Avionics/Systems Policy Updates - Small Airplane Directorate
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1 Avionics/Systems Policy Updates - Small Airplane Directorate Presented to: AEA 2014 By: Bill Schinstock Date: March, 2014
2 Overview Challenge Focus on GA Safety Key Safety Initiatives Policy/Regulatory Updates 2
3 GA Safety GA Accidents Not on path for 2018 Goals Exceeded 2012 & 2013 Limits Safety Focus - The Safety Continuum Managed Risk and Appropriate Certification Requirements Key to Safety Enhancements Levels of Safety & Cert. for Type of Aircraft and Operation Not a One Size Fits All ACE Safety Initiatives Targeting Specific Safety Enhancements Retrofit Avionics Initiative GAJSC Recommending Specific Solutions Like AoA Clarify Safety Objectives & Reduce Regulatory Roadblocks Part 23 Rewrite 3 3
4 Critical Time for GA Greater Scrutiny on GA Safety Greater Pressures - Cert. Burden, Costs, Public Perception Need Right Approach to Cert. 4
5 Glass Floor for Glass Cockpits New Avionics unaffordable In legacy aircraft Cost >> 50% airframe value LSA & Experimental flourishing New technology prototyped & successful w/o approval, TSO, etc. Allows for safety enhancements such as two-axis autopilot, envelope protection, auto-land, etc. New TC d Aircraft Get Latest & Greatest Not Available for Retrofit Fleet Caught in Middle 5
6 Retrofit Avionics Initiative Target legacy part 23 airplanes Majority of GA fleet Account for most fatal GA accidents Focus on Two-Axis Autopilots & Displays for Retrofit Considering Policy & Streamlined TSOs for Legacy Singles and Twins Under 6,000 lb. Manage risk vs. reward to safely allow & promote innovation Credit for architecture, design features, redundancy Consider function at aircraft level, and mitigations. 6 6
7 Thinking Reflects the Safety Continuum Risk Management for Safety Enhancing Equipment FIGURE: FAA System Safety Handbook Optimal certification rigor is key to advancing safety Too little rigor safety escapes Too much rigor innovative safety enhancements don t reach the fleet complexity & cost of compliance/installation too great Angle of Attack Indicators PHOTO: Alpha Systems AOA Seatbelt Airbags PHOTO: AmSafe Emergency Auto Land Systems PHOTO: Vertical Power Inc. Carbon Monoxide Detectors PHOTO: CO Guardian LLC Ballistic Recovery Parachutes PHOTO: BRS Aerospace 7 7
8 Example Angle of Attack Sensors Advisory AOA Existing Stall Warning Still Primary Source of Information More accurate than airspeed based stall warning i.e. in a dynamic stall Goal - Reduce Loss of Control Accidents GA Joint Steering Committee promoting AOA in GA to address LOC accidents.. March,
9 Advisory AOA Policy Policy AIR PM01, Approval of Non-Required Angle of Attack (AoA) Indicator Systems Production Approval of Simple AoA Systems to Solve 21.8 & 21.9 Related Issues Mechanic Makes the Determination of Installation Suitability by Minor Alteration for Advisory Use in Light GA Aircraft Safety Enhancement Existing Stall Warning Stays Intact - Mitigation Not Intended to Address Installation by STC for More Complex Intended Functions Feedback to Autopilot, etc. 9
10 Future Retrofit Challenge How to Move from Heavy Front Ended Processes to Verification & Validation (V&V) of Final Product & COS Management Current DO-178 Process Requires High Level of FAA Involvement i.e. Review of Plan for Software Aspects of Certification (PSAC), Software Audits, etc. Can Leverage Mature Manufacturer Processes to Shift Focus? Review DO-178 Details Only If COS Issues Arise? Is Level D with Extensive V&V Sufficient for Retrofit Equipment in Small Singles and Twins? 10
11 Retrofit Autopilot Technology Next Focus Area - Typically nonrequired equipment in light GA Now, Autopilots traditionally certified with never fail approach Even Simple wing leveler or attitude hold systems have ever-increasing level of rigor applied Focus on fault tolerant design & architecture so failure is little concern protect aircraft with fail safe design Certify assuming failure will happen - Pilot still knows how to hand fly aircraft & system is only there to reduce workload 11 11
12 Related Reg/Policy Possibilities To Accomplish These Safety Goals, Cert Process Study Indicated Need for Changes Burden for Part 23 Continually Increasing Go Back to Design for Redundancy & Fail Safe Design Counteract Increasing Focus on 10E-9 Statistics Instead of Good Design Practices, Architecture, and Redundancy Concepts Are Often Applied Incorrectly Clarify Qualitative and Quantitative Analysis Requirements 12
13 Part 23 Re-Write Focusing New Part 23 Rules on Top Level Safety Goals Streamlined Language Move Detailed Requirements & MOC into Industry Standards Improve Efficiency and Responsiveness of Regulations & Cert Process Respond To Technology Faster Accomplish Goals/Recommendations of Part 23 ARC and Cert. Process Study Position FAA Regulations for Future of GA 13
14 Interim Step Amendment 62 Part 23 Revised at Amd. 62 Greatly simplified the rule language Took out (d) intended function section and put expectations for function in (a). Ties proper function to criticality of system Codifies Tiered Approach used in AC E Still Have Improper Application of Qualitative & Statistical Analysis for GA Avionics Mixing pilot performance, operational scenario, and combined systems failures so everything has potential catastrophic failures 14
15 Continuing Challenge for Systems Applying Complete Risk Analysis is Difficult Don t have good statistics for human pilot performance and operational exposure for GA Difficult in part 23 system safety analysis process Must Avoid Trend Few existing systems can pass 100% assurance some appear to be seeking with the increasing application of statistical methods Clarifying System Safety Techniques and Expectations 15
16 Part 23 System Safety vs. Others Part 23 accident root causes reflect items that have long been substantially eliminated from part 25, since part 25 mitigation strategies are more mature Likelihood of common root causes have been mitigated by safety improvements over time in part 25 However, part 25 mitigation strategies are often unavailable, or unaffordable for part 23, warranting a different approach Seeking to Implement Use of Safety Continuum Focusing Too Much on Sufficiently Rare Events, i.e. Combined Failure Modes, Operational Scenarios, and Pilot Performance 16
17 Technology Reg/Policy Changes PS-ACE R1 - Installation of Portable Displays and Electronic Devices in Normal, Utility, and Acrobatic Category Airplanes Explains use and installation of portable avionics/systems PS-ACE Clarification of Requirements for 14 CFR Part 23, LED Installations in Taxi and Landing Lights Addresses concerns for LED lighting applications in GA AIR-100_ Approved Model List Supplemental Type Certificate Criteria and Clarification AML policy from AIR-100, but AC is still active for Part 23 projects PS-ACE Installation of Wireless Local Area Network using IEEE Protocols Deals with wireless installations in part 23 and provides a decision tree for level of FAA involvement 17
18 Future Challenges Recognize aviation no longer drives hardware development Computer & consumer products drive component development Consider Alternatives to DO-178, recognizing COTS equipment/sensors may hold key to huge safety enhancements Find synergy between UAS and Manned GA technology Leverage systems from optionally piloted aircraft Reduce loss of control with intuitive, affordable automation 18
19 Trends NOW Portable Devices Connected Devices Hybrid Avionics Auto Collision Avoidance - Air/Gnd Easy Button - Automatic Landing Optionally Piloted Vehicles Electric Propulsion UAS Autopilots Future? 19
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