eVTOL Certification presentation for reference
- 1. e/VTOL Certification 101 David Webber, Research/Flight Test Engineer, Aircraft Certification Service
- 2. Disclaimers • I’m a Flight Test Engineer, not a lawyer • This briefing attempts to shed some light, sometimes via analogy, on structure and application of the Code of Federal Regulations (CFR) • I will not offer, nor substantiate, any pre-decisional information – everything I brief is anchored to publicly available regulation, policy and/or guidance • Source: rgl.faa.gov, FAA.gov
- 4. FAA is a regulatory agency For purposes of this brief – “Law” and “Act” are synonymous An “Act" is a single enacted bill proposed in a single legislative session approved in a single Presidential assent... ...while a ”Law,” can be the result of multiple acts approved in multiple Presidential assents at different times and then codified into a single statute. Individual laws, also called acts, are arranged by subject in the United States Code (USC)
- 5. Federal Aviation Administration Per United States Code (USC), FAA is the agency of the United States Department of Transportation responsible for: • Regulation and Oversight of civil aviation within the U.S.; • Operation and Development of the National Airspace System (NAS) FAA’s mission is to provide the safest, most efficient aviation system in the world.
- 6. Law vs Regulation Regulations are created by a governmental agency, often to actually implement a given law (or act). While Laws are designed to govern everyone equally, Regulations only effect those who deal directly with the agency who is enforcing them. Regulations are rules made by executive departments and agencies, and are arranged by subject in the Code of Federal Regulations (CFR)
- 7. Regulation vs Rule While Regulations cover a topic broadly, Rules get into details. A regulation (e.g. 14 CFR Part 27 Airworthiness Standards: Normal Category Rotorcraft) may be comprised of many individual rules. As part of a regulation.... ....rules have the force of law.... so rulemaking has to be concerned with precedence, because changes in individual rules can effect the overall regulation FAA Rulemaking Characteristics • • Ensure SAFETY of civil aviation But, must be REASONABLE – Seek minimum safety standard – economic impact must be assessed - EFFICIENCY – when applied to a particular category/class then vehicle’s capabilities assumed • Must be applied equally to all users of airspace system – UNBIASED • Must be made known to the people who are going to be ruled by it – TRANSPARENCY • Should not suppress innovation... however... • Must be ENFORCEABLE.... Which drives a need to be MEASURABLE
- 8. Rule designed to deliver balance: • Acceptable SAFETY - assumes “Class” of vehicles using the zone being regulated • Commercial/Social acceptance Requisite characteristics: • TRANSPARENCY • MEASURABILITY • ENFORCEABILITY Example of Rule Prescriptive? Performance- based? Vehicle “Class” assumptions influence operations rules to achieve a level of safety Some zones may require minimum design assurances – “certified
- 9. What’s in a name? Can this vehicle utilize full performance capability of this road? Legal Description is important in a Regulatory environment – Vehicle “Category/Class” should be defined and appropriate – can provide operational advantage that may otherwise be limited
- 10. What’s in a name? Legal Description is important in a Regulatory environment – Vehicle “Category/Class” should be defined and appropriate – can provide operational advantage that may otherwise be limited What about this one?
- 11. Vehicle Category/Class grouping based upon intended use or operating limitations/similar characteristics Vehicles that do not meet assumed “Category/Class” capabilities create a regulatory burden and may require special rules, limits, or restrictions to uphold overall level of safety
- 12. Vehicle Category/Class grouping based upon intended use or operating limitations/similar characteristics
- 13. Policy, Guidance, etc. FAA Policy statements provide: • guidance or acceptable practices on how to find compliance with a specific CFR (Code of Federal Regulations) section or paragraph. These documents are • explanatory and not mandated. They are also not project-specific. Advisory Circulars are non-regulatory documents intended to inform and guide institutions and individuals within the aviation industry, as well as the general public. FAA Policy and Guidance become official after it is published in the Federal Register In order to assure that Policy is not arbitrary, the Federal Register handbook requires FAA Policy and guidance authors to explain the what, why, and effect of the document. Internal legal review is warranted to assure stability of the Regulatory system. Public comment is often sought.
