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aeronavegar
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ETOPS certification of passenger-to-freighter converted aircraft

Wed Nov 09, 2022 7:22 pm

I've read that the Boeing 737-800BCF and IAI's 737-800BDSF are not ETOPS certified, but AEI's 737-800SF is... Curious to understand why this is the case.
1) Does an aircraft that is type-certified, from a design/configuration perspective (such as a passenger 737-800, approved for 180 minutes ETOPS), lose its ETOPS certification if it's later converted to a freighter?
2) If that's the case, is it because of the Class E Main Deck Cargo Compartment installed as part of the P2F conversion, which doesn't have a fire suppression system, or for another reason? The assumption here being (please confirm) that all cargo compartments need to be Class C (with a fire suppression system) in ETOPS-certified aircraft (?).
Understanding that the operator is also responsible for obtaining operational approval for ETOPS, via an ETOPS maintenance program, my questions above are limited to the aircraft's pre-conversion configuration and type-certification, and what the impact of modifying the aircraft per a passenger-to-freighter STC is on ETOPS certification.
 
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exFWAOONW
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Thu Nov 17, 2022 8:52 pm

Many variables in play here.
Is ETOPS required for freight? I don't think it is, but I might be all wet. It might be a local requirement for certain freighters.
The A/C that kept ETOPS during conversion may be subject to leasing terms, where the residual value of the A/C is less without the ETOPS certification still current.
Different conversion facilities have different procedures for converting A/C that are certified by the local or end-use governmental authority. They cannot deviate from the certified procedure for just a plane or two.
 
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Starlionblue
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 12:28 am

exFWAOONW wrote:
Many variables in play here.
Is ETOPS required for freight? I don't think it is, but I might be all wet. It might be a local requirement for certain freighters.
The A/C that kept ETOPS during conversion may be subject to leasing terms, where the residual value of the A/C is less without the ETOPS certification still current.
Different conversion facilities have different procedures for converting A/C that are certified by the local or end-use governmental authority. They cannot deviate from the certified procedure for just a plane or two.


Yes, ETOPS/EDTO is required for freight. Why would it not be?
 
kalvado
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 1:23 am

Starlionblue wrote:
exFWAOONW wrote:
Many variables in play here.
Is ETOPS required for freight? I don't think it is, but I might be all wet. It might be a local requirement for certain freighters.
The A/C that kept ETOPS during conversion may be subject to leasing terms, where the residual value of the A/C is less without the ETOPS certification still current.
Different conversion facilities have different procedures for converting A/C that are certified by the local or end-use governmental authority. They cannot deviate from the certified procedure for just a plane or two.


Yes, ETOPS/EDTO is required for freight. Why would it not be?

For example, there is some slack in part 135:
14 CFR § 135.364 Maximum flying time outside the United States.

After August 13, 2008, no certificate holder may operate an airplane, other than an all-cargo airplane with more than two engines, on a planned route that exceeds 180 minutes flying time (at the one-engine-inoperative cruise speed under standard conditions in still air) from an Adequate Airport outside the continental United States unless the operation is approved by the FAA in accordance with Appendix G of this part, Extended Operations (ETOPS).

Risk analysis of 2 vs 200 souls and possibly some compensation limitations along the lines of "pilots should understand the risks of their job" may result in some differences.
 
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Starlionblue
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 1:50 am

Fair point, and the same is valid at my operator. But this doesn't remove EDTO. It simply moves the ETOPS/EDTO threshold from 60 to 180 minutes for aircraft with more than two engines.

Of course, this thread started specifically discussing a twin. :)
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 3:47 am

aeronavegar wrote:
I've read that the Boeing 737-800BCF and IAI's 737-800BDSF are not ETOPS certified, but AEI's 737-800SF is... Curious to understand why this is the case.
1) Does an aircraft that is type-certified, from a design/configuration perspective (such as a passenger 737-800, approved for 180 minutes ETOPS), lose its ETOPS certification if it's later converted to a freighter?

Any STC can impose additional limitations on aircraft so converted; I don't know about Boeing and IAI specifically but there is nothing inherent about P2F conversions that would prevent ETOPS certification. It's possible Boeing may not have wanted to certify their STC under ETOPS for cost or liability reasons.

