COVERSTORY

ETOPS Redefined A new name and sweeping new rules for ‘extended operations.’

BY PATRICK CHILES
© Michael Martoudis/airliners.net

A
fter more than two decades of recommended requirements that will four-engine airplanes, and Part 135
long-range flight operations be harmonized with the FAA’s. The In- on-demand operators, which previously
governed by a series of advisory ternational Civil Aviation Organization were not under the ETOPS umbrella.
circulars, policy letters and draft is crafting a proposal for member states As of early 2007, commercial aircraft
policies, the U.S. Federal Aviation Ad- that would consider these new rules. operators and manufacturers are still
ministration (FAA), with much interna- The wide-ranging package of examining the final rule to determine
tional input, has revised its regulations to changes to U.S. Federal Aviation its impact. There is much to digest, so
provide definitive guidance to long-haul Regulations (FARs) Parts 1, 21, 25, we will attempt here to describe the
operators. ETOPS, an acronym previous- 33, 121 and 135 is the product of a implications for the operator, focusing
ly describing extended-range twin-engine nearly seven-year rule-making process on the issues of most concern for those
operations, has been redefined to mean guided by recommendations of an previously not affected by ETOPS.
extended operations, the name applied to FAA/industry aviation rule-making
this package of regulations for all com- advisory committee (ARAC). The new Increased Diversion Times
mercial multi-engine airplanes. ETOPS requirements, most of which The FAA first allowed operators to fly
The development of the new rules took effect in February 2007, apply to twin-engine airplanes on routes that
not only has been anticipated by U.S. a larger number of operators and to a did not remain within 60 minutes of
commercial aircraft operators but also greater range of operations. an adequate alternate airport at single-
has been closely watched by other civil The new rules have provisions to engine speed in 1977, when it allowed a
aviation authorities. Australia, Canada increase maximum allowable diversion deviation time of up to 75 minutes for
and New Zealand intend to publish times for air carriers that have been Caribbean operations.
similar rules this year. Europe’s Joint conducting ETOPS flights. The more Clearly, turbine engines and time-
Aviation Authorities is developing significant changes affect three- and limited aircraft systems had become

12 | flight safety foundation | AeroSafetyWorld | March 2007

 COVERSTORY

more reliable over decades of operation. In new advisory circular, anticipated by mid-year,
1985, the FAA recognized this and issued Ad- as well as new handbook guidance for its opera-
visory Circular 120‑42, detailing how airlines tions and maintenance inspectors. The funda-
could get permission to operate routes with mental requirements are already familiar to U.S.
maximum diversion times up to 120 minutes, air carriers.
opening up the North Atlantic to twin-engine
airplanes. A subsequent revision allowing for Gaining Approval
maximum diversion times up to 180 minutes Initial approval generally requires a carrier to
— which eventually was further revised to allow have at least one year of operating experience
special increases to 207 minutes — opened the with a specific airplane to gain authority for a
door to Pacific routes. 120-minute diversion time and then another
Today, twin-engine airplanes largely have year of experience before gaining authority for
displaced three- and four-engine airplanes 180 minutes. Accelerated approval is possible in
on North Atlantic routes and have claimed a six months, with the intent of validating sound
healthy share of Pacific traffic. The 2007 rules processes for extended operations and ensuring
retain many of the existing maximum diversion a carrier’s commitment to them. These process-
times while extending the maximum diver- es focus on the concept of precluding in-flight
sion time to 240 minutes and more in some failure of engines and other critical systems,
situations. and protecting the aircraft and occupants in the
While ETOPS became accepted practice, event of a diversion.
none of its provisions were codified as FARs. As Operational planning is fairly straightfor-
extended operations became increasingly com- ward. Generally, the route of flight must remain
mon, it became clear that formal rule making was within the approved maximum diversion time,
needed to clarify the requirements. It also became computed using an approved single-engine The Narsarsuaq,
generally accepted that the safety principles used cruise speed in still air and standard atmospher- Greenland, airport
in ETOPS had great merit for use in other types of ic conditions (Figure 1, page 14). For flag and might serve as a safe
remote operations. For example, interest in trans- supplemental ETOPS, Part 121.646(b) requires haven for a light jet
polar routes that became viable after the collapse air carriers to plan for a sufficient fuel supply to on an on-demand
of the Soviet Union prompted the FAA to issue a divert to and land at an adequate airport after ETOPS flight over the
policy letter detailing rules applying to all airplanes one of the following occurs at the most critical North Atlantic.
for, among other things, systems endurance, alter-
nate airports and protection for passengers in the
event of a diversion in extreme climes.
The ARAC codified existing procedures and
“industry best practices” into a proposed compre-
hensive operating standard that was released in
November 2003. The proposal generated vigor-
ous public comment, which was not surprising
considering its scope. In particular, operators of
three- and four-engine airplanes and those operat-
ing under Part 135 would now have to carefully
consider maximum diversion times instead of just
equal-time points (ETPs), at which the diversion
times to designated en route alternates are equal.
Aware of the many questions — especially
by newly affected operators — about comply- © TripIET/airliners.net

