New Realities of Certification: Manufacturers' Winding Road to Finish Line

At long last on March 30, Gulfstream Aerospace was able to celebrate the certification of its new flagship, the ultra-long-range, ultra-high-tech G700, after an approval process that took at least two years longer than the Savannah, Georgia airframer anticipated.

Announced in 2019, the company initially targeted 2022 for certification but by April 2022, General Dynamics chairman and CEO Phebe Novakovic warned of delays looming related to time-consuming, extra requirements that she said were “the result of events independent of us.”

Gulfstream later had hoped to have the ticket in hand by the end of 2023, with the anticipation of delivering 15 in that year.  It was said to have built 50 by the end of the year as it prepped for deliveries.

When announcing the long-awaited approval, Gulfstream president Mark Burns proclaimed: “We have successfully completed the most rigorous certification program in company history with the G700.”

Speaking to BJT during Qatar Executive’s unveiling event of its first two G700s in Doha on May 22, Burns said the longer-than-initially-expected certification process of the new model was in large part due to the congressional directives in the U.S. calling for more oversight during product approvals.

The FAA requested more elements to be documented and tested and demanded more test flying as well. All this testing has created “an extremely mature aircraft,” Burns said, adding “The good news is that we did not have to change the aircraft. The aircraft remained as it was a year ago.”

Gulfstream’s flagship G700 received EASA validation in mid-May, and the Qatar General Civil Aviation Authority’s approval followed soon after, allowing the twinjet to be delivered to and operated by Qatar Executive. Gulfstream is in the process of seeking G700 validation by more than a dozen national aviation authorities, including China, Canada, and the UK, Burns noted.

Meanwhile, in the greater Dallas-Fort Worth area, helicopter manufacturer Bell has been developing perhaps its most advanced, and certainly its largest commercial helicopter yet with the Bell 525. Like the Gulfstream 700, this aircraft is equipped with new and far-reaching systems, such as a full fly-by-wire system, a first in the civil rotorcraft sector.

Bell announced the 525 in 2012 intending to carve a new niche in the super medium market. The program received a setback in 2016 when a prototype crashed. But overcoming that, the helicopter manufacturer moved forward and tentatively targeted a 2017 date for approval.

But then Bell changed. It informed reporters that it was no longer going to set a timeline for certification, with then-CEO Mitch Snyder saying that it is a joint process with the FAA. Again last year, Snyder tepidly pointed to the end of 2023 as a possibility but stressed this was in the hands of the FAA.

Then there’s the Dassault Falcon 6X, which was announced in 2018 as the follow-on to the ill-fated 5X. Certification slipped—but just a little in comparison—on this program as well; the wide-cabin jet received both its EASA certification and FAA validation in August 2023.

A Moving Target

From the outside, certification programs are always a bit of a moving target.  But long gone are the days of Cessna Aircraft, now Textron Aviation, unveiling a follow-on aircraft and having it certified and in the market a few years later.

There are many reasons for this. COVID brought complexities into the workplace with remote working and early retirements. Dassault pushed back its Falcon 10X timeline to 2027, and Dassault Aviation CEO and president Eric Trappier pointed to complications surrounding work during the pandemic as a prime reason. Speaking to reporters in late May, he added, “We are now confident that [2027] should work.”

Both remote work and the wave of retirements impacted the FAA as well. Pete Bunce, president of the General Aviation Manufacturers Association (GAMA), in 2023 testified on Capitol Hill about the delays involving certification and expressed concern about the turnover at FAA—40 percent of certification engineers had less than two years of experience. He said training them was hindered because of the dispersed workforce in the wake of the pandemic. Congress in the most recent reauthorization bill included a directive to ensure workers worked remotely in cases where it made sense in their jobs.

A second, and at least equally influential reason, is the Boeing factor. The FAA has come under substantial scrutiny globally in the aftermath of the Max crashes and subsequent investigations as well as with the production issues that surfaced.

