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

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

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

AI2

There’s not just one form of Artificial Intelligence (AI). This group term hides a great panoply of different configurations, shapes, and forms of applications.

One of the most impactful applications is that of machine learning or expert systems. It’s where we go beyond a conventional computer’s ability to store and manipulate information against set rules. It’s where the machine has the capability to learn new ways of interpreting information and thus becomes different every day of operation from the day it was switched on. That’s a bit vague but it captures the essence of moving from deterministic to non-deterministic systems.

In all this we do presuppose that such complex systems are in the hands of able and highly illiterate users who understand what they are doing in training that learning machine. There’s debate about how bias in algorithms can produce unintended consequences. In addition, a reliable and trustworthy machine can be trained in a way that embeds errors and biases too[1].

Just as a child picks up the bad habits of a parent, so “intelligent” machines can learn from pilots, controllers and engineers who may have less than optimal ways of undertaking tasks. This Human-AI interplay is likely to become a major area of study. As the topic of Human Factors is itself a large body of material.

Already with the debate on social media it is all too obvious that the aviation community has a wide range of views on the use of AI. All the way from utter rejection, or scepticism deeming such systems as “unsafe” to advocates who profess only the benefits and merits of such systems.

Clearly, both extreme ends of the spectrum of professional views don’t help much. I don’t think that the promoters of AI want to see blind overreliance on it. Equally, surly even ardent sceptics can see virtue in making the best use of the accumulated knowledge that is available.

I can foresee a system of systems approach. With my parent and child analogy, from time to time a child will ask a question that is blunt and to the point. A question that demands a straightforward answer. This can be uncomfortable but hits out at biases and bad habits.

In aircraft systems there are boundaries that must be respected. The physics of flight dictate that going beyond those boundaries is generally not good for life and limb. So, a system programmed to question an expert system, one AI questioning another AI, or even question its trainer, is not beyond the realms of possibility. It might even be a good idea.


[1] https://www.nature.com/articles/s41746-022-00737-z

Artificial Intelligence

In an on-line event, I listened to Professor Dr. Saskia Nagel of Aachen University[1] speak on Artificial Intelligence (AI) and Ethics last evening. It’s a topic that arouses a lot of interest amongst engineers and just about every other profession.

The talk was a round robin of the subject touching on points of debate that are far from resolved. Her talk provided an overview of key present ethical questions spanning the development and uses of “AI” technologies. It’s interesting that even the title of the talk was questionable. The debate rages as to what is encompassed in the commonly used term “AI”.

Scientific and technological advances have consequences that are best anticipated, in so much as we can. Far too often, as in the case of mobile phones, a capability has been launched onto humanity because of its great utility without much thinking through of potential impacts.

In a way, our collective mindset remains stone age. We do things because we can rather than asking the question as to whether we should or not. The Australian movie and musical Muriel’s Wedding captures this nicely[2]. “You Can’t Stop Progress” was the election billboard slogan of politician Bill Heslop in the story. The same theme might be posted as “Growth, growth, growth” in the current economic climate.

To an extent that’s what’s happening in the more audacious parts of aviation innovation. Different ways in which AI technologies can be used to facilitate autonomous flight are being explored and promoted. There’s no doubt such technology can process massive amounts of information in no time at all when compared with you or me. That advantage is only one side of the story.

Investigating questions of autonomy quickly leads to discussions on accountability and responsibility. In flight, there’s inevitably complex interactions between people and machines. On the normally rare occasions when this results in harm it’s essential to be able to say what or who was responsible.

It goes further than that too. Even to persuade a passenger to ride on an autonomous vehicle a good deal of confidence must be built-up. A fear of flying is often counteracted by arguments based on the long history of safe flight and the trustworthiness of those operating a transport system.

A question is: how do we trust something we don’t understand? Not a new question. Few members of the flying public may understand how a modern transport aircraft works. We put our faith in independent knowledgeable professionals asking difficult questions of the designers and builders of aircraft. We put our faith in rigorous controls and processes. If the internal workings of a complex machine are not explainable to those independent professionals, we have a problem. Thus, another key topic of explainability.

This is a fascinating research area. I’ve no doubt there are workable solutions, but we are some ways from having them to hand at the moment. Applied ethics are part of the toolbox needed.


[1] https://www.ethics.rwth-aachen.de/cms/ETHICS/Das-Lehr-und-Forschungsgebiet/Team/~fcnwz/Saskia-Nagel/

[2] https://fb.watch/h-uoLokeaY/

Poor law making

If you thought the Truss era was an aberration, and that the UK’s Conservative Party had learned a lesson, then please think again. Wheels set in motion by the ideologue Jacob Rees-Mogg MP are still spinning.

