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Foliage White PaperTransitioning to RTCA DO-178C/DO-278A:A Business Manager BriefHoyt Lougee, Engineering Director - Foliage, Inc.ABSTRACTWith the release of the new development guidance for certifiable aviation software, RTCADO-178C/DO-278A, executives and business managers for manufacturers of both airborne and groundbased systems are examining the short- and long-term impacts on their certifiable-productdevelopment approaches with respect to cost, schedule, and risk. Although the changes withinDO-178C/DO-278A proper are relatively few, manufacturers can expect critical wide-ranging businessimpacts on their current certifiable aviation software development. More significant are the fourdetailed supplements intended to address 20 years of technology and process progress since the lastmajor revisions of development guidelines.The new guidance represents a significant change in the FAA’s posture towards regulated softwaredevelopment with DO-178C/DO-278A tightening some previously established controls, while alsoestablishing concrete guidance for greater flexibility in development approaches. This flexibility,however, must be carefully examined, weighing potential business costs and benefits, to establish themost efficient certifiable product-development approach. This white paper discusses these shifts fromthe business perspective, providing business management visibility into the emerging challenges andopportunities associated with the updated guidance.INTRODUCTIONThe FAA released DO-178B, Software Considerations in Airborne Systems and Equipment Certification,20 years ago to provide guidance on the development of FAA certifiable airborne software 1. Sincethen, the software development world has matured significantly, with advances in technologies andprocesses providing new opportunities for manufacturers to streamline development and tackle1Note that DO-278, Guidelines for Communications, Navigation, Surveillance, and Air Traffic Management (CNS/ATM)Systems Software Integrity Assurance, was released 10 years later, tightly tied to the content of DO-178.Page 1 of 10 2012 Foliage, Inc.

Foliage White Paperincreasingly complex systems. For example, today, state-of-the-art software development ofteninvolves the use of advanced model-driven development with the corresponding benefit of automatedcode generation. Prior to the release of DO-178C, the FAA often scrutinized closely the certification ofa product developed in this manner, requiring additional meetings, white papers, and presentations,which added—from the business planning perspective—significant risk. Indeed, more often than not,the introduction of model-driven development resulted in confusion, stalled product completion, anddelayed time to market.Much of this progress, therefore, has been problematic in the certifiable-software developmentdomain. The general guidance provided by DO-178B/DO-278 often served only to muddle mattersfurther—with disagreements on the acceptability and treatment of emerging technologies andprocesses among the various aircraft component manufacturers, individuals within the FAA AircraftCertification Offices (ACOs), and their Designated Engineering Representatives (DERs).The result: industry has been hobbled in its ability to effectively plan and execute certifiable-softwaredevelopment, and has not kept pace with the state of the art in software engineering at large. In fact,the only dependable attribute of certifiable-software development seems to be the consistency ofmissed schedules and burst budgets, at times attributed to the shifting interpretations and datedguidance. The benefits of new tools, techniques, and processes—as leveraged successfully in noncertifiable-software development—have been at best elusive, at worse unavailable, as the certifiabilityoverhead has taken its toll.In 2001, to address common industry and certification-authority questions, RTCA released DO-248B,Final Report for Clarification of 178B “Software Considerations in Airborne Systems and EquipmentCertification.” This report addressed DO-178B errata, as well as provided more detail on specific issuesin the form of FAQs. Still, interpretation remained problematic and continued to hinder the ability ofmanufacturers to plan with confidence the cost and schedule impact of the certification efforts. Tofully address industry’s concerns and emerging technology, the FAA, in partnership with the aviationindustry, set out to update the guidance in 2004. In December of 2011, updated guidance wasreleased: RTCA DO-178C, Software Considerations in Airborne Systems and Equipment CertificationRTCA DO-278A, Guidelines for Communications, Navigation, Surveillance, and Air TrafficManagement (CNS/ATM) Systems Software Integrity AssurancePage 2 of 10 2012 Foliage, Inc.

