Category: Regulation

Don Bateman

At the start of the jet-age, changes in aircraft design and the improvement of maintenance procedures made a significant improvement in aviation safety. One set of accidents remain stubbornly difficult to reduce. This is the tragic case where a perfectly airworthy aircraft is flown into the ground or sea. Clearly the crew, in such cases had no intention to crash but never-the-less the crash happens. Loss of situation awareness, fixation on other problems or lack of adherence to standard operating procedures can all contribute to these aircraft accidents. So often these are fatal accidents.

One strategy for reducing accidents, where there is a significant human factor, is the implementation of suitable alerting and warning systems in the cockpit. It could be said that such aircraft systems support the vigilance of the crew and thus help reduce human error.

For decades the number one fatal accident category was Controlled Flight Into Terrain (CFIT). It always came top of global accident analysis reports. Pick up a book on the world’s major civil aircraft crashes since the 1960s and there will be a list of CFIT accidents. By the way, this term CFIT is an internationally agreed category for classifying accidents[1]. 20-years ago, I was part of a team that managed these classifications.

When I started work on aircraft certification, in the early 1990s, the Ground Proximity Warning System (GPWS) already existed. A huge amount of work had been done since the 1970s defining and refining a set of protection envelopes that underpinned cockpit warnings aimed at avoiding CFIT.

UK CAA Specification 14 on GPWS dates from 1976[2]. This safety equipment had been mandated in many countries for certain types of public transport aircraft operation. It was by no means fitted to all aircraft and all types of aircraft operation. This was highlighted when an Air Inter AIRBUS A320 crashed near Strasbourg, in France in January 1992[3].

No alerting or warning system is perfect. GPWS had been successful in reducing the number of CFIT accidents but there were still occurrences where the equipment proved ineffective or was ignored.

I first met Don Bateman[4] on one of his whistles-stop tours presenting detailed analysis of CFIT accidents and the latest versions of the GPWS. At that time, he was working for the company Sundstrand[5], based in Redmond in Washington State, US. It was a time when Enhanced GPWS (EGPWS)[6] was being promoted. This version of the equipment had an added capability to address approaches to runways where the classic GPWS was known to give false results. False alerts and warnings are the enemy of any aircraft system since they reduce a crew’s confidence in its workings.

My role was the UK approval of the systems and equipment. Over a decade the industry moved from a basic GPWS to EGPWS to what we have now, Terrain Avoidance and Warning Systems (TAWS).

When I think of Don Bateman’s contribution[7], there are few people who have advanced global aviation safety as much as he did. His dedication to driving forward GPWS ensured the technology became almost universal. Consequently, there must be a large number of lives saved because of the CFIT accidents that did not happen.

He left no doubt as to his passion for aviation safety, was outstandingly professional and a pleasure to work with on every occasion. This work was an example of a positive and constructive partnership between aviation authorities and industry. We need more of that approach.

POST 1: Don Bateman Saved More Lives Than Anyone in Aviation History | Aviation Pros

POST 2: Don Bateman, ‘Father’ Of Terrain Awareness Warning Systems, Dies At 91 | Aviation Week Network

[1] https://www.intlaviationstandards.org/Documents/CICTTStandardBriefing.pdf

[2] https://publicapps.caa.co.uk/docs/33/CASPEC14.PDF

[3] https://reports.aviation-safety.net/1992/19920120-0_A320_F-GGED.pdf

[4] https://www.invent.org/inductees/c-donald-bateman

[5] https://archive.seattletimes.com/archive/?date=19930125&slug=1681820

[6] https://aerospace.honeywell.com/us/en/pages/enhanced-ground-proximity-warning-system

[7] https://aviationweek.com/air-transport/safety-ops-regulation/don-bateman-father-terrain-awareness-warning-systems-dies-91

Ban

Some policies are directly targeted to fix a problem, other policies maybe aimed at indicating a direction of travel. I think the measures in France to ban domestic flights on short routes is the later.

Internal routes that can be flown in less than two-and-a-half hours, are prohibited[1]. That can be done because high-speed rail transport offers a means of connecting certain French cities.

