Regulation – Page 14 – John Vincent

Just H

What is the future of Hydrogen in Aviation? Good question. Every futurologist has a place for Hydrogen (H) in their predictions. However, the range of optimistic projections is almost matched by the number of pessimistic ones.

There’s no doubt that aircraft propulsion generated using H as a fuel can be done. There’s a variety of way of doing it but, the fact is, that it can be done. What’s less clear is a whole mass of factors related to economics, safety and security and desirability of having a hydrogen-based society.

H can be a clean form of energy[1], as in its purest form the process of combustion produces only water. We need to note that combustion processes are rarely completely pure.

It’s an abundant element but it prefers to be in company of other elements. Afterall, the planet is awash with H₂O. When H is on its own it has no colour, odour, or taste. In low concentrations, we humans could be oblivious to it even though there’s a lot of it in the compounds that make us up.

Number one on the periodic table, it’s a tiny lightweight element that can find all sorts of ways of migrating from A to B. Ironically, that makes it an expensive element to move around in commercially useable quantities. H is often produced far away from where it’s used. For users like aviation, this makes the subject of distribution a fundamental one.

Part of the challenge of moving H around is finding ways of increasing its energy density. So, making it liquid or pumping it as a high-pressure gas are the most economic ways of using it. If this is to be done with a high level of safety and security, then this is not going to come cheap.

There are a lot of pictures of what happens when this goes wrong. Looking back at the airships of the past there are numerous catastrophic events to reference. More relevantly, there’s the space industry to look at for spectacular failures[2]. A flammable hydrogen–air mixture doesn’t take much to set it off[3]. The upside is that H doesn’t hang around. Compared to other fuels H is likely to disperse quickly. It will not pool on the ground like Kerosene does.

In aviation super strict control procedure and maintenance requirements will certainly be needed. Every joint and connectors will need scrupulous attention. Every physical space where gas can accumulate will need a detection system and/or a fail proof vent.

This is a big new challenge to aircraft airworthiness. The trick is to learn from other industries.

NOTE: The picture. At 13:45 on 1 December 1783, Professor Jacques Charles and the Robert brothers launched a manned balloon in Paris. First manned hydrogen balloon flight was 240 years ago.

[1] https://knowledge.energyinst.org/collections/hydrogen

[2] https://appel.nasa.gov/2011/02/02/explosive-lessons-in-hydrogen-safety/

To provoke

Social media provocateurs are on the rise. Say something that’s a bit on the edge and wait for the avalanche of responses. It’s a way of getting traffic to a site. The scientific and technical sphere has these digital provocateurs less than the glossy magazine brigade, but the phenomena is growing.

Take a method or technique that is commonly used, challenge people to say why it’s good while branding it rubbish. It’s not a bad way to get clicks. This approach to the on-line world stimulates several typical responses.

One: Jump on-board. I agree the method is rubbish. Two: I’m a believer. You’re wrong and here’s why. Three: So, what? I’m going to argue for the sake of arguing. Four: Classical fence sitting. On the one hand you maybe right on the other hand you may be wrong.

Here’s one I saw recently about safety management[1]. You know those five-by-five risk matrices we use – they’re rubbish. They are subjective and unscientific. They give consultants the opportunity to escalate risks to make new work or they give managers the opportunity to deescalate risk to avoid doing more work. Now, that’s not a bad provocation.

If the author starts by alleging all consultants and managers of being manipulative bad actors that sure is going to provoke a response. In safety management there are four pillars and one of them is safety culture. So, if there are manipulative bad actors applying the process there’s surely a poor safety culture which makes everything else moot.

This plays into the discomfort some people have with the inevitable subjectivity of risk classification. It’s true that safety risk classification uses quantitative and qualitative methods. However, most typically quantitative methods are used to support qualitative decisions.

There’s an in-built complication with any risk classification scheme. It’s one reason why three-by-three risk matrices are often inadequate. When boundaries are set there’s always the cases to decide for items that are marginally one side or other side of a prescribed line.

