The FAA’s Last Word On Extended Range Safety Issues
The FAA published on Jan. 8 the final rule on Extended Operations of Multi-Engined Turbine Powered Airplanes (ETOPS), effective Feb. 15.
The rule was developed from the Nov. 14, 2003 NPRM and applies to air-carrier, commuter and on-demand operators but almost completely excuses compliance by all-cargo carriers with more than two engines. Here’s an analysis of the rule and what it means for the industry.
The frequency of long-range flights has grown fourfold since 1984. Last year, airlines scheduled nearly 16,000 flights a week that exceeded 3,000 miles. The 777-200LR has a range of 10,800 miles and Airbus’ A340-500 can fly up to 10,300 miles. Legacy carriers are increasingly leaving regional routes to low-cost carriers and are now “in it for the long-haul”. Flights over both poles are expected to grow from 1,600 a day to 3,200 a day by 2010.
The new rule is intended to boost dispatch reliability for carriers when alternate airports along a route are unavailable for landing due to inclement weather conditions, FAA air carrier operations branch manager Robert Reich said. A typical ETOPS approval for carriers flying twin-engine aircraft today is 180min, though United Air Lines has one approval for 207min. With the limit opened up, carriers will boost the chances of being able to fly the most efficient routes as the number of alternative airports will be greater.
“The rule has mechanisms for twins to go any length and any duration from an alternate airport, subject to the capabilities of the aircraft,” said Reich. The rule brings two-, three- and four-engine aircraft under a common regulation for non-stop operations involving limited diversion airports. According to Reich, the new rule is “intended to eliminate propulsion system reliability as a consideration from the maximum diversion time capability of the airplane. Only the most time-limiting airplane system capability [fire suppression, oxygen, etc.] will determine the maximum diversion time capability for a two-engine airplane under the new requirements.”
Reich pointed out that the FAA also extended most requirements previously applicable only to two-engine airplanes to a limited number of part 121 passenger-carrying three- and four-engine airplane operations. However, he added, “the rule excludes the ETOPS maintenance requirements from the operation of airplanes with more than two engines. FAA has sensibly accepted the argument that current engine reliabilities and the level of engine redundancy on such airplanes is sufficient to safeguard such operations.”
The bruited terms of LROPS and EROPS have now been dismissed in favor of retaining the familiar ETOPS sobriquet, despite its now enlarged meaning. The cost of compliance with the new 297-page rule is estimated at $12.4 million, in today’s dollars, for U.S. airlines over a 16-year period.
As wide-ranging rules go, this is a pittance. However, the longer term influence on airplane and system design will be considerable. The big offset will continue to be the fuel and time saved by twin-engine operators of course, via their more direct routings.
The rule codifies and expands existing FAA policy and route authorizations for all part 121 two-engine airplanes conducting ETOPS beyond certain distances from a suitable airport. It adopts most measures evolved over the past 21 years of ETOPS operations but expands the scope and applicability. The requirements applicable to part 121 passenger- carrying three- and four-engine airplanes will also extend to comparable part 135 operations, but only “twins” need bear the costly compliance with ETOPS strict maintenance requirements.
For existing ETOPS operators, nothing much will change in the short term. In eight year’s time, new fuel and oil system design rules will come into play but, in most cases, only for new designs. Existing ETOPS aircraft will mostly be grandfathered to permit unfettered continuity of today’s style of operations and to reduce the economic impact of compliance.
In its preamble, the rule describes the development of the existing ETOPS strictures via a number of advisory circulars. These saw the increasingly liberalized operating times from suitable airports at single-engine speed in still air go progressively from 75 mins (1977), 120 mins and 138 mins (1985) to 180 mins (1988).
The latter developments were based on a two-fold approval process: a type design approval of the airplane-engine combination and an operational approval consisting of ETOPS maintenance, flight dispatch regimens, and specialist crew training. The preoccupation was then almost solely with engine reliability.
Ultimately, in March of 2000, the industry agitated for (and the FAA issued) “207-minute ETOPS Approval Criteria”. That document provided a 15 percent increase in the 180- minute maximum diversion time. However, this approval was limited to ETOPS operators flying in the North Pacific and only applied when weather or airport conditions did not permit normal 180-minute ETOPS flights.
Since then, at least one maintained ETOPS diversion field has been able to be bypassed (the 7900ft runway on Midway Island). The runway at Henderson Field is still there and active and the island’s vital role had been subsidized in the past by Boeing. It was designated as an ETOPS emergency diversion airport in early 2004. However, it would appear that the facility may no longer be “suitable” under the new rules, because airport ops ceased on Nov. 22, 2004.
As well as being “abandoned”, the island is noted for its plentiful bird-life, so it wouldn’t appear to be the place to send a suddenly single-engined twin. Other intermediate oceanic refuges such as Adak and Wake Island have been closed down. Unavailability of a close-in emergency divert field can be a decisive factor in a Swissair 111 type emergency. Swissair 111 had nothing like 207 minutes to get down. Its “life” remaining, after smoke was first smelt, was about 15 minutes.
The Legacy Of The Leg-Times
It’s worth noting that the rules have always been somewhat elastic. The 15 percent stretch to 138 mins conveniently allowed ops to continue, even when North Atlantic diversion airports in Iceland and Greenland were closed by weather. There are two distinct routes across the North Atlantic, one using Iceland’s Keflavik airport as a key alternate, and another, more southerly route using Lajes in the Azores.
