ETOPS Authorization
The ARAC
has recommended that FAR 121.161 (the 60-Minute Rule) and
associated guidance and advisory material be revised to
- Establish
the basis and requirements for operating
twin-engine, turbine-powered airplanes beyond
60 min of flying time (at single-engine cruise speed
with no wind and in standard conditions) of an adequate
alternate airport.
- Apply
this same regulatory framework to the operation of turbine-powered
airplanes with more than two engines beyond 180 min (at
one-engine-inoperative cruise speed with no wind and in
standard conditions) of an adequate alternate airport, and
also make it applicable to all operations in polar areas
(see Polar Operations).
- Make
the designed and certified operating capabilities of the
airplane type the basis for determining the maximum diversion
authority of that type.
- Define
allowable diversion authorizations for different regions
of the world based on the overall operational needs of each
region.
- Apply
current ETOPS best practices to all extended operations.
It should be noted
that, although these proposed ETOPS requirements are consistent
for all jetliners, the threshold varies at which they would
take effect. For two-engine airplanes operating under FAR
Part 121, ETOPS will be in effect as is currently the
case on routes where the airplane is at some point more
than 60 min flying time from an alternate airport. For FAR
Part 121 operations by airplanes with three or more engines,
these new ETOPS rules will apply on routes that are at some
point more than 180 min from an alternate airport. They also
will apply to all operations in the polar regions (i.e., the
areas north of 78°N latitude and south of 60°S latitude).
Definitions
The ARAC has proposed that ETOPS-applicable definitions be
added to FAR Part 121. Many of the terms used in the new regulations
and guidance material for ETOPS are unique to extended operations
and demand precise definition to ensure common understanding
and proper compliance.
To encompass all
extended-diversion-time operations, not just those flown with
two-engine airplanes, the term ETOPS would be redefined
as extended operations (as used in this article) and
shall no longer mean extended-range operations with two-engine
airplanes. Another noteworthy change is the addition of the
term ETOPS alternate, which is an airport that meets
stated requirements for planned diversion use and at which
the weather conditions are at or above the operating minimums
specified for a safe landing. This new term would replace
the current ETOPS term suitable, which denotes an alternate
airport that is both above required weather minimums and available
for diversion use. Under the new rules, suitable would no
longer have an ETOPS-specific meaning; where it appears in
the new regulations and associated guidance material, therefore,
it should be interpreted only according to its broadly accepted,
everyday definition.
It should be noted
that long-range operations (LROPS) is not proposed
as an ETOPS term. Although used by some segments of the global
industry, LROPS currently does not appear or have legal
standing in the FARs. The ARAC ETOPS Working Group did not
propose adding LROPS because the term would be misleading
extended operations are defined by distance to an alternate
airport, not by overall length of flight and because
it invites confusion with the similar but unrelated term ultra-long-range
operations, which deals primarily with flight crew duty time,
crew rest, and other human-factors issues.
Communications
Current regulations require reliable communications. Recognizing
that advances in technology occur and that verbal communications
can be particularly valuable, the proposed rule promotes the
adoption of voice communications for extended operations.
Dispatch
The ARAC has proposed a new regulation specifying airplane
dispatch requirements for ETOPS alternate airports. The operator
would have to select en route alternate airports that meet
the weather requirements set forth in its operations specifications.
This proposed rule
states that the most reliable communications technology voice
based or data link shall be installed in all airplanes
operating beyond 180 min from an alternate airport. Alternative
means of communication must also be available in the event
the most reliable means is not available for any reason (e.g.,
lack of satellite coverage). Examples of these communications
technologies (e.g., SATCOM voice link, SATCOM data link, HF
data link) are given in the associated guidance material.
The proposed rule
is not intended to require operators to continually upgrade
existing installations on an incremental basis. Rather, the
rule is meant to further the adoption, as appropriate, of
new technologies that significantly enhance the quality and
reliability of communications. One example of such innovation
is todays transition from HF radio to satellite-based
technologies.
Because alternate
airport weather is checked before airplane departure, and
weather conditions can vary over time, the conservative weather
minimums required for dispatch are higher than those that
would be required to perform an instrument approach at that
alternate airport. As proposed, this dispatch rule further
requires the crew to verify the continuing availability of
a valid alternate airport by means of en route weather updating
at the beginning of the ETOPS phase of flight. For this en
route updating, the crew would be required to ascertain only
that the planned alternate is above normal landing minimums,
not above the higher minimums applied before dispatch.
