Category: Systems

From Prescription to Performance-Based Regulation

One regulatory development that has stuck since the start of the new century is the idea that we need to transition from prescriptive requirements to performance-based requirements. It’s not too hard to understand where the motivation to change has come from but there are several strands to the path. Here’s three that come to mind.

For one, the intense dislike of overbearing governmental regulators who adopt an almost parental attitude towards industry. It’s true that safety regulatory bodies have a duty to serve the public interest. The difficulty arises in interpreting that brief. Not as police officers sometimes did, imagining everyone as a potential miscreant.

My experience as a regulator started at a time when traditional institutional approach was quite common. There was a respectful distance between the airworthiness surveyor or operations inspector and the aviation industry that they oversaw. I think, even the term “surveyor” was one inherited from the insurance industry at the birth of flying.

A wave of liberalisation swept into the 1980s. It was an anathema to those who started their careers as men from the Ministry. The idea that regulators should be in a partnership with industry to meet common goals was not easily accepted. Undoubtably a change was necessary and, naturally, easier for an up-and-coming generation.

The next move away from regulatory prescription came as its value declined. That is, not that there will not always be an element of prescription by matter of the written law. However, for detailed technical considerations it became less and less practical to say, this is the way it must be. The minute decision-makers were faced with the complexity of a microprocessor it become clear that it’s not effective to simply prescribe solutions.

Much of the changes that took place can be traced to the evolution of system safety assessment and the use of probabilistic methods in aviation. In mechanics, prescribing a safety guard for a chain drive is straightforward. For complex electronics saying when a flight system is safe enough requires a different approach. Regulators are now driven to set objective rather than dictate solutions.

My third point is a future looking one. Whatever the history and heritage of aeronautical innovation, it’s true that a “conservative” but rapid adoption of new technology continues to be a source of success. Great safety success as well as commercial success.

Hidden amongst the successes are products, and ways of working that don’t meet the grade. The joke goes something like this: “How can I make a fortune in aviation?” Answer: “Just start with a big one.” Implicit in this observation is a wiliness to innovate at risk. That means, amongst many things, having confidence, adaptability and not be so constrained as to be assured failure. An objective or performance-based approach to safety regulation opens opportunity to innovate more freely whilst still protecting the public interest in safety.

There’s no fixed destination for regulatory development.

1985 to 2025 Trends

On reading J. C. Chaplin’s paper on the first 100-years of aviation safety regulation in the UK[1], it struck me that the journey from the 1910s to the 2010s was one of constant change. That change has not slowed down. In fact, the last 40-years of my aviation career have seen dramatic technological changes that have demanded ever new regulatory methods and practices.  

Overwhelmingly aviation history writings obsess about the early days of flying or the start of the jet age. It’s as if those periods were so dominated by great pioneers that nothing worthy has happened since. I exaggerate for effect, but I think you get the meaning of my comment.

So, what of the race from the 1985 to the 2025? I think that is useful period to look at. One of the reasons is that those years are mark the transition from an analogue era to a digital one.

The early 1980s saw experimentation with the potential for digital technologies, most particularly fly-by-wire systems. Quickly the military understood the increase in aircraft performance that could be gained by use of such technologies. Groundbreaking was Concorde in that it demonstrated that critical electronic control systems could safely go into everyday operation. That project drove the development of new regulatory methods and practices. 

A turning point occurred in the mid-1980s. That silicon revolution that impacted so much of life was dramatically put to use in civil aviation. Computing power had so miniaturised and become affordable so that past theoretical possibilities could now be practically realised.

The Airbus A320 aircraft first flew in 1987. It was a shaky start. Not everyone was convinced that safety critical systems were indeed safe. The not so obvious discovery that the human factor was even more important for a computerised aircraft. Learning to adapt and adjust ways of operating didn’t happen overnight.

The lesson is that learning lessons must be part of the process. Through applying continuous improvement, the Airbus A320 family has grown ever since.

