If the “basic” A32xneo didn’t require a seperate TC, it’s hard to argue that what is effectively installing a larger centre-tank would do so.

The 10MAX is at risk it if fails to meet the 31DEC deadline, as all aircraft certified after that date must have (EI)CAS installed as standard. FAA is, in my opinion, likely to extend the deadline, but the question is whether the other big NAAs are going to follow suit.

The 777X is a strange kettle of fish. Looking back in history, discussing whether it should require a new TC would be largely pointless. Following the MAX scandal everything changed as we all know, and if anything this model may therefore carry the biggest risk. That would be a major setback, not only when it comes to a delayed EIS, but also because of the added certification costs and the loss of having a single 777 pilot pool. This may place some orders at risk, which in turn may jeopardise the financial viability of the program.

The Leeham article has some very interesting points at the end, regarding the current state of Boeing (and not just BCA). Not the best of times, to put it politely.

While some of these may not 'need' a new certificate in a technical sense (I feel like the A321XLR needing a new type certificate is a real stretch), maybe they're needed to restore and bolster public confidence in these processes and procedures?

B777LRF wrote:

If the “basic” A32xneo didn’t require a seperate TC, it’s hard to argue that what is effectively installing a larger centre-tank would do so.

The 10MAX is at risk it if fails to meet the 31DEC deadline, as all aircraft certified after that date must have (EI)CAS installed as standard. FAA is, in my opinion, likely to extend the deadline, but the question is whether the other big NAAs are going to follow suit.

The 777X is a strange kettle of fish. Looking back in history, discussing whether it should require a new TC would be largely pointless. Following the MAX scandal everything changed as we all know, and if anything this model may therefore carry the biggest risk. That would be a major setback, not only when it comes to a delayed EIS, but also because of the added certification costs and the loss of having a single 777 pilot pool. This may place some orders at risk, which in turn may jeopardise the financial viability of the program.

The Leeham article has some very interesting points at the end, regarding the current state of Boeing (and not just BCA). Not the best of times, to put it politely.

The EICAS deadline is a deadline imposed by a law passed by the US congress and signed into law. The FAA can't extend the deadline, only congress can. The other NAAs do not have the same deadline.

The FAA became lax which led to the terrible MCAS design getting certified. Now the FAA has gone too far in the other direction and it is creating certification gridlock. The MAX 7 is just a shrink of the MAX 8 and it was used as the test bed for MAX 8 and MAX 9 recertification but it still isn't certified several months after the package was submitted to the FAA.

This doesn't just hurt Boeing as the other manufacturers will go through the same delays.

Cessna got the SkyCourier certified this year.

Opus99 wrote:

I think when you look at Boeings problems in a list like that it’s kind of scary

And it doesn't list the 737-7 which isn't certified (though everyone expects it soon), and the 787 - which has a type certification, but FAA pulled Boeing's certificate issuance authority related to production.

The SkyCourier is a clean sheet and a very basic airplane for the 9 and 19 seat category, it still took months and months longer than Cessna expected.

If the A321XLR does require a clean sheet certification while the A321LR didn't just a bit earlier it basically means that grandfathering is effectively dead. As so much is being digitally modeled to confirm the design, it appears the FAA & EASA wants an accurate digital model going forward for certifications, no longer references back to earlier certifications dating from when slide rules were used for the design.

Not mentioned was the new cockpit requirements that was part of the reason the MOM went quiet, are these revised regulations out, what is the standard for this new cockpit. There may be a silver lining here in that the 'new' cockpit is basically ready to be single pilot or autonomous except for the need for instrument observers for when the automation needs to be rebooted.

planecane wrote:

The FAA became lax which led to the terrible MCAS design getting certified. Now the FAA has gone too far in the other direction and it is creating certification gridlock. The MAX 7 is just a shrink of the MAX 8 and it was used as the test bed for MAX 8 and MAX 9 recertification but it still isn't certified several months after the package was submitted to the FAA.

This doesn't just hurt Boeing as the other manufacturers will go through the same delays.

