"Industry Divided on Extended Range Operations", Air Safety Week, Jun.06, 1999

A proposal to extend the time twin-engine aircraft can fly to a diversionary airfield in the event of the loss of one engine has sparked a distinct divergence of views within the industry.

In response to an industry solicitation to extend the current rules for Extended Twin-Engine Operations (ETOPS) from 180 minutes to 207 minutes, which would provide operators of the B777 particularly more flexibility on certain North Pacific routes, the Federal Aviation Administration (FAA) issued a request April 27th for public/industry comment, with a June 11th deadline for comments.

The vote is in. Of 16 comments submitted to the docket, opinions were equally divided, 8 in favor and 8 opposed to adding roughly another 200 miles to the 1,500 miles (180 minute) maximum distance currently allowed for planning to a divert airfield in the event of a loss of an engine on a twin jet.

This box score, however, includes comments from interested individuals. It is fair to argue that their views (overwhelmingly in favor, but with a vocal opposition, including one "Hell no!") probably should not carry the same weight as an organization or company. Eleven institutions submitted comments: 5 were in favor, 6 were opposed or expressed serious reservations.

The FAA's request for comment included the proposal from three organizations to extend ETOPS. They were: the Air Line Pilots Association (ALPA), the Independent Association of Continental Pilots, and the Air Transport Association (ATA). Two of these organizations did

not provide additional comments in the docket. If their support were included in the tally above, 7 organizations are on record supporting a 207 minute ETOPS and 6 organizations are opposed. It may be worth mentioning that if this proposal were a treaty, which requires a two-thirds vote of the Senate to ratify, it would not pass.

In its request for comment, the FAA seems favorably disposed to approve what amounts to a 15% extension to the current ETOPS limit. Among the key points it cited from the Boeing analysis included in the three parties' proposal:

* There has never been a diversion of 180 minutes' duration, for any aircraft of any type, regardless of the number of engines.

* Analysis, using the most conservative criteria, show a design and reliability capability for the B777 "well in excess of the 15% extension."

* The parties are prepared to modify aircraft fire protection systems to provide a 15% time extension to inflight fire suppression capability.

Opponents did not find these assurances persuasive. Presented below are highlights of the various views:

International Air Crash Victims Families Group:

As surviving families of air crashes that occurred on trans-Atlantic and trans-Pacific flights over water, with total fatalities, we have a special interest in the proposed regulation...we have great concerns about the requested extension of the range of separation between airports for two engine aircraft.... The fact that two engine aircraft have operated up to now without major accidents should not lull us into a false sense of safety...

* There is no guarantee that in a worst-case scenario both engines of a two engine plane may not fail.

* There is no guarantee that if one engine fails the second engine can carry the load of the plane for...(more than) 3 hours...

It is suggested that a study be made to create a catastrophic insurance rider to cover the cost which may be incurred in case of increased risk of operating two engine planes over vast expanses of water...

International Airline Passengers Association:

IAPA supports the concept...subject to the following:

* Substantial satisfactory evidence of 180-minute operations...

* The en-route ETOPS alternates...must have adequate facilities to...care for the maximum number of passengers that might be expected, including...appropriate aircraft steps... sufficient warm accommodation...adequate toilet facilities...

Without such provisions, a diversion to an ETOPS alternate would not be a fully satisfactory option...(Note: these issues may be more critical than they appear at first glance. The Airbus comment points out that in the harsh and demanding winter of the Northern Pacific region ground temperatures of -30 degrees F are not uncommon. "Following a long diversion in which cabin temperatures may have decreased substantially because of equipment failure, these temperatures present a real challenge, especially for the elderly or infirm who may be in summer clothes, traveling to or from a tropical destination. Most of the remote alternate airports have inadequate facilities for deplaning and...can offer passengers few (if any) accommodations to provide warm shelter, food, or medical care.")

A Carrier :American Airlines (the only individual carrier to respond to the request for comments, American has recently initiated ETOPS flights across the North Pacific with the B777): Empirical weather data indicates that there are occasionally periods, perhaps three or four times a year, when all enroute airports in the northerly route system between Anchorage and Sapporo fail to meet the forecast ceiling and visibility criteria to qualify as enroute alternate airports. During these periods, flights have two options under the 180 minute ETOPS rule: either fly a southerly route with only one airport, Midway, as the alternate, or operate even more northerly than normal so as to continuously remain within 60 minutes of an 'adequate' airport as required by FAR 121.161... The 207 minute ETOPS rule is a prudent evolution of procedures that have been extensively proven over many years.

Boeing (Note, the company's twin-engine B777 is in direct competition with the four-engine Airbus A340): Data shows that twins have a lower number of both diversions and turnbacks for propulsion related causes than four engine airplanes. Despite their excellent record, twins are still subject to requirements that are significantly more restrictive than those which apply to three and four-engine airplanes. While these restrictions may not have been prudent fourteen years ago...they now appear conservative.... Boeing supports the 207 minute...ETOPS...and encourages the FAA to adopt the proposed policy as soon as possible.

Airbus Industrie:

We are...concerned that this waiver would only be applied to domestic US airlines, and the limitations would continue to be applied by FAA's Aircraft Certification Service to exported airplanes.... Before ETOPS operational restrictions are relaxed....We believe it is time to consider actual forecast winds rather than assuming still-air conditions, and that time-limited aircraft systems should be required to function throughout maximum forecast diversion times as well. We explicitly recognize that some of the issues we raise in our comments are applicable to any long range operation regardless of the number of engines, and we urge that the modernization...of ETOPS regulations takes all types of extended range operations into account...we urge that this effort be initiated promptly on an international basis.

Allied Pilots Association (the union of American Airlines pilots):

The proponents of this change rely heavily on the technical merits of the B777....We do point out that two of the engine models currently used on the B777 have already been the subject of FAA Airworthiness Directives mandating the redesign and replacement of important subassemblies because of in service failures....No one involved in the design or certification of B777 aircraft equipped with these engines for ETOPS...anticipated these problems. Studies are often different than actual experience....

If all the alternates, including those located in Siberia, are considered, there would likely be only one day a year when weather would compel an operator to select a somewhat longer route to stay within 180 minutes...That doesn't seem to us to establish a real need. The proponents of this change avoid stating their case plainly because it is very weak.

Independent Pilots Association (IPA, the union of United Parcel Service air freighter pilots):

IPA has no confidence that fires would be contained within cargo compartments for the extended period of time. ( Extending an Engine-out Flight From 180 to 207 Minutes

* In favor - Boeing: "There are already over 200 B777's in service and all of them are equipped for ETOPS....The average twelve month rolling average inflight shutdown rate for the 777 fleet is .007/1000 hours, significantly better than the FAA recommended target rate of .02/1000 engine hours." (Editor's note: The FAA target rate works out to about one inflight engine shutdown every six years. The .007/1000 fleet experience cited by Boeing indicates an in-service rate of an engine shutdown every 16 years)

* Opposed - The Independent Pilots Association:

The proposal "is akin to a family travelling along a highway with a 3-year old child, figuring that, because certain rest stops along their normal route might be closed, they might as well travel on a route which has even longer distances between rest stops, and then simply ask the child to 'hold it in' a little longer until the next available rest stop. In both cases, the chances of an accident are increased, but for a miscalculation concerning ETOPS, rather than rest stops, the resulting accident would be a disaster, not just an inconvenience."

Source: FAA Docket No. 29547.