Maybe there needs to be a short paper to cover civil aviation safety regulation from 1985 to 2025. It’s needed now. It’s needed because the next 40-years are going to see equally dramatic changes. In the time to come the main driver will be the environment.

[1] https://www.aerosociety.com/media/4858/safety-regulation-the-first-100-years.pdf

A Key Political Agenda?

Whatever you might think, I think Keir Starmer is turning out to be a better conservative Prime Minister (PM) than most have been in the last couple of decades. On his list of things to do is reforming this, and reforming that, and making bullish statements on the world stage. Agreed that there’s the usual amount of crafted BS. Compromise and dealing with reality, not the world as one might wish it to be, are as they ever are in politics.

He’s in the business of stealing the clothes of the official opposition. Across the chamber they panic. Yes, further along the benches, the howling menace continues to howl. Fighting amongst themselves this week. Questioning their leader is not allowed. However, it’s surprising how high they stand in opinion polls, even if this is meaningless at this point in the electoral cycle.

The normal opposition now comes from the Liberal Democrats and a small number of unhappy Labour Members of Parliament.

This week I was amused to read of the concerns about Quangos[1]. That takes me back. I remember writing a motion for a conference on that subject back in the early 1990s. At that time there was questioning of why there was so many Quangos.

As a country we seem to go through waves. They go like this.

For a while national politicians take the view that day-to-day operational decisions of a sector should be made by dedicated professionals and at arm’s length. This has the advantage of getting politicians out of the complex detail, avoiding blame when things go wrong, a degree of continuity and setting their minds to the higher calling of top-level budgets and policy.

Then, if sector hasn’t performed as well as desired, the Quango at the heart of the storm is set ripe for taking apart. Thus, day-to-day operational decisions go back to “accountable” politicians, surely to do better. This has the advantage of reigniting the pace of change, a chance to be radical, securitising lower-level budgets and the satisfaction of blaming the past system.

I think you can tell which part of the wave that has hit now.

A point of reference here is, as so often is the case, Yes Minister. There’s a story line where the civil service pack the Minister’s red box with so much information and decisions to be made that he’s completely overwhelmed. Initially, he’s keen to have information on everything. Then the realisation that path leads to madness slowly dawns.

Now, it’s not clear what type of civil service, and associated Quangos, the PM thinks work best. It’s not strange to say I don’t like what I’ve got. It’s better to have an idea what it is that you want. A reform agenda in name is a headline grabber. It’s not a substitute to having a plan.

[1] https://www.bbc.co.uk/news/uk-politics-11405840

Life on Mars Remains a Dream

Exploration is part of our DNA. There are parts of the planet that we don’t know well. That said, there are not so many spots where a human foot has not trod. The mysteries of the deep ocean remain to be better known. Only we more often look heavenward than we study deep waters.

Looking up at the night sky the fascination with a twinkling red dot runs through history. It’s surprisingly recent that the notion that Mars might be inhabited prevailed. A 100 years ago a scientist might be frowned upon but wouldn’t get locked up for such a conjecture.

The possibility of Martian life still gets discussed. If existing, it would be extremely rare and unlike the life we take for granted on Earth. Discoveries are more likely to tell us about the history of Mars than the present.

A search for other civilisations goes on. Today, Mars is a planet for robots. Rovers and other contrivances are best equipped to deal with the harshness of the natural environment. If the radiation doesn’t get you the wide-ranging temperature fluctuations will. Humans are not well suited to live in extremely harsh environments.

On a trip to Phoenix in the United States about 30-years ago, I drove out into the desert. This was to have a look at the Biosphere[1]. A curious experiment in human behaviour. The experiment attempted to reproduce what it would be like to live as extraterrestrials. We’d be the alien civilisation on Mars. Living in a huge greenhouse on Earth. As much as to say this brave but shaky experiment proved that extraterrestrial living is very hard. In fact, impossible in the way it was conceived. The lesson from such empirical experiments is to value our unique circumstances even more. Polluting and trashing Earth is about the stupidest act “intelligent” but fragile beings could do.

