THE TAKEAWAY
Few initiatives ignite imaginations more than the possibilities presented by advanced air mobility (AAM) aircraft. Realizing their potential to move people and cargo between places not served or underserved by aviation demands revolutionary new aircraft – and successfully bringing them to market.
Conformity is the process by which aircraft design and build is proven to regulators, but it is more than a milestone. It is a major risk in the aircraft certification process. The heavy administrative burden of achieving Federal Aviation Administration (FAA) conformity strains even mature original equipment manufacturers (OEMs). Tracking and approving type design changes can overwhelm the best of the best. A single drawing or specification change to “Type Design” (14 CFR Part 21.31) after completing the FAA Request for Conformity (Form 8120-10) dramatically impacts an OEM’s costs and schedules.
A single unsatisfactory (UNSAT) determination during the FAA conformity process leads to rework, reapprovals and sometimes type design changes. These can add weeks or months to the aircraft development schedule, affecting next higher assemblies, manufacturing times and build sequences – potentially racking up millions of dollars in unplanned costs.
CONFORMITY CHALLENGES FACED BY AAM OEMS
Aviation Week reports that aviation safety rules already cover design, production, operations and maintenance of civil aircraft. FAA certification is a new challenge to first-time AAM OEMs, but it is not a new challenge.
Certification gate readiness risks are numerous and underestimated. How do we know? We’ve seen it while enabling go-to-market for AAMs. While this is not surprising, it is unfortunate, because it doesn’t have to be the case. Leadership, which has finite focus and resources, must determine whether it has the inhouse expertise to successfully navigate the conformity process, and, if not, whether it is worth the investment to develop and maintain that know-how inhouse.
Type design approvals and certification conformities provide the basis of type certification (TC). Three major challenges prevent aircraft from being ready for type inspection authorization (TIA) and certification. It’s worth noting that organizational size, budget and sophistication do not, of themselves, mitigate these challenges.
1. Process requirements vs start-up mentality – Frequent design-build iterations create churn in design records, creating many opportunities for less-rigorous processes to break down. Resources in start-up aircraft companies are primarily committed to the primary program objectives rather than the internal process and system management key to ensuring conformity. While new regulatory standards are still in development for the many AAM technology variations, Part 21 conformity requirements apply to all aircraft types – and will not be compromised.
2. Heavy records burden for conformity events – It is a massive endeavor to manage type design and certification artifacts from the supplier base, configuration changes, tests, manufacturing and compliance approvals up to FAA conformities. Not all OEMs want to retain inhouse the expertise required to support such a cyclical activity, but robust configuration management processes and systems are a necessity.
3. Underestimated risk-to-certification timeline – A single nonconformance can delay certification by weeks or months. Fixed certification dates for planned deliveries and investment milestones put millions of dollars at risk, yet risk mitigation focuses on aircraft technology not configuration management and data tracking for conformities.
A STRUCTURED APPROACH FOR MANAGING CONFORMITY RISK
The FAA fulfills a vital function in ensuring AAM aircraft achieve regulatory compliance. OEMs must work within those parameters while finding ways to efficiently bring these revolutionary aircraft to market. OEMs can increase their conformity event first pass yield (FPY) by avoiding UNSAT designations, regulatory missteps, Request for Conformity (RFC) 8120-10 rework and resubmittals.
Establishing foundational processes and systems that minimize the chance of rework and additional conformities reduces the likelihood and impact of noncompliance conformity events. It’s paramount, for example, that all type design drawings, details and processes are accurate and that FAA DER 8110-3 compliance records are truly representative of the part. Something as simple as a low-level part – such as a bushing or bearing – not conforming to a process – such as a finish or heat treatment – would trigger an UNSAT and a rejection by the FAA. This small item could result in tremendous time and schedule adjustments as well as placing an unnecessary burden onto the FAA.
OEMs need to efficiently manage external resources, including designated airworthiness representatives (DARs) and designated engineering representatives (DERs), as well as associated costs. Relying on purpose-built expertise can provide the strongest value proposition. Bringing in experts committed to conformity success for only as long as they’re needed frees core teams to focus on development, design and operations. They can also augment core teams to build and run critical processes/workflows, while managing and coordinating conformity events. This can mitigate schedule risks, helping maintain commitments to customers and investors, and protecting both certification schedules and costs. It can reduce the FAA burden and maintain program priority – alleviating the risk of FAA sequencing.
MITIGATING NONCONFORMANCE THE SEATEC WAY
AAM OEMs can reduce this major risk by integrating SeaTec’s critical-function expertise with their core teams for FAA conformity planning and management. SeaTec’s experience and proven systems effectively manage compliance, conformance, configuration management and lifecycle records. This includes a final, thorough crosscheck of the FAA’s Request for Conformity (RFC) Form 8120-10 prior to FAA Manufacturing Inspection District Office (MIDO) submittal. Better, safer air travel is the outcome new OEMs aspire to, the FAA requires – and we enable.
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