By Capt. Bob Reich (United), ALPA ETOPS Project Team Leader
Air Line Pilot, August 2003, p.22

In recent years, twin-engine jet airliners have been limited to routes that have a maximum diversion time of 180 minutes from an enroute alternate airport at single-engine cruise speed. However, this operational constraint has not come from a federal aviation regulation. The only FAR that sets a diversion limit for extended twin-engine operations (ETOPS) is FAR 121.161, which limits them to 60 minutes from an enroute alternate. This regulation, written in 1956, reflected the reliability (or unreliability) of the piston-driven airliners of that era. The 180-minute "limitation" is actually an authority granted to operators of twinjets in an FAA advisory circular, AC 120.42A, written in 1988. Its predecessor document, AC 120.42, which had been written in 1985, had authorized ETOPS with a single-engine diversion time as long as 120 minutes with a then-possible extension to 138 minutes. Both these advisory circulars were written in response to a request from the airline industry.

Although written for piston-powered airplanes, the requirements of FAR 121.161 were initially effective and flexible enough to accommodate the increased reliability of turbine-powered airplanes. With the advent in the 1980s of a new generation of twin-engine airliners that were significantly improved in range, payload, and reliability, airlines wanted to take advantage of the capability of these airplanes and to establish conditions under which extended-range operations with these airplanes could be conducted safely. AC 120-42 and AC 120-42A recognized the increasing reliability of turbojet engines and helped to establish certification requirements for type design and operational practices for safe and reliable long-range operations with twin-engine airliners. ALPA participated in developing both of these documents, and my first experience with ETOPS was as an ALPA staff engineer working on the first advisory circular.

ETOPS was a very new concept in the 1980s, with the airline industry having little experience in such extended operations of twins. Consequently, the airline industry, the FAA, and ALPA were wary of expanding ETOPS operational authority and realized the need to maintain the existing level of safety without introducing added risk. Although ALPA did not get everything it wanted out of either document, the airlines likewise did not get the full measure of freedom they were seeking. The safety criteria imposed on the certification standards for the airframe and the operational requirements that the FAA imposed on the airlines were quite conservative in many respects.

During the past 18 years of ETOPS experience, these types of operations have matured and expanded to include the majority of commercial flights across the North Atlantic and an ever-increasing number of flights across the Pacific. A significant amount of data has been obtained, and the operations have proven to be safe and reliable. Experience has validated the airline industry’s efforts and shown that ETOPS can be managed successfully and a high level of safety can be maintained by up-to-date regulations that articulate quantifiable standards of reliability and experience.

In March 2000, responding to a further request from the airline industry, the FAA issued a policy letter extending ETOPS operational authority from 180 minutes to 207 minutes for the specific and limited case of North Pacific operations. This new "twin" authority acknowledged the success of current ETOPS and the technical sophistication of the latest twin-engine airliners, such as the Boeing 777 and Airbus A330. ALPA once again actively participated in developing the policy. Although initially skeptical of such an expansion, ALPA was satisfied with the increased certification and operational requirements that the new policy imposed on twins and subsequently fully supported its implementation. ALPA was also able to use this latest airline industry request as a vehicle to address shortcomings in past ETOPS practices and to set what we perceived to be necessary precedents for any further expansion of ETOPS authority. As a condition of ALPA’s participation and ultimate support, one of the demands of ALPA and others within the airline industry was a commitment on the part of the FAA and industry to expeditiously review all the disparate directives currently governing ETOPS with the goal of organizing them into a single, coherent set of regulations and advisory material that could successfully manage ETOPS in the future.

Significantly, ALPA also demanded that such a review include long-range operations of all airliners, including three- and four-engine airplanes. ALPA and others in the airline industry believed that as the technology and reliability of twin-engine airliners continued to improve, due in large measure to ETOPS requirements, ETOPS had became compatible with long-range operations typically associated with three- and four-engine airliners.

At the same time that technology had given twins long range, the infrastructure to support such long-range flights was changing. Political and funding priorities forced the closure or reduction in basic services of a number of airports, both military and civil, in remote areas. These airports had been used as enroute alternates for routes over oceanic and/or desolate land areas. The increasing number of polar flights, while creating economic benefits, had brought new challenges. The reduction in operational infrastructure began to significantly affect the viability of all long-range twin-engine operations under current regulations and likewise began to erode the basic safety net that long-range operations in three- and four-engine airplanes had relied upon.

Because of these pressures and the increasing commonality of all long-range operations, people concerned about these operations looked at the data again and realized that the data were showing that ETOPS requirements and processes were generally applicable to all long-range operations, including those of three- and four-engine airplanes and would improve the safety and viability of all long-range operations. ALPA and others in the airline industry believed that all long-range airplanes, regardless of the number of engines, needed a viable diversion airport in the case of onboard fire, medical emergency, or catastrophic decompression. Ensuring availability of enroute alternate airports, adequate firefighting coverage at these airports, and fuel planning to account for depressurization are sound operational practices for all airplanes, including three- and four-engine airplanes. Likewise, all airplane time-critical systems should account for the maximum allowable diversion and worst-case scenarios. To address these issues, ALPA felt that a reasonable approach was to demand that many of the ETOPS requirements, based on sound safety principles and successfully proven over many years, should be applied to all long-range operations.