An assessment of safety risk is just that – an assessment. When we use the word “analysis” it’s the supporting work that is being referenced. Even an analysis contains estimations of the risk. This is particularly the case in calculations involving any kind of human action.

To say that this approach is not “scientific” is again a provocation. Science is far more than measuring phenomena. Far more than crunching numbers. It includes the judgement of experts. Yes, that judgement must be open to question. Testing and challenging is a good way of giving increased the credibility of conclusions drawn from risk assessment.

[1] https://publicapps.caa.co.uk/docs/33/CAP795_SMS_guidance_to_organisations.pdf

Artificial intelligence (AI) transition

There’s much that has been written on this subject. In fact, for a non-specialist observer it’s not so easy to get to grips with the different predictions and views that are buzzing around.

There’s absolutely no doubt that Artificial intelligence (AI) will change every corner of society. Maybe a few living off-grid in remote areas will remain untouched but every other human on the planet will be impacted by AI. Where there’s digital data there will be AI. Some will say this brings the benefits of AI into our everyday and others herald a pending nightmare where we lose control.

Neither maybe totally on the money but what’s clear is that this is no ordinary technological transition. Up until now, the software we use has been a tool. Built for a purpose and shaped by those who programmed its code. AI is not like that at all. It’s a step beyond just a tool.

Imagine wheeling a hammer that changed shape to suite a job, but the user had no control over the shape it took. How will we take to something so useful but beyond our immediate control?

In civil aviation, AI opens the possibility of autonomous flight, preventive maintenance, and optimal air traffic management. It may work with human operators or replace them in its more advanced future implementations. Even the thought of this causes some professional people to recoil.

I’ve just finished reading the book[1] of a former Google chief officer, Mo Gawdat and he starts off being pessimistic about the dangers of widespread general AI. As he moves through his arguments, the book points to us as the problem and not the machines. It’s what we teach AI that matters rather than the threat being intrinsic to the machine.

To me, that makes perfect sense. The notion of GIGO[2] or “Garbage In, Garbage Out” has been around as long as the computer. It does, however, put a big responsibility on those who provide the training data for AI or how that data is acquired.

Today’s social media gives us a glimpse of what happens when algorithms slavishly give us what we want. Anarchic public training from millions of hand-held devices can produce some undesirable and unpleasant outcomes.

It maybe that we need to move from a traditional software centric view of how these systems work to a more data centric view. If AI starts with poor training data, the outcome will be assuredly poor.

Gawdat dismisses the idea that general AI can be explainable. Whatever graphics or equations that may be contrived they are not going to give a useful representation of what goes on inside the machine after a period of running. An inability to explain the inner working of the AI maybe fine for non-critical applications but it’s a problem in relation to safety systems.

[1] Mo Gawdat. Scary Smart, the future of artificial intelligence and how you can save our world. 2021. ISBN 978-1-5290-7765-0.

[2] https://techterms.com/definition/gigo

High ALT

Normal commercial air traffic control doesn’t go beyond 60,000 ft in altitude. That makes sense since civil flying activities have been limited to lower altitudes. In fact, modern commercial airliners are not designed to fly above about 45,000 feet. This is a compromise based on what works commercially as much as what’s works best. Aircraft instruments are calibrated making standard assumption about the atmosphere.

For some of its flight, Concorde cruised at a height of 60,000 feet. More like a military jet, with its speed it had the capability to make use of higher altitudes.

It’s even possible to fly above 50,000 feet without an engine. The world record glider flight by AIRBUS shows it’s possible.

The Earth’s atmosphere is not uniform. It changes its characteristics with altitude. The atmosphere can be divided into five layers, as the temperature and density change. They are named: Troposphere, Stratosphere Mesosphere, Ionosphere and Exosphere.

The Troposphere is a layer that goes from 8 kms (26,247 ft) on the poles to about 18 kms (59,055 ft) on the equator. This is the layer where weather is experienced.

