US Transportation Secretary Sean Duffy recently announced a first-of-its-kind collaboration between the US Federal Aviation Administration (FAA), aviation authorities of Australia (Civil Aviation Safety Authority), Canada (Transport Canada Civil Aviation), New Zealand (Civil Aviation Authority), and the United Kingdom (Civil Aviation Authority), known together as the “National Aviation Authorities (NAA) Network” and each individually as a “Network Authority.”
Secretary Duffy announced the NAA Network’s Roadmap for Advanced Air Mobility Aircraft Type Certification (Roadmap) at the Paris Air Show, noting that the Roadmap is revolutionary, as “eVTOLs and all kinds of futuristic advanced air mobility vehicles will redefine how we transport goods and people.”
Electronic vertical take-off and landing (eVTOL) aircraft, hydrogen-based propulsion systems, and other advanced air mobility (AAM) technologies are revolutionizing urban mobility and offering new transportation solutions. However, differences in the certification process for these new advancing technologies make the current traditional aircraft type certification framework insufficient. The FAA Network’s Roadmap acknowledges these differences and provides a framework to harmonize current standards and streamline validation and safe entry of AAM aircrafts to meet multiple countries’ certification criteria.
The Roadmap establishes six key principles and associated guidelines to reach them. The NAA Network will update the Roadmap with increasing detail as it identifies and minimizes AAM certification progresses and differences.
The First Principle: Safety and Innovation
The first principle focuses on balancing safety standards with technological advancement and promoting innovation within a safety-first framework. The Roadmap will collaborate with the safety continuum, as described by the International Civil Aviation Organization (ICAO), which recognizes that greater safety assurances are needed as products and operations become more complex.
The NAA Network will draw on the current regulatory framework and type certification criteria, including the use of 14 CFR 21.17(b) as the type certification approach for special class aircraft to identify additional requirements for type certification. These safety standards will work in tandem with robust monitoring mechanisms to ensure compliance, which will allow innovation without sacrificing safety.
The Second Principle: Harmonized Type Certification
The second principle is aimed at harmonization of airworthiness standards and means of compliance for AAM type certificated aircraft. The objective is to develop a three-phase approach: utilizing performance-based requirements, seeking convergence on requirements where differences exist, and applying mutually accepted Means of Compliance.
First, the NAA Network will use current performance-based certification criteria from the NAA Network for certifying specific AAM designs and technologies. Second, the NAA Network will exchange knowledge and compliance information, which will allow convergence where differences exist and alignment of approaches between the Network Authorities. Lastly, the Network Authorities will seek to maximize the use of industry consensus standard, which will also lead to streamlined validation of AAM within the NAA Network.
The Third Principle: Collaboration and Alignment
The third principle focuses on fostering collaboration within the NAA Network, including parallel alignment with UK CAA and coordination with other key Authorities that have active domestic AAM certification projects. Collaboration will increase the exchange of Means of Compliance information between NAA Network members, increasing acceptance of published Industry Consensus Standards and reducing differences between airworthiness criteria.
Appropriate sharing and learning across the NAA Network will ensure inclusion of additional considerations, reducing the burden on future type certification. Ultimately, this collaboration and alignment will reduce the validation burdens associated with introducing AAM aircraft into operational service.
The Fourth Principle: Leverage Opportunities
The fourth principle focuses on leveraging opportunities for multi-authority validation, which is particularly important for AAM original equipment manufacturers (OEMs) seeking validation from multiple Network Authorities. While multi-authority validation will continue to be governed by respective bilateral agreements, with each authority retaining its regulatory independence on airworthiness requirements, the approach would allow for collaboration toward the common goal of validating the aircraft.
This would allow the benefits to be realized in the near term while bilateral agreements are simultaneously reviewed and updated to reflect a more formal process of validation and acceptance. The model will also set global precedent for AAM certification, allowing for exchange and transferability of Airworthiness Criteria and Means of Compliance between the NAA Network.
The Fifth Principle: Incremental Approach
The fifth principle builds on the now-familiar “crawl, walk, run” approach put forth by the FAA in its prior implementation plans to take advantage of existing opportunities and existing processes/standards. This principle focuses on increasing levels of autonomy by starting with piloted AAM certification systems before moving to remotely piloted AAM systems and eventually to fully autonomous AAM.
The Sixth Principle: Inclusive Bilateral Agreements
The sixth principle focuses on establishing a comprehensive process for creating new and updated bilateral agreements to formally streamline validation of AAM Aircraft. This will be accomplished by reviewing existing NAA Network bilateral agreements and working toward updating them where necessary to ensure the six principles of this Roadmap are realized. This approach to build upon current existing bilateral agreements reflects the commitment to harmonization and sets the stage for the continued prioritization of safety and innovation in AAM and other emerging technologies.
The NAA Network will continue to work constructively to understand and converge on differences in the current airworthiness requirements of AAM aircraft type certification. While the timelines are not certain given the early phase of AAM aircraft certification and operations, the Roadmap is aware of certain time constraints and the shared urgency of moving forward (i.e., updating regulations, bilaterals, etc.). The NAA Network plans to begin implementing this incremental approach by July 2025.
AAM is evolving rapidly, driven by technological advancements, environmental considerations, and the need for enhanced safety and security. The NAA Network’s Roadmap underscores the importance of a robust regulatory framework that adapts to these changes while safeguarding the interests of all stakeholders. As the aviation industry continues to evolve, staying informed on these developments is essential for industry professionals and enthusiasts alike. Please reach out to the Morgan Lewis team with any questions about the Roadmap or its potential impact on your business.
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