We'll provide the entire list. The JATR report came out with 12 separate recommendations. Some of them somewhat overlap the others, so I'll attempt to briefly describe them at a high level.
The fist one relates to the application of what we call the changed product rule, which is a regulation that deals with how we determine the applicable standards to an aircraft that is changed or modified. Some people use the term “derivative model” when you have one existing model and you do a modification to create a new model. This will happen successively over a number of years. In the case of the 737, it has gone through numerous generations or reiterations of the design.
That recommendation speaks to the fact that we struggle internationally with a common interpretation or application of the rule. Despite the fact that the rule has been completely harmonized and from a regulatory perspective remains common between the various authorities, it is the actual application of the rule that is sometimes open to interpretation.
The basic gist of the issue is this. At what point, when you're adding successive changes or additions to an aircraft, do you go back and establish that you have to apply the newer standards and also the newer interpretations of the standards or processes we use that have been developed over time to evaluate the aircraft?
In the case of the 737, it's been alleged that the aircraft was derived or added to in numerous cases, and yet in some cases the standards remained the older standards that were applicable to the previous derivatives, and that possibly the scope of the review, in the context of evaluating the new changes, was not as wide as it should be. That is an area which we already had on the table prior to these accidents, actually; it's not a surprise to us at all that the changed product rule is an area that will require further honing and international harmonization.
The next one—and again, I'm boiling the 12 down to three themes, just for brevity here—is the delegation systems, of course. I'm sure you've heard discussions about that. One of the recommendations speaks to another look at or another examination of the various delegation systems that exist. Do the authorities have sufficient expertise and a sufficient degree of oversight into what these delegated entities are doing? Also, are there enough systems and protections in place to avoid any undue pressure on these delegates, who are employees of the company?
The third theme speaks to what we call development assurance practices. It links back to the changed product rule topic to some extent. As aircraft have evolved in complexity, modern aircraft today involve systems that are no longer separated. The term we use is “federated”. They have systems that are typically driven by software and are highly interactive. In other words, they speak to each other.
In the old days, we used to go in and analyze discrete failures that we could predetermine. In a modern, more complex aircraft, we have to take what's called a design assurance approach, which admits that we have to find a more systemic approach to evaluating the failures and the consequences a little differently than we did in the past, in order to keep up with the evolution in technology.
Part of the challenge with the changed product rule issues that we acknowledge is that, arguably, as you introduce new technologies into an older design, you should perhaps migrate to a more modern design assurance approach, where you look at not just the area that has changed but at how that changed area affects the entire aircraft as well. That's another area where design development assurance practices are well in place for a brand new or what we call “clean sheet” airplane, but they may not necessarily be applied with the same rigour when we're talking about a derivative of a pre-existing aircraft.
At a high level, those are the main hit points in the JATR report.