A version of this article first appeared in the October 2019 edition of our free newsletter, to subscribe click here
In the article I included the paragraph:
“It is very easy to get into the type certification process. It is very difficult to complete. If you do not have a very clear route to get through certification the only way you will leave it is by going out of business.”
This did elicit some response. So rather than just spread doom and gloom on how difficult the certification process is maybe I should spend some time and give you my view of how to minimize certification risk and cost and how I would advise you to get through the certification process.
Bear in mind this is strictly an opinion piece – based on several decades of experience and the best data I could find. But you may disagree and if you do I would love to hear from you.
First of all some basic data on aircraft certification.
From a review we have done of many programs, gleaning data from articles, company websites, forums and my own experience we have determined an interesting metric. Form a survey of over 30 part 23 aircraft type certification programs, discounting outliers (4 projects, 1 unusually low cost, 3 unusually high cost) and accounting for inflation. For every program, from little 2 seater propeller aircraft up to larger business jets, the dollar consumption rate per year for the development/certification program comes to between 35M to 45M US Dollars per year.
If we assume this as a reliable datapoint you can draw two easy conclusions:
- This is the inescapable cost you incur for every year in the certification process.
- The only way to minimize costs is to reduce the amount of time spent in the certification process.
If we take all of the above data and conclusions to be correct the critical question for every aircraft program and aerospace startup becomes: How can I spend as little time as possible in the certification process?
There are two aspects to answering that question fully
- Get into certification as late as possible
- Get out of certification at the earliest opportunity
My apologies if that is over simplistic, but it is incontrovertibly true. Most companies confuse and conflate their development program with the certification program. I believe this to be a major error. The two phases of bringing the aircraft to market should be kept completely separate.
So how to create this separation? 5 easy (well, easy to write, less easy to implement) steps
- Define the simplest version of the aircraft
- You develop an aircraft that is inherently certifiable and complete the design and development before you talk to the certification authority.
- Only when the design of your inherently certifiable aircraft is complete and internally proven do you enter the certification process.
- The certification process exists exclusively of activities related to the demonstration of compliance.
- When in certification the only design changes that are allowed to occur are those related to correcting a failure to demonstrate compliance
Initial Type certification is different to Supplemental Type Certification. You can certify whatever you want in the initial type certification as long as it is certifiable. We recommend defining the simplest aircraft that can get through the certification process and get your initial type cert for that configuration. You may never sell a single example of that aircraft.
You can add attractive features and complexity through the supplemental type certification process. Stuffing lots of features into the initial type certification is probably not the best way to go, especially for a startup company and the level of complexity and the associated cost may be ruinous.
Concurrent design and company development – the following 4 things have to occur simultaneously and be carefully coordinated
Line 1 – Air vehicle development: Mission/Customer, Specification, Configuration, Detailed Design, Release, Manufacture
Line 2 – Company systems – Configuration Control, Change Control, Drawing standards, Quality System
Line 3 – Certification
Line 4 – Manufacturing facility/supplier build up, flight line build up and readiness
Line3: ‘Certification’. Only in house certification. At every stage all aspects of the design activities and company processes need to be rigorously audited for compliance by your in house certification team.
At the configuration stage comprehensive compliance plans must be written, scrutinized and made perfect. These compliance plans will intimately inform the design development and determine the order and scope of the later demonstration of compliance.
As wide a consultation as possible should be sought for the compliance planning work. The company and the whole development team should be 100% confident that every aspect of the aircraft is certifiable and have a clear understanding of how that informs all of the design decisions they are taking.
Only when you have finished development do you start the formal certification program: The demonstration of compliance for the certification authority.
As a mentor of mine told me. “You never test in front of the FAA for the first time”. Every test is run and rehearsed before it is witnessed. On composite aircraft where you typically take large scale test articles to ultimate level load multiple times to prove the no growth philosophy, your test articles should be good for this.
Remember, the certification authority is not your partner in the compliance process. The certification authority has a job to do and they have little regard for your schedule and budget. You should have a courteous, professional and adversarial relationship.
Get ready to give them what they want, in the form they want it and be ready to push back on compliance activity creep if conversations with the authority drifts into ‘it would be nice if…….’. ‘On another program we did this…..’. ‘Have you considered doing it this way…..’. These conversations need to be cut short by reference to the compliance plan.
Compliance should be as close to a special forces operation as possible. You have an impeccable plan based on the best available intelligence, you use the best people. You execute the plan and leave the theater of operations promptly with no casualties.
So what if you are developing an aircraft for which the regulations have not been written?
To use the previous analogy – that is like starting a mission with no intelligence and no plan. It does not matter how good your people are.
Programs fail or succeed in the certification phase. As difficult and impressive as it is to get a new aircraft design into the air, that accomplishment is easy compared to executing an efficient compliance program.
A strict reading of the above paints a negative picture for all of the urban mobility projects for which the regulations have yet to be written. This is not my intent. In order to force the creation of these new regulations these vehicles have to be invented to force a regulatory response. As I have written before, I am very impressed with the inventiveness and willingness of these programs and their investors to take risk. I am concerned that some of the programs who advertise they are in the certification phase of their program might believe their own publicity.
If you are waiting for the regulations to be written or published you cannot have started your certification program and you cannot have completed your design.
When I see the number of staff employed by these companies, and their associated budget burn rate, at this early stage in their development I do worry.