An extra step is being taken by U.S. government officials to assure that everyone in the airline industry appreciates the scope of mandated aircraft wiring inspections to come. The locomotive is lumbering down the regulatory tracks, and an extra measure is being taken to ensure that there are no last-minute surprises.
Operators could be looking at costs in the range of $100,000 per aircraft for an initial one-time cleaning and inspection of high-priority electrical wiring.
A notice will be published by the Federal Aviation Administration (FAA) in the Federal Register sometime in September inviting comment from the industry on two draft advisory circulars developed by a government-industry task force for inspecting and maintaining aircraft wiring. The “invitation to comment” is not part of the formal notice of proposed rulemaking (NPRM) process, which will come later. Rather, interested parties will be directed to view the documents developed by the Aviation Transport Systems Rulemaking Advisory Committee (ATSRAC). The draft advisory circulars (ACs) developed by ATSRAC deal with the maintenance of aircraft wiring and the training of technicians in wiring maintenance. The draft ACs are posted on the ATSRAC website (http://www.mitrecaasd.org/atsrac/final_reports.html under Tasks #8 and Task #9).
The initiative was announced at a July 10 ATSRAC meeting, in which the follow-on regulatory actions also were outlined.
“The intent is for all concerned to see where the FAA is heading” regarding aircraft wiring inspection and maintenance, said Charles Huber, an FAA official who also serves as ATSRAC executive director. “We are trying to balance our safety mission with the concerns of industry.”
Fred Sobeck, a senior FAA official, said it is important to understand that the ACs are not being formally published by the agency. Rather, all concerned are being provided an opportunity to view material which may become part of an NPRM to be published later. “Provide us comments and we’ll take them into consideration” pursuant to the NPRM, Sobeck said.
This unusual initiative appears to result from three factors. First, at the last two ATSRAC meetings some industry attendees have criticized the ATSRAC for lack of outreach – even though all meetings have been announced in the Federal Register and have been open to any and all in the industry with an interest in its deliberations. Second, a March 12 letter jointly sent by the Aerospace Industries Association (AIA) and the General Aviation Manufacturers Association (GAMA) challenged the direction ATSRAC was taking – even though AIA and GAMA participated in ATSRAC’s ongoing deliberations. Third, the FAA is experiencing a schedule slip in its rulemaking process and now acknowledges that the formal NPRM will not be issued until 2005. By issuing a notice for comment in September, the FAA intends to communicate valuable information as early as possible for voluntary incorporaiton by industry prior to rulemaking.
The overall plan has changed significantly, providing manufacturers and operators with more time to develop and carry out wiring-related inspections. The plan under consideration in October 2002 featured a starting date of January 2004 to develop and implement an enhanced zonal analysis program (EZAP). That plan allowed operators three years to conduct a one-time cleaning and inspection of cockpit, electronics and equipment (E&E) bay wiring and all power feeder cables (see ASW, May 5, 2003). The inspections of these three high-priority areas were known by the acronym CEEPF.
The timeline not only has slipped, it has been dramatically simplified. It now addresses all aircraft with five or more years of service capable of carrying 30 passengers or more and payloads greater than 7,500 pounds. Previous plans had divided this group into five populations of increasing service age (<5 years service, 5-10 year service, etc.), with the oldest airplanes (>20 years service) slated for wiring inspections first, and the younger aircraft starting the inspections at six month intervals (see ASW, July 15, 2002). Now, all aircraft with more than five years service are on the same timeline, which is to say the same deadline for compliance.
The controversial requirement to analyze and inspect the wiring for all existing supplemental type certificates (STCs) has been dropped. This proposed activity portended an enormous burden on repair stations and others involved in post-production modifications to aircraft. However, the manufacturers will be required to consider STCs issued to their aircraft as they develop the EZAP inspection protocols to be implemented by operators.
Lumbering locomotive’s schedule
At this juncture, the following schedule of activity can be anticipated:
September 2003: FAA invites industry comment on draft ACs developed by ATSRAC.
January 2005: FAA publishes NPRM laying out EZAP and CEEPF timelines. The NPRM will include the ACs, as possibly modified based on responses gleaned from the September 2003 invitation for comments.
April 2005: Comment period for the January 2005 NPRM closes.