There are plenty of extremely harsh environments on Earth. Wisely we (humans) choose not to live in them on a permanent basis although we like to make documentaries about them. For example, there must be an exceptional motivator to get people to live in a box in Antarctica.

It’s reported that Musk says that Space X will go to Mars next year. Adding more robots to the Martian population. In the field of exploration this makes sense to me. What doesn’t make any sense at all is the determination to put humans on the surface of Mars.

The only civilisation that is likely to inhabit Mars successfully, in the next century, is an android one. Every sign is that the capability of robotic life will advance ever more rapidly. They can be designed to thrive where we would fall by the wayside. What better use can we put our future robotic friends to than advancing exploration?

Putting a date on the first human footsteps on Mars is about as ridiculous as last century’s imaginative speculation about a Martian invasion. Although, such popular stories make great science fiction.

POST: This remote station has had reported problems. A case in point. Antarctic scientists plead for help after colleague ‘threatens to kill’ team members | The Independent

[1] https://www.euronews.com/green/2022/01/29/living-in-a-bubble-did-this-failed-90s-experiment-predict-the-future

The Human Touch

One of the most irritating aspects of bureaucracy is codification. What I mean is the need to tick a box that describes you or your problem. Restaurants, retailers, charities, religions, politicians and government departments all do the same. Sophisticated or crude administrative systems fall back on the same methods.

It’s immensely unsatisfying. Applicable to me, at this stage in life, is the age tick box. It doesn’t matter where the questionnaire or data gathering exercise comes from there’s always this box that starts at 65 years old. The previous box finishes at 64 years old.

This fits the respondent into the next step-up in age. Following from this simple date is a whole plethora of assumptions about the nature of a persons’ likes and dislikes, needs and wishes. An unsympathetic algorithm can then crunch numbers and send adverts for sheltered retirement homes, medication and certain types of undemanding travel opportunities.

Now, I could join the chorus of cries against bureaucracy. That would be popular but dumb. It’s a bit like the textiles we put on daily. We could go around naked as the day we were born. Trouble is that our present society doesn’t work well in the case where everyone is naked. Cold too.

So, it is with bureaucracy. It’s not going away anytime soon. The best we can do is to hunt for better ways of collecting data and making it useful for decision-makers and those who want to sell us something. Or even political parties that are keen to target us with their messages.

In the News this week is as good a sketch for an updated Yes Minister as any. Revolution is afoot. Suddenly the pen pushers who tie you up in red tape are going to be replaced with super-efficient algorithms and artificial intelligence to return us to paradise.

I think that’s the only reason Adam and Eve had to leave the garden of Eden. Nothing to do with apples. Well, not the ones that hang on trees. It was an iPad that had fallen though a time warp. Filling in a questionnaire on happiness it seems that one of them ticked the wrong box.

I see a difficulty with replacing civil servants with robotic algorithms and artificial intelligence. It might be the case that for routine activities, where the pattern of human behaviour is straightforward and well understood, a set of operations can be undertaken with a high degree of confidence that a good outcome will be provided.

Where I see the difficulty is that humans are notoriously messy. Inclined to irritation and not the least bit logical in their personal lives. Nothing that has been said this week is about truly eliminating bureaucracy, although that’s the illusion. It’s more about mechanising it using whizzy technology that’s so much better that that which has gone before (so they say).

Let’s just grow-up. We need public administration. We need it to work well. Fundamentally, it takes people to make it work. People who are motivated to work for the public good. People who are adaptive, caring and enabled to do a good job. Give them the tools to do the job. But are we kidding ourselves if we think complex algorithms and artificial intelligence are our saviours?

