From my perspective, the process could have been better in respect to the knowledge that the FAA had of the functionality that was introduced with the MAX. I'm primarily speaking of MCAS, the manoeuvring characteristics augmentation system. The MCAS was a system that was introduced for a specific purpose. It was added on in another flight mode to meet a similar purpose, but in doing so, some of the protection mechanisms that were originally envisaged were not included, and that was either not known or not communicated by the FAA. There seemed to have been a communication breakdown between Boeing and the FAA in that regard.
When we came along to do the validation, we investigated as part of our inquiry the existence of MCAS, but the full functionality of MCAS was not disclosed to us. Therefore, clearly there was an information breakdown in the process between Boeing and the FAA, which we ended up getting caught up in when we came to do our validation. That's the main concern.
There are other areas as well, which we'll be covering, moving forward, in respect to going back and looking at some of the certification policies, practices and processes that we feel were not followed appropriately, one of the most prominent ones being the application of what we call the “changed product rule”, which determines the nature in which a modified product is certified. There were definitely some pitfalls in there that we have to learn from, and we are going to be working with the FAA, which just introduced terms of reference to study that policy with the aim to tighten up some of the policy loopholes, you could call them, that were taken advantage of to allow, say, a less than full investigation of the changes to the product.