- 14. Orders and Notices An Order/Notice is a directive that the FAA uses to issue policy, instructions and work information to its own personnel and designees. It spells out how the FAA expects to carry out its responsibilities. Understanding intent – and insisting on use as a common source can save a lot of time and heartache during aircraft certification activities - particularly if you have never worked within the nuances of regulation
- 15. Thinking out of the box • Innovative • Collaborative • New Operational use cases e/VTOL Advanced Air Mobility
- 16. ≠ Thinking out of the box • Innovative • Collaborative • New Operational use cases Coloring outside of the lines • Cute ...probably not of lasting value Application of Vehicle Certification regulations to e/VTOL Advanced Air Mobility
- 17. Basic Legal Hierarchy Craft your foundation (your Certification Basis) wisely Basis will serve as assumptions for other rules Existing Regulations cannot be ignored Legally enforceable Not legally enforceable (e.g., Certification Basis, Type Design, etc.) (e.g, Administrative Procedures Act)
- 18. Quick Summary Law Regulation Act Act Rule Rule Policies, Guidance, Orders, Airworthiness criteria, standards, etc.
- 19. Are you with me?
- 20. Certification
- 21. What is “Certification” • Acknowledgement FAA regulatory requirements (a rule, or set of rules) have been, and will continue to be, met for: – Aircraft, Aeronautical Products, Airmen, Mechanics, Controllers, Operators, etc. • Different, but well proven, Risk-based processes for each FAA Line of Business (LOB) Once again: FAA’s mission is to provide the safest, most efficient aviation system in the world.
- 22. • FAA must safely manage the airspace and civil aircraft operations – Title 49 U.S. Code § 40103(a)(1) • Manage Operational Risk – Apply Resources/Rigor Based on Risk • Certification basis provides “Safety Assurance” – Confidence a proposed product or action will meet, and continue to meet, FAA safety expectations to protect the public* *you can imagine that a “level of safety” for one “operational use case” (e.g. rural cargo delivery), may not be appropriate for another (e.g. urban air taxi) – from public’s viewpoint Why Certify?
- 23. Overall Safety Assurance Comes from Combination of Factors – Airworthiness – Condition for safe flight for its intended use – Design – Verify design, engineering, construction, etc. meet applicable requirements in certification basis – Pilot/Operator – Trained for aircraft/system and level of risk – Maintenance – Repair/replace prior to failure - cycle rate – Operation – Limitations sufficient for the operational use case and expected/acceptable level or safety – Airspace – Level of Integration, Traffic exposure, Controller Involvement, and Equipage – Environment – Operational threats realized and mitigated
- 24. The importance of Foundation Vehicle Certification requires an appropriate “basis”
- 26. • Discipline • Practice • Predictability • Strict rule following Importance of Certification Process
- 28. Perspective on the nature of FAA
- 29. Who Are We? Key FAA Functions • Aircraft Certification Engineering- centric – Issuance of Airworthiness and Design Approvals for the Aircraft, Equipment, Engines, etc. – Aircraft Flight Manual – AIR, AEG • Flight Standards Ops/Mx Inspector- centric – Dictates Pilot Qualifications, Training and Operational Procedures/Limitations – Issues Airworthiness Certificates (incl. experimental) - AFS • Air Traffic – Handles Air Traffic and Airspace Related Requirements for Safe Operation • Airport Safety and Standards AVS Aviation Safety ATO Air Traffic Organization ARP Airports
- 30. FAA – Lines of Business ATO Air Traffic Organization AVS Aviation Safety ARP Airports Staff Offices And other LOBs 32,000 personnel 7,400 personnel 600 personnel 5,000 personnel 45,000 personnel
- 31. FAA – Lines of Business AVS Aviation Safety 7,400 personnel FAA organization responsible for the certification, production approval, and continued airworthiness of aircraft; and certification of pilots, mechanics, and others in safety-related positions 45,000 personnel
- 32. Aircraft Certification (AIR) is part of AVS AFS Flight Standards ~750-1,300* engineers, scientists, inspectors, test pilots involved in Vehicle Certification AIR Aircraft Certification AVS Aviation Safety AUS Flight Standards ARM Rulemaking AVP Accident Investigation AAM Aerospace Medicine FAA ~45,000 personnel *~2% of total FAA – Engineering is relatively small part of FAA population
- 33. Policy & Innovation AIR-600 Compliance & Airworthiness AIR-700 System Oversight AIR-800 Certification Validation Rev IR + Aircraft Certification Service (AIR) Develop Regulations, Guidance and Directives Issue Design Approvals Validate Foreign designs Appoint, oversee, and renew delegations New and Novel Technology integration Product Assurance Standards Branches Aircraft Certification Offices Oversight Offices National Flight Test Bran ch ~70 FTP/FTEs
- 34. What is the goal of “certification” of new, innovative, e/VTOL, advanced air mobility, concepts?