Navigating Change

Theres’s wisdom in having flexibility when making decisions. Being too high bound by ridged beliefs or a dogmatic creed isn’t a way of sustaining success. The saying, “When the facts change, I change my mind. What do you do, sir?” is attributed to John Maynard Keynes. It’s nice to have a quote like that to validate the wisdom of flexibility. Is it always true? Well, this is not a physical law like Force equals Mass times Acceleration. So, using the word “always” is not the least bit appropriate.

In the first months of 2025 the US seems to be going through a cycle of extreme plasticity. It goes like this; propose policy that’s drastic and disruptive and that shocks or puts everyone on edge. Let it ride for a day. Watch what happens. Then either double-down or reverse the whole move and start something else equally shocking. Meantime saying how great the achievement has been even if there’s no positive achievement.

Conventional wisdom isn’t wrong because it’s conventional. Reacting to conventional or traditional ways of working by deeming them automatically bad doesn’t add up. I know it’s conservative philosophy, but wisdom is acquired over time.

You could say, I’m burdened with being rational (or reading too much). That’s not wrong. What’s difficult is that a rational person must stretch the imagination a long way to see any good coming from a rapid cycle of change, often for the sake of change.

Setting the cat amongst the pigeons (or bull in a China shop) makes economies and financial systems quiver. Without a certain amount of understanding, or the perception of understanding, assessing risk becomes almost impossible. That’s the first months of 2025.

Where’s the vision? Maybe underlying the impulsiveness is a desire to get from here to there as quickly as possible.

75 years ago, after WWII, America entered a “golden age”. Baby boomers, technology and a sense of optimism drove the good times. The 1950’s ushered in a commercial exposition. Modern marketing and a proliferation of brands changed society, both in America and across the globe. Over the past decade, there’s not been that shiny newness or unbounded naivety that captured the imagination of the time.

If the overall vision is to get back to those times, then reality is going to bite. A sea change in circumstances could happen but it’s unlikely to be the one painted above.

Navigating Political Extremes

There’re arguments that can be made for stability. There’re arguments that can be made for disruption. I don’t think it matters if you are a socialist, centrist, conservative, liberal, oligarch or demigod. The virtue of one over the other is a temporary state of affairs. If this were not the case it would be unlikely that civilization, such as it is, would have ever got this far in its development.

Now, I have discounted the untenable. That is that stability becomes stasis. A moribund inability to do anything, totally regardless. It’s also the case for disruption so catastrophic that that we truly are in an end-of-the-world scenario.

“This too shall pass” has a long history. The temporary nature of everything is encapsulated in those four words. Or as Judas Priest put it “You’ve Got Another Thing Comin”. A thumping beat and screaming chords make great driving music. Put this on a Sony Walkman in the 1980s and the batteries would be flat in minutes.

Am I saying that Biden was stasis and Trump is catastrophic? Maybe. What is it in our minds that mean we flip from one extreme to another? These are question that erudite columnists are wrestling with as they chew over what’s happened with no idea of what’s to come.

In the British system of governance moderation wells up from centuries of tradition and custom and practice. As we are seeing it hardly matters who is in power, history runs so deep that it shapes every move. I never thought I’d have a good word to say for being a country that does NOT having a written constitution. Today, I’m rethinking how it can be advantageous to make things up as we go along.

Writing down sets of rules can be helpful in guiding decision making. Underlying this is the assumption that there’s some continuity and that those rules have a kind of universality. That’s mighty difficult to do given the passage of time.

The problem with writing down sets of rules is that they create something to be circumvented. Let’s use a river plunging over rapids as an analogy. If there is a forceful enough flow of water, it will go around or over any rocks in its way. Strident political forces, ranging from the crude to the cunning, have little difficulty in circumventing established custom and practice. What’s often called the “liberal media” may be horrified even as the river tumbles downhill with increasing speed. Predicting the future with a past perspective doesn’t work.

“This too shall pass” is a motif to hang onto. Just as the river eventually leaves the rapids so we might experience a steadier period ahead.

