Statement
of
Nathaniel Beuse,
Associate Administrator for Vehicle Safety Research,
National Highway Traffic Safety Administration
Before the
House Committee on Energy and Commerce
Subcommittee on Commerce, Manufacturing and Trade
Hearing On
“Driving a Safer Tomorrow: Vehicle-to-Vehicle Communications and Connected Roadways of the Future.”
June 25, 2015
Good morning Chairman Burgess, Ranking Member Schakowsky, and members of the subcommittee. I appreciate this opportunity to testify about Vehicle-to-Vehicle (V2V) communications and the extensive potential safety benefits that could result from fully deployed V2V technology.
In 2013, there were over 5.7 million motor vehicle crashes in the United States, and 32,719 people died in vehicle-related crashes. The consequences of these crashes range from personal tragedies that impact individual families forever, to billions of dollars in economic damage due to lost productivity, increased congestion, environmental impact and other negative consequences. While we have made significant improvements in motor vehicle safety, vehicle crashes remain the leading cause of death for ages 11 to 27—and a major factor in most other age ranges.
The National Highway Traffic Safety Administration’s (NHTSA) mission is to reduce deaths, injuries, and economic loss resulting from motor vehicle crashes. NHTSA’s vehicle safety activities will continue to enhance occupant protection when crashes occur, but, as Secretary Foxx recently said, “The Department wants to speed the nation toward an era when vehicle safety isn’t just about surviving crashes; it’s about avoiding them.” Our studies show that 94 percent of crashes are due to driver error, and technologies are now available or being developed that can help drivers avoid the crashes in the first place. An increasing part of NHTSA’s work is accelerating research on these types of technologies. NHTSA’s research is focused on emerging crash avoidance technologies that help the driver operate his or her vehicle in a safe manner, warn the driver of an impending collision, and can even take control of the vehicle’s brakes or steering if such warnings are not heeded.
NHTSA’s testing and analysis of Vehicle-to-Vehicle (“V2V”) communications crash avoidance technology, conducted in close cooperation with the Intelligent Transportation Systems (ITS) Joint Program Office (JPO) and the Federal Highway Administration (FHWA), show it can potentially address approximately 80% of crashes involving two or more motor vehicles. When fully realized, this communications technology may even be able to address crashes involving pedestrians and cyclists, which represent an increasing share of total motor vehicle involved fatalities. V2V technology is based on vehicles wirelessly sharing their position, speed and heading information with each other in near real-time fashion. Each vehicle uses the information to determine if a collision is imminent, and then warns the driver as needed.
Crash Avoidance
V2V is anticipated to augment today’s crash avoidance technologies such as forward collision warning, blind spot warning, and automatic emergency braking systems. V2V technology would potentially be fused with other crash avoidance technologies that rely on sensors such as radar or cameras to further improve the effectiveness of these safety systems— allowing for potential crash situations to be detected sooner and more reliably. Because V2V would allow for enhanced 360 degree situational awareness and allows a vehicle to “see” around corners, it can assist the driver in many challenging crash scenarios that are difficult for other types of sensors to detect—including, for example, intersection related crashes, one of the most deadly crash types.
Examples of what V2V-enabled safety applications may do for drivers:
- Warn if there is sudden braking in the vehicles ahead.
- Help drivers avoid collisions at intersections by alerting drivers if another vehicle approaching the intersection may run the red light. If you are the driver who might run a red light, V2V will send you an alert of a potential collision with cross traffic. Warn drivers of another vehicle in their blind spot.
- Inform drivers of bad road weather conditions, warning drivers of unsafe road conditions experienced by others ahead, enabling the driver to slow down or change routes altogether.
- V2V also has the potential to help enable warnings about pedestrians in crosswalks n crosswalks or work zones ahead.
NHTSA and a growing number of suppliers and vehicle manufacturers believe V2V will provide an important capability that can be leveraged to improve the performance, reliability and safety of fully self-driving vehicles, thus allowing for the full potential of a connected-automated vehicle and infrastructure environment to be realized.
V2V technology relies on licensed, dedicated short range communications (DSRC) to operate. In turn, our August 2014 Advance Notice of Proposed Rulemaking (ANPRM) relies on DSRC spectrum availability free of harmful interference. In 1999, the Federal Communications Commission (FCC) had the foresight to allocate the 5.9 GHz spectrum to ITS America and to the American Association of Highway and Transportation Official (AASHTO) to enable technology development with industry and government partners.