2) If that's the case, is it because of the Class E Main Deck Cargo Compartment installed as part of the P2F conversion, which doesn't have a fire suppression system, or for another reason? The assumption here being (please confirm) that all cargo compartments need to be Class C (with a fire suppression system) in ETOPS-certified aircraft (?).

All-cargo aircraft are not required to have fire supression, even for ETOPS operations, as the number of engines has nothing to do with a potential cargo fire. ETOPS is only concerned with the maximum time an airplane could be required to operate on a single engine.
 
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Starlionblue
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 10:25 am

As I understand it, ETOPS/EDTO limits are very much dependent on cargo fire suppression capability.

The remaining engine will most likely operate until it runs out of oil and fuel.
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 3:12 pm

Starlionblue wrote:
As I understand it, ETOPS/EDTO limits are very much dependent on cargo fire suppression capability.

Why would they? There are plenty of MD-11Fs and 747Fs flying around with no fire suppression systems and without any regard to ETOPS requirements.
 
aeronavegar
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 3:49 pm

All-cargo aircraft are not required to have fire suppression, even for ETOPS operations

Ok, but I'm still curious as to why would a Freighter conversion that doesn't otherwise modify ETOPS-approved systems (i.e. Propulsion, etc.) invalidate the aircraft's ETOPS type certification?
 
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Starlionblue
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Fri Nov 18, 2022 11:58 pm

ArcticFlyer wrote:
Starlionblue wrote:
As I understand it, ETOPS/EDTO limits are very much dependent on cargo fire suppression capability.

Why would they? There are plenty of MD-11Fs and 747Fs flying around with no fire suppression systems and without any regard to ETOPS requirements.


Yeah, but as mentioned above, they can go 180 minutes before they need ETOPS, meaning they don't need it at all, so it's a bit of a moot point.

If they needed to go beyond 180 minutes, e.g. ETOPS207, the limiting factor might well be cargo fire suppression capability, just as with twins.
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 1:12 am

Starlionblue wrote:
Yeah, but as mentioned above, they can go 180 minutes before they need ETOPS, meaning they don't need it at all, so it's a bit of a moot point.

If they needed to go beyond 180 minutes, e.g. ETOPS207, the limiting factor might well be cargo fire suppression capability, just as with twins.

Not so for cargo airplanes. See below:
121.161 - Airplane limitations: Type of Route

(a) Except as provided in paragraph (e) of this section, unless approved by the Administrator in accordance with Appendix P of this part and authorized in the certificate holder's operations specifications, no certificate holder may operate a turbine-engine-powered airplane over a route that contains a point -
(1) Farther than a flying time from an Adequate Airport (at a one-engine-inoperative cruise speed in still air) of 60 minutes for a two-engine airplane or 180 minutes for a passenger-carrying airplane with more than two engines;
(2)Within the North Polar Area; or
(3)Within the South Polar Area

So, unless flying in the North or South Polar Areas (which few operators do; you have to go north of 78 degrees north to be in the North Polar Area), cargo airplanes with more than two engines do not require ETOPS at all.
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 1:20 am

aeronavegar wrote:
Ok, but I'm still curious as to why would a Freighter conversion that doesn't otherwise modify ETOPS-approved systems (i.e. Propulsion, etc.) invalidate the aircraft's ETOPS type certification?

That is admittedly a little beyond my area of expertise, but as I mentioned before it could simply be that the shop doing the conversion (and thus owning the STC) didn't include ETOPS for some reason. Without knowing the intricacies of what goes into ETOPS approval I can't speculate as to why it would be advantageous to do so.

On a remotely similar note, my company learned (the hard way as usual) that Boeing removes the factory fire suppression system for the lower cargo compartments on its 767-300BCFs, making them Class E compartments along with the main deck (of course, unlike the main deck, the lower compartments are not accessible locations). I'm told it was because they are afraid of being held liable if there is a mishap involving hazardous materials. Perhaps a similar thought process can explain the lack of ETOPS approval for the 737-800BCF.
 
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Starlionblue
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 4:32 am

ArcticFlyer wrote:
Starlionblue wrote:
Yeah, but as mentioned above, they can go 180 minutes before they need ETOPS, meaning they don't need it at all, so it's a bit of a moot point.

If they needed to go beyond 180 minutes, e.g. ETOPS207, the limiting factor might well be cargo fire suppression capability, just as with twins.

