Electric Over Water – Safety Considerations for an All-Electric Floatplane for Commercial Passenger Service

Harbour Air is a Canadian-based aircraft operator that has built the world's first all-electric floatplane for commercial passenger operation. This aircraft is a modification of a DHC-2 de Havilland Beaver floatplane aircraft, in which the conventional fuel burning propulsion system is replaced with an all-electric propulsion system. Supplementary type certification of this aircraft modification involves showing the result of this conversion is no less safe than the unmodified aircraft. As for many instances of emergent technology across multiple industry sectors, it can be challenging to demonstrate compliance in an established regulatory environment based on requirements and guidance developed decades earlier with conventional technology in mind. Moreover, established requirements and guidance might not effectively and sufficiently address potential sources of safety risk associated with emergent technology. This paper offers an example of such challenges. In some cases, these challenges can be addressed by developing structured arguments showing how the underlying objective of the established regulatory requirements and guidance is achieved in different, but no less satisfactory way. In this paper, we offer an example of providing structured argument using Eliminative Argumentation to identify and validate potential hazards associated with various emergent technologies implemented within the electric floatplane.