October 8, 2021, ©. Leeham News: Last week, we described how we conduct the Certification Flight Test together with the Regulator.
Before we describe our path to completion of our flight test program, we need to pause for a minute and discuss some of the other parallel activities that need to come together prior to issues of Type Certificate and roll out of production aircraft.
In article 3 you’ll recall we reviewed the breadth of regulatory involvement in aircraft development. While the work on the design and initial airworthiness (on the left in the chart below) is critical, it’s not the only set of rules we need to be working with if we want to achieve a successful Entry Into Service (EIS) of the aircraft.
In Part 21 of our series we already discussed the preparation of the production system. In the next few articles, we’ll be discussing three additional areas of work that we’re engaged in that must all come together at the program’s completion:
The chart in Figure 1 is practical as it shows how different Parts under 14 CFR (Title 14 Code of Federal Regulations) are related. The left-hand side shows the Parts that handle the Original Airworthiness, that is the Type and Production Certificates, and the right-hand side the Recurrent Airworthiness, which is how to ensure the aircraft stays safe when in operation.
FAA statistics show that the right-hand side, Recurrent Airworthiness, is more a cause for aircraft accidents than the left-hand side, Type and Production Certificates. The attention today is therefore on measures to improve operational safety.
During aircraft development we have to work three areas to satisfy the requirements FAA has for Recurrent Airworthiness:
The authorities typically recognize this (not Type Certification) as their primary, most important, mandate. Once the aircraft is in the hands of the operator, how do we ensure design and manufacturing issues are discovered and corrected, the assumptions we used during the certification process hold up in practice, and the aircraft is used and maintained in a manner that ensures its continued airworthiness.
This is done through:
Safety Monitoring and Reporting (14 CFR 21.3, 14 CFR Part 39)
As a holder of the type certificate, we’re responsible to monitor in-service issues. If those issues are significant enough we may have to issue Service Bulletins (Figure 2) to inform the impacted operators. Even higher risk issues may drive Airworthiness Directives from the authority. Prior to EIS, we’ll need a system in place to manage this.
Instructions for Continued Airworthiness (14 CFR 23.1529)
The aircraft is airworthy when it rolls out of the factory but it needs to keep this condition for its 25 years or longer productive life. How this is done is contained in our Instructions for Continued Airworthiness (ICA). A lot of these instructions are maintenance documents, but there is more to it.
In order for our airplane to be useful to the customer, we must prepare its operations. The root of this operational preparedness is described in Part 91, the general operating and flight rules. This means not only designing the airplane to meet the design rules construed from its intended use in Part 135 (Commuter) and/or Part 121 (Airline) operations, it also means preparing items such as:
Pilot (and crew) Training (14 CFR Parts 61, 63)
Establishing a pilot training program for our new aircraft type can take a significant amount of time and effort. As we produce a large aircraft (>12,500 lbs as defined by 14 CFR 1.1) and as we intend for its use under Parts 135 and 121 (for the US), we need to establish an aircraft type rating and pilots must be trained & licensed to fly our aircraft prior to in-service flying.
Simulator Qualification (14 CFR Part 60)
To streamline EIS, we develop a full flight simulator for use in the above training. This means the simulator must develop to behave like the real aircraft. All aspects of the human-machine interface, the simulation of systems behavior including in abnormal conditions and the aircraft’s aerodynamic behavior have to be correct.
For service readiness, we produce Instructions for Continued Airworthiness, ICAs. The bulk of the ICAs are maintenance instructions around Continued Airworthiness, but how do we ensure maintenance is done by qualified personnel, through qualified organizations, and that larger alterations or repairs outside the scope of our ICAs are properly done?
As important for the customer, how do we, the OEM, ensure their repairs, maintenance, and part replacements are done in a timely manner? This is about service readiness, and the regulatory aspects are covered by:
Maintenance & Alterations (14 CFR Part 43)
Repair Stations (14 CFR Part 145)
In the next article, we’ll discuss Safety Monitoring and Reporting in more detail.