Not so for cargo airplanes. See below:
121.161 - Airplane limitations: Type of Route

(a) Except as provided in paragraph (e) of this section, unless approved by the Administrator in accordance with Appendix P of this part and authorized in the certificate holder's operations specifications, no certificate holder may operate a turbine-engine-powered airplane over a route that contains a point -
(1) Farther than a flying time from an Adequate Airport (at a one-engine-inoperative cruise speed in still air) of 60 minutes for a two-engine airplane or 180 minutes for a passenger-carrying airplane with more than two engines;
(2)Within the North Polar Area; or
(3)Within the South Polar Area

So, unless flying in the North or South Polar Areas (which few operators do; you have to go north of 78 degrees north to be in the North Polar Area), cargo airplanes with more than two engines do not require ETOPS at all.


I'll nitpick. In the regulation quoted, it says that ETOPS is required above 180 minutes for airplanes with more than two engines. Granted, going beyond 180 minutes for a cargo operator is of little practical use, but the regulation is there.

Also, this is jurisdiction-dependent. Not all jurisdictions have the same regulations.
 
Dalmd88
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 4:33 pm

ETOPS is a costly status to maintain if you don't really need it. There is a lot of training and record keeping. Many of the aircraft's components require specific maintenance, which is an added cost. These components are in just about every system that would cause a plane to divert. Yes that includes the engines, but also the electrical, fuel, and hydraulic systems.

When those items need a shop visit, it's to ETOPS standards. Those components can only be changed by an ETOPS trained AMT. For may things you need two ETOPS trained AMT's for the job. Just servicing engine oil, requires one AMT per engine. So even simple tasks, like a through flight check, requires multiple trained people.
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 7:51 pm

Dalmd88 wrote:
ETOPS is a costly status to maintain if you don't really need it. There is a lot of training and record keeping. Many of the aircraft's components require specific maintenance, which is an added cost. These components are in just about every system that would cause a plane to divert. Yes that includes the engines, but also the electrical, fuel, and hydraulic systems.

When those items need a shop visit, it's to ETOPS standards. Those components can only be changed by an ETOPS trained AMT. For may things you need two ETOPS trained AMT's for the job. Just servicing engine oil, requires one AMT per engine. So even simple tasks, like a through flight check, requires multiple trained people.

All points are absolutely true, but they would weigh more on an operator's decision on whether or not to seek ETOPS approval rather than a manufacturer or the owner of a STC conversion.
 
ArcticFlyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sat Nov 19, 2022 8:00 pm

Starlionblue wrote:
ArcticFlyer wrote:
Starlionblue wrote:
Yeah, but as mentioned above, they can go 180 minutes before they need ETOPS, meaning they don't need it at all, so it's a bit of a moot point.

If they needed to go beyond 180 minutes, e.g. ETOPS207, the limiting factor might well be cargo fire suppression capability, just as with twins.

Not so for cargo airplanes. See below:
121.161 - Airplane limitations: Type of Route

(a) Except as provided in paragraph (e) of this section, unless approved by the Administrator in accordance with Appendix P of this part and authorized in the certificate holder's operations specifications, no certificate holder may operate a turbine-engine-powered airplane over a route that contains a point -
(1) Farther than a flying time from an Adequate Airport (at a one-engine-inoperative cruise speed in still air) of 60 minutes for a two-engine airplane or 180 minutes for a passenger-carrying airplane with more than two engines;
(2)Within the North Polar Area; or
(3)Within the South Polar Area

So, unless flying in the North or South Polar Areas (which few operators do; you have to go north of 78 degrees north to be in the North Polar Area), cargo airplanes with more than two engines do not require ETOPS at all.


I'll nitpick. In the regulation quoted, it says that ETOPS is required above 180 minutes for airplanes with more than two engines. Granted, going beyond 180 minutes for a cargo operator is of little practical use, but the regulation is there.

Also, this is jurisdiction-dependent. Not all jurisdictions have the same regulations.

Not to belabor the point, but what am I missing when it refers to "passenger-carrying" airplanes with more than two engines? Clearly an all-cargo airplane (whether it came from the factory that way or was later converted) is not a passenger-carrying airplane.

As to your second point you are certainly correct; each country/aviation authority has its own rules on the subject although ICAO does provide for some standardization.
 
