SAFETY IS SERIOUSLY ENDANGER

SAFETY IS SERIOUSLY ENDANGER

Safety impact of ALPA/ATA proposal

The FAA's previous decision to allow a 138 minutes diversion time over the North Atlantic on an "exception" basis made sense, since it favored both operational safety and commercial interest: Alternate Airports in Greenland, which presents very severe winter conditions, become avoidable and flight cancellations due to the lack of visibility have been reduced.

On the contrary, the ongoing ALPA/ATA proposal to allow a 207 minutes diversion time over the North Pacific has only a commercial dimension to it without any safety benefit. It's just designed to avoid the southern route, based on Midway airport, and allows greater use of the slightly shorter Northern route based on the Artic alternates. Especially ni winter, when those alternates present the most severe safety problems !

Non compliance of the safety level with FAR 25.1309

The ALPA/ATA request suggests a limit Inflight ShutDown (IFSD) of 0.19 per 1000 flight hours, which is not sufficient to restore FAR 25.1309 compliance considering the longer mean diversion time over the North Pacific routes*. It also fails to admit the reliability of the state of the art engines that should constitute the new reference for any ETOPS related regulation. If such a propasal was accepted, the latest generation of engines might suffer a doubling of their ISFD and still be elligible for operation in the extreme environment of the North Pacific !

* ICAO formula for the calculation of the double engine failure probability:

P = 4.(Mean DT).(IFSD rate)2

No fire suppression systems on all-cargo aircraft !

The FAA's proposal is based on the premise that fire suppression systems can contain an onboard cargo compartment fire for 222 minutes (which is already not sufficient for a 4 hours diversion time). But this premise is very dubious with respect to all cargo aircraft, since they totally lack fire suppression systems !

For instance, in the case of federal Express flight 1406 in september 1996, its close proximity to an airport at which it could make an emergency landing was critical to saving the lives of its crew and jumpseat riders when a fire broke out in the aircraft's main cargo deck while it was 200 miles from its destination.

More about this: see Independant Pilots Association opposition to ETOPS (pdf)

Back to Contents