Category: Regulation

Digital Hazards

I agree[1]. The INTERNET information super highway isn’t so different from the highways we use to get around. Both have traffic. One presents hazards that are not always obvious and the other is riddled with hazards, many of which we can see. They are similar hazards, in that someone raiding your personal data can have just as devastating an impact as your car running off the road.

Giving people mandatory training before they venture out into the world of INTERNET banking, and the mad whirl of social media has merit. This will not reduce serious problems to zero, but it can mean fewer people suffer financial misfortunes and reputational nightmares.

I know this thinking is hard for anyone with an inbuilt downer on the notion that Governments should intervene to protect citizens from every threat. This is fine. There should be a reasonable threshold set before rules and regulations are grasped as a weapon against potential harms. Everyone has a responsibility to look after their own health and safety to the greatest extent that they can. That’s where there’s marked limitations in the case of the digital landscape.

Even for those aware of live digital threats the means to address them are not well known or easily accessible. The human factor plays a part too. Many people are reluctant to admit that they may have been dupped or take for a ride in the wild west of the INTERNET.

On another subject, but not unrelated, is that we live in a world of gurus and commentators. This predates social media but that has heightened the trend. It’s as if well-informed person A says, “don’t stick your finger in the fire” and nobody listens. However, when well-known person B says the same everybody listens. All the time the facts remain the same.

Sadly, this works with disinformation as well as the truth. There’s a propensity to wish to agree with people that we imagine others agree with at the same time. It’s a cosy security blanked. There was once a saying that; nobody ever got the sack for hiring IBM. This phrase captures the belief that those others can’t all be wrong and even if a choice is wrong for me, I’m not alone.

Such blame avoidance is pessimistic thinking. It elevates the fear of failure and places it at the heart of decision making. A balance is better. Awareness of hazards is the first step in managing risk.

[1] https://www.bbc.co.uk/programmes/b006qj9z

Single Pilot Operations

Single Pilot Operations is not new. What’s new is considering this way of working for everyday public transport operations of large aircraft

Research is of fundamental importance. It seems obvious to say so given the benefits it has given us. When proposals come forward to exploit new technologies there needs to be that moment when everyone steps back and takes a long hard look at the implications of its use.

In basic technical research it’s not the most important consideration is to focus on the drivers for change. They can be multifarious: economic, environmental, social, safety, security, political, and maybe just a matter of preference. Policy directions are taken by the industry and governments not constrained by what is happening now as much as what might happen tomorrow.

Research has delivered incredible safety improvements in aviation. This is not only in the basic design and construction of aircraft but all aspects of their operation. So, to see that the European Union Aviation Safety Agency (EASA) sponsoring research to study the implications of aircraft Single Pilot Operations[1] is a wholly good measure.

My history goes back to the early days of fly-by-wire aircraft systems. This is where the mechanical and physical connection between an aircraft pilot’s actions and the control surfaces that determine flight are replaced by digital computers. Back in the 1980s, a great deal of research and experimental flying proved the technology to make fly-by-wire work. It first found favour with the military. One reason being that an aircraft’s capability could be extended well beyond what was formerly reached. This change was introduced with caution, analysis, testing and much detailed risk assessment.

At the time, there was a significant body of professional pessimists who predicted a diminishment of aviation safety. Today, four decades on, studies show that even as air traffic has increased so civil aviation safety has improved. A momentous achievement. An achievement that has, in part, been because of the well-regulated adoption of advanced technologies. 

It is important to look at potential changes with an open mind. It’s easy to come to an instant opinion and dismiss proposals before a detailed study has been conducted. The detailed technical research can then be part of the challenge and response that is necessary to before approval of any major change. First difficult questions need to be tabled and thoroughly investigated.

[1] https://www.easa.europa.eu/en/research-projects/emco-sipo-extended-minimum-crew-operations-single-pilot-operations-safety-risk

Voters

It’s one of those things I do, most years. For the greatest part, I can predict what I’ll be doing in March-and April. It started back in the 1980s. At the time we lived in Cheltenham[1] town. Putting leaflets through doors. Knocking on doors. “Hello, I’m calling on behalf of …….” was usually the introductory line. With prepared words not only did I remind the town’s residents that there was a local election in May but let them know the name of the best candidate.

I’m writing this as credentials. Yes, I know a thing or two about the nitty gritty of local elections in the UK. My experience has been accumulated over nearly 40-years. Lots of cold early spring evenings and weekend delivery rounds to get a message out in a short space of time.

