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Old 19th Jan 2020, 02:44
  #186 (permalink)  
fdr
 
Join Date: Jun 2001
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Originally Posted by WillowRun 6-3

A second reported assertion is that certification as a new type wouldn't have improved the overall safety of the airplane. I'm going to plead dumbfoundedness on this....new type, but no bare airframe testing without MCAS? No revealing its inclusion to pilots, no simulator training? One AoA sensor only? I must be missing something (again, just SLF + att'y). At the very least, this is a stark counter-factual -- the panel is a roster of heavies but they don't have magic portals for seeing into what "would have happened" either.

Third and almost last, regarding the scheme [sic]of delegating areas of the certification process, for now my response is, "but of course the status quo will counter-attack, and this is part of that." Some other worthies on Capitol Hill are obviously angling to re-reconfigure the delegation scheme, and those efforts now have one more obstacle.
WillowRun, fair points.

Had grandfathering not been available, then the conditions precedent would likely have been vastly different. The plane would not have need of the geometry that the MAX assumed, gear length would have been able to balance weight/cost of gear to development potential and optimised airframe configuration. That would have also permitted TBC to establish a fuselage section that permits LD loading which would permit the TBC product a cargo capability that it sorely misses out on in its 737 design. MCAS would not have been needed, however lord knows what else would come about out of a fresh design. Certification would be in the 10B+ range and that would add directly about 2M for 5000 airframes, and double that for the cost of finance for the sunk costs of development and certification. An aircraft such as the A330 was developed with relatively modern revisions of CS 25, and yet following a well thought out design (beauty in the eye of the beholder) and testing, the A330-300 ended up a hole in the ground doing a OEI GA on automation. Any design can have issues, old ones warmed over or new ones, and time exposes the strengths and weaknesses that are missed in the relatively exhaustive certification process.

A fresh start design has "unknown unknowns".

FAA delegation is not a scheme dreamt up by the FAA to circumvent the regulatory oversight, the FAA lags behind EASA in the establishment of DOA. Any delegation is dependent on the ethical standards of the delegate, and that is always going to be a point of contention; Chinese firewalls only work so well, as was exhibited by the investment banking communities. The issue of conflicting demands exists within a system that doesn't use delegation, where the regulator is responsible for both regulation development, certification and enforcement, as is being suggested, the back to the future scenario. In all cases, the certification of designs eats up talent, and that is scarce in all areas, with regulators disadvantaged usually to the commercial end of town in maintaining and developing talented people.

A continuing concern is the marginalisation of the quality processes, which are a stain on the industry. It is a specific part of the ODA/DOA system that the system is underpinned by effective QA, and there are examples abounding on systems disregarding and in fact silencing QA personnel going about their duties. As long as that is an accepted situation, there are dark clouds on the horizon. If an entity abuses the QA staff, or whistleblowers trying to get an urgent message to responsible managers or regulators, as long as they are treated the way they are, then any process is going to be inherently unbounded and heading towards badness.
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