I have very little sympathy for Boeing here, it was their corporate culture that pushed their DERs to try and reduce the cost they provided to airlines saying the MAX was the same as the NG. If they were not hell bent on this point, they would not have the problems they are having now. This is the bed they made, it is not the rank and file engineers and technicians that caused this, it is Boeing management.

I don’t see why they need to change the arrangements on amended type certificates. The system, as far as I can tell was pretty good and was basically “having an aircraft in demonstrably safe operation is as good as having an aircraft designed to the latest standards”, an official safety standard of better the devil you know. The reasoning behind it was sound, just because the execution was poor by Boeing and the FAA doesn’t seem like a good reason to get rid.

Fred


Sent from my iPad using Tapatalk

planecane wrote:

The EICAS deadline is a deadline imposed by a law passed by the US congress and signed into law. The FAA can't extend the deadline, only congress can. The other NAAs do not have the same deadline.
.

The chair of the oversight committee that has been handling this has already said she'd grant an extension if the FAA agreed.

https://www.aviationpros.com/aircraft/n ... afety-rule

Brazil, Canada, China, Japan and Russia previously raised with ICAO and WTO, that generous grandfathering creates barriers of entry for new models and OEM's, stifles innovation, and protects the duopoly. Canada will be quiet now. Post-MAX, the others will be waving the safety card.

zeke wrote:

planecane wrote:

The FAA became lax which led to the terrible MCAS design getting certified. Now the FAA has gone too far in the other direction and it is creating certification gridlock. The MAX 7 is just a shrink of the MAX 8 and it was used as the test bed for MAX 8 and MAX 9 recertification but it still isn't certified several months after the package was submitted to the FAA.

This doesn't just hurt Boeing as the other manufacturers will go through the same delays.

I have very little sympathy for Boeing here, it was their corporate culture that pushed their DERs to try and reduce the cost they provided to airlines saying the MAX was the same as the NG. If they were not hell bent on this point, they would not have the problems they are having now. This is the bed they made, it is not the rank and file engineers and technicians that caused this, it is Boeing management.

Boeing suffered major consequences due to the culture and bad decisions. I don't think they should continue to be punished for bad decisions made 10 years ago or more recent decisions made by people who are no longer at Boeing. There is no doubt that the FAA needed to have more direct oversight for aircraft certification so that something similar to the MCAS situation doesn't happen again.

However, there is no need to go to a ridiculous extreme that causes things like the MAX 7 to still not be certified even though it is just a shrink of the MAX 8 and was used as the test bed for the MAX recertification. It isn't just Boeing that suffers from this. Airlines waiting for the new variants suffer. You can argue that the environment suffers since these much more efficient models can't be put into service to save 15% of the fuel being used by the aircraft they will replace. Airbus will also suffer because the FAA will have to apply the same standards to their aircraft and we'll see things like a ridiculous length of time to certify a new fuel tank on an aircraft that is already certified and has been for several years.

I also disagree that the rank and file engineers should not be blamed. The engineering of the MCAS system was incompetent. It doesn't matter what pressure management applied or what deadlines were imposed. As an engineer you just can't put out such an unsafe design. The failure scenario wasn't some kind of swiss cheese model that was difficult to predict with a fault tree. It was the simplest and most obvious failure mode.

Years ago, I was an engineer for a cell phone manufacturer. We were extremely diligent with fault tree analysis to ensure that no failure would cause the earpiece speaker to exceed the maximum safe SPL. There was no risk of somebody being killed if we didn't get the design right but I would have been disciplined or terminated if I approved a design where a single sensor failure could lead to unsafe sound levels. The management certainly gets a large share of blame but I will not just forgive the rank and file because they were under pressure from the evil executives.

I have a feeling most of these certification delays stem from a time when Boeing could just give the FAA some pieces of documentation and it was ok.

Now the FAA actually demands full documentation of every piece of code, hardware and analysis and Boeing just does not have the stuff because they took it too easy a few years ago. You could argue that this is nitpicking but to be fair if stuff is not documented correctly it will be really hard in the future to trace back where an error happened.