For 2½ years, under the auspices of the Aviation Rulemaking Advisory Committee (ARAC), the airline industry has had an ETOPS Working Group undertaking that task. ALPA has once again participated actively. Capts. Bud Musser (Delta), Mike Hynes (Continental), Tom Phillips (US Airways), and I made up the ALPA team.

The first phase of this effort was completed when the ARAC Working Group submitted its 231-page report to the FAA on Dec. 16, 2002. The report was a broad and extensive review covering 22 federal aviation regulations, of which 13 are totally new and 17 are specific to air carrier operations. Responding to the Working Group’s mandate, the report covers the operations and certification of ETOPS airplanes in large transport category operations (FAR Part 121 and cargo), as well as commuter and charter operations (FAR Part 135). It also covers the certification of engines and maintenance procedures used in ETOPS.

This submission is a significant step in the evolution of ETOPS and all long-range operations; and if the FAA accepts it and subsequently publishes it as a final rule, it will herald a sea change in the way the airline industry views and manages long-range operations.

The road between submission and implementation is long, however. Although one cannot determine the exact timeline for this process, the assumption is that the FAA will spend the greater part of 2003 reviewing and refining the document before publishing it in the Federal Register in the form of a notice of proposed rulemaking (NPRM) for public review and comment. At that time, the airline industry will have an opportunity to make formal comment to the FAA, and the FAA will then review the body of comments for inclusion (or not) into the final rule. Publication of a final rule is probably several years away.

During the entire 2½-year process of developing the report, I and the others representing ALPA on the ARAC Working Group have been keeping your MECs and central air safety chairmen informed of the issues and the progress of the Working Group’s efforts. We have been acting on the safety chairmen’s direction and your behalf, reporting regularly to them.

Now that the ARAC has submitted its product, the report has become public, and I am able to brief you directly on the issues. As you can imagine, a 231-page document of the scope I have described can be quite complicated. For that reason, I will highlight only the important points and describe the major changes and issues that will occur when and if the FAA adopts these principles as a final rule.

I must mention several other ETOPS initiatives that are also under way. The European airline industry, under the auspices of the Joint Aviation Authorities (JAA), is developing its own set of new ETOPS and long-range rules. This effort started about 6 months after the ARAC process and is currently nearing completion. ALPA, as a member of the International Federation of Air Line Pilots Associations (IFALPA), is currently represented by several foreign carrier pilots and me in this European initiative. Although differences exist between the JAA effort and that completed by the ARAC, the majority of those issues and positions I will include are the same. Likewise, the International Civil Aviation Organization (ICAO) has a concurrent process under way covering the same issues, and I represent ALPA as a member of that working group, as well.

In December 2002, the ARAC ETOPS Working Group successfully completed three basic tasks:

1. Codifying all current twinjet ETOPS practices in the FARs and rationalizing current requirements.

2. Expanding twinjet ETOPS authority in the FARs and developing enhanced operational and certification requirements for this new authority.

3. Applying within the FARs similar practices for all three- and four-engine airplanes operating in ETOPS and normalizing these new requirements to twinjet ETOPS criteria.

First, note that the term ETOPS has been redefined. The new definition, as proposed in the ARAC report, is: Extended operations with twin-engine airplanes beyond 60 minutes flight time at single-engine cruise speed from an alternate landing airport and beyond 180 minutes from an alternate for an airplane having three or four engines. This revision captures long-range operations of three- and four-engine airplanes in the definition.

The operations of twin-engine airplanes operating in ETOPS are generally broken into two basic types: ETOPS at 180 minutes or less (current operations to include the 207-minute authority in the North Pacific), and ETOPS beyond 180 minutes (new authorities).

I. For operations of twin-engine airplanes more than 60 minutes and up to 180 minutes from an alternate airport, the following points are germane:

• Operations are generally the same as present.

• The current 75-, 120-, 138-, and 180-minute authorities have been retained, as has the 207-minute authority and its limited application to the North Pacific.

• A new 90-minute authority for Micronesia similar to the 75-minute authority in the Caribbean (no maintenance inspection on the outbound leg) has been created.

• All current ETOPS requirements are now codified in the regulations.

• Certain aspects of the current enroute alternate dispatch weather requirements have been reduced and normalized to international standards.

• Certain current fuel requirements have been reduced for the critical fuel scenario, based on improvements in wind-forecasting techniques and ice-accretion analysis.

