Federal AviationAdministrationNPRM2012-NM-004-ADPresented to Industry MeetingMarch 7, 20122Federal AviationAdministrationStatus•AD 2011-04-09/SFAR 111 Issued March 2011•ARC formed and made recommendations April-August 2011•Policy Statement PS-ANM-25-04 issued December 21, 2011•NPRM AD 2012-NM-004-AD published February 27, 2012 tosupersede AD 2011-04-093Federal AviationAdministrationStatus•COG installations in lavatories require an AMOC to AD 2011-04-09•Non-COG installations, as well asCOG installation not in alavatorydo not require an AMOC•AnyCOG installation will be judged against policy statementPS-ANM-25-04 at some point•Any approvals granted in advance of the final AD would notbe subject to the AD4Federal AviationAdministrationRationale for NPRM AD Approach•Alternatives Considered•Timing•Nature of the Action•Reconcile Original AD5Federal AviationAdministrationAlternatives Considered•Terminate the SFAR–Rulemaking Process–Indirect imposition of requirements, i.e., implicit but not explicit–Ultimately requires further rulemaking•Part 121/129 Rule Change–Normally used to raise the level of safety, or address issues notpreviously identified–This action simply restores level of safety (oxygen provision inlavatories)6Federal AviationAdministrationTiming•Changes to regulations take time•Even with expedited process would take multiple years•Safety/risk assessment was based on limited exposure,basically not to exceed 4 years•Any action needs to allow completeretrofit in time to permitcompliance compatible with the safety assessment7Federal AviationAdministrationNature of the Action•Reinstallation of oxygen in the lavatories is a remedial action•Resulting level of safety is whatit was prior to AD 2011-04-09•Improvement insecurityis a necessary action to maintain thesafe operation of the airplane•Net affect is thatsafetyis back to where it was8Federal AviationAdministrationReconcile AD 2011-04-09•AD 2011-04-09 was always going to require a supersedingaction•AMOCs to that AD would be required indefinitely•ADs are typically resolved with a terminating action when theoriginal action is known to be, or learned to be, interim•This proposal is typical in that respect9Federal AviationAdministrationNPRM Key Points•Distinction between COG and non-COG installations•Applicability•Approval process•AMOCs10Federal AviationAdministrationCOG Distinction•Several distinctions based on the use of COG or not•Use of COG necessitates consideration of security measures•New application of security measures necessitates TADinvolvement•Although ‘immediately obvious’ meets the securityprovisions, we’re not ready tohave applicants making thatdetermination on their own•Approval process differsfor non-COG installations•AMOC process differs for non-COG installations11Federal AviationAdministrationDiscussion of NPRM Provisions•Applicability–Original applicability of AD 2011-04-09 alone won’t work—noairplanes in US commercial service have COG in lavatories–However, original applicability needs to be retained to prevent otherairplanes from entering the fleet ‘unmodified’12Federal AviationAdministrationDiscussion of NPRM Provisions•Approval process is known to be an industry concern•NPRM permits full exercise of delegated authority if non-COGinstallation–ODAs with the authority to approve major modifications can do soeven though this is an AD action–‘Normal’ STC process can be followed•In other words, for a non-COGinstallation it’s more like astandard STC installationthan an AD approval13Federal AviationAdministrationDiscussion of NPRM Provisions•AMOC provisions are also different–No formal AMOC required for non-COG installations if deviations toapproved service instructions are needed–Still requires approval•AMOCs (for COG installations) approved by TAD–Close coordination with ACOs and AFS–Expect to develop expedited process14Federal AviationAdministrationRelated FAA Actions•Aircraft Certification Team/Focal Points–All ACOs have a focal point for this activity–TAD has held periodic telecons with team to update on actions andstandardized process–Projects will be given priority–No tail number required to apply for an STC–Multiple TAD contacts to assist ACOs with any questions–TAD will be involved—similar to flightdeck doors—to make sureconsistent standards are applied15Federal AviationAdministrationRelated FAA Actions•Close coordination between Aircraft Certification and FlightStandards•AFS participation in the ACO telecons•InFO drafted to inform both operators and field inspectors ofunique AD provisions