Overview
Title
Airworthiness Directives; Bombardier, Inc., Airplanes
Agencies
ELI5 AI
The FAA wants to make sure some planes are safe, so they are telling people to check certain parts often because sand and rust might make them work poorly, like if a toy robot's arms got stuck. They are also asking people to say what they think about this plan by April 12, 2021.
Summary AI
The Federal Aviation Administration (FAA) has proposed a new airworthiness directive (AD) targeting Bombardier, Inc., Model BD-700-1A10 and BD-700-1A11 airplanes. This proposal was prompted by issues with sand and corrosion affecting elevator torque tube bearings, which could potentially hinder airplane pitch control. The AD mandates regular inspections, functional tests, and possible replacements of these parts to avert risks to flight safety. Comments on this proposed directive are due by April 12, 2021.
Abstract
The FAA proposes to adopt a new airworthiness directive (AD) for all Bombardier, Inc., Model BD-700-1A10 and BD-700-1A11 airplanes. This proposed AD was prompted by reports indicating that the left- and right-hand elevator torque tube bearings were contaminated with sand and corrosion, restricting free rotation. This proposed AD would require repetitive general visual inspections of the left- and right- hand elevator torque tube bearings for any sand, dust, or corrosion; repetitive functional tests of the elevator control system; and replacement of the elevator torque tube bearings if necessary. The FAA is proposing this AD to address the unsafe condition on these products.
Keywords AI
Sources
AnalysisAI
The document in question outlines a proposal by the Federal Aviation Administration (FAA) to introduce new safety requirements for certain Bombardier airplanes. This proposal is known as an airworthiness directive (AD), which aims to ensure the continued safety of aircraft operations. The main concern prompting this directive is the contamination and corrosion of elevator torque tube bearings found in Bombardier's Model BD-700-1A10 and BD-700-1A11 airplanes, which can pose risks to the control of the aircraft.
Summary
In essence, the FAA is proposing regular inspections, functional tests, and possible replacements of these bearings to avoid inherent risks associated with their degradation. Stakeholders and the general public are invited to comment on this proposal by the specified deadline of April 12, 2021. The effort demonstrates the FAA's proactive approach in identifying and addressing potential safety issues before they can affect the broader aviation community.
Significant Issues
The document does raise some concerns. One of the primary issues is the lack of details regarding the costs associated with the directive, particularly those related to unforeseen but potential necessary actions ("on-condition actions"). Without cost estimates, it becomes challenging for aircraft operators to gauge the financial impact of compliance fully.
Secondly, the document mentions that some costs may be covered under warranty by the manufacturer, Bombardier. However, it does not specify which costs are covered or the warranty conditions, leaving operators uncertain about the full cost responsibility.
Moreover, technical terms like "general visual inspections" and "functional tests" are briefly mentioned without explicit definitions, causing potential confusion about the precise maintenance activities expected. Additionally, references to Bombardier Service Bulletins, identified only by numbers, may be unclear for readers who do not have immediate access to these proprietary documents.
Public and Stakeholder Impact
For the general public, the proposal represents an essential aspect of aviation safety, signaling robust oversight by the FAA to prevent accidents and maintain the high safety standards of passenger travel. However, for operators of the affected aircraft models, the impacts are more direct and multifaceted.
Aircraft operators might face increases in maintenance workloads and associated costs due to the newly mandated inspections and potential replacements. For operators without warranty coverage, these financial burdens could be significant, particularly when multiple aircraft are involved. Conversely, for those with warranty agreements, the financial strain might be mitigated somewhat, assuming the conditions of these warranties are met.
Conclusion
The FAA's proposed airworthiness directive is clearly driven by safety concerns and reflects a commitment to public welfare in the aviation industry. However, enhanced clarity on the directive’s requirements, cost implications, and technical terminology would greatly benefit operators and stakeholders, ensuring comprehensive compliance and safety outcomes. Stakeholders are encouraged to engage with the proposal actively, providing feedback that might refine and improve the final regulatory action.
Financial Assessment
The Federal Register document outlines a proposed airworthiness directive (AD) by the Federal Aviation Administration (FAA) regarding Bombardier, Inc. airplanes. Embedded within this directive are a few key financial aspects that are crucial to understanding the document's potential economic impact on affected parties.
Cost Estimates and Financial Impact
The document provides an estimate that the average labor rate for compliance with the proposed AD actions is $85 per hour. This figure is pivotal in calculating the overall cost of compliance for reporting inspection results from U.S. operators. According to the document, the FAA estimates that the cost of this reporting requirement will total $33,320, or $85 per product. This estimation is based solely on the labor costs for reporting and does not include other potential costs for additional actions.
Indeterminacy of On-Condition Actions
One notable financial concern highlighted in the document is the lack of a specific cost estimate for on-condition actions, which are additional steps required based on the results of initial inspections and tests. The FAA explicitly states that it "has no way of determining the number of aircraft that might need this on-condition action." This uncertainty poses a challenge for operators trying to forecast the total financial impact of complying with the proposed AD. The absence of a clear cost estimation for these potential actions leaves operators in a position of financial ambiguity, making budgeting and financial planning difficult.
Warranty Concerns
The document includes a statement that some or all of the costs related to the proposed AD might be covered under warranty. However, it fails to delineate which specific costs might be warranty-eligible and under what conditions the warranty would apply. This lack of specificity regarding warranties can create confusion for operators who may not know whether they will bear the financial burden of compliance or if and how a warranty might offset these costs. This can also impact financial planning for operators who must prepare for the worst-case scenario of bearing all costs themselves.
Complexity and Technical Jargon
The presence of aviation-specific jargon and references, such as "general visual inspections" and numerous service bulletins, adds a layer of complexity. The financial references may be difficult to parse without extensive knowledge of aviation compliance processes and industry standards. This complexity can obscure the true financial implications for those responsible for compliance, making it essential for operators to seek clarifications on what the directives entail in terms of additional time and resources.
Overall, the financial references within the document highlight significant considerations and potential concerns that must be addressed to fully understand the directive's impact on affected operators. The gaps in specific cost details and warranty information underline the need for clearer guidelines and supportive documentation to aid operators in implementing the proposed rule effectively.
Issues
• The document does not provide specific estimates of the costs for on-condition actions, only stating that the FAA has no way of determining the number of aircraft that might need such actions. This lack of cost estimation makes it difficult to assess the full financial impact on operators.
• The document mentions that some or all costs may be covered under warranty but does not specify which costs or the conditions under which the warranty would apply, leading to potential confusion regarding cost responsibilities.
• Certain terms such as 'general visual inspections' and 'functional tests' are not defined in detail within the document, potentially causing confusion about the specific actions required.
• There are multiple references to specific Bombardier Service Bulletins by their numbers, but without further explanation, this might be challenging for readers who do not have easy access to these bulletins.
• The document includes complex cross-references to regulations and other documents, which could make it difficult for readers to fully understand the compliance requirements without additional guidance.
• The reporting requirements section refers to the Paperwork Reduction Act and an OMB control number without clearly explaining what specific information needs to be collected or how this affects operators.
• The use of aviation-specific jargon and references such as 'AMOCs', 'TCCA MCAI', and service bulletin numbers may be difficult for individuals who are not deeply familiar with aviation compliance documentation.