August 2006: Final rule issued (must be issued no later than 16 months after comment period closes). Effective date of the final rule could be the same as its date of publication.
- Two years from the effective date, manufacturers must develop EZAP protocols.
- After manufacturers have completed development of EZAP, operators will have one year to incorporate the new EZAP wiring inspections into their maintenance programs.
- Operators will have three years to complete EZAP. The EZAP process covers the entire aircraft. The EZAP process will be repetitive, incorporated at periodic intervals – most likely to accord with overhauls.
- Operators will have five years to complete the one-time cleaning and inspection of the high priority areas under the CEEPF mandate. The CEEPF will start upon effective date of the final rule. Thus, it is likely that much of the work under CEEPF will be completed before EZAP, but not necessarily. If the EZAP analysis calls for inspection sooner than one of the three categories under CEEPF, the earlier date rules.
Sobeck explained, “There’s a five year window for doing the one-time cleaning and inspection under CEEPF from the effective date of the final rule, but that’s really five years or EZAP, whichever is sooner.”
It should be noted that all of this activity is an outgrowth of the 1996 explosion of TWA Flight 800, which was attributed by the National Transportation Safety Board to a wiring fault. Hence, based on the latest schedule envisioned by FAA officials, the CEEPF inspections commence a decade after the TWA disaster.
One carrier’s experience
Some carriers already have undertaken the CEEPF cleanings and inspections. Nick Drivas, director of quality assurance at AirTran Airways [NYSE: AAI], said his airline undertook the CEEPF cleaning and inspection effort in 2001. At that time, the carrier was flying mostly high-time DC-9s, many of which have since been replaced by the new B717. Drivas described a “nose-to-tail” effort over six months. “We opened up all the troughs and looked at all the power feeder cables,” Drivas said by way of explaining the level of effort involved. With whisk brooms, vacuum cleaners and other materials, the wiring and wire bundles were cleaned of dirt, dust and debris. Where cables were sagging, their tension was adjusted. “We did 57 airplanes,” Drivas said. Average time out of service was four days. The average cost per airplane was about $100,000. Thus, AirTran spent nearly $6 million on the cockpit, E&E bay and power feeder cable inspections and maintenance.
The payoff has been a marked increase in dispatch reliability, Drivas said. It has increased from 96 percent to more than 99 percent. “We’ve changed the culture about the way we look at wiring,” Drivas said. “We are continuously analyzing our non-routine cards.”
The time and cost of the CEEPF effort at AirTran is an indicator of what other operators can expect when the FAA requires this one-time project. The larger EZAP effort will involve additional – yet to be determined – expenses.
Related issues
Some related issues are involved. For one thing, the EZAP effort must be harmonized with other regulatory bodies in Europe and Canada. The goal is to develop “equivalent compliance times” for aircraft in foreign registry. “Our goal is a harmonized package,” Huber said.
Wiring on engines is another issue. There appears to be a feeling in some quarters that EZAP should exempt the wiring on engines because it is inspected regularly at engine shop visits. Such a waiver could set the stage for excluding other wiring, such as that on the landing gear and in fuel tanks. Ric Anderson of the Air Transport Association (ATA) said flatly, “The engine is part of the overall zonal analysis.”
Anderson said the exclusion would contradict the MSG-3 maintenance protocol.
“To exclude a zone is a direct contradiction of the philosophy, which is to make sure every square inch of the airplane is covered,” he declared. “In MSG-3, you have to have a zonal analysis that covers the airplane.”
The matter of modifications under the STC process remains unresolved. “Right now, we don’t have a requirement for the operators to do an EZAP analysis of STCs,” Huber said. However, two areas are under consideration: (1) passenger-to-freighter conversions, and (2) major STCs that significantly increase the wiring density in a zone. The “greater density” is more difficult to define as a regulatory requirement. For example, how much more wiring does it take to change the density in a zone? What about wire routing? What about inspectability? For the moment, the wiring installed under an STC, other than that done by manufacturers, lingers in sort of a regulatory twilight zone.
Changed Attitudes
“We’ve changed the culture about the way we look at wiring. We are continuously analyzing our non-routine cards.”
Nick Drivas, AirTran Airways
“Our mechanics are aware that you cannot have dust on wiring.”
Larry Stevick, Northwest Airlines