AIN Blog: Torqued: Emergency AD Inappropriate in Case of Boeing 787

 - March 1, 2013, 12:10 AM

Since when is an Emergency AD used to ground an aircraft fleet, as it has been in the case of the Boeing 787 Dreamliner? First off, let me be clear that if anything good can be said of the Boeing Dreamliner nightmare it’s that no one had to die before the FAA would take definitive action to ground the 787 until its battery fire problems could be investigated properly. That’s a big deal indeed. There’s no question in my mind that further operations without understanding and correcting what was happening to the batteries would have placed an unacceptable level of risk on the passengers, crew and aircraft. I’ve walked through the charred wreckage of too many aircraft accidents–and met with far too many grieving relatives of the victims–not to appreciate the significance of this moment. 

Yes, it should be obvious that when the FAA learns of a significant threat to air safety–and an onboard fire anywhere on an aircraft surely qualifies–it has a duty to act, and act immediately. Bureaucrats in Washington cannot allow passengers or crewmembers to be flying guinea pigs while they try to figure out what the problems are and how to fix them. But this is not often the FAA way. Whether it’s held captive to the aviation industry or just has a difficult time making tough decisions, the agency–on far too many occasions–has failed to take appropriate action until after a deadly accident. So often it’s only under the intense media pressure of a disaster, and the unrelenting lobbying of family members of the deceased, that the FAA is finally forced–usually by Congressional direction–to make safety improvements. 

And, yes, I know that the groundings in Japan probably forced the FAA’s hand in this case. The FAA issued the emergency AD only after both Japan Airlines and All Nippon Airways announced that they would ground their fleets, following the emergency landing of the ANA 787. That emergency landing was prompted by an unusual odor in the cockpit that was traced to a battery fire. Yet it’s still nice to see that the FAA can act quickly in the face of a significant safety question. 

And, of course, the problems with the lithium-ion batteries (it’s not exactly a surprise that they have problems with overheating and catching fire) may lead back to the way the FAA certifies new aircraft types. Many of its own engineers have complained in recent times that too much work is delegated to designees and the agency provides so much less oversight than it did in the past. This problem is no doubt exacerbated by the challenges of overseeing development of an aircraft whose component parts are produced all over the world, many of them thousands of miles from any FAA certification office.

Type Certificate Action Warranted

I don’t question that a grounding of the 787 fleet was prudent and necessary in the interests of air safety. But I do question the use of an Emergency Airworthiness Directive to accomplish that grounding, when no fix is provided. There’s no inspection that’s mandated, no corrective action that needs to be taken. The action required is a marvel of government gobbledygook. Under the heading AD Requirements, it states: “[T]his AD requires modification of the battery system, or other actions, in accordance with a method approved by the manager, Seattle Aircraft Certification Office (ACO) FAA.” What does that mean when no method is provided? 

What it means to me is that the FAA engaged in linguistic–if not legalistic–contortions to arrive at this method of grounding the fleet. In the process it basically made a sham of the airworthiness directive process. Why does that matter, you ask?  Well, first, the government shouldn’t engage in legal contortions for one entity that it perhaps wouldn’t do for anyone else. Process matters, and treating everyone the same is a worthy government goal.

So what I deduce from this extreme stretching of the AD process is that the FAA was trying to ground the fleet without pulling the 787’s type certificate. I can understand that Boeing would have fought hard to keep the agency from pulling its type certificate. Clearly that would have impugned the aircraft and Boeing’s design and manufacturing far more than an Emergency Airworthiness Directive. But does that make it the right thing to do?

Those of us old enough to remember the 1979 grounding of the McDonnell Douglas DC-10 remember that it was accomplished by pulling the aircraft’s type certificate. In that case, after American Airlines Flight 191 crashed on takeoff from Chicago O’Hare Airport on May 25, 1979, killing all 271 on board and two people on the ground, investigators determined that the accident occurred because of faulty maintenance procedures. But investigators also found a design flaw in the aircraft. Because of that design flaw, the FAA suspended the DC-10’s type certificate. Once the design flaw was fixed, the FAA lifted the order suspending the type certificate.

The FAA pulled the type certificate because of questions it had regarding the aircraft design, and pulling the type certificate was the only way to legitimately halt operation of the aircraft. The agency didn’t issue an Emergency AD to the aircraft operators, because aircraft operators can’t fix design or manufacturing problems.