Foliage White PaperIn addition, supplements were released to provide a detailed treatment of four critical areas:1. RTCA DO-330Software Tool Qualification Considerations2. RTCA DO-331Model-Based Development and Verification Supplement to DO-178C and DO-278A3. RTCA DO-332Object-Oriented Technology and Related Techniques Supplement to DO-178C and DO-2784. RTCA DO-333Formal Methods Supplement to DO-178C and DO-278This guidance offers a more effective roadmap for certifiable-software development, lowering risksand providing a dependable basis for cost/schedule projection. The initial path forward, however, willnot be easy. The guidance must be carefully studied, and, for the specifics of each certifiable productmanufacturer, its impacts assessed and detailed plans developed. The certification authorities shouldthen approve these plans prior to the start of the development effort. Only then can manufacturers beconfident that the new guidance will work for them, enabling advances in technology and process toyield cost, schedule, and risk-mitigation benefits; while preventing costly misinterpretations and11th-hour roadblocks.WHAT HAS CHANGED?In the big picture, two types of changes have occurred:1. Clarification of original guidance2. Detailed guidance related to major shifts in technology/processBoth areas will have significant impact on the way certifiable-software development is managed.CLARIFICATIONSIronically, a major clarification within DO-178C/DO-278A doesn’t concern the software developmentprocess directly. Instead, the clarification relates to the certifiable-software development interactionwith the higher-level system processes, as detailed in the newly revised ARP4754, Guidelines forDevelopment of Civil Aircraft and Systems. The potential impact of these clarifications must not beunderestimated. The certification authorities are looking to tighten up this interaction with formal,iterative, closed-loop data flow among the system, hardware, and software processes. Across theaviation industry, addressing the information flow between systems and software, especially withrespect to interfaces, requirements allocation, and safety-related requirements has varied. ThePage 3 of 10 2012 Foliage, Inc.

Foliage White Paperinformation flow has ranged from a cursory, after-the-fact treatment to a very formal, detailed multistage analysis—including elaborate System Safety Analysis, Functional Hazard Analysis, FunctionalFailure Path Analysis, and Failure Modes and Effects Analysis. A manufacturer’s understanding ofwhere its organization stands in this continuum, relative to the new guidance, will be critical inplanning and risk management of its next certifiable-software development efforts. Very feworganizations will emerge without having to modify their processes at all.The updated guidance also provides direction on the oversight of suppliers, establishing formalexpectations for auditable supplier compliance and oversight. Interestingly, the traditional and logicalinterpretation of DO-178B already allowed for certification-authority oversight into a supplier’sapplicable certifiable-software development processes, so alignment to the revised DO-178C supplieroversight processes should not be significant. Opening up the manufacturer-supplier relationship todetailed oversight planning with certification authority audits will, however, introduce the need fordocumented coordination and may drive additional geographically distributed supplier audits—first bythe manufacturer and then by the certification authorities (and/or their designees).Another significant change in the existing guidance is the introduction of a Parameter Data Item File, adata set that can influence the behavior of the software without modifying the executable object code.Formal guidance is now provided in the development, control, and verification of this data, which may,or may not, align well with a manufacturer’s current practices—and may have a significant impact onthe planning, development, verification, and configuration management of the certifiable product.The expectations for traceability have been clarified also. Traceability is the backbone of a certifiablesoftware development process, and, if performed or reworked after the fact, can be incrediblyexpensive and error prone. Although most organizations will have little impact from the refinement ofthe traceability guidance, a careful up-front review of the expectations will be necessary to confirmalignment.To summarize, there is little doubt that the revisions to DO-178B/DO-278 will impact an organization’scertifiable development efforts—the only question is how (and how much). A careful and thoughtfulgap analysis must be a priority, sooner rather than later, to understand and accommodate theimpact—providing a solid basis on which to plan the next certifiable-software development effort.SUPPLEMENTSAs discussed earlier, the revision to the guidance is not limited to clarification; also included are fournew, complex addendums to address the state of the art and practice in software development.1. RTCA DO-330, Software Tool Qualification ConsiderationsAdvances in technologies are typically associated with promises of significant efficiency gains, driven byever more prolific and complex tools. Tool guidance has migrated from DO-178B/DO-278 to a separatePage 4 of 10 2012 Foliage, Inc.