II. Operations of twin-engine airplanes have been expanded to encompass authorities beyond 180 minutes from an alternate airport. These added authorities are, however, limited in frequency (specific need) and scope (geographical area). Likewise, 180-minute ETOPS has been set as a benchmark. Regulatory language requires that the operator "shall make every attempt to minimize diversion distance along the preferred track and plan ETOPS operations at a maximum diversion distance [time] of 180 minutes or less." This new authority also requires the operator to consider the current winds’ effect on possible diversion distances during flight planning, and all airplane systems must be designed to "support" the diversion. This means that each airplane system must be capable of functioning to protect the airplane during the maximum divert authority plus 15 minutes.

The specific, new proposed authorities are as follows:

• This area is governed by current 180-minute ETOPS authority, with the ability to gain an exception on a case-by-case basis to go to 240 minutes based only on weather extremes at the alternates.

• Polar weather-related requirements are addressed and follow the guidelines that are outlined in the current FAA Polar Operations Letter.

• The operation requires a new, 240-minute type design for the airframe/engine combination (AEC).

• The inflight shutdown rate (IFSD) may not exceed .01/1,000 hours—i.e., one inflight engine shutdown for every 100,000 hours of flight time of that engine/airframe combination by that airline (half the current 180-minute criteria of .02/1,000 hours).

• This authority is limited to the Pacific Ocean between the U.S. West Coast and Australia, New Zealand, and Polynesia; South Atlantic oceanic areas; Indian Ocean areas; and oceanic areas between Australia and South America. Notably excluded are the North Atlantic and Central Pacific, where this authority is not needed, based on alternate availability.

• Again, all twin ETOPS greater than 180 minutes require maintaining an IFSD of .01/1,000 hours of flight time or better.

• This authority is "unlimited" based on type design and need.

• This authority is again limited to the Pacific Ocean between the U.S. West Coast and Australia, New Zealand, and Polynesia; South Atlantic oceanic areas; Indian Ocean areas; and oceanic areas between Australia and South America.

• Again, the .01/1,000 flight hours IFSD requirement applies.

• This authority can be given only to an operator that has had 2 years of ETOPS experience beyond 180 minutes, with at least 12 consecutive months of 240-minute experience.

• This authority will be requested and granted only on a city-pair basis.

Significantly, a regulatory framework will now apply to operations of three- and four-engine airplanes operating beyond 180 minutes from an enroute alternate airport.

Regulations applicable to long-range operations of three- and four-engine airplanes beyond 180 minutes include the following:

• Requirements for ETOPS maintenance, operations, and dispatch are similar to those for ETOPS twins.

• All airplane systems must be designed to "support" the diversion. Once again, this means that each airplane system must be capable of functioning to protect the airplane during the maximum divert authority plus 15 minutes.

• A route must be planned to the nearest available alternate within 240 minutes of the airplane’s planned routing, or if unable, up to the airplane’s system capabilities. The basic regulatory requirement is, "The operator must designate the nearest available ETOPS alternate(s) along the planned route of flight."

• All flights must also abide by the specific polar operational requirements when within that region.

• These requirements for enroute alternates, commensurate type design, and proactive flight following when beyond 180 minutes from an alternate are all contained in the FARs.

To summarize, ALPA and the airline industry have achieved the following with regard to long-range operations of two-, three-, and four-engine airliners:

• Regulations will require operators of three- and four-engine ETOPS airplanes to dispatch with an enroute alternate airport. Such operations will require ETOPS-like maintenance, operational, and dispatch functions.

• The maximum diversion authority for any ETOPS airplane will be limited to that airplane’s most time-limited system plus 15 minutes (for approach and landing). Previously, this applied only to twins.

• A new requirement for a passenger recovery plan for all ETOPS airplanes (twins from 60 minutes).

• All operations and their requirements are codified in the regulations rather than simply placed in an advisory circular.

• All enhanced systems/MEL requirements for 207-minute ETOPS have been carried forward in the regulation for any twin ETOPS greater than 180 minutes.

—At a minimum, an airplane will be required to have three independent electrical generators for ETOPS.

—For ETOPS greater than 180 minutes, an airplane must have at least one boost pump powered by a standby electrical power source.

• A new regulation will require reliable voice communication for all operations that are greater than 180 minutes. Previously, only "rapid and reliable" communication with the flight crew was required and that could be satisfied with datalink only.

• A new regulation will require operators to account for wind in the divert scenario beyond 180 minutes for all airplanes.

• A new regulation will require a higher level of airport rescue and firefighting (ARFF) services than is currently required at enroute alternate airports.

• A regulation will require a flight crew to reevaluate alternate airport weather before proceeding beyond the ETOPS entry point and to have suitable alternates (i.e., operational weather minimums) before proceeding.

• All airliners must be type-designed for their maximum diversion authority.

• Specific crew training and qualifications for all ETOPS (two-, three-, and four-engine airliners) greater than 180 minutes will be codified in the regulations.

• B-777 and A330 systems architecture will be required as a minimum for ETOPS beyond 180 minutes.

If you have any questions, please feel free to contact me or the members of your MEC safety structure. Keep in mind that until the FAA issues these documents in the Federal Register and considers all public comments in response to the NPRM, none of this will become regulatory.