NHTSA and other modes within DOT have been conducting research on V2V technology for over a decade. Our collective work has focused on:
- supporting the development of industry standards to ensure interoperability (a key factor for the technology to be successful);
- developing and demonstrating safety applications to address specific types of crashes
- researching driver interface issues to ensure the technology provides warnings without causing distraction, and
- analyzing customer acceptance, reliability, cost and other deployment issues.
Security and Privacy
NHTSA has placed special emphasis on researching the security and privacy issues surrounding V2V. NHTSA does not believe that V2V technology will involve collecting or exchanging personal information or tracking specific drivers or their vehicles. The information sent between vehicles would not identify those vehicles, but would merely contain basic safety data, such as speed and position, ten times per second. It is not anticipated to record or store that information. In fact, the system as contemplated contains several layers of security and privacy protection to ensure that vehicles can rely on messages sent from other vehicles to accomplish safety goals.
A key research milestone was reached in 2013 when the technology was taken out of the lab and put into the real world for testing. The ITS JPO-managed Safety Pilot Model Deployment tested 3000 prototype vehicles from six different manufacturers driven by regular citizens going about their daily business for one year in the Ann Arbor, Michigan area. The promise of this technology based on the data collected from that study helped shape NHTSA’s decision to move forward with V2V technology.
ANPRM and V2V Report
In August 2014, NHTSA issued an Advance Notice of Proposed Rulemaking (ANPRM) that requested comment on the comprehensive “Vehicle-to-Vehicle Communications: Readiness of V2V Technology for Application Report” (or Readiness Report), which provided details on the technology, results of testing programs, benefits, deployment considerations, as well as security, policy, privacy and regulatory issues. The ANPRM initiated rulemaking to create a new Federal Motor Vehicle Safety Standard to require V2V communications capability on all light vehicles.
- NHTSA’s ANPRM outlined how the agency could require the basic radio system, security features, and functionality to support interoperable communications—but would not require specific safety applications. Such an approach will allow the market to innovate and compete in offering safety applications.
Key Findings and issues addressed in the ANPRM and Readiness Report included:
- V2V devices installed in light vehicles as part of the Connected Vehicle Safety Pilot Model Deployment were able to transmit and receive messages from one another, with a security management system providing trusted and secure communications among the vehicles during the Model Deployment.
- Safety applications enabled by V2V, which include intersection movement assist (IMA), forward collision warning (FCW), and left turn assist (LTA), showed they have the potential to mitigate or prevent potential crashes. Additional refinement to the prototype safety applications used in the Model Deployment is needed before minimum performance standards could be finalized and issued.
- The agency has the legal authority to mandate V2V devices in new light vehicles, and could also require them to be installed in commercial vehicles already in use on the road.
NHTSA received more than 900 comments in response to the ANPRM and the V2V Readiness Report. The automotive manufacturers stated that the Federal government needed to assume a large role in establishing key elements of the V2V environment, including establishing common operating criteria for V2V devices, establishing a security credentials system, and preserving the 5.9 GHz spectrum for V2V safety. Automotive suppliers generally expressed support for the technology and indicated the technology and standards for the technology were mature enough for initial deployment. Safety advocacy groups also expressed support, but emphasized the importance of ensuring interference-free spectrum for V2V.
Many auto companies are embracing V2V technology as demonstrated by GM’s September 2014 Press announcement that they would be implementing V2V technology with a target of 2017 on select models. GM acknowledged in their comments that NHTSA’s rulemaking actions on V2V technology is needed to fully realize its benefits.
In May of this year, Secretary Foxx announced USDOT’s intent to accelerate the V2V rulemaking activities and issue a proposal in 2016. NHTSA has accepted the challenge and our Agency is working diligently to meet this goal.
In addition, Secretary Foxx announced our readiness to accelerate testing of potential interference from sharing arrangements in the 5.9 GHz spectrum. Given the interest in determining whether the 5.9GHz spectrum reserved for V2V communications can be shared with unlicensed users, the Department is committed to completing a preliminary test plan within 12 months after industry makes production-ready devices available for testing.
NHTSA announced its intent to move forward with V2V in February 2014 because of its demonstrated potential to dramatically improve vehicle safety and its importance as a stepping stone toward achieving safe automated driving. The USDOT-led research program has demonstrated through extensive analysis, controlled testing, and real world field studies that V2V communications offers an important opportunity to dramatically improve safety on our Nation’s roads. Thank you for this opportunity to testify and I look forward to your questions.