ing with the new rules, the FAA is working on a

www.flightsafety.org | AeroSafetyWorld | March 2007 | 13

 COVERSTORY

point on the route: an engine failure; a rapid minimums. A pilot-in-command for a supple-
cabin decompression necessitating descent to mental carrier or a dispatcher for a flag carrier
a safe altitude, typically 10,000 ft; or an engine must update the flight plan as needed for in-flight
failure and a rapid decompression. contingencies, such as changing an ETOPS alter-
Once the operating area is defined, the carrier nate because of weather conditions.
is responsible for prudent flight planning with For twin-engine airplanes operated under
accurate forecast models and thorough opera- Part 121, the ETOPS diversion time threshold
tional control. Part 121.624(a) states that suf- is unchanged from the original 60 minutes.
ficient ETOPS alternates must be included in the Passenger airplanes with more than two engines
flight release to ensure that the aircraft remains and Part 135 twins have a 180-minute diversion
within the authorized maximum diversion time, time threshold. Any operations planned beyond
based on the alternate weather minimums listed those thresholds require ETOPS approval.
in the carrier’s operations specifications (ops In addition to the obvious concern for an
specs). Once the flight is under way, conditions engine failure, route planning must consider the
at the alternate airports can go down to operating most time-limited aircraft system. For example, di-
minimums — the published instrument approach version time cannot exceed the time limit of cargo
fire suppression minus 15 minutes, which means
that the fire suppression system must be certified
ETOPS Versus Great Circle Route
to 195 minutes duration for 180-minute approval.
Operations items to be validated through the
approval process include:

• A proven flight planning program and

dispatch program appropriate to ETOPS;

Los Angeles
• Availability of meteorological information
and an ETOPS-specific minimum equip-
ment list (MEL);

• Initial and recurrent training, and a line-

Hilo, Hawaii
check program for ETOPS flight opera-
te
rou

te

tions personnel; and,

rou
S
OP

cle
ET

cir

• Assurance that flight crews and dispatch

at
Gre

personnel are familiar with the ETOPS

routes to be flown.

Accelerated Approval
Maintenance programs are still the keystone
Tahiti
of any successful ETOPS program. The FAA
wants to see a commitment to sound processes,
demonstrated best practices and continuous
monitoring for accelerated approval.
Note: This example shows an ETOPS (extended operations) route that remains within 180
However, the FAA was convinced by com-
minutes flying time, under specific conditions, of an adequate alternate airport; the route is ments pointing out the safe operating history of
240 nm (444 km) longer than the great circle route from Los Angeles to Tahiti.
airplanes with more than two engines and agreed
Source: Patrick Chiles
that carriers do not have to adopt ETOPS mainte-
Figure 1 nance programs for those aircraft. Also, all-cargo

14 | flight safety foundation | AeroSafetyWorld | March 2007

 COVERSTORY

airplanes with more than two engines must meet

only the polar operating requirements.
The following items are validated during the
accelerated approval process:

• A fully developed maintenance program,

including parts tracking and control;

• An ETOPS maintenance manual;

• An oil-consumption-monitoring program;

• An engine-condition-monitoring and
-reporting system;

• A plan for resolving discrepancies with the

airframe/engine configuration, mainte- © Anders Presterud/airliners.net
nance and procedures (CMP) document;

• An ETOPS reliability program; Polar Routes Operators seeking

Extended operations in polar regions also are polar ETOPS approval
• A propulsion-system-monitoring pro- governed by the new rules, with exceptions for must evaluate
gram. The carrier must establish a high intrastate operations in the state of Alaska. Ef- adequate alternates,
degree of confidence that propulsion sys- fective February 2008, carriers operating in the such as the airport in
tem reliability for the requested diversion North Polar Area (above 78 degrees north lati- Stord, Norway.
time can be maintained; and, tude) and South Polar Area (below 60 degrees
• ETOPS-specific qualification programs for south latitude) will need the following approvals
maintenance personnel. in their ops specs:

• Designation of en route alternates, with

The airframe/engine combination must be
passenger-recovery plans for these
certified for single-engine operations up to
alternates;
the desired maximum diversion time. This has
become common for modern twins. However, it • Fuel-freeze monitoring procedures;
is the carrier’s responsibility to keep the aircraft
• Propulsion-system reliability program;
in compliance with the model’s CMP document.
Developed by the manufacturer, the CMP docu- • Ensured communications capability;
ment includes standards for special inspections, • A polar-operations-specific MEL;
parts control, hardware life limits and mainte-
nance practices that the FAA considers to be the • A plan to mitigate crew exposure to radia-
minimum acceptable level for ETOPS. tion during solar flare activity; and,
A significant maintenance requirement is • Provisions for at least two cold-weather
the prohibition against having one technician exposure suits for crewmembers.
perform the same task on left and right en-
gines or other redundant critical systems. This Development of passenger-recovery plans could
protects against a repeatable error resulting in be a greater hurdle for a Part 121 carrier than a
an in-flight shutdown or malfunction. There is Part 135 operator because of the greater number
also a requirement to use the ETOPS-specific of passengers. A carrier might have to keep an
MEL during a predeparture service check prior aircraft on standby for recovery operations. Car-
to each extended operation. riers that already have authority to operate in