Foliage White Paperdetailed addendum, which describes a significantly more complex treatment of tools—driving thetreatment of tools to more closely align with the treatment of certifiable software.For example, DO-178B/DO-278 addressed the acceptability and qualification of tools within thecertifiable-software development environment with a simple partition into Development tools andVerification tools. Development tools were to be developed with the same rigor as the certifiablesoftware, whereas Verification tools only required basic testing against documented requirements. Incontrast, DO-330 identifies five Tool Qualification Levels (TQLs) based on the tool use and its potentialimpact to the software life cycle process, with the level of tool qualification rigor varying according tothe TQL.Overall, manufacturers can expect the tool qualification burden to be higher, with additionalexpectations/formality across the “development” tool spectrum, and a slight additional bump oncertain “verification” tools.Establishing a process for certifiable-software development and selecting the associated tools can be adaunting task, with large costs and risks associated with both short- and long-term impacts. Therefore,with respect to the cost/benefit tradeoffs of the adoption of tools and tool suites to be used, eachmanufacturer should always first consider the impacts of the revised tool-qualification guidance withrespect to both the long-term (multiple product development efforts), before addressing their shortterm immediate project needs.The associated tool selections/qualifications made will need to be detailed and justified in the planningdocumentation for each instantiation of a certifiable-software development effort. That said, the newguidance does address the reuse of previously qualified tools, with formalization of a common-senseadoption of existing qualification data for demonstrably similar applications (and TQLs). With thisformalization and an understanding of the rigor required—tool strategies can and should be developedwith more confidence.As with the clarification impact discussed above, all certifiable-software development organizationswill be affected by the new tool qualification guidance, with the size of the impact and the ease ofadoption critically dependent on timely planning.Page 5 of 10 2012 Foliage, Inc.

Foliage White Paper2. RTCA DO-331, Model-Based Development and Verification Supplement to DO-178Cand DO-278ADO-178C/DO-278A defines a model as an abstract representation of a set of software aspects of asystem that is used to support the software development or software verification processes.Ultimately, this generally translates into the use of specific methods and tools in describingrequirements, auto-generating code and tests, and analyzing/simulating requirements, architecture,and/or executable code.Certifiable-software development is inherently expensive, especially at higher-criticality levels. Thoughcomprised of best (albeit conservative) development practices, in general, putting together a formalauditable configuration can be an overwhelming task. As a result, many tools are available to reducethe development/verification burden through automation and analysis—some specific to certifiablesoftware development; some not.In the certifiable software arena, industry has pushed hard for the acceptance of model-baseddevelopment and a clear path to certifiability. With the promise of faster, more reliable development,many tool suppliers are fielding tools for a wide variety of purposes—each facing the formidablechallenge of certification-authority acceptability. These tools typically are quite expensive, especiallywhen considering the costly tool-qualification packages necessary for adoption into certifiablesoftware development.Prior to the release of DO-178C, however, the guidance has been murky with respect to the modelbased development qualification/certification hurdles that must be addressed. The introduction of DO331, however, is a mixed blessing to the model-based development proponents. The new guidanceclearly establishes the model-based development expectations, but these expectations include somevery specific constraints, which enabled the retention of the original DO-178B/DO-278 breakdownbetween high-level requirements (the Specification Model), and low-level requirements andarchitecture (the Design Model).One of the historic complaints of the certifiable-software development process was the complexity ofthe guidance, with its many nuances and a seemingly endless learning curve. The certificationauthorities, however, have been unmoved: only those capable of understanding the complex guidanceestablished to provide flight-worthy confidence are allowed to play in the certifiable-softwaredevelopment game. The guidance associated with DO-331 is no exception. The guidance is complex,the concepts are not straightforward, and early adopters will face an uphill battle as theinterpretations are wrung out.Therefore, although model-based development can provide benefit, a full understanding of theguidance and expected impacts of initial adoption on a certifiable-software development program willPage 6 of 10 2012 Foliage, Inc.