Key V2V Milestone Dates and Activities from 2013 to the Present
November 2013: GAO issues Report on Vehicle to Vehicle technology. What GAO found:
The development of vehicle-to-vehicle (V2V) technologies has progressed to the point of real world testing, and if broadly deployed, they are anticipated to offer significant safety benefits.
February 2014: Secretary of Transportation Anthony Foxx announces intent to move forward with a V2V regulatory proposal “within this Administration” (by 2016).
August 2014: NHTSA issues an ANPRM requesting comment on its comprehensive “Vehicle-to-Vehicle Communications: Readiness of V2V Technology for Application” report that provides details on the technology, results of testing programs, benefits, deployment considerations, as well as security, policy, privacy and regulatory issues. The ANPRM outlined a regulatory approach that considers mandating the radio communication system only.
October 2014: NHTSA issues a Request for Interest related to deploying and operating a Security Credential Management System (SCMS) that would support vehicle to vehicle communications to ensure security and protect privacy. Responses received from 21 entities expressing varying degrees of interest.
October 2014: FHWA previews summary of Vehicle to Infrastructure (V2I) Deployment Guidance document at ITS World Congress in Detroit. Provides States and local transportation agencies with guidance on deploying DSRC infrastructure. Initial publication of the guidance along with “deployment tool kits” to be available fall of 2015.
October 2014: General Motors announces its intent to offer DSRC technology on production vehicles beginning in 2017.
January 2015: USDOT issues Broad Agency Announcement seeking proposals from State and local transportation agencies to participate in Connected Vehicle Pilot Deployments. Multiple proposals received in March.
April 2015: The National Academies Committee (an independent review committee of the Transportation Research Board) issues a Letter Report on its review of USDOT’s “Status of the Dedicated Short-Range Communications Technology and Applications [Draft] Report to Congress”. Key findings from Exec Summary:
The use of 5.9 gigahertz (GHz) DSRC is appropriate for the connected vehicle initiative. The committee agrees with the DSRC report’s arguments concerning the low latency, privacy protection, and other benefits this technology offers compared with other communications technologies for safety-critical messages.
With regard to DSRC as the chosen low latency technology for communicating safety-critical information, the committee agrees with the DSRC report conclusion that proposed spectrum sharing in the 5.9 GHz band is the most serious risk and uncertainty for the program, but it is not the only one. The committee believes that unless local area wireless technology (Wi-Fi) and other unlicensed and licensed technologies are determined not to interfere with DSRC, the potential benefits of the program will be severely compromised.
May 2015: Secretary Foxx announces USDOT’s intent to accelerate Vehicle to Vehicle rulemaking activities with goal of issuing a regulatory proposal within 2015.
STATEMENT
OF
DORENDA BAKER,
DIRECTOR OF THE AIRCRAFT CERTIFICATION SERVICE,
FEDERAL AVIATION ADMINISTRATION (FAA),
BEFORE THE
SENATE COMMITTEE ON COMMERCE, SCIENCE & TRANSPORTATION,
SUBCOMMITTEE ON AVIATION OPERATIONS, SAFETY, AND SECURITY,
ON
FAA REAUTHORIZATION: CERTIFICATION AND U.S. AVIATION MANUFACTURING COMPETITIVENESS,
APRIL 21, 2015.
Senator Ayotte, Senator Cantwell, Members of the Subcommittee:
Thank you for the opportunity to speak with you today about the Federal Aviation Administration’s (FAA) role in the aircraft certification process. As Director of the FAA’s Aircraft Certification Service (AIR), I am responsible for overseeing the design, production, and continued operational safety of aircraft, engines, propellers, and articles. Efficiently and effectively managing the safe oversight of the largest fleet of aircraft in the world, while continuing to support the innovation of new and novel technologies is a challenge, but one that we recognize is vital to the economic growth of our country. The U.S. aviation manufacturing industry provides the livelihood for millions of Americans and is a dynamic and innovative industry that we are proud to oversee.
FAA certification is vital to the production of aircraft and aircraft components both domestically and internationally. Our certification means that the product was thoroughly reviewed, tested, and analyzed, and has been deemed to meet the stringent safety standards we require. Certification is a dynamic process with both industry and the FAA having important roles and responsibilities critical to success. We are constantly working to improve the process. Both in response to Congressional direction, and on our own initiative, the FAA is working closely with industry to understand and respond to their concerns in order to improve the efficiency and effectiveness of the certification process without compromising safety. Central to the success of this effort is transparency. All parties need to know what we are doing and why, as well as what is working and what is not. I would like to share the FAA’s vision on reforming the certification process, what we have been doing in response to the 2012 FAA reauthorization, and our efforts to drive certification reform at the local, national, and international level.