Congress put in a variety of controls, including stepped-up oversight of delegation activities, through the Aircraft Certification, Safety, and Accountability Act of 2020.  No change is implemented quickly but all agree having a permanent FAA administrator in place, Michael Whitaker, is helping this.

“After the Boeing accidents, the certification agencies are more meticulous, and quite rightly, to make sure that passengers will be safe. Therefore, things are a bit more difficult,” Trappier told media and analysts during the company’s 2023 results presentation in March. EASA, which is in charge of the certification of the Falcon business jets, demanded several modifications to the 6X, he said. Because of these required modifications, the 6X entered service only on November 30.

In the meantime, the Pratt & Whitney PW812D-powered 6X obtained approval from the aviation authorities of Turkey, the Isle of Man, and San Marino, while the certification process is ongoing in Canada, India, and the UK.

The French OEM is also still working on obtaining additional product approvals such as for steep approach as well as for its FalconEye Combined Vision System (CVS). According to Dassault’s executive v-p of civil aircraft, Carlos Brana, these are just a matter of time, and “up to 99 percent of the missions can already now be performed with the aircraft as it is.”

A Longer Road

While many point to the FAA as taking much longer for approvals, Walter Desrosier, v-p of engineering and maintenance with GAMA, said he is seeing heightened scrutiny in certification programs from all of the agencies, not just the U.S. aviation authority.

“Certification authorities are now much more demanding than they used to be,” agreed Brana. “We will need to take into consideration that the 10X may also require a very stringent certification process. Safety comes first at Dassault, since always. It would be wrong to tell certification authorities they are requesting too much information if safety is our primary concern.”

Why one program may appear to move through faster than another may be more a matter of how mature the program is at the point of certification application or how novel the technology a new program may be bringing to the market.

Or, there could be internal changes made to a new program that is not visible to the outside markets. However, Desrosier did say that programs in general are taking longer. 

As for the FAA, “there's been significant review” of the agency’s certifications processes and procedures, he said. “There's been a stream of different recommendations…that have come in various forms—whether it's a rulemaking advisory committee, whether it's some of the [Department of Transportation Inspector General] or [Government Accountability Office] IG studies. And then, most recently as a result of the Max accidents, there was an unprecedented amount of review and scrutiny.”

The key question with all of these recommendations and directives for increased oversight is how the FAA manages the rapidly evolving technologies at a predictable pace while maintaining the necessary level of involvement and upholding the highest standards, Desrosier said. This is a balancing act especially as the industry is in unprecedented times with the leap in new and transformative technologies.

However, as a result of the stepped-up oversight, Desrosier added, “Some of the things that we're seeing are basically a recertification of some areas that have already been certified when [there is a] change of product.”

Also, the process now involves more extensive documentation surrounding certification tests. In the end, he explained, the result may not necessarily require a change to a manufacturer’s design, “but a much more robust involvement and review” from the regulators.

He added that this is a shift “we are seeing from the FAA and all authorities in terms of strengthening the documentation and what we call the substantiation of compliance.”

The reason this has “come to the forefront,” Desrosier further explained, is aviation authorities are taking a deeper dive into a certification program’s compliance reports, including previous engineering documentation. “And they have started asking questions such as: 'How did you make this leap or how did you make this connection, or more importantly, this is an area we don't see a lot of substantiation.'”

The Re-evaluation

Many aircraft programs involve follow-ons or evolutions of previous models, and some of these questions the manufacturers have encountered from regulators surrounded an earlier modification, Desrosier said. That documentation that the agency is requesting may have involved a change made three or four derivatives earlier, or 10 or 15 years before, and doesn’t necessarily involve what’s new on the latest project.

“We're seeing a little bit of a change from all authorities expecting more substantiation in the documentation robustness and compliance showings on each program and not just recognizing it's previously approved and therefore it can continue to go forward. You have to bring that data forward, show the substantiation documentation, and then include it into that program, and then add the additional substantiations of compliance for the areas in your design change.”