One of the biggest changes, in terms of practical organisation, has been a change that has affected all parts of life. In 1985, everything was paper based. If I said: “Shuttleworths[2]” to a 21st century campaigner there’s a good chance they will not have a clue what I’m talking about. These were paper pads used to record names and addresses of supporters.

Local campaigning has undergone a digital transformation. However, in the British electoral system paper is still at the heart of everything that is done. The ballot paper is sacrosanct. Voters put a cross in a box set against a name and a logo. It remains inclusive in that there are few people who cannot manage that basic act.

In all my time campaigning, I can remember no voter fraud or corrupt activities. Yes, over enthusiastic, or idiotic behaviours pop-up now and then, as they do in all walks of life. It’s always an important function but also amusing to check spoilt ballot papers at an election count. A small number of voters can be creative in the insults and images they draw on ballot papers.

So, listening to last night’s Parliamentary debate on new Voter ID Regulations was distressing. The Conservative Government plan is to spend £180 million on solving a problem that doesn’t exist. This law is being pushed forward aggressively at a time when local Councils are cutting services due to lack of funding. The Local Government Association (LGA)[3] is saying that there’s not enough time to make the demanded changes before next May.

Ministers are ignoring such advice. Additionally, these regulations seem nonsensical. They impose new requirements on the operation of polling stations but do nothing in respect of postal voting. The natural suspicion for the forceful timescale is that this act is to suppress votes at a time when Conservative candidates are expected to loose in great numbers next May.

A further reason to be sceptical that Voter ID can prevent instances of electoral fraud is that convictions for voting offences have overwhelmingly related to postal votes, not personation at polling stations. Measure that create a barrier to voting in person will lower local election turnout. That’s a voter turnout that is as low as 29% of registered voters in my Borough.

This is a sad day for British democracy.

[1] https://www.visitcheltenham.com/

[2] https://www.libdemvoice.org/how-did-shuttleworths-get-their-name-40299.html

[3] https://www.local.gov.uk/about/news/lga-statement-parliamentary-vote-plans-introduce-voter-id

Cold Data

It’s cold. The numbers on the energy meter keep clocking up and getting to new highs. Compared with last year my energy bill is going to be horrendous. Add to that inflation on just about everything else and it’s hard work to make it a winter of good cheer. Smart energy meters are useful in that they give real time feedback on household energy use. I’m not sure they have an impact on behaviour, but meters do forewarn of astronomical bills to come. Comparing Christmas past, present and Christmas future gave author Charles Dickens an idea.

Looking at media reports this year’s Christmas looks more Dickensian than ever. That is without the transformation that Mr Scrooge[1] underwent. It’s certain the attitudes of Ministers resemble that of Mr Scrooge. Protect the moneymen in their obsession with money and penalise the ordinary working soul. This story is being played out up and down Britain.

The fact that it’s not seen as strange to be talking of freeing up the City of Lonon from regulation at the same time as restricting and controlling working men and women is a bad indication of these difficult times. The Prime Minister may look like a busy light-hearted mouse, but he has a heart as cold as the winter mists.

As the Government has said it wants to collect data from our smart meters, I wonder what can possibly flow from that intrusion into our privacy. In so far as it might guide national policy and reminds Ministers of the benefits of insulating homes, data collection could be helpful. However, there’s a dangerous precedent set when Governments collect every bit of data homes produce.

There’s a creeping tendance to always ask for more data. Mr Scrooge can then compile a leger on the comings and goings of every citizen. Don’t believe for one moment that GDPR will protect our data. Personal information such as names, addresses and bank details are not stored on a smart energy meter. However, computing capability being as powerful as it is, relating energy data to its point of collection and thus bill payer isn’t so difficult to do.

To me, this recalls the saying about knowing the cost of everything but the value of nothing[2].

[1] Ebenezer Scrooge, character in the story A Christmas Carol (1843) by Charles Dickens

[2] Oscar Wilde’s famous definition — someone who “knows the price of everything and the value of nothing”

Air Safety List 2

It may seem obvious that there should be an Air Safety List that bans airlines that do not sufficiently met international standards. It’s a right that exists within the Chicago Convention[1]. The first words of the convention concern sovereignty. Every State has complete and exclusive sovereignty over their airspace. From the first days of flight the potential use of aircraft to wage war was recognised. Thus, it could be said that the first article of the Chicago Convention existed even before it was written down and agreed.

However, it’s similarly recognised that the future development of international civil aviation has always depended upon agreements between States. Without over-flight and permission to land in another country there is no international civil aviation.