Certification Reform Vision
In order to support the safest, largest, most complex aviation system in the world, the FAA must continue to make our processes as efficient and effective as possible, while also maintaining high standards of safety. The future vision of AIR, or AIR:2018, aligns with the FAA’s Strategic Initiatives and shows where we want to go and the type of work environment we want to create. Our vision is built around four key focus areas: safety, people, organizational excellence, and globalization. Certification reform is a key component of this vision. It includes initiatives in response to the requirements set forth in section 312 of the Federal Aviation Administration Modernization and Reform Act of 2012 (the Act), and internally driven activities to improve several components of the current certification process.
As an organization, we are confronted with new challenges every day: limited finite number of resources, new technologies, new entrants to the marketplace, and the expanding globalization of aviation. In order to address these challenges and the expectations of our stakeholders and the general public, we are applying safety management principles and using risk-based decision making to leverage our partnerships and designees to make better decisions about where to focus FAA resources. As a result, we are creating an agile, collaborative organization that embraces technology and is a leader in developing the future of aerospace.
Section 312 Implementation
Section 312 of the Act required the FAA to work with industry to develop consensus recommendations on ways to improve efficiency and reduce costs through streamlining and reengineering the certification process without compromising safety. In response to this direction, the FAA formed the Aircraft Certification Process and Review Aviation Rulemaking Committee (ARC), which developed six recommendations that resulted in 14 initiatives. To date, the FAA has successfully completed 10 of the 14 initiatives and is making significant progress on the remaining four initiatives. Many of the initiatives are directly related to FAA’s efforts to expand the use of delegated authority and implement a risk-based systems approach to the oversight of that delegation system.
For example, as part of the FAA’s ongoing commitment to improve responsiveness to industry as it certificates new products, the FAA replaced project sequencing with a new “project prioritization” process in September 2014. The new system prioritizes projects based on their safety benefits and complexity, and allows more efficient allocation of FAA’s resources. In contrast to sequencing, project prioritization offers applicants a commitment to a response time for the review of compliance data based on the priority of the certification project. Now, applicants are able to initiate projects without delay. If an applicant is an Organization Designation Authorization (ODA) holder or is using an FAA-approved individual delegated representative, they can immediately move forward with much of the work required to certify the product.
The FAA plans to develop and track the metrics related to implementing the 14 recommended initiatives in three phases: measuring (1) the progress of implementing the initiatives throughout FAA, (2) the outcomes of each initiative, and (3) the return on investment for the FAA and industry resulting from implementing the initiatives as a whole. The metrics for phase one have been developed and are contained in the latest revision of the Section 312 Implementation Plan posted on the FAA website.[1] Transparency and accountability in FAA’s relationship with industry and a data-driven approach will make the agency more effective and efficient, and drive certification reform.
The initiatives recommended by the Section 312 ARC are helping us to identify and address national certification issues; however, we recognize that these steps may not solve the problems experienced by individual companies. Therefore, the FAA is reexamining how it conducts business and implementing internally driven initiatives at the local, national, and international levels.
Local Efforts
ODAs and individual designees play a vital role in the effort to streamline the certification process. AIR currently oversees 71 ODAs and more than 2,900 individual designees. The FAA is working with individual companies to establish short- and long-term goals to help them reach their vision of full utilization of ODA by reinvigorating the Partnership for Safety Plans. These safety plans outline operating norms, define a process for issue resolution, and identify certification priorities; they are our foundation for setting common expectations when working with a company and ensure that both sides are held accountable. Revitalizing the safety plans will be a catalyst to drive positive change, reinforce expectations for the highest levels of regulatory performance, and reestablish the spirit of partnership for our mutual long-term success.
In collaboration with the Aerospace Industries Association and the General Aviation Manufacturers Association, we are also creating an ODA scorecard that will collect qualitative and quantitative data related to safety, FAA involvement, and ODA holder compliance. The scorecard will facilitate constructive dialogue between FAA management and ODA holders about compliance, timeliness, and any performance improvement enhancements that may be needed. Once individual goals are established through the reinvigoration of the safety plans, AIR will monitor how ODAs are progressing towards individual company goals. A national rollup of the scorecard data will also track progress by measuring the overall efficiency and effectiveness of all ODAs.