The calculation being that greenhouse gas emissions will be reduced by this control. There had been many calls for even stricter restrictions on flying in France. Lowering carbon emissions is a priority for many European governments. Sovereignty is primary in this respect. A State can take measures to control domestic flying much more readily than they can internationally. Connecting flights will not be changed by this new legislation.

High-speed trains do take passengers from airlines and take cars off the roads. Where a mature rail network exists, there are significant benefits in focusing on rail transport between cities. Often rail and air are complementary, with major high-speed rail stations at airports.

Given the rhetoric surrounding the “climate emergency” these restrictions are a modest measure that will make only a small difference to carbon emissions. The symbolism is significant. It’s a drive in a transport policy direction that may go further in time and other States may do the same.

Flying between Paris and Lyon doesn’t make much sense when a good alternative is available. Flying between London and Birmingham doesn’t make much sense either. However, changes like these need to be data-driven transformations. There needs to be a measure reduction in greenhouse gas emissions because of their implementation. For example, displacing travellers onto the roads would be a negative outcome.

The imperative of greenhouse gas emission reduction means creative and new measure will happen. It’s far better for aviation to adapt to this framework of operations rather than push back. The direction of travel is set.

[1] https://www.bbc.co.uk/news/world-europe-65687665

Lables

Performance based regulatory systems are all the rage. That’s when regulatory action is taken based on the measurement of a key indicator or a series of indicators. Sounds like a good idea. It is for the most part. Set a target of reducing or eliminating something that is damaging or undesirable and track progress towards achieving that goal.

Wouldn’t it have been to the benefit of all if a performance-based approach had been applied in the 1989 Water Act which privatised water in England and Wales? A great deal of sewage flooding into rivers could have been avoided. 

However, it wouldn’t have helped to have nothing more than a simple “good” or “bad” indicator. In a performance-based system there’s a need for reasonably accurate measurement and graduated bans of performance achieved. The measurements taken need to be done in a timely manner too. Publishing measures that are a year or more out-of-date isn’t a good way of confidently plotting a way forward to hit a goal.

Listening to the News about Ofsted’s grading scheme, I can’t help but think that having a four-category grid is wholly inadequate for their purpose. Ofsted is the Office for Standards in Education, Children’s Services and Skills. The Education inspection framework (EIF)[1] in England is primitive in this respect. Shoe-horning every school in England into Outstanding, Good, Requires Improvement or Inadequate is brutal.

What’s the betting that at any one day many of the schools graded Outstanding are not, and many of the schools graded Inadequate are not either. The problem with these indicators is the crudity of the labels. We’ve all seen huge banners erected outside schools if there’s favourable news to communicate. What passers-by and parents see is the headline and not the reality of the performance of a particular school.

The sub-division of the lowest category into schools with serious weaknesses and in need of significant improvement doesn’t help much. Negative words get merged into a negative judgement.

Experience with risk management is that categorisation schemes face challenges when performance sits on the borderline between categories. That’s one reason why anything less than five categories is not often used.

The aim of a performance based regulatory systems is to improve performance. If the tools used become those that blame and shame, then that system is not working. Nothing, I’m saying here isn’t already written-up in the annals of quality management. People have been wrestling over different methods for 60 years, at least.

The current Ofsted’s grading scheme is poor and unimaginative.

[1] https://www.gov.uk/government/publications/education-inspection-framework/education-inspection-framework

Fake/Real?

So, why might artificial intelligence (AI) be so dangerous in a free society?

Democracy depends upon information being available to voters. Ideally, this would be legal, decent, and honest information. All too often the letter of the law may be followed whilst shaping a message to maximise its appeal to potential supporters. Is it honest to leave out chunks of embarrassing information for the one nugget that makes a politician look good? We make our own judgement on that one. We make a judgement assuming that outright lying is a rare case.

During key elections news can travel fast and seemingly small events can be telescoped into major debacles. I’m reminded of the remark made by Prime Minister Gordon Brown[1] when he thought the media’s microphones were dead. In 2010, when an aide asked: What did she say? Gordon Brown was candid in his reply. It’s an occasion when the honest thoughts of a PM on the campaign trail popped into the public domain and livened up that election coverage considerably.