I do remember some agonising over having an explicit list of banned countries and airlines. In a liberal democracy choice is greatly valued. Here the choice concerns passengers being permitted to board aircraft from another country where there is knowledge of safety deficiencies related to the operation of the aircraft of that country. Should the law make that choice for the air traveller, or should the air traveller be free to make an informed choice?

There lies the crux of the matter. How do ordinary citizens, without aviation safety expertise make judgements concerning complex technical information? Understanding the implications of failing to meet the International Civil Aviation Organization’s Standards and Recommended Practices (SARPs)[2] is not so easy even for aviation experts.

Additionally, there is the issue of third-party risks. It would not be wise to permit foreign aircraft, whose safety is not sufficiently assured, to fly over a nation’s towns and cities.

Regulatory legislation was framed not only to put airlines on the Air Safety List but to take them off the list too. In fact, sometimes this is harder law to frame. In this case the decisions must be made in a fair, transparent, and technically rigorous manner otherwise the politics of such choices could overwhelm the whole process.

There’s been much success in this endeavour. It’s clear that this is a valuable aviation safety measure. It may have driven some contracting States to improve the performance of their airlines.

[1] https://www.icao.int/publications/Pages/doc7300.aspx

[2] https://www.icao.int/safety/CMAForum/Pages/default.aspx

Air Safety List

A long time ago in a far away place. Well, that’s how it seems, and it was more than 17 years ago.

A flight ban was placed on Turkish airline Onur Air back in 2005. At that time, I was in my first full year in Cologne, Germany building up the European Aviation Safety Agency (EASA). We were well on the road managing the handover of responsibilities from activities of the Joint Aviation Authorities (JAA) to EASA. However, the European legislation that empowered EASA was in a first and most basic version. This was planned to be so because taking on aircraft certification work was a big enough task to start the new Agency.

The JAA had coordinated an aircraft ramp inspection programme and maintained a centralised database for its members. This was where a member state would inspect an aircraft arriving from a third country to ensure that international rules were fully met. The SAFA programme was launched by the European Civil Aviation Conference (ECAC) in 1996. SAFA standing for Safety Assessment of Foreign Aircraft.

Onur Air failed such inspections, and the Dutch government imposed a flight ban[1]. Similar bans were imposed by Germany, Switzerland, and France. However, if my reflections are correct the airline moved operations to Beligum where there was no ban. As you might imagine this caused concern amongst EU Member States. Where everyone had agreed to cooperate on aviation safety matters there seemed to be a degree of incoherence.

Long before the first EASA Basic Regulation, which by the way, didn’t address this subject, there was Regulation 3922/91[2]. I remember a hastily convened committee composed of representatives of the Member States and chaired by the European Commission (EC). The “3922[3]” committee hadn’t sat for years but then it sprung into action in response to the lack of a consistent approach to airline safety bans across Europe. I was there representing EASA.

So, the EU Air Safety List was born and the associated legislation[4] to support it. Even though the UK has left the EU, and left EASA this safety list remains the basis of the UK’s own Air Safety List[5]. Adding and removing air carriers and States that fail to meet internationally agreed safety standards is work that no one State should do alone.

[For safety’s sake, this should not be one of the parts of adopted EU legislation the UK Parliament wants to sweep away with its planned new Brexit law].

POST: Current list The EU Air Safety List (europa.eu)

[1] https://www.expatica.com/nl/general/dutch-lift-ban-on-onur-air-38258/

[2] Council Regulation (EEC) No 3922/91 of 16 December 1991 on the harmonization of technical requirements and administrative procedures in the field of civil aviation.

[3] https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ%3AL%3A1991%3A373%3A0004%3A0008%3AEN%3APDF

[4] https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32005R2111&rid=6

[5] https://www.caa.co.uk/commercial-industry/airlines/licensing/requirements-and-guidance/third-country-operator-certificates/

Bird Strike 2

What makes a bird strike different is that it’s an unpredictable collision. If we talk about aircraft collisions with terrain the outcome is predicable bad. All that kinetic energy must go somewhere. So, a high-speed vehicle hitting something that is immovable is not going to end well.

Now, it must be said that some hunting birds can dive at incredible speeds. More typically, a large bird in flight between feeding sites isn’t going to be traveling fast. In fact, it may as well be viewed as a static object relative to an aircraft in flight. A bird in-flight is unlikely to be able to take avoiding action. For a pilot the action of “see and avoid” may work in respect of other aircraft but a bird ahead is no more than a pinprick in the sky.