West of these islands, there’s a small, triangular area which is not within 120 minutes of any suitable airport. A 138 minute rule-time totally removed this last “no-go” area over the North Atlantic, so the U.K.’s CAA approved operation under this “enhanced” rule for several carriers. ETOPS of 180 mins is significantly more difficult to get approval for; with no reason for it over the Atlantic, many carriers didn’t want that added expense. The 207 min stretch was allowed only to the 777 when North Pacific diversion airports were closed.
For some elusive reason, stretching limits to suit the geography isn’t seen to be stretching credibility, once commercial considerations for continuity of all-weather ops are factored in. Proposals for ETOPS 240 and 330 (for the 777-300ER) have been put forward for Antarctic and South Pacific ops, but ETOPS 180/207 presently covers 95 percent of the earth’s surface.
The official line is that design standards and operational processes for ETOPS were designed to prevent circumstances that could cause an engine in-flight shutdown or otherwise cause a diversion — and to protect the safety of a diversion if one does occur. How exactly is that done?
First, airplane-engine type design approval establishes unique criteria — for example, triple redundancy of engine driven generators and an APU that can be started reliably after many hours of cold-soak at height. Comms, nav, anti-icing and pressurization come into it but the really limiting factor is the time for which cargo-hold fire suppression is able to operate.
For 180 min ETOPS, a 195 minute suppression capability is required. Systems reliability is also critical. Over 250,000 hrs of in-service use, IFSD’s (inflight engine shutdowns) must be held down to below .02/1000hrs for a 180min ETOPS ticket. This target must then be monitored for any divergences in the world-wide fleet. An overall average figure of .01 is currently being achieved (i.e., half the targeted max rate).
FAA’s view is that a desire to have a common pool of non-ETOPS and ETOPS engines will eventually drag all engines up to a higher reliability standard. A CMP (Configuration, Maintenance and Procedures) document will maintain the service history of, and report upon, an operator’s ability to maintain its ETOPS Fleet at the enhanced reliability standard required. It will also include a pre-departure service check.
There will be engine health and oil consumption and contaminant analysis monitoring programs. Dual engine maintenance gets a mention. It means denying the possibility of, for example, leaving access plugs out of each engine through having bore-scoped both engines simultaneously. For ETOPS beyond 180mins, the additional requirements in equipment go exponential (autothrottle, single-engine autoland, fuel crossfeed integrity monitoring, SATCOM etc).
Second, operator endorsements are based on exhibited abilities to successfully operate at lesser levels of approval. For instance, a 180min ETOPS certification will require 12 months of 120min ETOPS with the same airframe/engine. A 207min ticket will require a current approval at 180mins. An ETOPS operator’s MMEL (Master Min Equipt List) will be of course different to a non-ETOPS MEL for the same type airplane. Required redundancy means that there will be little scope for deferring discrepancies. Dispatchers will need systems and comms to flight-follow and simultaneously watch the weather at enroute diversions. Flight-crews will need an education in critical decision-making and specialist simulator training.
Finally, an operator will need to conduct proving and validation flights. There are particular further considerations for trans-Polar and trans-Siberian routings, not the least of which is fuel-freezing, passenger pickup from remote alternates and carriage of automated defibrillators. Such concerns aren’t just limited to twin-engined airplanes. Sounds like calculated risk? Well it is.
Fire, Smoke And Ashes
FAA dismissed the extensive concerned comments on the subject of fire and smoke detection by blandly declaring that “these issues are beyond the scope of this proposal…Since the issues raised by these commenters introduce new safety requirements, the FAA may consider them for future rulemaking, but will not discuss them further here.”
The illogicality of this blatant “denial” approach to a very real problem seems to defy any coherent explanation. The only parallel would be a similar decision to “not carry life-rafts or life-vests on the basis that large underwing-podded jets have very malignant ditching characteristics and so their carriage would be a waste of time and money.”
Whose rule is it? It applies to:
a. Twin-engine airplanes under part 121 operating at >60mins from an adequate airport
b. Trijets and quads carrying pax under part 121 when operating ETOPS180
c. Transport Category Twins (i.e. freighters), and pax-carrying trijets and quads operating under part 135 when operating ETOPS180
….but portions of the rule also apply to all genders of jets operating in Polar areas (even though not under ETOPS rules).
FAA has liberalized grandfathering and the compliance times for those few operators required to modify airplanes and provide training and pax recovery plans. In some instances (e.g., cargo fire suppression) the timing allowed is up to six years for part 121 (and 8 years for part 135). IFSD rates are to be rolled over from one month to the next, so that only the prior 12 months are ever in play. Exceeding the target rate will not cause a cessation of ETOPS for an operator, just precipitate an FAA investigation. Reductions to idle will not count as an IFSD event, even though thrust is unavailable.
Bearing in mind the financial paroxysms of the industry and high fuel prices, terrorist threats and security related costs impinging on all during the development of this rule, the FAA has exercised a great degree of industry empathy, while still applying the ruler to the rule. The industry should not be unhappy, as it knew that it was coming and that logic would dictate stricter operating guidelines and design guidance.
It will tidy up a disarray of Advisory Circulars and Policy Letters and give designers parameters within which they can fine-tune. Boeing’s 787 team has expressed its delight at the timing of the rule’s release. They can now incorporate rather than just add. Only the grumps among us will point at the FAA’s inability to grapple with the threat of inflight fire and smoke.
To conclude on that aspect, we will now point at a recent 737 Special Airworthiness Information Bulletin that amply illustrates the validity of the concern. You can turn it up at this link ( tinyurl.com/yzjf8n ).
If you know why it’s an SAIB and not an AD, please let us in on the secret. Perhaps the FAA view is that the best way to suppress fire is not to stoke it with a directive, but to disguise it.