One of the distinguishing
features of ETOPS is the identification of and reliance on
alternate airports to which airplanes can divert should an
unscheduled landing become desirable or necessary. Under this
proposed regulation, operators flying three- and four-engine
airplanes in extended operations would be required to designate
ETOPS alternate airports within 240 min, or if beyond 240
min, designate the nearest available ETOPS alternate.
Propulsion-Related
Diversions
The ARAC has proposed no substantive change to the rule that
governs diversion following an in-flight engine failure or
shutdown. However, the committee did offer guidance to further
clarify existing diversion requirements for two engine airplanes
in the event of engine failure or shutdown.
To aid flight crews,
the proposed guidance lists factors
(e.g., airplane condition and systems status, weather conditions
en route, terrain and facilities at the alternate airport)
that the pilot in command should consider when deciding which
alternate airport to divert to. To ensure that safety always
remain paramount, the ARAC further identified factors that
shall not be considered sufficient justification for flying
beyond the nearest available alternate airport (e.g., additional
range capability based on remaining fuel supply, passenger
accommodations beyond basic safety, maintenance and repair
facilities at the available alternate airports).
Fuel Reserve
The ARAC has proposed that all airplanes flown in extended
operations shall carry an ETOPS fuel reserve to protect the
passengers, crew, and airplane in the event of a cabin depressurization
followed by a low-altitude diversion.
Cabin depressurization
is a very rare event that can occur on any jetliner and is
largely unrelated to the number of engines. If it does occur,
the flight crew must immediately descend to an appropriate
altitude, as defined by oxygen availability or oxygen systems
capability. A diversion is then generally required because
of the increased fuel consumption of turbine engines at low
altitudes and the corresponding reduction in range.
This ETOPS fuel
reserve requirement assumes that
decompression would occur at the most critical point along
the route in terms of total fuel consumption (a concurrent
engine failure is further assumed if it would add to the total).
The reserve thus calculated would ensure sufficient fuel for
an extended low-altitude diversion followed by a descent to
1,500 ft at the alternate airport, a 15-min hold, and an approach
and landing. Further allowance is made for possible airframe
icing and wind forecasting error.
Following extensive
review of data related to the accuracy of wind forecasting,
as well as review of the icing scenario based on the Canadian
Atlantic Storms Program (CASP II), the ARAC proposed revising
the ETOPS fuel reserve requirement. Under this proposed rule,
two-engine airplanes on extended operations would carry somewhat
less reserve fuel than in the past. Airplanes with more than
two engines would be required to carry an ETOPS fuel reserve
for the first time, although many three- and four-engine operators
do currently carry a depressurization fuel reserve as a matter
of internal airline policy.
Maintenance
The ARAC has proposed making current twin-engine ETOPS maintenance
standards applicable to all airplanes flown in extended operations.
This would require three- and four-engine operators to also
have an ETOPS maintenance program in place before flying routes
with the potential for an extended diversion.
ETOPS maintenance
requirements have significantly reduced the incidence of in-flight
engine failures. Such events can be enormously costly and
disruptive for airlines, which is why some operators of three-
and four-engine airplanes have already voluntarily raised
their maintenance standards to ETOPS levels.
Passenger Recovery
Plan
The ARAC has proposed that all extended operators shall develop
a plan to ensure the well-being of passengers and crewmembers
at diversion airports. This plan should address their safety
and comfort at that airport in terms of the facilities and
accommodations and their retrieval from that airport.
Currently, passenger
recovery plans are required only
for cross-polar operations. Because diversions can occur anywhere,
however, the ARAC has proposed that every operator flying
routes over remote areas of the world should anticipate the
possibility of a diversion within those regions and devise
a plan outlining how it would recover the passengers, crew,
and airplane.
Cargo Fire Suppression
To further ensure safety, the ARAC has proposed that all time-critical
systems aboard airplanes flown in extended operations shall
have sufficient capability to protect the airplane throughout
the longest potential diversion for that route. In particular,
each flight shall have continuous fire suppression capability
for a period equivalent to the maximum planned diversion time
plus an additional 15 min to cover approach and landing at
the alternate airport.
Two-engine airplanes
flown in extended operations have met this requirement since
1985. In contrast, although all jets have fire suppression
systems, those with more than two engines are not currently
required to carry sufficient fire suppressant during extended
operations to protect the airplane continuously throughout
a maximum-duration diversion.
