The bean counters will always be there. Alternatively, one can think of the 737 MAX (and prior new 737 models) as an example of regulation imposing perverse incentives. ( https://en.wikipedia.org/wiki/Type_certificate )
Interesting point, but what would be the alternative? Are you really suggesting that pilots should be able to switch from e.g. the 737 to the A320 without any kind of additional training?
The alternative is that manufacturers shouldn't be allowed to impose new underlying systems to manage undesirable flight handling characteristics without briefing pilots about them and without breaking type certification.
the default should be that if the flight handling characteristics of the airframe itself inherently are not the same then it doesn't get type certification, and you should have to prove why your tweaks make it OK.
Type certificates are not about pilots; they're about airframes. Maybe skim the link?
> A type certificate signifies the airworthiness of a particular category of aircraft, according to its manufacturing design (‘type’). It confirms that the aircraft is manufactured according to an approved design, and that the design ensures compliance with airworthiness requirements.
And to be clear, since it seems my comment was also not totally clear: I'm not saying aircraft regulation / Type Certification is bad in general. Just that this particular implementation currently has unintended perverse incentives which lead to the 737 MAX.
A pilot is qualified ("type rated") to fly planes of a given type certificate, so it's not helpful to say that type certificates are not about pilots. Having that belief causes you to miss out on fully understanding the situation.
I wouldn't call this a perverse or unexpected incentive either. It's very straightforward: there is regulation saying you can't keep the same type certificate if the plane flies differently enough to demand pilot retraining. The regulation is good and the consequences of following the regulation correctly are good, unlike in actual perverse incentive situations.
Boeing didn't want to comply with the regulation so they lied about how the plane worked and then hundreds of people died.
That's not an example of a perverse incentive of regulation: it's an example of dishonestly evading regulation, hopefully criminally so.
> A pilot is qualified ("type rated") to fly planes of a given type certificate, so it's not helpful to say that type certificates are not about pilots.
Eh. The relationship here is between the manufacturer and the FAA. That the regulation is tangentially related to pilots is moot to the point.
> It's very straightforward: there is regulation saying you can't keep the same type certificate if the plane flies differently enough to demand pilot retraining. The regulation is good
I agree!
> and the consequences of following the regulation correctly are good
Mostly true!
> Boeing didn't want to comply with the regulation
This was (arguably) an outcome, but I don't believe it was the goal. I.e., Boeing would love to comply with this regulation in the magical hypothetical where it cost them nothing to do so. They're not comical villains.
The problem with this simplistic summary you've provided is that qualifying a new type certificate is extremely costly.
Convincing the FAA your new aircraft is actually just a modified version of an existing type certificate (whether or not that is true) is much less costly (and given how much of the 1960s airframe is still being used in the MAX to keep that type certificate, it's even plausibly reasonable to consider it like earlier extensions to the cert).
So, long story short, there is a direct financial motivation for Boeing to skirt the rules and pretend new products are just another modified 737. That is exactly the perverse incentive I am highlighting.
> That's not an example of a perverse incentive of regulation: it's an example of dishonestly evading regulation, hopefully criminally so.
I think you mostly missed the point. Regulations with mostly good consequences can still create perverse incentives in some areas and positive incentives in others.
The problem with this simplistic summary you've provided is that qualifying a new type certificate is extremely costly.
Yes but you're missing that there are two sets of costs: the recertification cost for Boeing, and the retraining costs for their customers, the airlines. Boeing didn't want to pay and it didn't want to tell its customers that there was this additional cost and risk losing some sales.
Cool, I agree with most of that. It just sounds like I think Boeing has behaved closer to comical villains than you do! I don't think some jail time for executives would be an overreaction.
I don't see how you parse that out of my comment without some extremely uncharitable interpretation. I haven't suggested any particular change, nor that any particular change be carried out "casually," without due consideration.
Erm, it's pretty obvious something was wrong at the FAA, in that it seems fairly clear they let Boeing dictate terms to them on multiple occasions, and effectively overrule them.
The FAA's goal is to prevent aircraft related accidents. While you may not agree about the sharpness of their pencils or the color of their uniforms or some other tangential nonsense, flying is insanely safe in America because of them.
They're so good at their jobs, you should be asking what they know that you don't when they make decisions, not trying to correct them.
Historically, yes. There was a reason previously the CAA and EASA were historically happy accept the FAA's certification for new aircraft, on the assumption the FAA were very good at its job.
That no longer seems to be the case (given the fact that EASA now want to have their pilots fly the MAX before it returns to service), and there's well documented evidence (many news articles over the past few months talk about this) showing that over the past 10 years, the FAA's budget was drastically cut, forcing them to effectively outsource certification in part to Boeing to "self-certify".
The problem is that the 737-MAX behaves so differently from the base 737 that it shouldn’t be regulated as the same plane. Definitely a regulatory gap that can and should be addressed. Boeing built an unsafe plane and definitely exploited the issue, but the whole point of regulations is to stop a company like Boeing from shipping an unsafe plane.