These factors make aircraft bird strikes inevitable. That said, the range of outcome because of impacts are rarely at the severe end of the scale. One reason for this is the effort made at design certification to ensure an aircraft is sufficiently robust. Damage can occur but if the aircraft design and test processes have been rigorous everyone should get home safely.

I remember paying particular attention to the zonal analysis done by several major manufacturers. In my experience the most difficult designs are for those of business jets and large helicopters. One of the design challenges in both cases is the limited physical real estate within the aircraft structure. Weight is another big consideration. This leads to cramming essential avionics and electrical systems and their interconnections into confined spaces.

Zonal analysis is about ensuring there’s segregation between different systems. Afterall what’s the point of having two Attitude & Heading Reference Systems (AHRSs)[1] and putting them next to each other in the nose cone of an aircraft. That’s not a good design strategy. One damaging impact must not take out two essential independent aircraft systems.

It’s just as important to ensure an aircraft’s wiring isn’t all bundled togther and taken through one connector. That may save money on electrical parts but it’s not going to work after being hit hard by a 5kg goose.

These issues will need particular care in the new electric vertical take-off and landing (eVTOL) aircraft that are on the drawing boards. Choosing a safe architecture, manufacturers must balance the use of creative design solutions, to produce a competitive product, with limited physical space.

A couple of key words in the certification requirements concern hazards that are anticipated. Bird Strike is hazardous and aircraft systems and equipment must “perform their intended function” should it occur. See EASA Special Condition for small-category VTOL aircraft, Subpart F[2].

POST: Good to see the bird strike criteria Joby’s airworthiness criteria: A blueprint for the nascent eVTOL industry – Vertical Mag

[1] https://helicoptermaintenancemagazine.com/article/layman%E2%80%99s-guide-attitude-heading-reference-systems-ahrs

[2] https://www.easa.europa.eu/sites/default/files/dfu/SC-VTOL-01.pdf

Walk the line

Aeronautical products must be certified before entering transport services. Is certification too complex? Is it too expensive and thus a barrier to innovation? Hasn’t deregulation delivered successes since the 1970s? More choice and more aviation services across the globe.

These are perfectly reasonable questions. They are asked frequently. Especially during economically tough times and when new products are pushing to get operational. In answering, it’s all too often a butting of heads that results. Industry puts its point. Authorities put theirs. Commercial reality and public interests settle at some point which leaves the debate on the table for next time.

Walking that line between satisfying the demand of the new and protecting the good safety performance of the aviation system is a perpetual challenge. It goes without saying that we all know what happens when the line is crossed. Textbooks will continue to chew over stories like that of the Boeing 737 MAX development. In fact, the stories of safety lapses are an important part of the learning process that led to aviation’s admirable safety record.

The counter argument is that we are in a new situation and that technology has significantly changed. This argument of the “new” is not new. Every major new step encountered significant hurdles to overcome. Pick-up the story of the development of the Boeing 747[1][2] and it’s a real dramatic page turner. However, the problem remains the same but as much innovative thinking needs to go into certification as the products that are certified. There’s a reason that’s difficult and its called legacy.

On the public’s behalf, how big is the risk appetite of the certification authorities? At the same time how far do the innovators want to push the envelope knowing that liability rest on their shoulders?

What I find inadequate is that when reading reports like “Funding Growth in Aerospace[3]” I find little, or no consideration is given to funding regulatory improvement. Arguments are for product development and little else. It’s as if certification activities are to be blamed for holding up innovations introduction to service but forget any thought of increasing the resources for certification activities.

It’s short-sighted. Believe it or not there is money to be made in testing and validation. There’s money to be made in education and training. These go hand in hand with efforts to exploit innovative products.

[1] https://www.bbc.co.uk/news/business-37231980

[2] https://www.theguardian.com/science/2016/sep/07/joe-sutter-obituary

[3] https://www.ati.org.uk/publications/

Air Taxi 3

Urban mobility by air, had a flurry of success in the 1970s. However, it did not end well.

Canadian Joni Mitchell is one of the most celebrated singer-songwriters and my favourite. She has tapped into the social and environmental issues that have concerned a lot of us for decades. Of her large catalogue, I can’t tell you how much I love this song[1]. The shear beauty of the lyric.

