I'm not going to hog this so I will just address the point that was directed to me.
All aeroplanes that are produced by Boeing and Airbus have to comply with
25.1302 Installed systems and equipment for use by the flightcrew:
Installed systems and equipment for use by the flightcrew.
This section applies to installed systems and equipment intended for flightcrew members' use in operating the airplane from their normally seated positions on the flight deck. The applicant must show that these systems and installed equipment, individually and in combination with other such systems and equipment, are designed so that qualified flightcrew members trained in their use can safely perform all of the tasks associated with the systems' and equipment's intended functions.
and
25.1329 - Flight guidance systems.
In themselves, these two rules are objective - i.e. they state the objective and leave the methods of compliance to the applicant/regulator.
With respect to both of them, the advisory material contains a great deal of information which is rightfully in the human factors domain. This guidance includes the requirement to meet human-centric design methods. As such it fully considers the pilot-in-the-loop.
During the recent conference we put a number of flips on the wall which contained the questions we needed to answer in the presentations and in the following discussion. On the flips was contained the mantra:
It is important that synergy is achieved in a ‘design’ / ‘training’ / ‘operations’ system solution but no one area should dominate. Extra training and complex procedures must not be used to mask a poor design. The flight crew should not be expected to compensate for poor design to achieve the desired flight path, or monitor effectively.
This was posted to constantly remind attendees - during the conference - that we should not tolerate deficient designs.
Also around the walls of the conference theatre were pictures of the AH225, AH175, AW139, AW169, AW189, S92 and S76D; these were there to show those who were not aware (our presenters from the fixed wing world) of the complexity of more recent helicopter cockpits. Those presenters remarked on the complexity of the displays, integrated systems and HMIs -
more complex than the A380 or the B787.
The fact is that these two rules are necessary to ensure that the standard of certification is appropriate; for, without them, it is not clear to us mere observers, what standards are being applied and why. There is no good reason why the rules are not in Parts 27/29.
In a recent EASA Discussion Document on automation, the Working Group made the same recommendation. However, we were informed that, during consultation, comments were received in opposition to such a recommendation.
This is not a request for something that is not recognised as being logical or necessary.
Jim