Cert + Policy Team
Merlin is on a mission to enhance the safety and efficiency of flight operations through increased automation. However, developing, certifying, and commercializing aviation systems is a difficult endeavor, especially when those systems challenge traditional norms and push against the boundaries of existing regulations.
Aviation is a highly regulated and interconnected space where new technologies cannot be implemented in isolation. Instead, the industry only moves forward when the systems and processes exist to ensure new technologies are safe and do not compromise the integrity of the existing ecosystem. This process involves outreach and engagement with regulators, labor unions, aircraft operators, and many other critical stakeholders across government and the private sector. It also includes participation in industry committees and groups to identify crucial gaps and develop best practices for how to close them.
To help navigate this long and complex process, Merlin is focusing on three key policy areas as the basis for engagement with the industry as these are what we believe to be foundational to safely certifying and commercializing new forms of automation.
Regardless of automation level, all systems at some point interface with a human operator. Thus, to properly perform their functions, automated systems must be designed and implemented with human-machine teaming as a key consideration. For example, we’ve built our integrated hardware and software solution, the Merlin Pilot, to make Human Factor-driven decisions so that it can transcend unexpected, environmental, or experience-based impacts.
Merlin believes that human factors considerations are central to the design and integration of autonomous systems on aircraft, and that there is significant opportunity for the industry to work together on maturing human factors methods to better assess the performance of automated systems.
The underlying purpose of FAA regulation is safety assurance — the systematic processes that ensure the continued safety and airworthiness of aircraft, operations, and aviation systems. Updating the safety continuum to certify autonomous systems will require new metrics and methods that sufficiently assess – prove – these systems can operate safely and as intended. This also includes establishing measurable expectations for system performance and crew operations.
While artificial intelligence (AI) is not a new technology, recent developments in its maturity have spurred international policy discussions on how to regulate it to ensure optimal performance and mitigate risks. Regulating AI is challenging because there is a wide range of potential applications — both known and unknown — with varying levels of risk and impacts on human safety.
"Advance assurance" refers to a framework through which AI systems are evaluated and certified for their safety, reliability, and compliance with certain standards or regulations before they are deployed. It is very difficult to demonstrate that an autonomous system using AI is as safe as a human operator, and equally difficult to show that the system does not introduce safety critical errors. Merlin is participating in discussions on advance assurance to support the development of methods that ensure the safety of AI.
In conclusion, Merlin believes that automated systems will enable a new era in aviation. However, the safety and operational benefits these technologies provide will only be realized with a thoughtful and pragmatic approach that ensures a safe integration within the existing aviation ecosystem. By concentrating on human-machine teaming, an updated safety continuum, and methods for advanced assurance, Merlin seeks to make a meaningful contribution to the integration of autonomous systems into the aviation industry.
The future of aviation is autonomous, and Merlin is at the forefront of making this future a reality. Keep an eye out for future blog posts that will do a deep dive into each of these driving policy thrusts.