FR 2021-03574

This document, issued by the Federal Aviation Administration (FAA), introduces a new rule targeting particular Bombardier BD-700-1A10 airplanes. The rule arises from a concerning report of smoke and overheating linked to corrosion in internal lead-acid batteries, which can result in an electrical short circuit. This directive mandates inspections to determine when these batteries were last replaced and requires replacements if they are found to be over four years old. Additionally, it requires updates to the maintenance schedule to enhance safety and prevent potential fire hazards.

Significant Issues and Concerns

A notable issue with this directive is the absence of a specified cost estimate for replacing outdated emergency light batteries. This missing information could result in unforeseen expenses for airplane operators, who may face financial strain upon discovering during inspections that replacements are necessary.

The document utilizes technical terms and complex language that may be challenging for individuals without technical expertise. Smaller operators or those not well-versed in aviation terminology might struggle to comprehend the directive fully, which could lead to compliance difficulties.

Another point of concern is the lack of a detailed explanation for the 90 work-hour estimate needed to update the maintenance program. This lack of detail might lead to questions regarding the accuracy and reliability of the FAA's cost estimation.

The rule also relies on approvals from specific authorities for operators needing to obtain manufacturer instructions. Any delay or lack of responsiveness from these bodies could slow down the compliance process, impacting the operators' ability to meet deadlines.

Moreover, the document presumes that operators will have easy access to necessary service information, but this may not hold true for all, leading to potential delays or complications in adhering to the rule.

Impact on the Public

For the general public, this rule signals a proactive approach by the FAA to ensure aircraft safety, thereby reassuring travelers regarding their safety. The inspections and possible replacements aim to mitigate the risk of onboard fires, which could have severe consequences if left unaddressed.

Impact on Specific Stakeholders

Operators of the affected Bombardier airplanes are the primary stakeholders impacted by this directive. While safety improvements benefit them and their passengers, the potential costs and operational disruptions from adhering to the rule could pose challenges. Especially for smaller operators, the resource allocation required for compliance could be significant.

Additionally, ambiguous instructions around date management and inconsistent notation practices could lead to varied compliance levels, depending on how operators understand and implement the rule. This inconsistency might require the FAA to offer additional guidance or support, ensuring uniform compliance across the industry.

In summary, while this rule aims to enhance safety within the aviation sector, its implementation may present challenges for airplane operators. The directive's reliance on technical language, lack of clear cost implications, and assumptions about the availability of needed resources are areas that could impact its adoption and effectiveness.

The Federal Register document in question discusses a new airworthiness directive (AD) by the Federal Aviation Administration (FAA) for specific Bombardier airplane models. Financial aspects of this directive are considered crucial for understanding the potential economic impact on the affected operators.

Financial Overview

The document estimates that the directive will affect a total of 69 airplanes registered in the United States. Each operator is expected to spend approximately $7,650 to revise the maintenance or inspection program, based on a calculation of 90 work-hours multiplied by $85 per work-hour. This calculation takes into account labor costs but leaves out other potential expenses tied to physical components or materials.

Financial Challenges and Uncertainties

One of the primary issues noted is the absence of specific costs associated with the replacement of the emergency light battery (ELB) if found outdated. This lack of detail could lead to unforeseen financial burdens on operators. Since the requirement specifies replacing the ELB if the inspection reveals an age of four years or older, operators might encounter additional expenses not captured in the estimated cost per operator. Such unforeseen costs could be particularly challenging for smaller operators who may not have extensive financial buffers or flexibility.

Estimation of Work-Hour Costs

The financial estimate of 90 work-hours for revising maintenance programs lacks a detailed breakdown, which raises questions about its accuracy. Without information on how these work-hours were determined, operators might be skeptical of this estimate. Any deviation from this workload in actual application could lead to either an unexpected increase in labor costs or an underutilization of resources. This lack of detailed cost analysis can make financial planning difficult for operators.

Dependency on External Approvals

The document also outlines that for certain actions, operators might need to get instructions from the manufacturer, which has to be approved by specific authorities. This process might introduce delays, inadvertently leading to increased labor costs if operators need to extend or adjust their workforce deployment based on the availability of these instructions. For operators, the time spent awaiting approvals could translate into financial inefficiencies.

Accessibility and Compliance Consistency

Moreover, the assumption that all service information is easily accessible might not hold true for every operator. Delays or complications in obtaining necessary service documents could prevent timely compliance, further affecting financial outlay due to extended labor beyond the estimated scope. Additionally, the directive's focus on time frames without outlining specific procedures for date management could result in inconsistent application of labor resources, potentially impacting operational budgets negatively.

In conclusion, while the directive attempts to outline the expected financial commitment in terms of work-hour expenditure, several aspects such as additional replacement costs, potential delays in obtaining necessary approvals, and inconsistent access to required information and schedules introduce elements of financial uncertainty for the operators affected by this directive.