MCAS showed this pretty horrificly. So the FAA demands now full documentation of everything and Boeing has to deliver.

It is like writing code. If you do not comment every function, what it does and why it is there, the next programer will have a hard time understand the code (it will take ages at least). Good code should have as much comments as actually working code.

Boeing must have skipped a lot of documentation during previous development and certification and now they have to go back and get it straight. And from an outside perspective that is what I excpect form someone that develops and builds aircraft. Of course it sucks when you are caught and have to go back and actually do the work but you should not have skipped it in the first place.

There is a reason companies get audited and have to show every single recipt if asked for, same standard should apply for aircraft certification too and just now the FAA actually does that and Boeing can not deliver because they just skipped it in the past.

planecane wrote:

Boeing suffered major consequences due to the culture and bad decisions. I don't think they should continue to be punished for bad decisions made 10 years ago or more recent decisions made by people who are no longer at Boeing. There is no doubt that the FAA needed to have more direct oversight for aircraft certification so that something similar to the MCAS situation doesn't happen again.

I don’t think the hundreds of passengers and crew that lost their lives, airlines that had their reputations damaged, the hundreds of thousands of passengers and the large number of airlines that had their MAX fleets (and some still do) disrupted and grounded will agree.

IMHO Boeing has got off easy because of COVID

planecane wrote:

I also disagree that the rank and file engineers should not be blamed. The engineering of the MCAS system was incompetent. It doesn't matter what pressure management applied or what deadlines were imposed. As an engineer you just can't put out such an unsafe design. The failure scenario wasn't some kind of swiss cheese model that was difficult to predict with a fault tree. It was the simplest and most obvious failure mode.

It was not rank and file engineers that set the policy that no additional training will be required for the MAX, and it was not rank and file engineers that wanted to keep non redundant systems, these were top level management directions.

zeke wrote:

planecane wrote:

I also disagree that the rank and file engineers should not be blamed. The engineering of the MCAS system was incompetent. It doesn't matter what pressure management applied or what deadlines were imposed. As an engineer you just can't put out such an unsafe design. The failure scenario wasn't some kind of swiss cheese model that was difficult to predict with a fault tree. It was the simplest and most obvious failure mode.

It was not rank and file engineers that set the policy that no additional training will be required for the MAX, and it was not rank and file engineers that wanted to keep non redundant systems, these were top level management directions.

Didn't the rank and file engineers voice their concern of this non-redundant half-fast done system? Weren't those concerns shut down by higher management?

alancostello wrote:

While some of these may not 'need' a new certificate in a technical sense (I feel like the A321XLR needing a new type certificate is a real stretch), maybe they're needed to restore and bolster public confidence in these processes and procedures?

Am not sure the need to restore public confidence would have any relevance whatsoever though, in the sense that probably 99.9% have no real need to know of it. Whilst most of the general public certainly have knowledge and interest (irrespective of 'claims' to the contrary on a.net) there are obviously aspects of no interest at all. For example, other than airlines themselves, who 'needs' to know that really the only difference in the A321XLR is that it has a new centre tank fuel system, or indeed, why would they be interested in such?

planecane wrote:

The FAA became lax which led to the terrible MCAS design getting certified. Now the FAA has gone too far in the other direction and it is creating certification gridlock. The MAX 7 is just a shrink of the MAX 8 and it was used as the test bed for MAX 8 and MAX 9 recertification but it still isn't certified several months after the package was submitted to the FAA.

This doesn't just hurt Boeing as the other manufacturers will go through the same delays.

The FAA had some responsibility yes, but they were not responsible for the design of MCAS, nor Boeing lying simply to reduce costs to avoid certification.

planecane wrote:

Boeing suffered major consequences due to the culture and bad decisions. I don't think they should continue to be punished for bad decisions made 10 years ago or more recent decisions made by people who are no longer at Boeing. There is no doubt that the FAA needed to have more direct oversight for aircraft certification so that something similar to the MCAS situation doesn't happen again.