National Efforts
As the commercial aviation safety rate indicates, FAA continually strives to improve its performance in all areas, including certification. The Office of Aviation Safety (AVS) is an ISO 9000 registered organization and requires a quarterly review of Quality Management System (QMS) measures to gauge the overall health of AVS. The QMS measures also monitor the efficiency and effectiveness of the certification process. Our goal is to efficiently certify products that meet the safety requirements that the world recognizes as a gold standard. QMS measures are designed to quantify our efforts to maximize efficiency and minimize risk areas associated with the issuance of domestic Type Certificates, Supplemental Type Certificates, and Production Certificates.
The FAA is committed to continuous improvement, applying safety management systems principles and using risk-based decision making to determine the level of rigor necessary in each certification. For example, in support of the FAA’s NextGen implementation goals, the agency issued a policy memo in March allowing ODA holders to conduct certain certification projects without notifying the FAA in advance. The policy contains criteria that, when met, alleviates the need for a Project Notification Letter (PNL). Relieving industry from the PNL requirement will result in time and cost savings to their design, manufacturing, and production processes.
AIR also updated its training curriculum to improve training for personnel assigned to oversee ODAs in October 2014. The enhanced training includes an emphasis on auditing the ODAs to ensure they are compliant with their agreed upon procedures. While expanding the number of ODA holders is critical to the industry’s view of how to streamline certification, in order for FAA’s staff to expand delegation, the agency must be able to show that industry is compliant with its regulatory responsibilities.
International Efforts
The FAA is a global leader in safety and efficiency. The global transportation network is changing, however, and the growth of the U.S aviation industry is expanding to global suppliers. We recognize the importance of working across geopolitical boundaries and have adapted our international efforts to maintain and enhance our leadership position.
In FY 2014, the FAA launched the Asia Pacific training initiative at the Singapore Aviation Academy to deliver targeted training to the regional civil aviation authorities and industry with the delivery of two courses – Cabin Safety Workshop and Changed Product Rule. This regional training initiative is an efficient way of using the FAA’s resources while promoting the FAA’s policies and procedures globally. The training initiative helps achieve a consistent level of safety across geopolitical borders and facilitates the export of U.S. products and articles.
We are also working with our global partners to leverage our bilateral agreements. This year we are working with the European Aviation Safety Agency (EASA) toward mutual recognition of European Technical Standard Order Authorizations (TSOA) and FAA TSOAs, and to accept classification of basic Supplemental Type Certificates without further review. This will allow manufacturers of TSOA articles to sell their products in Europe without further approval by EASA. The agreement is expected to be finalized at the end of this year and will eliminate duplicative processes, reducing costs through time savings for both industry and the FAA.
The FAA also signed agreements with Transport Canada Civil Aviation and EASA to promote rulemaking cooperation. The activities between the U.S. and Canada under the Regulatory Cooperation Council encourage the sharing of rulemaking experiences to promote cooperation and align rulemaking requirements.
The FAA is working to enhance global manufacturing by working with our global partners to provide reciprocal assistance in overseeing manufacturing facilities. For example, the FAA and the Mexican Dirección General de Aeronáutica Civil (DGAC) are finalizing a Special Arrangement to allow the Mexican DGAC to perform certain types of certificate management activities on behalf of the FAA. A successful Special Arrangement is already in place in Brazil. The FAA will continue to leverage these arrangements as globalization of the aviation industry creates more complex business partnerships.
Section 313 Implementation
The FAA is also making progress in response to section 313 of the Act, which focused on the consistency and standardization of regulatory interpretation. In an effort to remain transparent with our stakeholders, the FAA posted an implementation plan for section 313 on the FAA website.[2] We have taken several steps to implement the recommendations and we have closed two of the six initiatives in the plan with the support of industry.
The highest priority initiative is to develop a single master source for guidance organized by regulation. We are making progress in reviewing our existing databases to assure the information is up to date. In January, I participated in a demonstration of the proof of concept for a tool that will link documents from multiple sources. I was impressed with the system’s capabilities; it will link the regulatory material not only by regulation as requested by industry, but also by concept in case the user does not know the regulatory citation.
Unmanned Aircraft Systems
The FAA is also working tirelessly to safely integrate Unmanned Aircraft Systems (UAS) into the National Airspace System (NAS). The 2012 Act established the framework for this effort and tasked the FAA with safely integrating civil UAS into the system by September 2015. We have worked together with government partners and industry stakeholders to complete milestones put forward by the Act. This includes long-term planning for the future integration, collaborative research and development with interagency partners and industry, and the establishment of test sites and airspace for UAS research and development and testing. As of April 9, the FAA has issued 137 exemptions under section 333 of the Act and is working to decrease processing time for future exemptions.