Which brings me to the Emergency AD on the Boeing 787. It’s pretty clear that United–currently the only U.S. operator of the type–can’t fix a design or manufacturing problem with the aircraft, its electrical system or its batteries and that any FAA order should have been directed at the manufacturer, Boeing. So what difference does it make? The aircraft is grounded, right? Well, it may end up making a difference when a supposed fix is found for the problem. It’s a lot easier to say that an AD has been complied with than to ensure that the requirements of a type certificate have been met.


Roland Delhomme's picture

With a six year history of cover-up, and multiple incidents of highly exothermic events in ground test, in flight test, and in passenger service, there's no way the FAA was going to own up to to having failed to mandate a safer design-not as long as Boeing's long arm of influence could exert pressure in DC. The current fix is an insult to the Boeing workforce and contractor team, but a monument to the arrogance of McNerney and his skill at manipulating the FAA; the DC press conference/Boeing infomercial after the JAL flight was the clear signal that Boeing was calling the shots.

Roger Lowry's picture

This problem is basically about the wisdom of allowing combustible batteries [Li-ion / Li-polymer] to be used in aircraft at all....................
Lead-acid and Nickel-alkaline batteries NEVER catch fire: Their electrolyte is
Li-ion batteries are not allowed to be transported by air......................
Combustible upholstery materials are not allowed in airplanes.............
Lead-acid RV/Marine batteries could replace the Li-ion at a weight penalty of about 100lb per 787.
It is incredible that $6M per day is being thrown away on a problem that any good auto electrician could solve for about $2000 per plane [but would not get FAA/DOT/NTSB approval].
Maybe the batteries are not the REAL problem................................'s picture

The current 787 woes do not seem to be restricted only to 1)the battery, but also
2) - smoke being reported to have escaped into the cabin and cockpit, and
3) - possible damage to the composite fuselage.
These possible dangers were included in specific 787 FAA
airworthiness Special Condition requirements.

Roger Lowry's picture

At 25 degrees Centigrade the LVP-65 can supply almost 4 volts at 250 amps for 15 minutes; AMAZING!
BUT it requires 50 amps at 4 volts for 3 hours to charge the cell in the first place........
Energy supplied per cell to charge: 600 watt-hours.
Energy actually stored in cell: 250 watt-hours.
Energy lost in heat charging cell: 350 watt-hours i.e. 1.26 Megajoules i.e. 301 Kilocalories.
Mass of cell 2.75 Kilograms; therefore maximum possible thermal capacity 2.75 Kcal./deg. Centigrade.
Minimum temperature rise in cell during charge [without external cooling]: 301000/2750 i.e. 109 deg C.
Stack eight of these cells to make a 787 battery and after charging, the outer cells will be at 25+109 i.e. 134 degrees C while the middle cells will certainly be much hotter than this, AND there will be hotspots at even higher temperatures..........
If I owned a 787 I would want to fit 13-cell lead acid batteries with their greater tolerance to abuse, simpler charging requirements, and zero tendency to self-ignition.

Geo's picture

Seems to be a difference without a distinction. Did the Japanese ground their a/c through an ad-like mechanism or did the Japanese airworthiness authorities pull their certification of the Boeing airframe?

In any event if Boeing was in the pocket of the US FAA the United aircraft, at least, would have been returned to service by now.

I think what is happening is that the FAA and best industry people are looking into all aspects of the design and manufacturing of this airframe. I think the battery may be only one of several issues, perhaps not even the major one.

Vipanch's picture

Who provides you to install Li-ion batteries on aircrafts?!
Of course, Li-ion batteries are good on celular phones, note-books and more on
But sport-car provides only one people and in "one way"...
On aircraft are flying one hundred lives! And we ought to remember about safety
at first.
We know about knew conception of Li-ion batteries on sport-cars "Honda" and
"Tesla", very good compact, but its good for one way and for one man, its are
working on the ground and in the field of view...

Li-ion batteries are dangerous!
1. Deep discharge can destroy battery and more - can provide to explosion.
Only for this one, Li-ion batteris can't install on aircrafts.
2. Li-ion battery grows old yet without exploitation.

Read physics and chemistry. Lithium is a very active element of I group of
Mendeleev table. So, all processes with it are quick and very active...

What to do?
Good practice provides us to NiMH batteries.
Good experience we can see on "Toyota-Prius" scheme.
As conception of construction of batteries as well as complete electronic scheme
of managing.
Apart of this one - a traditional construction of NiMH batteries, for now are well
known so called LSD-batteries. Low self-discharge physical with contemporal inno-
vation of chemistry processes and technics of producing of elements give SANYO
exclusive new batteries. But this is another theme for discussion...

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