On average, the Stratosphere goes up to about 40 kms (131,234 ft). The winds blows fast but they tend to be more consistent as they wrap around the globe. The lower portion of the Stratosphere is virtually isothermal (layer of constant temperature).

A medieval English philosopher and Franciscan friar, Roger Bacon[1] figured out that the air might support a ship in the same way that water supports ships. In the 13^th Century that was a nice academic conclusion but little more.

With all the current controversy surrounding high altitude balloons, that the road to flight started with balloons, could be said to be a bit ironic. It’s long been known about that balloons fly well at high altitudes but it’s a new frontier as far as commercial activity is concerned. For science, weather balloons may go up to 40 km to measure the high level winds.

Some experimental work has been done on trying to commercially use the airspace above normally civil flying. The Google Loon trials[2] are an example of an attempt to float a telecommunications platform high in the sky. These balloon trials were abandoned as difficulties proved greater than anticipated.

It’s not so easy to keep a high altitue balloon on-station.

Now, considering the news in North America, maybe high-altitude operations ought to be a matter of regulatory concern. This is not a subject that any one country can address alone.

There is some legal, regulatory and technical work[3] underway in Europe[4] but it needs to make progress. This is a subject for international collaboration.

[1] https://en.wikipedia.org/wiki/Roger_Bacon

[2] https://blog.x.company/loons-final-flight-e9d699123a96

[3] https://www.eurocontrol.int/article/echo-making-space-new-high-altitude-entrants

[4] https://www.eurocontrol.int/events/european-higher-airspace-operations-symposium

Rules

Let’s be controversial. Principle Based Rules could be retitled Hypocrisy Based Rules.

Now, I’ve already caused confusion because most consumers, or users of services will not have a clue what I’m talking about. The way rules are put together is not an everyday topic for conversation. Even if, in our complex society, this subject is vitally important.

Listening to the daily news it’s clear there’s been a break down between British Gas and its regulator and some vulnerable customers. Practices undertaken by a British Gas sub-contractor have shocked people. Breaking into people’s homes should not be normal business practice.

Yet, these real-world actions happened, and they sharply go against the “principles” of the energy supplier[1] and its regulator. So, do the rules that exist produce behaviours that fit with public expectations? This is the “how long is a piece of string” question. In other word the perception of the rules, such as they are, can be favourable but when it comes to implementation it’s another story completely.

Sadly, the defensive reactions of both energy supplier and regulator are to frame the whole problem as one of first not knowing then discovery, investigation, and corrective action. This is not bad in of itself, but it’s the most basic kind of reactive response that can be expected. It says to the consumer, we will wait for an influential spokesperson[2] to highlight a failing and then respond to pressure.

Has British Gas captured its regulator? That is to convince them that everything is hunky-dory and maybe convinced themselves it’s hunky-dory too but at the same time not bother to look at customer facing bad practices?

Hence my coining the notion of Hypocrisy Based Rules. I’m not saying for one moment that regulatory rules can be written that have no gaps, inconsistencies, or avenues for “creative compliance”. It can be advantageous to the consumer that an energy suppler has a degree of freedom on how they comply with rules.

What was missing is that regard for the need for constant vigilance. Reports suggest that British Gas’s sub-contractor undertook behaviour that did not fulfil regulatory goals.

Although it’s long in the tooth, this quote from an Irish statesman has resonance:

The condition upon which God hath given liberty to man is eternal vigilance. John Philpot Curran[3]

In this simple sentence “liberty” can be replaced with safety, security, prosperity, and honesty. It’s often been reworked.

[1] https://www.centrica.com/about-us/people-culture/our-code

[2] https://www.thetimes.co.uk/article/british-gas-prepayment-meter-debt-energy-bills-investigation-wrgnzt6xs

[3] https://www.britannica.com/biography/John-Philpot-Curran

3-years on

Today, the weakest arguments are being used to sustain Brexit. Still the advocates of Brexit call for deregulation, slashing taxes but more Government borrowing. The Truss formula, despite its disastrous effect remains popular amongst Brexit supporters.

