The FAA is working to tear down the “titanium silos” within its operating organizations in an effort to make the aircraft certification process more user-friendly. That was the message from Earl Lawrence, the head of the FAA’s aircraft certification organization, on Sunday at a CAFE Foundation urban air mobility (UAM)/electric aircraft symposium at the University of Wisconsin-Oshkosh. Lawrence said the agency is currently using its UAS office to coordinate urban mobility activities, but that the agency administrator is looking at creating a new office of innovation to “focus on those activities.”
Lawrence said the glut of proposed UAM/eVTOL designs—now numbering some 175—does not present a challenge to the FAA per se, but rather the inter-agency gauntlet that prospective new aircraft designers, with new ideas for aircraft operation and control, must navigate on the road to certification.
“We know how to certify aircraft,” Lawrence said. “We’ve been building vertical-lift aircraft for decades. We have lots of people on our staff working on vertical lift who understand vertical lift. We understand that is not where the struggle is. A lot of people who come to us are looking to change the way the operation is conducted. They don’t want pilots to have certain certificates; they want to move around airspace differently. We are not good at that at the FAA. We are a series of titanium silos. We have aircraft certification, we have flight standards, we have air traffic, airports and we don’t talk to each other very well.
"A lot of new technologies are focused on the risk of mitigating risks in all those areas—not just one area. My engineers want to mitigate all the risks in your design, flight standards wants to mitigate the risks in your pilot. Air traffic is going to keep you away from everybody and mitigate the risk by not letting you fly over anybody. You can see the trend,” he said. “The FAA is working very hard to make sure we are talking to each other. We are forming agreements with companies that are coming in, including executives, across all of those silos. We are sitting down to working with you as one group and early and often.”
Make the Case for Safety
Lawrence said aircraft builders need to make a strong safety case, first and foremost. “We really don’t care about your business case or how much money you are going to make. We look to make sure all the safety risks are mitigated. When you come to us start with safety. That’s our focus, that’s what all our regulations are built around. If you always come in with safety, you will keep moving forward.”
One of the best ways to bolster a safety case is to liberally adopt industry standards as embodied in the new Part 23 certification rules, Lawrence counseled. “The use of industry consensus standards gives us a huge benefit. We bring in the experts from any field from anywhere in the world who put down their thought on paper and say if you do it this way then it is the best way to address a particular design issue or approach. That is invaluable to the agency to have access to that brain trust.” Lawrence said the aircraft certification office is in the process of establishing an “industry consensus standards office” that will be focused on working with standards groups like SAE, ASTM, and Institute of Electrical and Electronics Engineers.
“The new Part 23 is not the answer to all of your problems, but it is a good example of where we want to move forward from a policy and regulatory standpoint,” he said, adding that inherent in the new Part 23 is a “risk continuum” based on the aircraft/operations likely activities. “We are committed to matching the level of regulatory oversight to the level of risk in your organization. For those who fly experimental aircraft, we don’t dedicate a lot of time to you,” but for aircraft used in commercial operations, the scrutiny is higher, Lawrence said. However, he acknowledged that the FAA’s use of a risk continuum is not widely adopted worldwide and that has the potential to cause issues for those seeking multijurisdictional certifications.
Lawrence counseled that the first UAM/eVTOL developers who file a type certificate application will likely face tough sledding. “You’re never going to break through until somebody is first. It will be harder for you than anyone else. But having a real piece of hardware and a real project forces us to bring those [FAA] teams together.” Nevertheless, Lawrence told UAM developers, “The FAA does want to support your project and we have the resources in place.”