Anyway, it’s another track on the album called “Hejira” that I want to refer. When I looked it up, I found out, I was wrong. The song I want to refer to is on the 1975 album “The Hissing of Summer Lawns”. The song “Harry’s House[2]” contains the line “a helicopter lands on the Pan Am roof like a dragon fly on a tomb.” Without going into what it’s all about, the lyrical image is that flying from a city skyscraper roof was seen as glamorous and the pinnacle of success.

In 1970, prominent aviation authorities were talking about the regulatory criteria needed for the city-centre VTOL[3] aircraft of the future. Then on the afternoon of 16 May 1977, New York Airways Flight 971, a Sikorsky S-61 helicopter, crashed[4] on Pan Am’s building rooftop heliport[5]. That ghastly fatal accident reset thinking about city centre operations air transport operations.

So, what’s different 50-year on? Proposals for city centre eVTOL operations are much in the News. City planners are imagining how they integrate an airborne dimension into public transport operations. Cars, busses, trains and eVTOL aircraft may all be connected in new multimodal terminals. That’s the city transport planners’ vision for less than a decade ahead.

For one, the vehicles are radically different. Yes, the physics of flight will not change but getting airborne is quite different between a conventional large helicopter and the plethora of different eVTOL developments that are underway across the world.

Another point, and that’s why I’m writing this piece, is the shear amount of safety data that can be made available to aircraft operators. Whereas in the 1970s, a 5-parameter flight recorder was thought to be neat, now the number of digital parameters that could be collected weighs in over thousands. In the 1970s, large helicopters didn’t even have the basic recording of minimal flight data as a consideration. The complexity in the future of eVTOL will be, not how or where to get data but what to do with all the data that is streamed off the new aircraft.

Interestingly, this changes the shape of the Heinrich and Bird “safety pyramid” model[6]. Even knowing about such a safety model is a bit nerdy. That said, it’s cited by specialist in countless aviation safety presentations.

Top level events, that’s the peak of the pyramid, remain the same, but the base of the pyramid becomes much larger. The amount of safety data that could be available on operational occurrences grows dramatically. Or at least it should.

POST: Growing consideration is being given to the eVTOL ecosystem. This will mean a growing need to share data Advanced Air Mobility Portal (nasa.gov)

[1] https://youtu.be/nyj5Be5ovas

[2] A nice cover https://youtu.be/bjvYgpm–tY

[3] VTOL = Vertical Take Off and Landing.

[4] https://www.nytimes.com/1977/05/17/archives/5-killed-as-copter-on-pan-am-building-throws-rotor-blade-one-victim.html

[5] https://www.thisdayinaviation.com/16-may-1977/

[6] https://skybrary.aero/articles/heinrich-pyramid

Air Taxi 2

As a quick effort at simple research, I looked at several local government websites searching for Air Taxi or Urban Air Mobility (UAM) or Advanced Air Mobility (AAM). The result was lots of blanks with one or two exceptions[1][2]

There’s numerous articles about e-scooters and how they might be integrated into cityscapes.

Addressing local governments, much of what has been published to date concerns the use of drones. Yes, the use of drones is happening here and now, so this is not such a surprise. However, to me, this was a reminder that the frenetic world of aviation often discussed the future in rooms full of like-minded people. Embracing a wider audience is overdue.

In the case of UAM/AAM, innovations in civil aviation are move beyond airports, upper airspace, and specialist technical interest. If the electrification of flight is to take hold it will touch the lives of many more people than conventional commercial aviation.

These new aviation developments will generate new business models and offer new services. This is challenging stuff. It’s clear to me that, without the agreement of local authorities such enterprises will be dead before they start.

National governments may take a regulatory approach that imposes on local governments. That would be ill advised and ultimately unsustainable. A cooperative partnership would open a smooth transition from transport novelty to accepted everyday part of mobility.

Local authorities will need to adapt their formal local plans to include planning considerations of zoning, land-use, multi-modal matters, environmental impact, construction, utilities/support infrastructure, public privacy and much more.

Local government is a partner in risk management too. Just as highway authorities wrestle with improving road safety so, no doubt, UAM/AAM accidents and incidents will be on their agenda.

Fostering public-private partnerships is talked about but few examples have moved beyond theory and into practice.

POST 1: These issues have been highlighted at ICAO this year Urban Air Mobility and the Role of Air Transport – ICAO 2022 Innovation Fair – ICAO TV

POST 2: The organisation is looking at possible future operations https://varon.aero/

POST 3: People taking a holistic view http://www.supernal.aero

[1] https://www.civataglobal.org/

[2] https://www.urbanairmobilitynews.com/global-map/