Britain, having left the EU Customs Union and Single Market, has agreed roll-over trade deals with some countries. However, there has been no huge boost to trade as Brexit advocates claimed there would be after the 2016 vote. Brexit negotiations drag on and on. It’s perpetual motion. Maybe there’s a fix to the Northern Ireland difficulties. Maybe not.

If you are inclined, you can always blame everything on the Government’s pandemic response. As politicians are apt to do, there are quite a few avenues open to excuse away the negative impact of Brexit.

The lies told during the UK referendum campaign of 2016 will not go away.

On the 3-year anniversary of leaving the EU, pollsters have been out and about to gauge public opinion. It seems that apart from some parliamentary constituencies in Lincolnshire, others show a majority think Brexit wasn’t a good idea. 54% say Britain was wrong to leave the EU[1][2].

We don’t not know exactly when the next UK General Election will be, but political parties are gearing up for the fight to come. Because of the dreadful First Past the Post (FPTP) electoral system the UK’s opposition parties have a hill to climb in the race for Westminster. Again, referencing the current polls, even with that hill to climb there’s a high likelihood that change is on the way.

The end of this Brexit Government will not come soon enough. Look at the state the country is in. The longer this Conservative party remains in power the more damage will be done.

NOTE: The United Kingdom withdrew from the European Union on 31 January 2020. Based on the Withdrawal Agreement that had been ratified by both the EU and the UK, a transitional period during which EU law continued to apply in the United Kingdom ended on 31 December 2020.

POST: Ardent Brexit supporters are saying: we have to give it more time. Judging our economic position after 3-years isn’t enough to draw conclusions. This is like saying that having made a bad investment, it’s best to stick with the bad investment. Some people may agree with this type of argument. I say it’s foolish. The Brexit referendum has done damage. It will only be repaired by reversing a destructive and much regretted decision.

[1] https://unherd.com/2023/01/introducing-unherd-britain-2023/

[2] https://www.independent.co.uk/news/uk/politics/brexit-regrets-map-uk-b2272117.html

Cyber

Now, where did that word come from? My earliest recollection is the scariest adversary of Dr Who. The cybermen hit the small screen back in 1966. This fiction of an amalgam of machine and human is particularly scary. This was the fabled monster that drove young children to hide behind the sofa. The BBC hasn’t given-up on this character. Somehow, these fictional metal-men are almost certainly going to retrun to run amok and devastate humanity.

Patrick Stewart being assimilated by the Borg is a mega dramatic cliff-hanger. The Cylons[1] obliterating the colonies sent humanity on a runaway across the endless expanse of space. The indestructible killing machine of the Terminator was a huge box office success. There’s a recuring theme. In the popular imagination the combination of machine and human is thought of as fundamental threat. The enemy is the machine that transforms human mind and body into a single-minded demon intent on mischief or destruction.

By this reckoning you might think that “cyber security” was a Robocop like police force committed to routing out bad cyborgs. Yet, that’s nothing like the common usage of the term. There’s a certain threat, and it does involve digital systems and humans. However, in this century they are not yet[2] wandering around doing unpleasant things to all and sundry.

Strangely enough the term “cybernetics” has been around for a long-time. It’s not about robots. It came into being before modern digital systems and the silicon revolution were kicked-off. In part, cyber was coined as a way of expressing the almost magical qualities of feedback processes. It was wide-ranging, in that this term described natural as well as mechanical systems. In the words’ origins there was nothing sinister or chilling implied.

In 2023, “cyber security” is how we reduce the risk of cyber-attack[3]. Not a great description but let’s just say the notion is dealing with a recognised threats in digital systems.

This wasn’t something that was commonplace until the Personal Computer (PC), its software and the INTERNET connected billions of people. The normal human limitations that constrained our sphere of influence have been extended across the globe. Now, bad actors intentionally doing bad things can be based anywhere on the planet.