The ARAC has proposed
that three- and four-engine airplane operators that do not
currently comply with this requirement shall have six years
after ETOPS regulations take effect to bring their existing
fleets into compliance with this new rule.
Many airplane systems
enhance safety during flight. Of
these, cargo fire suppression is generally the most time-limited.
Applying ETOPS
cargo fire suppression requirements to all extended operations
can thus further protect passengers, crews, and airplanes
on routes with extended diversion times.
Performance
Data
The ARAC has proposed that existing regulations be modified
to require that performance data be available to support all
phases of extended operations. Flight crews and dispatchers
must have data available that describe the specific performance
of the airplane in normal and non-normal situations, including
those that might be encountered during an extended diversion.
Polar
Operations
The ARAC has recommended that the North Polar area
(i.e., everything north of 78°N latitude) shall be designated
an area of ETOPS applicability. The same designation shall
be applied to the South Pole and surrounding region (i.e.,
everything south of 60°S latitude). Within these areas,
ETOPS requirements shall apply to all airplanes, regardless
of the number of engines or distance from an adequate airport.
This proposed requirement recognizes the challenges associated
with these areas and sets forth steps to protect diversion.
Polar operators
require training and expertise to support airplane diversions
and their subsequent recovery. These operators must consider
requirements for en route alternate airports, a strategy for
and monitoring of fuel freeze, a passenger recovery plan,
and reliable communications capability.
Rescue and Fire
Fighting
The ARAC has proposed a rule specifying rescue and fire fighting
(RFF) requirements at ETOPS en route alternate airports. If
adopted, this rule will further ensure the safety of all airplanes
when flying extended operations, regardless of how many engines
an airplane has.
Before dispatch,
ETOPS operators have always had to
designate alternate airports that are above ETOPS-specified
weather minimums. In addition, these designated alternates
must provide the necessary facilities and equipment to ensure
the safety and well-being of the passengers and crew throughout
an extended diversion, after landing at the alternate airport,
and for as long as they remain at that airport before being
retrieved. RFF capability is a key element of this protection.
During nearly two
decades of ETOPS and more than three million ETOPS twinjet
flights around the globe, there has not been a single landing
accident following an extended diversion from the ETOPS phase
of flight. The fact that RFF services have not been needed
does not mean that such an event will never happen. Therefore,
the ARAC finds it prudent to formalize RFF requirements for
alternate airports in the regulations.
Other Proposed
Changes
The proposed regulatory changes described above would affect
FAR Part 121, the section of the FARs governing the operation
of transport-category airplanes. In response to the FAA tasking
statement, the ARAC ETOPS Working Group also has proposed
changes to other parts of the FARs.
In particular,
the ARAC has proposed changes to FAR Part 25, which governs
the design and testing of transportcategory airplanes, and
FAR Part 33, which governs engine design and testing. If adopted,
these regulatory modifications will benefit the development
of future transport airplanes regardless of the number
of engines by formalizing ETOPS-inspired improvements
that have been shown in service to further protect airplanes
and reduce the likelihood that they will need to divert.
The ARAC has further
recommended that operators must comply with all rules within
FAR Parts 25 and 33 when considering the longest flight and
longest diversion time for which approval is sought. The rigor
of this practice will ensure that all airplanes designed to
these requirements will have the necessary redundancy and
reliability to ensure safe extended operations.
To further protect
airplanes during extended operations, the ARAC has identified
the factors that ensure high levels of safety on flights with
the potential for a long diversion. In the case of two-engine
airplanes, the most significant element is propulsion system
reliability.
Using several methods
to assess risk, the ARAC concluded that diversion time can
be significantly increased without added risk if the IFSD
rate is sufficiently low. An IFSD rate of 0.01 per 1,000 engine-hours or
twice the engine reliability level required for 180-min ETOPS has
been determined to allow unconstrained operations with two-engine
airplanes. Currently, the world-fleet average IFSD rates for
the 767 and 777, which together perform the majority of ETOPS,
are both below this threshold.
Other key elements
that support extended diversion times are proper testing and
validation of an airplane type (i.e., airframe-engine combination)
to ensure ETOPS safety at service entry. The Boeing 777 Early
ETOPS program processes provided a successful template on
which to base future such programs. Consequently, the design,
analysis, and test features from the 777 Early ETOPS program
are incorporated in the proposed ETOPS regulations.
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