I have been dissecting some of your recent commentary about the certification process(es) with regard to the 777X. I find that you’ve contradicted yourself and appear to apologetic on Boeing’s behalf.
This is not a personal attack against you, that is not my intention. I am just trying to make sense of all of it.
I need to correct an incorrect impression on this thread. For new and major derivative airplane programs (and I worked on five airplane programs), Boeing and the FAA negotiate the means-of-compliance to the regulations and whether finding compliance to a regulation is delegated to the applicant's designated representative or is retained by the FAA. If the finding of compliance is retained by the FAA, the certification documents must be provided to the FAA for review and acceptance. Generally, if the applicant has certificated something similar in the past, the FAA will delegate finding of compliance to the applicants' designated representative.
So unless you have the certification plan in front of you for the CCS, you really don't know how much of this has been delegated and how much has been retained
… The FAA has linked completion of the CCS Development Assurance to flight test. Further, it appears that this is a fairly recent requirement from the FAA in that the letter that is referenced was written April 7, 2021.
Taking this one step further, what the FAA is asking of Boeing is to essentially provide the data required to certify the CCS before TIA, which could be construed as moving the goal post. Knowing how certification is parsed out among the technical disciplines, one could see how the E-UM at Boeing and the specific regulators at the FAA for this discipline would have put together a certification plan and schedule independent of the requirements from flight test.
A two year delay would be consistent with findings that flight critical software was non-certifiable and needed to be re-written. A hypotheses would be the approach was to re-use 787 software and subsequent re-assessment by Boeing and the FAA found that assumption to be non-certifiable. We will see.
1. In quote 1, you’ve stated that Boeing and the FAA would have come to an agreement with regards to the certification process. That I have no issue with, perfectly logical for all parties concerned. Now in quote 2, you’ve suggested, without any reference or source, that the FAA has changed its modus operandi with regard to certification.
I think that if was the case, the letter would have provided an indication of this to re-agreement to the terms of certification. eg. “With regards to to terms of the amended agreement of certification…”. There is no indication, suggestion, or evidence, of this.
2. If Boeing, as the programme integrator and manager, has determined itself to be the manager of the development of the CCS, they have the responsibility of producing what the FAA requires, not GE. An excuse of “but this is what we’ve been given”, is not an acceptable submission to the FAA. It only suggests that they’re not doing their assigned role and using a third party as a scapegoat.
3. My understanding of the 777X CCS, based on reading what’s available on the web, is that it has its roots from the 787 CCS but incorporates several more functions and/or systems. Therefore testing using 787 data is not pertinent as you’re not conducting tests on all elements. As an example:
A car manufacturer produces model A which is a 2WD (Two Wheel Drive) vehicle that like any modern car, has an ESC (Electronic Stability Control). The same manufacturer then releases another vehicle, model B, that is 4WD and 4WS (Four Wheel Steered). Do you think that using the software from model A would be definitive in terms of testing?
The simple fact that Boeing has not been able to provide relevant data, as required, to the FAA, suggests that they have not been managing the project as they could/should have been. To request an interim test certificate to demonstrate capability in areas they can is indicative of a juggling act, in my understanding and perception.
If the amount of hardware they load on board of a test aircraft cannot capture the data that the FAA has requested is a concern. It either meets requirements, or it doesn’t.