Look out for extremes. Milking my analogy as far as I can, changing everything, all at once, and relentlessly, is a proven route to disaster. Institutions, accepted norms and the fabric of society getting smashed up on the rapids, forever and a day is the definition of disaster.

The Revolutionary Role of Hydrogen

Hydrogen has a history with aviation. What could be better. A gas that is so light. So easily produced and with no need heat it up. With a lightweight gas-tight bag and a fair amount of rope, balloon construction took-off. Literally. The proof that hydrogen gas could lift a balloon goes back to the 1780s in France.

Sadly, the downside of this gaseous element is its propensity to combine with other elements. In fact, where would we be without liquid water. On this planet, that most basic and prolific combination of hydrogen and oxygen. Not so much sadly but more luckily.

Step forward about 250 years and we have a different vision for hydrogen in aviation. If it’s combined with the oxygen in the air that we breath, we get nothing more noxious than water. Since, the other forms of combustion, that populate our everyday lives, is distinctly noxious, surely hydrogen has a lot to offer. Talk about downsides. Burning fossil fuels is distinctly unsustainable. Polluting the atmosphere.

This week, I was looking out to sea. At the English Channel (No name changes there, I see). Standing on the pebble beach at Budleigh Salterton. They ought to have an award just for that name. It’s a small seaside town in Devon. The towns cliffs are part of a World Heritage Site, namely The Jurassic Coast[1]. 

Forget the 250 years of humans flying, cited above. About 185 million years of the Earth’s history is for all to see on the Devon and Dorset coast. When we say “fossil fuels” what we mean is that we are living off the back of Earth’s history. Society powers modern life on dinosaur juice. Well, not exactly but plant and animal life from hundreds of millions of years ago. How crazy is that?

Hydrogen, on the other hand, is one of the most abundant elements. It’s everywhere.

Modern day dinosaurs (politicians and pundits) insist that we continue to exploit dinosaur juice until it’s all gone. That’s putting aside any concerns about returning all that carbon to the Earth’s atmosphere. Carbon accumulated over millions of years.

Hydrogen can be a clean fuel. The problem is that saying that and then doing it are two different things. There are complexities that come with using Hydrogen as a fuel. It might be reasonably easy to produce, in multiple different ways, but it’s not so easy to transport.

Producing leak proof systems for transport and storage requires innovative thinking. We can’t just treat it with the familiarity of conventional fuels. Whole new regimes are going to be needed to get Hydrogen from where it’s produced to where it’s needed.

Producing leak proof systems for aircraft is a challenge. Given the odourless and invisible nature of this light gas, accurate and extensive detection systems are going to be needed. If the gas is to be consumed by fuel cells to produce electricity, then there’s going to be a constant struggle against complexity and significant expenditures.

What is reassuring is that none of the above is insolvable. At this time in history, we have the materials technology and control systems that make Hydrogen a viable clean fuel.

[1] https://jurassiccoast.org/

Understanding Aviation Safety

The recent dramatic events in Toronto brought to mind the equally dramatic event of Air France Flight 358 back at the latter half of 2005. Then a large aircraft was destroyed but the crew and passengers got away without fatalities. The combination of bad weather and poor decision-making led to a catastrophic runway excursion.

I remember that the year 2005 shook the aviation community. There was a whole succession of fatal aircraft accidents across the globe. In Europe, Helios Airways Flight 522 was particularly tragic. Errors led to the crew suffering hypoxia and as a result the aircraft and everyone onboard was lost. In Italy, lives were lost as an ATR72 aircraft ran out of fuel and plunged into the Mediterranean Sea near Palermo.

West Caribbean Airways Flight 708 fell from the sky killing all on-board. Kam Air Flight 904 hit a mountain killing all on-board. In Indonesian, Mandala Airlines Flight 091 crashed. A few passengers survived but many people were killed on the ground.