Foliage White Paperbe necessary to truly understand the costs and benefits of migrating to model-based development.Note that the processes described, however, were not developed out of whole cloth. Many companieshave already incorporated model-based development under the DO-178B/DO-278 guidance. Althoughthese companies may have to modify their approaches to suit the new guidance; they have, in fact, laida solid groundwork for model-based development. Even though adoption of model-baseddevelopment is associated with challenges, it will quickly become a basic cost of playing in thecertifiable product development arena—as manufacturers leverage the efficiency and associatedcompetitive advantage that model-based development will bring.In summary, model-based development can and will provide benefit to the certifiable productdevelopment community—with graphical building blocks and auto-code generation able to reduce theoverall complexity of the software development. The costs and benefits, however, must be carefullyanalyzed and weighed. Business management must temper its expectations of an immediate return forthe adoption of model-based development. Longer-term investment (in tools, processes, and training)will be required to fully benefit from the new technology and processes—and will be necessary tomaintain competitive product costs and time-to-market.3. RTCA DO-332, Object-Oriented Technology and Related Techniques Supplement to DO-178Cand DO-278AObject-oriented technology (OOT) is not new, with early representation stretching back to the 1960sand 1970s. Neither the release of DO-178B in 1992 nor the release of DO-278 in 2002 addressed theunique considerations and challenges represented by OOT and languages. Instead, the guidelines wereloosely based on the more traditional and, at the time, more widely-used structured-designmethodologies. In the 20 years after the release of DO-178B, OOT has overtaken structured design,from academic treatment and training to application in the development of complex and life-criticalsafety systems. In fact, OOT reigns supreme in nearly all domains, except, however, in certifiableairborne applications.In late October 2004, after a handful of manufacturers fielded object-oriented airborne applicationsusing the ill-fitting existing guidance, the FAA2 co-sponsored the Object-Oriented Technology inAviation (OOTiA) project with the National Aeronautics and Space Administration (NASA) to addressthe challenges and constraints associated with the incorporation of OOT in a development processintended to meet the extreme rigors of FAA certifiable-software development. The resulting four2Handbook for Object-Oriented Technology in Aviation (OOTiA, Volume 1 Handbook Overview, Revision 0, October 26,2004; Section 1.1.2 BackgroundPage 7 of 10 2012 Foliage, Inc.

Foliage White Papervolumes set the stage for the adoption of OOT, including ramifications on DO-178B/DO-278, bestpractices, and explicit guidance for certification authorities and their designees.After seven years, however, the prevalence of object-oriented technology in aviation still doesn’treflect the overall adoption in industry as a whole. With the promises of greater efficiency, theproliferation of object-oriented toolsets, and the growing population of engineers whose primaryacademic training was in OOT, the question of why object-oriented technology hasn’t taken hold is,indeed, enigmatic.The answer lies in the difficulties inherent in meeting the extreme expectations for developing andverifying deterministic, verifiable software that forms the backbone of FAA guidance. Being able toaddress the challenges related to object-oriented complexities; such as hierarchical encapsulation,polymorphism, dynamic memory management, and virtualization; did not seem to be worth the effortin an already risk-rich certifiable-product development context.The new guidance, DO-332, supersedes the OOTiA, and provides a more concise treatment of theapplication of object-oriented technology into aviation software; however, the fundamental issuesremain, with the constraints and additional hoops necessary to incorporate OOT still present. What ischanging is the context. More and more manufacturers are biting the bullet and shifting to objectoriented technologies, establishing a clearer path to certifiability. Possibly even more significant,academia is increasingly deemphasizing structured methodologies, with structured design given only abrief nod as an introduction to the industry-favored object-oriented methodologies. Hiring andretaining engineering staff who will be satisfied working on the older technology will becomeincreasingly challenging.The question remains: should you make the jump to object-oriented technologies? Many factors willcontribute to the calculus necessary to make the ultimate decision, including the cost of migrationfrom your existing, instantiated platforms—not forgetting the associated retooling and retrainingcosts. The maturity of your staff will be a significant variable, aligning growth and maintenanceconsiderations as engineers retire or leave, and must be replaced in a cost-effective manner. Cash flowand schedule constraints must also enter into the equation, with short-term migration impactsweighted against long-term stability and gain. Furthermore, a complete understanding of theguidance, its ramifications, and possible solutions will be critical in understanding the overall tradeoff:the true cost versus benefit of adopting OOT for your certifiable product development.For many, the migration to OOT is inevitable, a necessary step to keep pace with the competition andmaintain a solid foundation for future staffing. For the business manager, the timing of the migration—based on a clear view of the costs and benefits—will be the critical decision.Page 8 of 10 2012 Foliage, Inc.