Dalmd88
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sun Nov 20, 2022 2:30 pm

ArcticFlyer wrote:
Dalmd88 wrote:
ETOPS is a costly status to maintain if you don't really need it. There is a lot of training and record keeping. Many of the aircraft's components require specific maintenance, which is an added cost. These components are in just about every system that would cause a plane to divert. Yes that includes the engines, but also the electrical, fuel, and hydraulic systems.

When those items need a shop visit, it's to ETOPS standards. Those components can only be changed by an ETOPS trained AMT. For may things you need two ETOPS trained AMT's for the job. Just servicing engine oil, requires one AMT per engine. So even simple tasks, like a through flight check, requires multiple trained people.

All points are absolutely true, but they would weigh more on an operator's decision on whether or not to seek ETOPS approval rather than a manufacturer or the owner of a STC conversion.

But the cost of ETOPS capable would have to be baked into the STC. The proof of that capability lies with the owner of the STC process. If few of your customers are expected to need ETOPS, then it doesn't make sense to go through the process of certifying your STC as ETOPS capable.
 
kalvado
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Sun Nov 20, 2022 3:30 pm

Dalmd88 wrote:
ArcticFlyer wrote:
Dalmd88 wrote:
ETOPS is a costly status to maintain if you don't really need it. There is a lot of training and record keeping. Many of the aircraft's components require specific maintenance, which is an added cost. These components are in just about every system that would cause a plane to divert. Yes that includes the engines, but also the electrical, fuel, and hydraulic systems.

When those items need a shop visit, it's to ETOPS standards. Those components can only be changed by an ETOPS trained AMT. For may things you need two ETOPS trained AMT's for the job. Just servicing engine oil, requires one AMT per engine. So even simple tasks, like a through flight check, requires multiple trained people.

All points are absolutely true, but they would weigh more on an operator's decision on whether or not to seek ETOPS approval rather than a manufacturer or the owner of a STC conversion.

But the cost of ETOPS capable would have to be baked into the STC. The proof of that capability lies with the owner of the STC process. If few of your customers are expected to need ETOPS, then it doesn't make sense to go through the process of certifying your STC as ETOPS capable.

But wouldn't a lot of these requirements be satisfied by the reference to the original type certificate? What kind of changes in conversion would trigger additional testing, other than fire suppression?
If "anything that can cause diversion" criteria is applied, neither floor beams nor cargo door really matters. An electric loading system may be an issue, but it would likely be powered down for the flight - just to save energy and fuel if nothing else.
 
aeronavegar
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Mon Nov 28, 2022 2:03 pm

ArcticFlyer wrote:
aeronavegar wrote:
On a remotely similar note, my company learned (the hard way as usual) that Boeing removes the factory fire suppression system for the lower cargo compartments on its 767-300BCFs, making them Class E compartments along with the main deck (of course, unlike the main deck, the lower compartments are not accessible locations). I'm told it was because they are afraid of being held liable if there is a mishap involving hazardous materials. Perhaps a similar thought process can explain the lack of ETOPS approval for the 737-800BCF


I agree there's more to it... thanks for the insight!
 
Natflyer
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Re: ETOPS certification of passenger-to-freighter converted aircraft

Mon Nov 28, 2022 11:44 pm

I have flown several converted ETOPS 757-200, the all kept the ETOPS status and Class C lower holds, whereas the B757-200PFs I flew were non-ETOPS with Class E holds.
 
Natflyer
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Joined: Fri Oct 11, 2013 9:29 pm

Re: ETOPS certification of passenger-to-freighter converted aircraft

Mon Nov 28, 2022 11:49 pm

I have flown several converted ETOPS 757-200, the all kept the ETOPS status and Class C lower holds, whereas the B757-200PFs I flew were non-ETOPS with Class E holds.
 
aeronavegar
Topic Author
Posts: 5
Joined: Wed Nov 09, 2022 6:01 pm

Re: ETOPS certification of passenger-to-freighter converted aircraft

Wed Dec 07, 2022 4:47 pm

Natflyer wrote:
I have flown several converted ETOPS 757-200, the all kept the ETOPS status and Class C lower holds, whereas the B757-200PFs I flew were non-ETOPS with Class E holds.


Thanks for the feedback!

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