The Retained European Union Law (Revocation and Reform) Bill is trundling its way through the UK Parliament. The Government Bill will next be prepared for its 3rd reading in the House of Commons[1]. The Conservative Government has brought forward this Bill to revoke, reform or revise all the remaining law in the UK that was formerly derived from the UK’s membership of the EU. This turns on its head the normal approach to changing UK legislation. Revocation is automatic unless there’s an intervention by a Minister.

UK civil aviation depends on several thousand pages of legislation derived from EU law[2]. Much of this law was created with considerable contributions from the UK. There’s hardly any if any advocates for automatic revocation of current aviation legislation. Even the thought of this action sends a shiver down the spin of aviation professionals. Generations of them have worked to harmonise rules and regulations to ensure that this most international of industries works efficiently.

Unless amended, the Government’s EU Retained Law (Revocation and Reform) Bill[3] could turn out to be an absolute disaster. Even those who have an irrational wish to eliminate any and every past, present, or future link to Europe must come up with a practical alternative and do this in an incredibly short time. Without a consistent, stable, and effective framework civil aviation in the UK will grind to a halt. Again, even those who have an unsound need to change for change’s sake will be hitting a vital industry hard, as it is only just getting back on its feet after the COVID pandemic and now setting out to meet tough environmental standards.

It’s going to be interesting to see what happens when this poor Bill reaches the House of Lords. Once again, the country will be relying on the upper house to add some common sense to this draft law.  

POST 1: The 3rd reading debate makes it clear that the Government is unsure which laws are covered by the Bill. If the Ministers responsible for this legislation do not themselves know its extent, how can anyone expect civil servants working on this legislation to know the full extent of change? A most strange state of affairs Retained EU Law (Revocation and Reform) Bill (Third si – Hansard – UK Parliament

POST 2: Retained EU law lays down rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisations in the UK Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and production organisations (recast) (Text with EEA relevance) (legislation.gov.uk)

POST 3: Retained EU Law Bill is being debated in the House of Lords on Monday, 6 February.


[1] https://bills.parliament.uk/bills/3340

[2] https://www.eiag.org.uk/paper/future-retained-eu-law/

[3] https://www.gov.uk/government/news/the-retained-eu-law-revocation-and-reform-bill-2022

Where’s the common sense?

It’s two whole years since the end of the UK’s Brexit transitional period. That’s since the day when the UK fully withdrew from the European Union (EU). Have we seen any, I mean any, Brexit benefits from the day of the Brexit referendum? The sad truth is – No. We are worse-off. Investments haven’t happened, political turmoil persists and bureaucratic barriers have grown.

Certainly, it’s right to say that British politicians have been busy. They have found lots of targets to blame for this continuing underperformance. You name it; Remainers, young people, environmentalists, protesters, strikers, human rights, overseas aid, COVID, flu, global economic downturn, energy prices, war in Europe, Biden’s administration, China, France, Germany, hot weather, cold weather, the list goes on and on and on. The Brexiter’s blame list is an exceptionally long one. Add to this the fact that Boris Johnson comes in for caustic blame. Often strongest from the people who trumpeted his ascendancy to power in 2019.

Although we should not dwell too much on the past, it’s as well to not let what has happened in this last year be swept under the carpet. Remember 2022, after 44 days, Conservative Liz Truss resigned as British Prime Minister (PM). She was the first choice of the members of the political party most entrenched in Brexit thinking. This extraordinary farce made the country look it was run by like a bunch of incompetent fools, of ill-disciplined fanatics, of preposterous comics.

The blatant dishonesty behind Brexit can not be denied. A recent example was the Government statement on having not attained a promised boost from new trade agreements. A ridiculous political line about not signing deals until they are right for the country is a brazen smoke screen to cover-up a significant lack of achievement[1].

We need some serious common sense injected into our politics. The UK is not going away. The EU is not going away. Both share an immense common interest. Both are faced with similar challenges and threats. Both share the same values.

Brexit has added to costs, adding to inflation, labour shortage and under performance. Most people[2] now accept this analysis and want to see serious change[3]. The more both Conservatives and the Labour Party cling on to the mythology of Brexit, the more damage will be done. Keir Starmer has confirmed that the Labour Party will not seek for Britain to re‑join the EU. What a reckless folly from a would be PM.

POST: referendum – latest news, breaking stories and comment – The Independent


[1] https://www.bbc.co.uk/news/uk-politics-63808657

[2] https://www.statista.com/statistics/987347/brexit-opinion-poll/

[3] https://yougov.co.uk/topics/politics/explore/issue/European_Union

SPO 3

Now, there’s an activity with two humans in the loop. Given the physics involved the goalkeeper should be beaten every time. Well, I’m saying that assuming a high level of expected performance on the part of the footballer taking the penalty. I guess that’s why we are often critical when they miss. In the last few weeks there have been more than a few examples to watch.