But yet it was due to the intense, and expensive, lobbying by Boeing itself which led to the FAA having major responsibilities removed from it, in order that Boeing could continue to hide it's bad safety/management culture and cost cutting practices. The same US Congress that then implemented the new laws, which Boeing (and the likes of yourself) still does not want to comply with by looking for more waivers/extensions.

Remember this is all based on gossip that Hamilton picked up at a New York convention, no actual facts

Vicenza wrote:

But yet it was due to the intense, and expensive, lobbying by Boeing itself which led to the FAA having major responsibilities removed from it, in order that Boeing could continue to hide it's bad safety/management culture and cost cutting practices. The same US Congress that then implemented the new laws, which Boeing (and the likes of yourself) still does not want to comply with by looking for more waivers/extensions.

In this case, it isn't Boeing trying to get a waiver or extension due to something that is under their control. The FAA isn't able to handle the current workload of pending certifications in a timely fashion. If the deadline isn't met it will be due to the FAA not processing the application in time, not because Boeing didn't submit the required data and documentation in time.

The MAX 7 is essentially the exact same aircraft as the MAX 8. It is a simple shrink. The MAX 7 was used to gather the flight test data on the MCAS fix to recertify the MAX 8 and MAX 9. The FAA still hasn't certified the MAX 7 which indicates that they are incapable of performing their work in a timely fashion.

Even with the added AoA and airspeed redundancy systems and the gear modifications on the MAX 10, it shouldn't take over a year from submission for the FAA to certify a derivative in the same generation of a family of already certified aircraft.

The deadline for requiring EICAS on new certifications was completely arbitrary and set because they had to pick a date as the deadline. The intent of the law wasn't to force an already produced 737 derivative to incorporate EICAS. The intent was to prevent a new generation of aircraft from being grandfathered out of the requirement.

That's why I'm certain that congress will grant the extension. It isn't like Boeing is trying to get 3 more years added to have time to design the 737 UltraMAX and get around having to add EICAS.

JayinKitsap wrote:

The SkyCourier is a clean sheet and a very basic airplane for the 9 and 19 seat category, it still took months and months longer than Cessna expected.

If the A321XLR does require a clean sheet certification while the A321LR didn't just a bit earlier it basically means that grandfathering is effectively dead. As so much is being digitally modeled to confirm the design, it appears the FAA & EASA wants an accurate digital model going forward for certifications, no longer references back to earlier certifications dating from when slide rules were used for the design.

Not mentioned was the new cockpit requirements that was part of the reason the MOM went quiet, are these revised regulations out, what is the standard for this new cockpit. There may be a silver lining here in that the 'new' cockpit is basically ready to be single pilot or autonomous except for the need for instrument observers for when the automation needs to be rebooted.

Grandfathering was killed 20 years ago, formally.
https://www.flightglobal.com/faa-rules- ... 15.article

When 787 development costs and time had exploded, a NEO competitor and 77W successor were urgently needed, grandfathering of requirements and design was rediscovered and embraced.
Meanwhile FAA was held in a strangulation by congress
https://www.gao.gov/assets/gao-17-508t.pdf

Using the FAA re-authorizations / cost cutting putting pressure to "streamline" the slow and bureaucratic FAA.
The Hill was cheered on by US Aerospace organizations (AIA) and representatives.
https://www.aia-aerospace.org/wp-conten ... 017_v3.pdf

It all happened in the previous decade and (almost) all key players around are staying low, trying hard to forget
Attacking the FAA, Muilenburg, other individuals. But Google is our friend..

I can see letting an airframe getting 2 generations out of it but after that the changes are 2 drastic and it really stops innovation. I think it is a good thing that the 737-MAX10 is so different as is the 777X they both need to be separate types.

Do you think all potential derivative aircraft would be impacted?

VV wrote:

Do you think all potential derivative aircraft would be impacted?

I was thinking about the A220-500 that has been lengthily discussed here in airliners.net.
The aircraft version is the one that could become a very huge success.

Do you think the certification would be an issue in light of the discussion in this thread?

@Mods Should this thread be transferred to Tech/Ops considering the detailed discussion on type certification?