A couple of times a week, I spend a few hours basking in the glow of my computer screen scanning the aviation web sites trying to stay hangar smart with what is happening in our industry. Besides this autistic reason for doing the research, I harbor a more practical reason — just trying to stay out from being under foot. Once you change careers you got to remember that your wife took you for better or worse but not for lunch, so you better look busy all the time.
So as a closet wordsmith and a dues paying member of the Cynics of America club, I pay closer attention to news briefs published on the web or newspaper than most because I now have the time. One of the things I have noticed is that good news always comes out on a Sunday or Monday and bad news comes out on Fridays. Here are a few news briefs and my unedited comments.
News brief No. 1
The FAA has announced that as of Friday, July 20 the FAA Suspected Unapproved Parts Program Office located just east of Dulles Airport will be realigned. Its duties will be taken over by Flight Standards in Headquarters. After July 20 anyone who wants to submit a SUP report can call the 24-hour Aviation Safety Hotline at (800) 255-1111 or email a report to the Aviation Safety Hotline Office.
Comment: Notice the word the FAA uses is “realigned.” Translated that means the SUP’s Program Office has been eliminated. The SUP’s Program Office has been around since Nov. 15, 1995. Like all new program offices it was created in the midst of controversy. Charges and counter-charges between a high-ranking FAA official and the DOT Inspector General on the size of the SUP problem within the U.S. fleet was a matter of media interest for weeks. That exchange of charges was the catalyst that caused the creation of the SUP’s Program Office.
Despite its somewhat awkward beginnings, the SUP’s Program Office did some great work in making our industry aware of the size of the SUP problem and stopping most of the trash that is out there being peddled off as airworthy parts. Many SUP producers paid heavy fines and a few thieves spent hard time in jail. Now a victim of its own success most of its staff has been moved to Washington Headquarters where the remaining SUP specialists will be parceled out to different Flight Standards Divisions. It is interesting to note that responsibility for SUP issues is going back to the same Service where the SUP problems were originally handled prior to 1995. My, my, sounds like déjà vu all over again.
I have two fears concerning this realignment of SUP’s oversight. First is lower priority. I know that the former SUP specialist(s) will be assigned to a branch(s) in headquarters where the overworked manager has at any given time 15 major problems he has to handle now! It is a fact that in disaster central, SUP issues will no longer enjoy priority status. I also am worried that with a drastically reduced staff, who is going to do the analysis, work with the field inspector, coordinate with law enforcement, etc.
The second fear is that in the next few years FAA will lose close to 60 percent of its experienced inspectors to retirement. The slow hiring rate due to budget restraints will cause a short fall of trained inspectors. The result will be that the FAA by 2010 will not have enough experienced inspectors to audit work performed in FAA foreign repair stations. Helicopter operators and U.S. airlines that outsource work, especially heavy inspections/checks/overhauls, share the greatest risk of having a SUP installed on their aircraft because those aircraft use the majority of high dollar parts. Both kinds of operators should take special pains to ensure that the parts replaced on their aircraft are traceable and airworthy because it is the owner/operator who holds the airworthiness wet paper bag of responsibility, no one else.
News brief No. 2
New repair station regulations will be delayed. The changes to Part 145 will not be out in December of this year as I originally thought. The public comment period for the Notice of Proposed Rulemaking on Part 145 closed on April 15, 2007. There were 156 public comments submitted to the docket and many of these comments fall into the category of “substantial.” Use of the words “Substantial Comments” in rulemaking triggers the same level of concern in the FAA as you would have if your dentist says “uh-oh” during your annual checkup. So from here on out there will be a lot of meetings inside and outside the FAA to resolve industry’s Part 145 concerns.
Comment: While these comments account for 3 percent of the 5,000 total number of FAA Part 145 repair stations, the three biggest areas of concern I could glean from the comments located on the Federal Register website: hhtp://dms.dot.gov/search (docket number 26408) are: the new rating system, the term “chief inspector,” cost to change manuals and ops specifications, and work done by a foreign repair station in another country.
My best guess is that after worrying over the comments, the FAA will draft another Part 145 Repair Station Notice of Proposed Rulemaking that will be published in the Federal Register in February or March of 2008.
Allow me a closing comment on this news brief. Approximately 50 substantial comments from the public stopped this rule dead in its tracks. So despite the common mechanic’s perception, you don’t have to have the big numbers on your side to stop a proposed rule. But imagine if all 5,000 repair stations commented on the NPRM. Do you think the FAA would have a better understanding of industry concerns and their needs if and when they have to write a new revision to the Part 145 NPRM later this year?
News brief No. 3
The Boeing Company unveiled its new Boeing 787 Dreamliner on Sunday July 5, 2007. With more than 15,000 people in attendance and another 30,000 watching via satellite, Boeing rolled out its first new aircraft in 10 years. The B-787 will burn 20 percent less fuel, cruise at .85 mach, and carry 240 to 296 passengers depending if the airline wants loose or interference fit seating arrangements. Boeing has reported sales of 677 aircraft to the tune of $110 billion in sales. The first B-787 Dreamliner will go to Japan’s ANA Airline in May 2008.
Comment: Hurray! Boeing finally got it right after the disasters in management in 2000 and losing the lead of the world’s primary aircraft manufacturer to Airbus for the past five years. But being a card-carrying cynic I have to bring some rain on this parade. The B-787 is almost a 70 percent composite aircraft, the fuselage is a carbon fiber tube made in one piece. Boeing claims it eliminates 70,000 fasteners and the fuselage is stronger and lighter than conventional fuselages.
I do not doubt the claims, but what worries me is who is going to repair damage to the airframe once the 787 enters service in numbers. You know the kind of in-service damage I am talking about: the food truck that backs into the side of the aircraft or the fuel truck that does a suicide run into the engine nacelle. In the short-term, I am sure Boeing will have specialized composite repair teams standing by to support their customers, but as the fleet ages over the next 10 to 15 years, most of the composite repairs will be accomplished by the airlines or appropriate rated repair stations.
The point I am trying to make is — this is a new breed of aircraft, with Star Trek technology. It is as different as the Boeing 707 was from the DC-7. I hope that industry and the FAA start looking seriously at mandating training/ratings for mechanics and technicians in the art of NDI and the science of making composite repairs. Mechanics and repair stations also will need access to FAA approved data to make those repairs. That is the short-term fix.
The long-term fix is to revise Part 147 mechanic’s school rule so the brand new A&P of 2015 is as comfortable around composites repairs as the A&P of 1967 was comfortable around aluminum repairs. The Part 147 rule has been desperately in need of revision for years now and since it takes a minimum of three years to get rulemaking through the system, its revision needs to become a FAA and industry priority. Also, the industry and the FAA need to educate the current and new mechanic workforce that this new technology brings serious health risks to anyone working with carbon fibers. So new Material Safety Data Sheets (MSDS) will have to be developed for working with and around carbon fibers structures.
While I am still in full cynic mode, does anyone in the FAA or industry realize that carbon fibers (5 to 7 microns) are electrically conductive? Now what if a composite aircraft catches fire at LAX and millions of small carbon filaments are released? They will short out electrical equipment as effectively as putting a digit with a wedding ring across two live contacts. How does an airport function when its phones, lights, communications, and radar are out of action? What about the health risks of this kind of release?
OK, OK I better stop this before it gets out of control. I will leave you with this final thought. The next time you read a news release, don’t just read it. If you have the time, think about it a bit.