In February, the FAA issued a Notice of Proposed Rulemaking that would allow routine use of certain small UAS in the NAS. The proposed rule would cover many potential small UAS operations and would offer a flexible framework for the safe use of small unmanned aircraft, while accommodating future innovation in the industry. Under the new authority provided in section 333, it contains operational limitations that will allow the entire category of small UAS to avoid airworthiness certification and be subject to the least burdensome level of regulation that is necessary to protect the safety and security of the NAS. As proposed, the United States would have one of the most flexible UAS regulatory frameworks in the world.
The FAA has successfully issued four UAS type certificates using existing FAA certification processes and is currently working with five other companies to type certificate their UAS using the FAA certification process available for Special Class aircraft. This process has sufficient flexibility to evaluate designs of aircraft of various size, speed, intended use, and area of operation. The same process is utilized for the certification of airships, gliders, and very light aircraft, and enables the FAA and applicants to collaborate together on appropriate certification requirements. It utilizes a risk-based classification and certification approach to identify the expected level of safety to determine FAA involvement and oversight. The FAA is currently developing advisory material to assist applicants, industry stakeholders, and the general public in understanding this process. As the FAA gains experience in certificating UAS products, it will continue to mature its policies and procedures to balance the needs of our applicants and UAS owners and operators with its responsibility to maintain safety in the NAS.
Conclusion
The FAA has made significant progress in implementing the requirements in section 312 of the Act and the initiatives recommended by the ARC to expand the use of delegated authority and establish a risk-based, systems approach to safety oversight. The FAA shares the Subcommittee’s desire to streamline aircraft certification and will continue to implement internally driven reform activities at the local, national, and international levels.
To become more effective and efficient while maintaining and improving aviation safety, the FAA must collaborate with industry and improve transparency with stakeholders. When it comes to working together with industry, we need to respect each other’s goals. For the FAA, the goal is a product that is compliant with the regulations. Industry wants to find ways to get new and safer products to market efficiently. For both of us, the safety of the aviation system is paramount. We are working to find ways to be more sensitive and responsive to industry’s schedules without sacrificing compliance.
The FAA is tracking the progress of implementing the initiatives, and will develop means to measure the performance outcomes and the global return on investment for the FAA and industry as a whole. The FAA will continue efforts to develop meaningful metrics and a data-driven approach that promotes open, constructive dialogue, facilitates positive change, and keeps both sides accountable for certification reform.
This concludes my statement. I will be happy to answer your questions at this time.
STATEMENT OF
DORENDA BAKER,
DIRECTOR OF THE AIRCRAFT CERTIFICATION SERVICE,
FEDERAL AVIATION ADMINISTRATION,
BEFORE THE
COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE
ON
FAA REAUTHORIZATION: REFORMING AND STREAMLINING THE
FAA’S REGULATORY CERTIFICATION PROCESS
JANUARY 21, 2015
Chairman Shuster, Congressman DeFazio, Members of the Committee:
I appreciate the opportunity to speak with you today. As Director of the Federal Aviation Administration’s (FAA) Aircraft Certification Service (AIR), I am responsible for oversight of the design and production of aircraft, engines, propellers, and articles. AIR monitors the production and continued operational safety of all the products it certifies for the life of those products. In that respect, we are responsible for an ever expanding range of products. Effectively managing the safe oversight of the largest fleet of aircraft in the world, while continuing to support the innovation of new products and technologies is a challenge, but one that we recognize is vital to the economic growth of our country. The U.S. aviation manufacturing industry provides the livelihood for millions of Americans and is a dynamic and innovative industry that we are proud to oversee.
FAA certification is vital to the production of aircraft and aircraft components both domestically and internationally. Our certification means that the product was thoroughly reviewed, tested, and analyzed, and has been deemed to meet the stringent safety standards we require. Certification is a dynamic process with both industry and the FAA having important roles and responsibilities critical to success. We are constantly working to improve the process. Both in response to Congressional direction, and on our own initiative, the FAA is working closely with industry to understand and respond to their concerns in order to improve the efficiency of the process without compromising the safety of the product. Central to the success of this effort is transparency. All parties need to know what we are doing and why, as well as what is working and what is not. I would like to share what we have been doing in response to the reauthorization Congress passed in 2012, and our efforts to drive certification reform at the local, national, and international level.
