This work presents a method for representativeness assessment of AI/ML constituent ODDs in the context of aviation safety assurance and illustrates how statistical distribution comparison methods can support the assessment of representativeness for safety-critical AI applications.
Abstract
Artificial Intelligence (AI) offers significant potential for future aviation systems; however, its integration into safety-critical applications requires compliance with the aviation sector's stringent safety standards. For AI and Machine Learning (ML)-based systems, the European Union Aviation Safety Agency (EASA) emphasizes the need to demonstrate the representativeness and completeness of the Operational Design Domain (ODD) and the associated data distributions used during development and verification. Despite this requirement, a structured engineering process for defining target distributions and evaluating representativeness within ODDs remains largely unexplored. This work presents a method for representativeness assessment of AI/ML constituent ODDs in the context of aviation safety assurance. Starting from the methodical identification of suitable target distributions, a process flow is proposed that guides developers from ODD definition and parameter distribution modeling to the quantitative assessment and interpretation of coverage results with respect to EASA's learning assurance objectives. As quantitative measures, the chi-squared goodness-of-fit test is examined and found unsuitable for the large data sets arising in this setting, leading to the adoption of the Kullback--Leibler divergence and Cram\'er's $V$ for the representativeness assessment. The method is demonstrated using the example of AI-based airborne collision avoidance, employing experimental data from previous Horizontal Collision Avoidance System (HCAS) and Vertical Collision Avoidance System (VCAS) simulations. The results illustrate how statistical distribution comparison methods can support the assessment of representativeness for safety-critical AI applications and contribute toward a systematic Safety-by-Design AI engineering process aligned with emerging EASA guidance.
This work provides the first-ever open-source implementation of Safety Nets for HCAS and VCAS with replicable results, demonstrating a practical pathway toward certifiable AI-based systems in aviation and establishing Safety Nets as a viable Safety-by-Design solution for safety-critical applications.
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