What’s concerning about AI[2] is that, in the hands of a “bad actor,” such events could be faked[3] extremely convincingly. Since the fast pace of election campaigning leaves never enough time for in-depth technical investigations there’s a chance that fake events can sway people before they are uncovered. The time between occurrence and discovery need only be a few days. Deep fakes are moving from amateur student pranks to the tools of propagandists.

Misinformation happens now, you might say. Well, yes it does, and we do need people to fact-check claims and counter claims on a regular basis. However, we still depend on simple techniques, like a reporter or member of the public asking a question. It’s rather a basic in format.

This leaves the door open for AI to be used to produce compelling fakes. Sometimes, all it needs is to inject or eliminate one word from a recording or live event. The accuracy and speed of complex algorithms to provide seamless continuity is new. It can be said that we are a cynical lot. For all the protest of fakery that a politician may make after an exposure there will be a plenty of people who will not accept any subsequent debunking.

My example is but a simple one. There’s a whole plethora of possibilities when convincing fake pictures, audio and videos are only a couple of keyboard stokes away.

Regulatory intervention by lawmakers may not be easy but it does need some attention. In terms of printed media, that is election leaflets there are strict rules. Same with party political broadcasts.

Being realistic about the risks posed by technology is not to shut it down altogether. No, let’s accept that it will become part of our lives. At the same time, using that technology for corrupt purposes obviously needs to be stamped on. Regulatory intervention is a useful way of addressing heightened risks. Some of our 19th century assumptions about democracy need a shake-up. 

[1] https://www.independent.co.uk/news/uk/politics/bigotgate-gordon-brown-anniversary-gillian-duffy-transcript-full-read-1957274.html

[2] https://edition.cnn.com/2023/05/16/tech/sam-altman-openai-congress/index.html

[3] https://www.nytimes.com/2023/02/07/technology/artificial-intelligence-training-deepfake.html

Turbulence

Brexit “outrage” as The Express newspaper put it. Headlines like this are signs of shear desperation. It seems every time something goes wrong, which it regularly does, the call comes out from Brexit supporters – it must be Remainers or the House of Commons or Lords or civil servants or large corporations or lefty liberals thwarting the great Brexit plan. Noting, of course, that there never was a plan in the first place.

“Take Back Control” has become the hollowest political slogan in British history. Rather than dimming the light of fervent Brexit advocates these repeated setbacks just pump them up. This kind of thinking is both sad and dangerous. It has a deep flavour of paranoia.

This month, shocks from the Conservative Party’s council election meltdown are another trigger for the political right to agitate. Shouting: bring back Boris Johnson is unsurprising. The dreamy magical thinking is that because he delivered a big parliamentary majority in 2019, somehow, he, and he alone, can do the same in 2024. Other conservatives are positioning themselves for the next run at being Prime Minister.

I’m not one to totally dismiss the Johnson proposition. Naturally, it would be calamitous and beyond reason but that has not been an impenetrable barrier since 2016. Brexit, as a happening, delights in causing chaos. There’re political thinkers who invite chaos and disruption to free potentially creative energies. They’re not a bit concerned about the impact of that approach on the average person.

Brexit continues to hobble aviation in UK. A large percentage of the people who worked in UK aviation, before the COVID pandemic, were EU nationals. A lot have gone. Now, it’s often the case that when EU nationals apply for jobs in the UK, the aviation industry must turn them down[1].

The legislative proposal to remove retained EU laws has created yet more uncertainty for UK’s aviation sector. The threat remains regardless that it may be in the process of being watered down. Debates in the House of Lords focused on democratic scrutiny of the process where significant changes are planned[2]. Ministers continue to wish to use arbitrary powers to make changes. There’s ambition in the policies advanced while, at the same time, there’s a wish to look all ways at once.

For a lot of aviation topics, the UK has stated it will continue to use European Union Aviation Safety Agency (EASA) rules and guidance. Although, this is eminently sensible in an international setting it does suggest that Brexit benefits, if they exist at all, have been greatly overstated.