I sincerely hope that 2025 is not going to turn into another 2005. However, I do take the view that there is a cyclic element to the occurrence of fatal accidents. We are often proud to be able to say that the time (number of years) between one cluster of aviation accidents and another grows as overall safety improves but we are a long way from zero-accidents.

The global aviation industry is an incredibly safe industry when considering how many passengers are carried every year. However, zero-accidents remain an illusion however it might be touted as the ultimate goal.

As safety practitioners try to be ever more pro-active in our safety regimes there’s inevitably a reactive element to aviation safety. The aftermath of the 2005 experiences led to ICAO holding its first high-level safety conference in 2010 in Montréal. There have been two more such conferences since. One in 2015 and one in 2011.

The results have been to push the aviation industry towards a more pro-active management of safety. It’s not just the industry. In cases, the regulatory weaknesses that exist in individual States has needed to be given attention.

Add all this up over the last 20-years and you would expect everyone to be pro-actively managing aviation safety. Sadly, that’s not the case as some States and organisations are still managing the transition to a more pro-active approach. Some are so resource constrained that they are more inclined to talk about aviation safety than to act upon it.

Regulatory weaknesses exist in some unlikely places. Additionally, with the fashion of the time being to cut “red tape” at every opportunity, more troubles might be just over the horizon.

I’d like to see a break between the association of what is regulatory and what is considered bureaucracy. The two are not necessarily the same. Regulation and standards are synonymous. And what we know is that there is no successful complex industry without standards.

Please let’s not wait for the next accident report to tell us what to do.

The Evolution of Air Traffic Control

Until civil air traffic started to grow the need for its control wasn’t the number one consideration. The pilot was the master of the skies. A basic “see and avoid” approach was taken. See another aircraft and avoid it at all costs. Note, I am talking about the early 1920s.

If you want a nice exploration of how it all started keep an eye on the site of the Croydon Airport Visitor Centre[1]. The first London airport was not Heathrow or Gatwick. No, there’s a stretch of grass, a hotel, industrial units and out of town shopping standing on the site in Croydon of the first London airport. 

Firstly, we can thank Marconi for the first radiotelephony. Providing a means for pilots to speak to airports enabled the development of Air Traffic Control (ATC)[2]. It got going out of necessity because there was limited space on the ground and many aircraft wanted to take-off and land.

Aerial navigation took off in the 1920s. A hundred years ago. WWII drove advancement in every aspect of technology. After WWII, the basic having been established, an international body was established to set standards for international flying. That’s where today’s ICAO originated.

Radar and VHF radio transmissions were the cutting-edge technology that enabled air traffic to grow. Radio navigation aids developed as did automatic landing systems. So, by the time the jet-age started there was a whole selection of technology available to manage air traffic. Not only that but the standards required for these systems to interoperate around the globe were put down on paper.

That legacy has served aviation remarkably well. Incremental changes have been made as new capabilities have been developed. Most notable of that evolution is to return elements of control to the cockpit. A traffic alert and collision avoidance system (TCAS) does just that. It provides a safety net.

What we have available to manage dense airspace and busy airports is a complex, highly interconnected, interdependent set of systems of systems and procedures that is not easy to unravel. Each part, in each phase of flight, plays its role in assuring safe operations.

News and rumours are that quick fixes are being demanded in the US. Responding to recent accidents and a perception that all the above in antiquated, a well know tech guru has been thrown at the “problem”. I shouldn’t be a cynic, as having a fresh pair of eyes looking at the next steps in the development of air traffic management should be good – shouldn’t it?

It’s my observation, as an engineer who knows a thing or two about these things, is that any simple solution means that the parties have not thought long enough about the problem. In this case there are no quick fixes. However, there’s likely to be incremental improvements and they will not come cheap. 

[1] https://www.historiccroydonairport.org.uk/opening-hours/

[2] https://www.historiccroydonairport.org.uk/interesting-topics/air-traffic-control/