# Presentation: 202493

## The Future of Design Validation:  Balancing the Needs of Authorities and Industry

## Major Discussion Points

**Future Validation Alternatives Proposed**
- Single Worldwide Airworthiness Code
- Further Streamlining of Existing Validation Processes
- Joint Certification by Airworthiness Authorities
- Mutual Acceptance by Airworthiness Authorities
**Issues Identified**
- Non-standardized Operational Requirements Negatively Impact TC Validations
- Worldwide List of Requirement Differences Not Available
- No Common Definition of “Validation”
- Validation Roles and Responsibilities not Standardized

**Notes:**
Single Worldwide Code – Approximately five years ago an International Working Group proposed a single airworthiness code that could be adopted by most/all of the world’s airworthiness authorities. If adopted, it would have potentially eliminated regulatory differences thereby streamlining all validations.  The timing of this proposal coincided with the decision to create EASA, therefore this recommendation has been placed on the hold since its creation.
Streamlining of Existing Validation Process – Process by which we would continue to streamline the existing validation process thereby further minimizing the time and resources needed for design validation.
Joint Certification – Process by which the Airworthiness Authority Design Certification Team is made up multinational specialists with a goal of concurrent certification.
Mutual Acceptance -  Process by which the Validating Authority accepts the State of Design’s Certification without additional review.  

ISSUES IDENTIFIED
- Numerous comments were made by both panelists and audience members stating that non-standardized operational requirements were minimizing the potential advantages from harmonized design requirements.
-Commentors stated that an “all encompassing” list of every unique FCAA design and operational requirement does not exist and therefore validation requirement surprises still occur regularly
- Commentor stated that a common worldwide definition of “validation” with common “roles and responsibilities” does not exist.  Further, it was stated that some foreign authorities conduct validation directly with the manufacturer instead of through the State of Design. 

## Reaction from the Floor

**Validation process vastly improved over last 20+ years – International Trust Increasing**
**Leasing business model would greatly benefit from Mutual acceptance or Single Worldwide Code**
- STC validation burden is significant (Cost and Time)
**Joint Certification may work in the near future**
**Other proposals discussed:**
- Use a safety data (e.g. CAST) to develop new worldwide code
- Foreign Authorities who accept State of Design Certification without additional work may only need airplane design and method of compliance familiarization instead of complete validation

**Notes:**
 - Audience/Panelists recapped the increase in trust between authorities which has improved the validation process over the last 20+ years.

 ILFC stated that 40% of the European Transport Fleet is made up of leased airplanes.  Therefore the transfer of existing airplanes between countries is frequent and the resultant STC validation burden is significant in both cost and time.  ILFC panelist and other airline members in the audience requested the regulatory authorities to reconsider mutual acceptance or even the single worldwide code to minimize the STC validation burden.

 It was stated that Joint Certification would be an upcoming option (at Applicant’s request) that will be included in the draft FAA/EASA Bilateral Implementation Procedures.  At least one Manufacturer stated that they would consider Joint Certification in the future.

Other proposals that were discussed by audience members include:
1)create a working group to develop a new single worldwide code based entirely on safety data (e.g. CAST data)
2) Some foreign authorities accept the State of Design’s Product Certification without applying additional ops/design requirements. Typically these are foreign authorities who do not directly certify airplanes products within there own country. Therefore, the proposal was to possibly create two categories of validation in the future:
	a) use the existing thorough validation process for those countries that have unique cert/ops requirements
	b) use a simplified validation process consisting of design familiarization and method of compliance overview for those countries that rely on the State of Design’s certification process. 

## Outcomes/Additional Ideas

**Authority’s legal responsibilities will not allow mutual acceptance proposal**
**Diverse operational requirements need to be better understood/defined and ultimately harmonized**
**Proposal for Single Worldwide Code is attractive but may not be realistic yet **
**Joint Certification can be pursued near term**
**Streamlining should continue on existing Validation Process**
**Evaluate the possibility of a Design/MOC Familiarization instead of a complete validation**

**Notes:**
 EASA and FAA made it very clear that mutual acceptance would not be acceptable in Europe or the United States.
- It was agreed that ultimate goal should be harmonization of the operational requirements which were causing numerous validation issues.  EASA made it clear that they could not really address this issue until EASA takes over NAA operational responsibilities in the future.
 Although there was interest to implement a single worldwide code, there were a overwhelming number of significant implementation hurdles stated by airworthiness authorities (and certain industry members) which still have to be overcome prior to considering this proposal.
 It was agreed that Joint Certification may be an attractive option in the near future.
 It was agreed that the authorities/industry need to continue to refine/streamline the existing validation process to minimize the time and cost burden.
 Lastly it appeared that most of the audience/panel was in agreement that a potential simplified validation process (consisting mainly of design/MOC familiarization) should be evaluated for those airworthiness authorities that rely entirely on the State of Design’s certification process.  No specific actions were taken related to this proposal