Given the tabloid media jitters seen in recent headlines, it’s perfectly clear that Brexit is a million miles from being “done”. A bad idea remains a bad idea, however it’s dressed up.

Expect turbulence right up to the next General Election. Change is not assured. People will have to campaign hard to make it happen. In comment on the change of the crown, “The country is in a waiting room” said historian Simon Schama.

[1] One major airline – We have had to turn down a huge number [8,000] of EU nationals because of Brexit. Another has blamed the British government’s post-Brexit immigration constraints on the labour market for fuelling staff shortages.

[2] https://www.bbc.co.uk/news/uk-politics-65605035

Engineering

I know this is not a new issue to raise but it is enduring. Years go by and nothing much changes. One of the reasons that “engineering” is poorly represented in the UK is that its voice is fragmented.

I could do a simple vox pop. Knock on a random door and ask – who speaks for engineers in the UK. The likelihood is that few would give an answer, let alone name an organisation. If I asked who speaks for doctors, those in the know would say the BMA[1]. If I asked who speaks for lawyers, most would answer the law society[2]. I dare not ask who represents accountants.

Professional engineering institution have an important role. That’s nice and easy to say, in-fact all the ones that are extant do say so. Supporting professional development is key to increasing access to engineering jobs. It’s spokespersons, specialist groups and networking opportunities can provide visibility of the opportunities in the profession.

So, why are there so many different voices? There’s a great deal of legacy. An inheritance from bygone eras. I see lots of overlap in the aviation and aerospace industries. There’re invitations in my in-box to events driven by IET[3], IMECHE, Royal Aero Society and various manufacturing, software, safety, and reliability organisations.

The variety of activities may serve specialist niches, but the overall effect is to dilute the impact the engineering community has on our society. Ever present change means that new specialist activities are arising all the time. It’s better to adapt and include these within existing technical institutions rather than invent new ones.

What’s the solution? There have been amalgamations in the past. Certainly, where there are significant overlaps between organisations then amalgamation maybe the best way forward.

There’s the case for sharing facilities. Having separate multiple technical libraries seems strange in the age of the connected device. Even sharing buildings needs to be explored.

Joint activities do happen but not to the extent that could fully exploit the opportunities that exits.

If the UK wishes to increase the number of competent engineers, it’s got to re-think the proliferation of different institutions, societies, associations, groupings, and licencing bodies.  

To elevate the professional status of engineering in our society we need organisations that have the scale and range to communicate and represent at all levels. Having said the above, I’m not hopeful of change. Too many vested interests are wedded to the status-quo. We have both the benefits of our Victorian past and the milestone of that grand legacy. 

[1] https://www.bma.org.uk/

[2] https://www.lawsociety.org.uk/en

[3] http://www.theiet.org/

Deregulation

There’s nothing wrong with making an argument for deregulation. What’s absurd is to make that argument as an unchallengeable dogma. It’s the irrationality of saying that deregulation is good, and regulation is bad, de-facto. This kind of unintelligent nonsense does permeate a particular type of right-wing political thinking. It pops it’s head up in a lot of Brexiters utterances. For advocates of Brexit their great goal is to throw away rules and lower standards. Mostly, this is for financial gain.

Let’s take some simple examples. The reasons for rules and regulations can often be found in recent history. Hazards are recognised and action is taken.

There’s still lead paint to be found in many older houses. There was a time when such paint was used on children’s toys. Toy safety has been a confusing area of law, and there have been several sets of regulations since the 1960. From our current perspective this past laxness seems insane, but such lead paint mixtures were commonplace. In fact, all sorts of toxic chemicals have been used in widely used paints.

I remember working in one factory building where a survey was done of the surrounding grounds. Outside certain windows there were small fluorescent flags placed at in the grass verges. They marked places where minor amounts of radiation had been detected. This came from discarded paint brushes and tins that had accumulated in the war years. At that time radioactive luminescent paint was used to paint aircraft instrument dials.

Any arguments for the deregulation of toxic chemicals in commonly used paints should be one that is quashed instantly. However, some deregulation fanatics are only to happy to endorse a loosening of the rules that protect the public from toxic chemicals.