Since they are human actors, they are mighty creative and inventive. These people are a constant threat, like the Borg[4] that adapts and modifies what they do so as to counter any actions to defeat them. Our defence can’t be as that of the Battleship Galactica, disconnection, we are going to have to find another way. Unlike some threats there’s little chance this one will ever go away.

[1] https://ew.com/gallery/battlestar-galactica-12-things-you-need-know-about-cylons/

[2] https://www.bostondynamics.com/

[3] https://www.ncsc.gov.uk/section/about-ncsc/what-is-cyber-security

[4] https://intl.startrek.com/database_article/borg

Fatal accident in Nepal 2

We are now one week from the fatal accident that occurred on Sunday, 15 January in Nepal. Yeti Airlines Flight 691, an ATR 72-500 aircraft, crashed while on approach at Pokhara International Airport in Nepal[1]. Sadly, this accident resulted in 72 fatalities. No one survived. Only one body remains to be discovered[2].

This has been Nepal’s deadliest aviation accident in over 30 years.

After years of pandemic-caused travel disruption this land locked nation was hopeful that their new airport would bring the tourists back. The nation’s second-largest city sits in the shadows of a towering mountain range. It’s a picture postcode setting for this tragedy.

Nepal’s government has set-up a five-member committee to investigate the accident.

As stated in the International Civil Aviation Organisation (ICAO) Annex 13, Aircraft Accident, and Incident Investigation[3], it’s the responsibility of the State of Occurrence to lead an investigation. The objective of that investigation should be prevention of future accidents and incidents. It’s not the purpose of a technical activity to apportion blame or liability.

Nepal is the State of Registry and the State of the Operator, but they must notify the State of Design, the State of Manufacture (France) of the aircraft and ICAO in Montreal.

There are numerous speculations concerning the cause of this accident. The scant evidence available on social media does suggest that this aircraft accident fits into the category of Loss of Control in Flight. However, that suggestion is purely informed conjecture at this time.

I agree with David Learmount[4] in that it’s likely that this will be found to be a preventable accident. That said, once the accident flight recorders have been replayed there should be a substantially better indication of what really happened on that fateful day.

Whereas it was previously reported the accident recoders were going to France it’s now reported that they are going to Singapotre for replay Black boxes from Nepal plane crash to be sent to Singapore – ABC News (go.com)

Based on the experience of the analysis of numerous accidents it’s unlikely to be a simple single cause. Such fatal aircraft accidents are often combinations of factors that come together. Approach to a new airport plus an unexpected event or error plus aspects of organisational culture can be enough to tip the balance.

Aviation, in itself, is not inherently dangerous. But to an even greater degree than the sea, it is terribly unforgiving of any carelessness, incapacity or neglect.

A quote of Captain A. G. Lamplugh, British Aviation Insurance Group, London. c. early 1930’s. This famous phrase has been reproduced on posters many times.

POST: Here’s some examples of what can happen again and again. Lessons learned from business aviation accidents maybe equally applicable to this case. Lessons Learned from Business Aviation Accidents | NBAA – National Business Aviation Association

[1] https://aviation-safety.net/database/record.php?id=20230115-0

[2] https://www.thehindu.com/news/international/nepal-plane-crash-search-continues-for-lone-missing-person/article66415303.ece

[3] https://store.icao.int/en/annexes/annex-13

[4] https://davidlearmount.com/2023/01/21/regional-airline-safety-really-doesnt-have-to-be-this-bad/

Still learning leasons

Mobility has transformed society. By land, by sea or by air the world we see around us has been shaped by the technology that has enabled us to move people, goods, and services. Aviation, the youngest means of everyday transport, has radically transformed society in just over a century.

Demand for air transport is linked to economic development and at the same time air transport is a driver in an economy. Nearly all States work to encourage the growth of aviation in one form or another. All States acknowledge the need for the stringent regulation of activities in their airspace.

4.5 billion people moved around the globe by air. Well, that is until the COVID pandemic struck[1]. Even so, there’s an expectation that global air traffic levels will start to exceed those of 2019 when we start to get into 2025 and beyond.