What we know is that football penalties are much more than mechanical actions and reactions. However, there’s a degree of mythology about the inevitability of human factors taking control of the outcome: goal or no goal. I’d like to think that there’s an ever-shifting blend of what physics does to the ball and what the human does. Is it always possible to predict the slipperiness of a spinning ball traveling at speed that is then touched by the fingertip of a goalkeeper?

What if the footballer taking the penalty, was an “intelligent” machine. That is a machine with a sensor array and computational capability that far exceeded normal human performance. Such advance automation could calculate the most probable reaction of a goalkeeper based on history and the immediate movements they make right up to the last millisecond before the ball is struck.

Assuming the machine was limited in term of the force it can apply to the ball, it could still adjust its actions as soon as any new information was available. I’m not saying the outcome will always be better for the machine football striker. However, it could reduce the scope for error and randomness to dictate what finally happens.

So, with that argument, in aviation, I’m saying it’s not right to say that Single Pilot Operation will always be worse than two crew operations. Don’t get me wrong, those people aggressively advancing the idea that the intelligent machine will always be better than a human are missing something too.

One thing that highly capable automation could have to bring to the party is not only early detection and diagnosis of problems but a massive library of stored experience. How we embed and constantly update that flight experience is an almighty challenge.

Afterall, the dread in aviation is knowledge with hindsight. It takes the form: “You should have known. Why did you let this incident happen?”

I’m now tempted to think of a Star Trek analogy. Every second an aircraft of a type is flying, experience of its operation is being accumulated. If there are hundreds of a type flying at any moment across the globe, that’s a lot of data to collect and absorb and think about before acting. 

The fictional and scarry Borg are cybernetic creatures linked by a hive mind and they know a thing or two about assimilation. Granted that’s farfetched as analogies go but my point is that I believe we are generations away from that kind of capability. Not only that, just as humans fail so any such “intelligence” designed by humans will fail to.

SPO 2

An instant reaction to Single Pilot Operations (SPO) is like the instant reaction to completely autonomous flight. “I’m not getting on an aircraft without a pilot!” Then to justify that reaction fatal accidents of the past are cited. Typically, this is to remind everyone of the tragic Germanwings accident[1]. It was 24 March 2015, that an Airbus A320 was crashed deliberately killing all onboard.  

However, it’s wise to remember that the likelihood of incapacitation[2] is much greater than that of the malicious behaviour of the pilot in command. Cases of malicious behaviour leading to a catastrophic outcome are truly shocking but extremely rare.

One fatal accident, that is still disputed is EgyptAir Flight 990[3] that killed 217 people in 1999. The possibility of inflight pilot suicide is unnerving, since on the face of it there is little any of the aircraft’s cabin crew or passengers can do to stop it.

This could be a future opportunity to use automation to prevent these scenarios occurring. Afterall the aircraft knows where it is and that a sustained high-speed dive towards the ground is not normally intended. A safety system exists to do this[4], but its outputs are not connected to the aircraft’s flight controls.

Humans being adaptable, extremely creative and capable of highly irrational actions, it’s unlikely that malicious behaviour resulting in aviation accidents will ever be reduced to zero. This is said regardless of the procedures or technology involved. The fate of flight MH 370 remains a mystery.

Thus, the prominent safety issue in respect of SPO is pilot incapacitation. Where the pilot in command is no longer able to perform as expected. That is, if the aircraft flown is not capable of safely landing itself. The objective always being safe continued flight and landing.

I’ve had the “1% Rule” rule explained to me by a notable aviation doctor, but I must admit I didn’t fully take it in. So far, the rule has stood the test of time. When the pilot in command of a Czech Airlines aircraft collapsed and died on route from Warsaw to Prague in 2012, the co-pilot took over and everyone got home safely.

Any automated co-pilot must be at least as capable as a human co-pilot in all aspects of operation of an aircraft. The key word here being “all”. It’s not enough to have the functions necessary to undertake safe continued flight and landing. Task such as communicating with the cabin crew and passengers must also be considered. Including preparation for an emergency landing.


[1] https://www.bbc.co.uk/news/world-europe-32072218

[2] http://www.avmed.in/2012/02/pilot-incapacitation-debate-on-assessment-1-rule-etc/

[3] https://www.theguardian.com/world/2002/mar/16/duncancampbell

[4] https://skybrary.aero/articles/terrain-avoidance-and-warning-system-taws

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