www.flightsafety.org | AeroSafetyWorld | March 2007 | 15

 COVERSTORY

areas of magnetic unreliability and the 10 percent of the divert segment only if that the payload be reduced or that the
North Polar track system should not as- icing is forecast. trip be canceled.
sume that they may continue to operate Charter operators that have been
as before. Part 135 Requirements conducting transoceanic trips may
The new Part 135.364 likely will have a find themselves unable to comply with
Part 121 Differences dramatic impact on charter operators. ETOPS requirements, depending on data
There are some new requirements for Effective February 2008, passenger char- their manufacturers generate this year.
Part 121 carriers. Among the most sig- ter flights conducted beyond 180 min- If a Part 135 operator finds it neces-
nificant is that the planning for passen- utes of an adequate airport will require sary to gain ETOPS approval, it will
ger flights in airplanes with more than ETOPS approval. The FAA believes that have to meet the same maintenance
two engines must consider maximum the higher diversion-time threshold is requirements as the airlines. Con-
diversion times, instead of the simpler justified because charter operators are ducting predeparture service checks
ETP fuel planning. These aircraft now not limited to using Part 139–approved with ETOPS-trained mechanics when
require ETOPS approval if the carrier in- airports, so a greater range of alternate operating away from home base will
tends to operate them on routes exceed- airports will be available. Maximum ap- be a serious consideration. Lacking an
ing a 180-minute diversion time. provable diversion time is 240 minutes. airline’s in-house maintenance re-
There also are allowances for increas- What remains to be seen is how sources, charter operators may consider
ing the maximum diversion time. During many Part 135 operators will be able carrying flight mechanics in addition to
the ARAC process, carriers had asked for to avoid being forced into an ETOPS arranging for more qualified vendors.
expanded ability to exceed 180 minutes, program. In effect, that will be deter- In addition to delaying implemen-
which the FAA accommodated by al- mined by the manufacturers. General tation for a year, FAA included an
lowing maximum diversion times up to aviation turbine airplanes usually are eight-year grandfather clause for newly
240 minutes in specific areas, along with not provided with the variety of one- manufactured airplanes operated under
other operating and MEL requirements. engine-inoperative (OEI) performance Part 135. This was expected since the
The carrier must already have 180- data that accompanies large transport large majority of these aircraft have not
minute approval and may exceed it only aircraft. OEI performance is often been subject to an ETOPS configura-
if day-of-flight conditions, considering based only on the best lift/drag ratio tion management plan.
wind, necessitate going farther. For spe- speed or long-range cruise speed. This
cific preapproved city pairs, it will even be will probably not be adequate over A New Chapter
possible to exceed 240 minutes. more remote areas with a 180-minute The FAA’s codification, refinement and
Similar to provisions in the old ad- maximum diversion time. At those expansion of requirements for extended
visory circular, the new rule mandates speeds, the North Atlantic won’t be out operations — and similar efforts under
compensation for the effects of wind, of reach, but a trip from Los Angeles to way worldwide — begin a new chapter
icing and auxiliary power unit fuel Hawaii could easily exceed the 180- in long-range flight. The pioneer-
consumption. These factors have been minute maximum diversion time. ing flights by Piedmont and TWA in
reduced as the FAA has recognized Implementation of the Part 135 the 1980s have led to well-established
substantial improvements in wind and ETOPS rule is being delayed for one year safety practices, improved operating
temperature forecasting models over to allow manufacturers enough time to economies and more opportunities for
the last two decades. Diversion fuel create more speed profiles. The as-yet- point-to-point travel between a greater
burn calculations previously had to unknown factor will be fuel capacity. In variety of airports. Looking to the
be increased by 5 percent to allow for addition to the fuel implications of faster future, harmonizing standards across
wind-forecasting errors. The require- engine-out speeds, the required assump- the different national regulators will
ment now is to increase forecast tail tion of a simultaneous cabin decompres- enhance safety for all operators. ●
wind or head wind component speed sion will drive the diversion altitude even
Patrick Chiles is the technical operations man-
by 5 percent, which reduces the fuel lower. Exact figures are not available, but ager for the NetJets BBJ program and a member
requirements. Similarly, carriers must there is good reason to believe that the of the Flight Safety Foundation Corporate
account for ice drag penalties during increased fuel consumption could require Advisory Committee since 2000.

16 | flight safety foundation | AeroSafetyWorld | March 2007