be any good at all.

If you create standards and fail to promulgate and enforce them, it is the same as having no standards. An experience I had a few years ago with a client comes to mind. They were having trouble with consistent drawing standards as they were using different contract engineering groups to produce the type design drawing set. I wrote a drafting standards manual for them (based on the excellent NASA drafting standards manual). We got it checked and approved – however, the approver changed the title of the document from “Drawing Standards” to “Drawing Guidelines”. Standards are mandatory, Guidelines are optional.

I assume you can guess the outcome; there was no increase in drawing standards, it was as if the document had never been written.

So, there is a set of problems associated with an absence of process, there is another set of problems caused by over definition of engineering processes

Company standards and processes are like laws – they have to be drafted and approved, there is an enforcement cost and a restriction of freedom.

We have worked with several established OEMs that have processes which are excessive and burdensome and greatly increase the cost of product development.

And just like a government department, once you establish a department inside a company for processes and standard development, with the best will in the world, it will justify its own existence and importance by ever more important and burdensome processes.

So leave the process development and maintenance in the hands of the senior engineers and not a group of process specialists.

Just make sure you hire the right senior engineers……..

The creation of even a simple engineering system takes time and and also a considerable effort to introduce to a team. It requires a rigorous level of check and enforcement.

It requires technical leads who can say no and engineers who can handle rejection.

A company has to decide what it need to control in order to develop a reliable, cost effective, certifiable product. These may include

  • Design Standards
  • Drawing Standards
  • Stress Methods
  • Approved Hardware
  • Approved Materials
  • Approved Processes
  • Approved Means of Inspection
  • Reporting Standards
  • Release and Approval Processes
  • Change Processes
  • CAD System Processes
  • CAD Creation Standards

All of these standards are informed by the compliance plan – that which you know to be certifiable and the means that you will use to demonstrate compliance.

Take a moment to think about the processes where you work – do they do harm by being over restrictive or by giving too much freedom? Do they help by focusing the teams on the right thing to do? Can they be improved?