For new programs, manufacturers can enter with full knowledge of these changes. But those that had already been underway—such as Gulfstream’s G700, Bell’s 525, and even the Falcon 6X— may have been caught by this shift in test and other documentation. “There are new expectations being set [from the regulators]. There are new things being put into place that are required to be shown and that requires the manufacturers to go back and redo stuff that they've already gone past,” Desrosier said. “That is what we have seen from some of the companies when they say there's been a surprise, that there's been some delays. That's because there has been some change. Those changes aren't necessarily in big new requirements. The changes are in the policy and the guidance and the expectation of the level of substantiation.”

This is the result of investigations of the more recent crashes, he explained. Accident investigating authorities determined that the substantiation should be easy to identify. But for the manufacturers, “All of that is just additional work when it was not planned and not expected,” he said, adding the various aviation authorities are in “lockstep” in recognizing this, even if their processes may have their own nuances.

As far as those nuances, he cited as an example, Transport Canada may have an additional focus on cold weather operations. “It's the same requirements that apply for everybody but they dig in and have a lot more substantiation requirements, a lot more documentation requirements, and a lot more test requirements because that's an area of emphasis and focus for them.”

However, once the manufacturers know what the expectations are and the regulators can better communicate them, that will ease the path for the companies. “They'll just plan to do it, and they can plan for it and be prepared for it,” he said. “The greatest impact when it comes to impact on certification project plans, things like schedules and expectations for schedules, is when there's a change that occurs that was unexpected, that wasn't planned for.”

Desrosier further noted that GAMA has heard from the companies that have had delays when these additional requirements popped up unexpectedly. “If you're in year five [of a certification program] and suddenly there's an expectation that these reports are all going to have to be documented differently. That has a bigger impact moving forward.”

He further stressed: “What's really important is that the manufacturers and the applicants have an understanding of what is expected by the regulators. The regulator's primary job in the certification process is establishing the requirements up front.”

Desrosier pointed to the complexities, however, of setting those expectations. Part 25 requirements for transport-category aircraft are well known as are the means of compliance used in the past. This should have a high level of predictability.

“You can put together a project plan and a schedule that's pretty accurate because you have high predictability on what those requirements are,” he said.  However, most new programs incorporate a lot of new technologies, whether they be new materials to make an aircraft lighter and burn less fuel or safety enhancements involving automation.

The Rulemaking Factor

Companies also are updating their manufacturing methods. “Every time we incorporate something new that the existing regulations don't address or the existing means of compliance that are accepted don't address, that means that's an additional level of work for both the applicant and for the regulator. We now have to come up with new applicable requirements.”

This leads to special conditions. “Well, that's a whole rulemaking process,” he said.  And this may be a key difference between the FAA and other regulators.  “The FAA’s rulemaking process—and the effectiveness and efficiency of that process—really comes into play on impacting type certification, project timelines, and programs.”

He pointed to special conditions that didn’t come out for Gulfstream until this year. “If the FAA didn’t finish the rulemaking for a special condition until 2024, it’s impossible to certify.  They have to know the requirements. Obviously, Gulfstream did know what those requirements were upfront because they already did the design, they already did the compliance. They were just waiting for the FAA to finish promulgating and publishing and adopting it through that administrative process. So obviously, there's some things that are out of sync here.”

He added this wait for special conditions, in general, is a “huge frustration” and concern for manufacturers. He noted rulemaking is not fully under the FAA’s control. It must still go to the Department of Transportation and the Office of Management and Budget for regulatory clearance. Other authorities may not have such an extensive process in certain rulemaking areas.

Another area that makes the process longer is outdated and aging systems. One of the areas that the most recently passed FAA reauthorization bill addresses is digitization. Why that’s important is it will further streamline the process. “We still have to provide paper—two-dimensional design—when every young person does it in 3D,” Bunce said.

Engineering designs are typically done through sophisticated computer systems. “We have to translate it to paper.  This is ridiculous. We have to push the regulators to move into the 21st century,” he added.