- 35. Analogy: Formation Flying Goal • Move in complete harmony in a confined space Enablers • Flight Lead – mental workload high •Wingmen - physical workload high What Characteristics make it work? • Discipline • Practice • Predictability •Strict rule following Result • The whole is greater than the sum of the parts
- 36. e/VTOL Advanced Air Mobility Goal • Move in complete harmony in a confined space Enablers • Appropriate Vehicle Certification Basis • Appropriate operational rules • Appropriate infrastructure What Characteristics make it work? • Discipline • Practice • Predictability •Strict rule following Result • The whole is greater than the sum of the parts
- 37. Reminder that FAA is a REGULATORY agency Regulations only effect those who deal directly with the agency who is enforcing* them *and the enforcers are not the 2% you’ll be dealing with when your aircraft is in conceptual design phase – do your homework/know the law
- 38. Infrastructure Aircraft Airmen FAA addresses three Inter-Related Aspects Vehicle certification basis decisions directly drive operations, airmen and infrastructure rule applicability
- 39. Part 1 Definitions and Abbreviations Don’t expect to find all you’ll need – any necessary definitions unique and necessary to your design can be defined in Certification Basis Part 3 General Requirements Airworthy defined here - aircraft conforms to its type design and is in a condition for safe operation Part 11 General Rulemaking Procedures FAA follows the Administrative Procedures Act ANPRM... NPRM... Final Rule Assures TRANSPARENCY Special Condition is a rule applied to a particular aircraft design (type design) Part 13 Part 14 Part 15 Part 16 Part 17 Legal stuff, including enforcement and certificate actions
- 40. §1.1 Definitions and Abbreviations (a few examples) Airplane means an engine-driven fixed-wing aircraft heavier than air, that is supported in flight by the dynamic reaction of the air against its wings. Helicopter means a rotorcraft that, for its horizontal motion, depends principally on its engine-driven rotors. Powered-lift means a heavier-than-air aircraft capable of vertical takeoff, vertical landing, and low speed flight that depends principally on engine- driven lift devices or engine thrust for lift during these flight regimes and on nonrotating airfoil(s) for lift during horizontal flight. Class: As used with respect to the certification of aircraft, means a broad grouping of aircraft having similar characteristics of propulsion, flight, or landing. Examples include: airplane; rotorcraft; glider; balloon; landplane; and seaplane. Person means an individual, firm, partnership, corporation, company, association, joint- stock association, or governmental entity. It includes a trustee, receiver, assignee, or similar representative of any of them.
- 41. “Special” “otherwise different from what is usual” used throughout the FAA Lines of Business “Unique,” “Uncommon,” “Unusual,” “Noteworthy” in comparison to status quo • Special Class (e.g., Airship) • Special Condition (e.g., Airbus Envelope Protection) • Special Certification (e.g., unique helicopter instrument procedure) • Special VFR • Special Airworthiness Information Bulletin (SAIB) • etc.
- 42. Part 21 Defines the Certification Procedures for Products and Parts Part 23 Defines the Airworthiness Requirements for Normal Category Airplanes Part 25 Defines the Airworthiness Requirements for Transport Category Airplanes Part 27 Defines the Airworthiness Requirements for Normal Category Rotorcraft Part 29 Defines the Airworthiness Requirements for Transport Category Rotorcraft Part 31 Defines the Airworthiness Requirements for Manned Free Balloons Part 33 Defines the Airworthiness Requirements for Aircraft Engines Part 35 Defines the Airworthiness Requirements for Propellers Special Conditions, Equivalent Level of Safety findings, Exemptions Regulatory standards applied to a particular aircraft design (type design) Developing Certification Basis
- 43. Post Certification Activities Type Certification process Ref: FAA Order 8110.4 Compliance Planning/ Implementatio n Requirement s Definition Conceptual Design Pre-project guidance Familiarization Briefings Certification Plan TC Application Initial Certification Basis Issue Papers Certification Tests Safety Analysis Type Inspection Authorization Flight Tests Operational and Maintenance Evaluation Review of Flight Manuals TC Issuance Airworthiness Certificate Cont’d Airworthiness/ Cont’d Ops Safety Finalize Certification Basis -or continue at risk
- 44. Approach Constraints Chart – Calm Wind UAM Surrogate vehicle Calm Winds
- 45. Calm Winds Conventional Normal Category Airplane Subpart B Design Assurance area (Performance, Stability & Control) – Assumes operations at Airports
- 46. Calm Winds UAM, Steep Approach? Subpart B Design Assurance (Performance, Stability & Control) – Assumes operations at Heliports, Vertiports and Airports
- 47. Calm Winds UAM, Moderate Approach? Subpart B Design Assurance (Performance, Stability & Control) – Assumes operations at Heliports, Vertiports and Airports
- 48. Calm Winds Other AAM Operational Use Cases Subpart B Design Assurance (Performance, Stability & Control) – Assumes cargo? operations at special landing area ?