One result of the loosening of public protection is often to put greater profits in the hands of unscrupulous industrialist. Across the globe there are numerous cases studies of this sad folly. Newspapers and political parties that push the line that rules, regulations and regulators, by their very nature are crushing our freedoms are as bad as those unscrupulous industrialists.

Yes, there’s a case to be made for pushing back over-regulation. There’s risks we are prepared to take where the risks are low, and the benefits are large. This is a matter for intelligent debate and not throwing around mindless slogans. We should not be cowed by loud voices from small corners of society intent on tearing down decades of learning and sound practical laws. I could come up with an encyclopaedic list of examples. Opponents rarely, if ever want to address a particular case since it’s much easier for them to thunder off sweeping assertions. Beware these siren voices.

NOTE: The Toys (Safety) Regulations 2011 implemented the requirements of Directive 2009/48/EC, whose purpose is to ensure a high level of toy safety.

Experts

The rate of increase in the power of artificial intelligence (AI) is matched by the rate of increase in the number of “experts” in the field. I’ve heard that jokingly said. 5-minutes on Twitter and it’s immediately apparent that off-the-shelf opinions run from – what’s all the fuss about? to Armageddon is just around the corner.

Being a bit of a stoic[1], I take the view that opinions are fine, but the question is what’s the reality? That doesn’t mean ignoring honest speculation, but that speculation should have some foundation in what’s known to be true. There’s plenty of emotive opinions that are wonderfully imaginative. Problem is that it doesn’t help us take the best steps forward when faced with monumental changes.

Today’s report is of the retirement of Dr Geoffrey Hinton from Google. Now, there’s a body of experience in working with AI. He warns that the technology is heading towards a state where it’s far more “intelligent” than humans. He’s raised the issue of “bad actors” using AI to the detriment of us all. These seem to me valid concerns from an experienced practitioner.

For decades, the prospect of a hive mind has peppered science fiction stories with tales of catastrophe. With good reason given that mind-to-mind interconnection is something that humans haven’t mastered. This is likely to be the highest risk and potential benefit. If machine learning can gain knowledge at phenomenal speeds from a vast diversity of sources, it becomes difficult to challenge. It’s not that AI will exhibit wisdom. It’s that its acquired information will give it the capability to develop, promote and sustain almost any opinion.

Let’s say the “bad actor” is a colourful politician of limited competence with a massive ego and ambition beyond reason. Sitting alongside, AI that can conjure-up brilliant speeches and strategies for beating opponents and that character can become dangerous.

So, to talk about AI as the most important inflection point in generations is not hype. In that respect the rapid progress of AI is like the invention of the explosive dynamite[2]. It changed the world in both positive and negative ways. Around the world countries have explosives laws and require licenses to manufacture, distribute, store, use, and possess explosives or its ingredients.

So far, mention of the regulation of AI makes people in power shudder. Some lawmakers are bigging-up a “light-touch” approach. Others are hunched over a table trying to put together threads of a regulatory regime[3] that will accentuate the positive and eliminate the negative[4].

[1] https://dailystoic.com/what-is-stoicism-a-definition-3-stoic-exercises-to-get-you-started/

[2] https://en.wikipedia.org/wiki/Dynamite

[3] https://digital-strategy.ec.europa.eu/en/policies/european-approach-artificial-intelligence

[4] https://youtu.be/JS_QoRdRD7k

AI awakens

Artificial Intelligence (AI)[1] is with us. Give it a question and it will answer you. Do it many times, with access to many information sources and it will improve its answer to you. That seems like a computer that can act like a human. In everyday reality, AI mimics a small number of the tasks that “intelligent” humans can do and do with little effort.

AI has a future. It could be immensely useful to humanity. As with other revolutions, it could take the drudgery out of administrative tasks, simple research, and well characterised human activities. One reaction to this is to joke that – I like the drudgery. Certainly, there’s work that could be classified as better done by machine but there’s pleasure to be had in doing that work.

AI will transform many industries but will it ever wake-up[2].  Will it ever become conscious.