Foliage White Paper4. RTCA DO-333, Formal Methods Supplement to DO-178C and DO-278ADO-333 defines formal methods as mathematically based techniques for the specification,development, and verification of computer systems. In other words, formal methods define adefensible formal process to model, describe, or verify some aspect of certifiable software.DO-333 suggests that formal methods can provide value to the certifiable-software community inmany areas. Formal methods can allow precise and systematic communication among engineers—aswell as providing verification confidence in freedom from exceptions and deadlocks, bounds on stacksize during execution, and so forth.Formal methods are described as two types of activities: modeling and analysis, with the modelrepresenting a given set of software aspects, which can then be used for analysis, simulation and/orcode generation. Although the establishment of a formal model has intrinsic value in providing asystematic treatment of some aspect of software development, e.g., requirements development, theanalysis of a formal model can provide significant value to the certifiable-software developmentprocess.Formal methods were briefly introduced in DO-178B, but, in general, haven’t been consideredsufficiently mature to provide widespread benefit. In the 20 years since the introduction of DO-178B,tools and techniques have advanced sufficiently to establish formal methods as a readily available toolin an aviation software development toolkit. Note that, with respect to analysis, the new guidancereally represents a formal notification of the tightening of the certifiability guidance. For example,worse-case stack analysis has always been a necessary consideration of a certifiable-softwaredevelopment; but greater leeway in its justification, planning, and documentation has been enjoyed bythe certifiable software engineering community. With the release of DO-178C, the FAA will demandmore of the certifiable software developers with respect to formal and detailed treatment of theanalyses presented as part of the certifiable-software verification efforts.Therefore, the new guidance on formal methods must be approached with caution. Acceptableanalytical verification performed in the past may no longer meet FAA muster. Formal methods—consisting of formal logic, discrete mathematics, and computer readable language—may be required.Simple documentation of experienced engineering judgment may no longer be considered sufficient.In summary, the new guidance on formal methods will impact your established, business-as-usualcertification practices, as well as establish formal expectations for migrating to new, advanced modelbased techniques and tools. Understanding the associated impacts with both gap analyses and detailedprojections will be necessary to both shore up existing practices and support an effective migration tomore competitive model-based certifiable software processes.Page 9 of 10 2012 Foliage, Inc.

Foliage White PaperCONCLUSIONWithout question, the new guidance adopted by the FAA will impact established certifiable-softwaredevelopment processes. Manufacturers will need to modify their existing practices to accommodatethe revised guidance. Although the benefits from the adoption of new technologies and tools will besignificant; expectations, especially in the short term, must be tempered by a clear vision of thechallenges associated with migration and early adoption. Manufacturers must carefully consider bothshort- and long-term costs and benefits. A comprehensive and detailed gap analysis—together with awell-considered certifiable-development process roadmap—will be necessary for a certifiable productmanufacturer to prepare for an effective treatment of the revised guidance. Avoiding costly rework,while effectively leveraging new technologies, is the key to remaining competitive. The time to plan isnow; the costs of delay can be dramatic.ABOUT FOLIAGEFoliage, Inc., a product development company, partners with companies to address the business andtechnical challenges inherent in developing complex software-intensive systems. Providing a fullcomplement of engineering and consulting services aligned to business needs and applied over theentire product lifecycle, Foliage enables companies to accelerate development and drive morepredictability and productivity into their businesses.Foliage leverages over 20 years of experience partnering with leading companies in the Medical andLife Sciences, Aerospace and Defense, and Industrial Equipment industries. Working with Foliage, ourclients gain the critical insights necessary to develop products with a difference, and to deliver theproducts their customers want, when they want them.Foliage is based in Burlington, Massachusetts with additional offices in California, the Netherlands andIndia. For more information, visit foliage.com.168 Middlesex Turnpike, Burlington, MA 01803 781.993.5500Page 10 of 10 2012 Foliage, Inc.

ASTRA T With the release of the new development guidance for certifiable aviation software, RTCA DO-178C/DO-278A, executives and business managers for manufacturers of both airborne and ground-based systems are examining the short- and long-term impacts on their certifiable-product development approaches w