Certification Reform Vision
In order to support the safest, largest, most complex aviation system in the world, the FAA must continue to strive to make our processes as efficient and effective as possible, while also maintaining high standards of safety. Certification reform includes responding to requirements in Section 312 of The Federal Aviation Administration Modernization and Reform Act of 2012 (the Act), addressing the recommendations from the Aircraft Certification Process Review and Reform Advisory Rulemaking Committee (ARC), and reviewing the FAA’s activities to improve several components of the current certification process.
Numerous external forces are affecting our existing certification process: the globalization of aviation, advances in technology, a high velocity of change, and heightened expectations from our stakeholders and the general public. In order to address these issues and expectations, we are applying safety management principles and using risk-based decision making to leverage our partnerships and make better decisions about where we need to focus FAA resources.
Section 312 Implementation
Section 312 of the Act required the FAA to work with industry to develop consensus recommendations on ways to reduce the time and cost of certification without compromising safety. In response to this direction, the FAA formed the ARC, which developed six recommendations that resulted in 14 specific FAA initiatives. To date, FAA has completed 10 of the 14 initiatives, many of which are directly related to FAA’s efforts to expand the use of delegated authority and to implement a risk-based systems approach to the oversight of that delegation system.
For example, as part of the FAA’s ongoing efforts to improve its responsiveness to industry as it certificates new products, in September 2014, the FAA replaced project sequencing with a new “project prioritization” process. The new system prioritizes projects based on their safety benefits and complexity, and allows more efficient allocation of FAA’s resources. In contrast to sequencing, project prioritization offers applicants a commitment to a response time for the review of compliance data based on the priority of the certification project. Now, applicants will be able to initiate projects without delay. If they have an Organization Designation Authorization (ODA) or are using an FAA-approved individual delegated engineering representative, they can immediately move forward with much of the work required to certify the product.
The FAA is working diligently to address the initiatives recommended by the Section 312 ARC. These initiatives are helping us to identify and address national certification issues; however, we recognize that may not solve the problems experienced by individual companies. To reform certification, the FAA must also implement activities that address issues and expectations at each level. Therefore, the FAA is reexamining how it conducts business and implementing internally driven initiatives at three levels.
Local Efforts
The FAA is working with individual companies to establish short and long-term goals to help them reach their vision of full utilization of ODA by reinvigorating the Partnership for Safety Plans. These safety plans outline operating norms, define a process for issue resolution, and identify certification priorities; they are our foundation for setting common expectations when working with a company and ensure that both sides are held accountable. Revitalizing the safety plans will be a catalyst to drive positive change, reinforce expectations for the highest levels of regulatory performance, and reestablish the spirit of partnership for our mutual long-term success.
In collaboration with the Aerospace Industries Association and the General Aviation Manufacturers Association, we are also creating an ODA scorecard that will collect qualitative and quantitative data related to safety, FAA involvement, and ODA holder compliance. The scorecard will support constructive dialogue between FAA management and ODA holders about compliance, timeliness, and any performance improvement enhancements that may be needed. Once a baseline and individual goals are established through the reinvigoration of the safety plans, AIR will monitor how ODAs are progressing towards individual company goals. The national rollup of the scorecard will also track progress by monitoring the effectiveness and efficiency of all ODAs, help differentiate between national and local issues, and point to areas where policy improvement may be needed.
National Efforts
As the commercial aviation safety rate indicates, FAA continually strives to improve its performance in all areas, including certification. The Office of Aviation Safety (AVS) requires a quarterly review of Quality Management System (QMS) measures that measure the overall health of AVS. In addition, the QMS measures monitor the efficiency and effectiveness of the certification process. Our goal is to efficiently certify products that meet the safety requirements that the world recognizes as a gold standard. QMS measures are designed to quantify our efforts to maximize efficiency and minimize risk areas associated with the issuance of domestic Type Certificates, Supplemental Type Certificates, and Production Certificates.
Supplementing the QMS data, my office is also working to track improvements to the time it takes to bring products to market, a fundamental goal of industry. Determining success in this area must also take into account the increasing complexity of the products being certified and industry’s accountability to a compliance culture.
In addition, a new policy is in development that will help define the projected level of FAA’s involvement in the process and clarify what companies can do to reduce that involvement. This safety management system approach uses risk-based decision making to determine the level of rigor necessary in each certification. Risk-based decision making proactively addresses emerging safety risks by using consistent, data-informed approaches to make informed, system-level decisions. We expect to complete this policy in spring of this year.