One quote, among many, sums up the reason for the safety regulation of flying, and it is:

“Aviation in itself is not inherently dangerous. But to an even greater degree than the sea, it is terribly unforgiving of any carelessness, incapacity or neglect.”

[Captain A. G. Lamplugh, British Aviation Insurance Group, London. 1930.]

Here the emphasis is on aviation safety and security as the top considerations. In fact, ask an airline CEO of the number one priority of their business and that’s likely how they will answer, if on the record. Much of that open expression will be sincere but additionally it’s linked to the need to maintain public confidence in the air transport system.

We need to remember that aviation had a shaky start. Those magnificent men, and women in their flying machines were adventurous spirits and born risk takers. That is calculated risk takers. Few of them lasted long unless they mastered both the skill and science of flying.

In the post war era, improvements in aviation safety have been dramatic. As the number of hours flown and the complexity of aircraft has grown so has the level of flight safety. Aviation has been an uncompromising learning machine. A partnership between States and industry.

Sadly, in part, the framework of international regulation we may now take for granted has been developed because of lessons learned from accidents and incidents, many of which were fatal.

[1] https://www.icao.int/sustainability/Documents/COVID-19/ICAO_Coronavirus_Econ_Impact.pdf

Fatal accident in Nepal

My condolences to all those people who have been affected by the catastrophic aircraft accident in Nepal. On-board the ATR 72 aircraft operated by Nepal’s Yeti Airlines were 72 people – 4 crew members and 68 passengers.

The aircraft took off from Kathmandu at 10:33 (local time) on Sunday. At around 11:00, while on approach to the airport the twin-engine ATR 72 crashed into a riverbed gorge located between the former airport (VNPK) and new international airport (VNPR). Nepal’s Civil Aviation Authority said the aircraft last contacted the airport at 10:50. There are no reports of distress calls from the aircraft before the accident.

As only a short time has elapsed, it’s good to hear that the accident flight recorders have been discovered[1]. It is reported that they are to be sent to France for replay and analysis.

Sadly, Nepal has a grim record in respect of fatal air accidents. There have been 42 fatal air accidents since 1946[2]. Poor weather and hazardous terrain can often be a problem in this nation. However, in the case of this tragic flight, video circulating on social media indicates clear skies at the time of the accident.

Nepal became a member of International Civil Aviation Organisation (ICAO) back in 1960. Nepal’s improvement in safety measures and compliance with international standards was recognised by ICAO in 2018. However, Nepal remains on the EU Air Safety List.

Prior to the accident, Yeti Airlines has 6 ATR 72 aircrafts, aged between 11 and 15 years old.

The new international Pokhara Airport[3], was inaugurated on the 1^st January, this year by Nepal’s Prime Minister. This was seen as a significant step to boost tourism in the region. The airport project was a cooperation as part of China’s Belt and Road Initiative (BRI)[4]. The new international airport was built to replace the city’s former airport, located 1.6 nm to the West. Flights were gradually being transferring to the new airport facility[5].

The Civil Aviation Authority of Nepal (CAAN) has checked the airworthiness of the ATR aircraft on its register. No technical faults have been found[6].

POST: Teams of aviation experts, including those from ATR and EASA are on their way to Nepal to help in the accident investigation French team starts probe into Nepal plane crash (msn.com)

[1] https://www.reuters.com/world/asia-pacific/search-resumes-four-people-missing-nepal-after-deadly-air-crash-2023-01-16/

[2] according to Flight Safety Foundation data

[3] http://pokharaairport.com.np/

[4] https://www.telegraphindia.com/world/nepals-pokhara-airport-was-inaugurated-two-weeks-ago-and-built-with-chinese-assistance/cid/1910031

[5] https://aviationweek.com/air-transport/safety-ops-regulation/yeti-airlines-atr-72-crash-nepal-kills-least-68

[6] https://nepalnews.com/s/nation/caan-carries-out-technical-tests-on-all-atr-aircraft-operational