- 49. Type Certification process Ref: FAA Order 8110.4C • Establish Type Certification (TC) Project • Establish TC Team/Type Certification Board (TCB) • Develop Certification Project Plan (CPP) • Preliminary TCB Meeting (TCBM) • Tools for managing the Certification • Determining Certification Basis • Interim TCB Meeting to Finalize Certification Basis • Develop Project Specific Certification Plan (PSCP) • Interim TCB Meeting to Finalize Certification Plan • Compliance Data Generation • Conformity Inspections • Compliance Substantiation • Applicant Showing • Compliance Finding • Review of Compliance Data/Flight Test results/Risk Management • Pre-flight TCB Meeting/Type Inspection Authorization (TIA) • Conformity of flight vehicles/Certification Flight Tests • Ops & Mx Evals/ICAs/Function & Reliability testing/Flight Manual • Final TCB Meeting to Issue Type Certificate and Data Sheet Requirements Definition Compliance Planning Implementation Show Compliance/ Find Compliance
- 50. Type Certification process - Team Ref: FAA Order 8110.4C • Establish TC Team • Project Manager – Aircraft Certification Office (ACO) • Engineers/Tech Specialists • Flight Test Pilots/Flight Test Engineers • Manufacturing Inspectors • AEG Ops and Airworthiness Inspectors • A project officer and other persons at discretion of Directorate • Form Type Certification Board (TCB) • Includes TC Team and may include outside subject matter experts to support certification or participate in an advisory committee • Develop Certification Project Plan (CPP) • Defines relationship between ACO and Directorate and outlines project schedule. Represents FAA plan to support applicant’s schedule • Preliminary TCB Meeting (TCBM) • Formal meeting combining interests of engineering, flight test, manufacturing, and maintenance and operations Note: “Directorate” function now resides in “Policy & Innovation” division – ref: FAA Order 8100.5D
- 51. Type Certification process - Tools Ref: FAA Order 8110.4C • Issue Papers – used to document and bring to closure technical issues related to the certification ref: FAA Order 8110.112 • Certification Basis • Means/Methods of Compliance • Special Conditions • Equivalent Levels of Safety • Issues Book • Project Specific Certification Plan (PSCP) • Builds on the foundation set by the Certification Basis and details the certification compliance tasks required to show compliance to the regulations applied to the vehicle.