ODA holders will play a vital role in any effort to streamline the certification process. There are currently 81 ODAs, with more than 4,700 individual designees. In addition to the efforts noted above, I have personally held nine teleconferences with AIR managers to ensure that all offices receive a consistent and timely message on the importance of certification reform to the future vision of aviation certification. AIR updated its training curriculum to improve training for personnel assigned to oversee ODAs in October 2014. The enhanced training includes an emphasis on auditing the ODAs to ensure they are compliant with their agreed upon procedures. While expanding the number of ODA holders is critical to the industry’s view of how to streamline certification, in order for FAA’s staff to expand delegation, the agency must be able to show that industry is compliant with its regulatory responsibilities.
The FAA also understands industry’s desire for timely certification. Consequently, we are working collaboratively to develop performance metrics and goals for streamlining certification while simultaneously ensuring compliance with safety regulations. The data gathered from these metrics will begin to capture the larger picture of certification reform, defining the global return on investment for FAA and industry. We have made progress and will continue to work to build consensus with industry on these performance metrics.
International Efforts
The FAA has been the leading model for safety and efficiency around the world. However, the global transportation network is changing and the growth of the U.S. industry is expanding to global suppliers. We recognize the importance of working across geopolitical boundaries and have adapted our international efforts to maintain and enhance our leadership position.
In FY 2014, the FAA launched the Asia Pacific training initiative at the Singapore Aviation Academy to deliver targeted training to the regional civil aviation authorities and industry with the delivery of two courses – Cabin Safety Workshop and Changed Product Rule. This regional training initiative is an efficient way of using the FAA’s resources while promoting the FAA’s policies and procedures globally. The training initiative helps achieve uniformity and facilitates the seamless transfer of U.S. industry products overseas.
We are also working with our global partners to leverage our bilateral agreements this year. We committed to work with the European Aviation Safety Agency (EASA) towards mutual acceptance of European Technical Standard Order Authorizations and FAA Technical Standard Order Authorizations, and to accept classifications of basic or non-basic Supplemental Type Certificates without further review during initial validation. This will allow our manufacturers of TSOA articles to sell their product in Europe without further approval by EASA. This mutual acceptance model will result in a time savings for both industry and the FAA, and industry will realize cost savings as a result of eliminating duplicative processes. We also committed to implement a post-validation audit program to ensure that the process is providing the expected result.
The FAA also signed agreements with Transport Canada Civil Aviation and EASA to promote rulemaking cooperation. The activities between the U.S. and Canada under the Regulatory Cooperation Council encourage the sharing of rulemaking experiences to promote cooperation and aligning of rulemaking requirements.
Conclusion
The FAA has made significant progress in implementing the requirements in Section 312 of the Act and the recommendations in the Aircraft Certification Process Review and Reform ARC to expand the use of delegated authority and establish a risk-based, systems approach to safety oversight. The FAA shares the Committees’ desire to streamline aircraft certification, and will also continue to implement internally developed improvement activities at a local, national, and international level to supplement the initiatives of Section 312.
To become more effective and efficient while maintaining and improving aviation safety, the FAA must also improve accountability and transparency with stakeholders. When it comes to working together with industry, we need to respect each other’s goals. We both have an interest in maintaining the safety of the aviation system. For the FAA, the goal is a product that is compliant with the regulations. For industry a major concern is finding ways to get new and safer products to market efficiently. Both of these goals are paramount to safety. We need to find ways to be more sensitive and responsive to industry’s schedules without sacrificing compliance.
The FAA is tracking the progress of implementing the initiatives, the performance outcomes, and the global return on investment for the FAA and industry resulting from the initiatives as a whole to increase accountability in the certification reform process. The FAA will continue efforts to develop meaningful metrics and a data-driven approach that promotes open, constructive dialogue, facilitates positive change, and keeps both sides accountable for certification reform.
Mr. Chairman, I am happy to answer any questions you have at this time.
STATEMENT OF MARGARET GILLIGAN, ASSOCIATE ADMINISTRATOR FOR AVIATION SAFETY, FEDERAL AVIATION ADMINISTRATION, BEFORE THE COMMITTEE ON TRANSPORTATION AND INFRASTRUCTURE, SUBCOMMITTEE ON AVIATION, ON BUILDING A 21ST CENTURY INFRASTRUCTURE FOR AMERICA: STATE OF AMERICAN AVIATION MANUFACTURING,...