A machine acting human is not the same as it becoming conscious. AI mimicking humans can give the appearance of being self-aware but it’s not. Digging deep inside the mechanism it remains a computational machine that knows nothing of its own existence.

We don’t know what it is that can give rise to consciousness. It’s a mystery how it happens within our own brains. It’s not a simple matter. It’s not magic either but it is a product of millions of years of evolution.

Humans learn from our senses. A vast quantity of experiences over millennia have shaped us. Not by our own choosing but by chance and circumstances. Fortunately, a degree of planetary stability has aided this growth from simple life to the complex creatures we are now.

One proposition is that complexity and conscious are linked. That is that conscious in a machine may arise from billions and billions of connections and experiences. It’s an emergent behaviour that arises at some unknown threshold. As such this proposition leaves us with a major dilemma. What if we inadvertently create conscious AI? What do we do at that moment?

Will it be an accidental event? There are far more questions than answers. No wonder there’s a call for more research[3].

[1] https://www.bbc.co.uk/newsround/49274918

[2] https://www2.deloitte.com/us/en/pages/consulting/articles/the-future-of-ai.html

[3] https://www.bbc.co.uk/news/technology-65401783.amp

Head in Sand

Well, it’s happened. A debate. Are we any wiser? Well, not much. So many good points are raised but so many good points are dismissed by current Government Ministers. So deep are they in a mess of their own making.

On Monday, 24 April at 16:30, a UK Parliamentary debate[1] took place on the impact of the UK’s exit from the European Union (EU). This was consideration of e-petition[2] 628-226 relating to the impact of the UK’s exit from the EU. On the day of this debate this petition had attracted over 178 000 signatures. Petition debates are “general” debates which allow UK Members of Parliament (MPs) from all political parties to discuss important issues raised by the public.

The petition reasons that the benefits that were promised, if the UK exited the EU have not been delivered. Not at all. Although this fact might be self-evident it never-the-less warranted a timely debate. Public support for Brexit is falling as every day that goes by.

The petitioners called upon the UK Government to hold a public inquiry to assess the impact that Brexit has had on this country and its people. Given that other less impactful events have been subject to a public inquiry it seems only right that Brexit be investigated.

The call for an independent public inquiry, free from ideology and the opinions of vested interests is only fair, right, and proper in an accountable democratic 21st Century country. Transparency is a mark of good governance.

Today’s, Brexit is damaging the UK’s economy, opportunities for young people and rights of individuals. It’s well past the time that the people of the UK were told the full story. There needs to be a way out of this mess.

In the debate the point was made that the two biggest Westminster political parties continue to be committed to Brexit despite the harm that it’s doing to the UK. A long list of disbenefits were rattled off as speakers paced through the evidence. A long list that is growing.

The Government’s current approach is to ask UK Parliamentarians to stop talking about Brexit. It’s the ultimate ostrich with its head in the sand[3]. Brexit is a gigantic strategic mistake. Unfortunately, there remains a significant number of English politicians so entrenched in the mythology of Brexit that change is slow in coming. The public are way ahead of the politicians.

Stereotyping people as being in one camp or another, with the aim of continuing to divide the public is the unscrupulous tool of those people without a rational or coherent argument to make. It’s clear, progress will not be made until Ministers recognise that Brexit was a mistake. We may have to wait until after the next UK General Election before a real change is possible. Let’s hope that day comes soon.

POST 1: UK Press reports on the debate MPs debate consequences of Brexit for first time | The Independent MPs debate Brexit impact ‘for the first time since leaving the EU’ | The National Brexit: MPs call for public inquiry into impact of leaving EU – BBC News

POST 2: Brexit is a drag on the UK Sunak Grins And Bears It As Boss Hits Out At Brexit’s ‘Drag On Growth’ | HuffPost UK Politics (huffingtonpost.co.uk)

[1] https://youtu.be/iHzf1BQFXq8

[2] https://petition.parliament.uk/

[3] It’s a myth ostriches bury their head in the sand. Though this isn’t true, Ostrich Syndrome is a popular belief. It’s avoidance coping that people use to manage uncomfortable feelings or rather, not deal with them.