- 52. Type Certification process – Certification Basis Ref: FAA Order 8110.4C established per §21.17 “Designation of applicable regulations” ref G-1 Issue Paper • §21.17(a) - IF Airworthiness Regulations exist for the applicant’s category/class of vehicle -amendment level of the those standards is established by application date; • §21.17(b) - IF Airworthiness Regulations do not exist for the applicant’s class of vehicle - FAA may permit development of a set of airworthiness standards appropriate to the special class of aircraft – these airworthiness criteria become the Certification Basis for the aircraft • §21.17(a)(2) - Special Conditions • IF FAA finds that the Airworthiness Regulations are not appropriate for an established class of aircraft due to novel or unusual design features, Special Conditions may be required under authority of IAW §21.16. • Special conditions are rulemaking and follow public procedures prescribed in §11.16 • Once rulemaking process is complete, the Special Conditions become part of the Certification Basis
- 53. Special Condition Process ref: 8110.4C Note: “Directorate” function now resides in “Policy & Innovation” division – ref: FAA Order 8100.5D
- 54. TC process – Certification Basis (continued) Ref: FAA Order 8110.4C • Equivalent Level Of Safety (ELOS) – IF literal compliance with the governing regulations cannot be shown, but compensating features of the type design can be shown to provide equivalency – FAA makes ELOS finding via memorandum • ELOS Finding is not rulemaking, and not subject to public process, but details are publicly releasable and are included as part of Certification Basis • Exemptions – Are a grant of relief from an applicable regulation given to an applicant when provisions can be met: • Relief benefits the public as a whole; and, • Relief does not negatively effect the overall safety level • Subject to rulemaking process In practice, Exemptions are rarely granted – preference is for ELOS Certification Basis Rolls up either: • The “Applicable Requirements (Part XX) plus any Special Conditions, ELOS and/or Exemptions” – or – • The “Airworthiness Criteria” established for a Special Class Aircraft
- 55. Class Airplane Rotorcraft Manned free balloon + , + Designating Applicable Regulations New Type Design 21.17(a) 21.17(b) Part 23 Part 25 Part 27 AC 21.17-2A AC 21.17-1A ??? Part 33 Part 35 Special Conditions, etc. Regulatory Certification Basis Special Class Glider Airship Tilt-Rotor Other nonconventional Part 31 Part 29 Normal Category Transport 25 + 29 + TR Unique Airworthiness Requirements As required Utilize Parts 23,25, 27, 29, 31, 33,35 as appropriate ELOS
- 56. Type Certification process – Show Compliance Ref: FAA Order 8110.4C Regulatory Certification Basis should provide a clear definition of the Vehicle and assumed operational use case that is being certified – Type Design must be established • Conformity Inspections provide objective evidence that test articles, parts, assemblies, etc. conform to the type design • Consult manufacturing personnel early in the certification project • Aircraft Certification Office (ACO) Test Plan approvals • Compliance Substantiation • Applicant Showing • Compliance Finding • Review of Compliance Data/Flight Test results/Risk Management • Pre-flight TCB Meeting/Type Inspection Authorization (TIA) • Conformity of flight vehicles/Certification Flight Tests • Ops & Mx Evals/ICAs/Function & Reliability testing/Flight Manual • Final TCB Meeting to Issue Type Certificate and Data Sheet
- 57. Policy & Innovation AIR-600 Compliance & Airworthiness AIR-700 System Oversight AIR-800 Validatio n Certification Rev IR + Aircraft Certification Service (AIR) Develop Regulations, Guidance and Directives Issue Design Approvals Validate Foreign designs Appoint, oversee, and renew delegations New and Novel Technology integration Product Assurance Standards Branches Aircraft Certification Offices Oversight Offices
- 58. Compliance Phase
- 59. Type Certificate Data Sheet (TCDS) Captures Regulatory Certification Basis Prescribes conditions and limitations under which the aircraft meets the Airworthiness Requirements* *Part of the Type Design and legally enforceable – tells the world what your aircraft is, and what it’s capabilities and limitations are… A Category/Class/Different Models B Performance/Flight Characteristics C Loads/Flight Envelope D Design/Construction E Powerplant Provides legal framework for continued operational safety of this aviation product
- 60. Vehicle provides the cornerstone of evolutionary operational use cases
- 61. Appropriate Regulatory Certification basis enables new air transportation paradigms after critical loss of thrust… Transport category, airplane Certified to 2.4 - 3 percent climb gradient Normal category, (multi-engine) airplane Certified to 1 - 2 percent climb gradient - or - no minimum climb rate assurance if crashworthiness is adequate after critical loss of thrust… Transport category A, helicopter Certified to be capable of returning to the Point of departure – and/or flyaway with >100 feet per minute climb rate Normal category, helicopter no minimum climb rate assurance Certification Basis needs to align with Urban Air Mobility Operational Use Case
- 62. 1886 1903 1939 2017 …First Driver’s license 1903 …Autobahn construction began 1929 …First purpose built heliport 1956 …helicopters are granted relaxed minimum safe altitudes under 91.119 Define and prove the vehicle capabilities – operations and infrastructure will follow …First tarmac road 1901 …First airport 1909 …First Pilot’s license 1927 …First US airliner ILS landing 1938 …First e/Vertiport …First On-Demand Mobility operations
- 63. Safety Continuum
- 64. Questions?
- 65. Backups
- 66. Example of “Special” Airworthiness Criteria
- 67. Importance of Regulatory Certification Basis description and assured capabilities Ref: FAA Order 8260.3D U.S. Standard for Terminal Instrument Procedures (TERPS)