Proposed FQIS Wire 

Separation on Cargo Aircraft 

A4A / FAA Meeting

December 1, 2015
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Introduction

FAA intends to issue rulemaking requiring US freighter operators to do additional fuel 

safety modifications to meet latest aircraft certification requirements.

Fuel safety has already been improved with other modifications, overhaul processes, 

repair processes, and maintenance program changes.

Airbus and Boeing indicate that service bulletins for additional modifications will be 

intrusive, expensive and will not significantly improve safety.

Competitive position of US freighter operators will be harmed because foreign 

regulators will not be requiring additional modifications.
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Discussion

US freighter operators have already spent tens of millions on

fuel tank safety improvements

UPS alone has spent $35.5 million to do 51 SFAR88 AD’s on the four fleet types 

potentially affected.

Freighter operators already have recurring expenses for EAPAS maintenance program 

tasks that continue to help ensure fuel tank safety.

Freighter operators have already invested in improved and more expensive fuel tank 

component CMM repair and overhaul processes. 
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Discussion

Initial FRM rulemaking did not account for safety benefits of SFAR88 modifications, 

component repair process, and wiring maintenance program improvements.

There have been no incidents since the above changes were implemented. This provides 

direct evidence that FAA projections for additional incidents was overstated and that 

SFAR88 changes have worked. 

Foreign regulatory agencies did not mandate retrofit inerting and will not mandate 

additional actions on their freighter operators. (EASA SIB 2014, China CAN 2012 No.30, 

JCAB AIM Part III-3)
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

NTSB Safety Recommendation Closures

The NTSB previously issued the following Safety Recommendations related to 

flammability, Wiring and Wiring Maintenance

• A-00-106 – Assess wiring criticality and separation

• Closed – Acceptable Action: EAPAS/FTS Rulemaking

• A-00-108 – Repair of potentially unsafe wiring conditions

• Closed – Acceptable Action: EAPAS/FTS Rulemaking

• A-98-038 – Separation of FQIS wires to the max extent possible

• Closed – Acceptable Action: SFAR 88 Rulemaking

• A-98-039 – Require surge protection systems for FQIS wires

• Closed – Acceptable Action: SFAR 88 Rulemaking

• A-96-174 – Preclude flammable fuel air mixtures in fuel tanks

• Closed – Acceptable Action: FRM Rulemaking

All applicable NTSB Safety Recommendations are closed with Acceptable Actions 

taken by FAA
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Proposed Wire Separation Issues

• Wire separation Service Bulletins do not meet new design criteria

• 757 example:

• Only about 5% of FQIS wires can be separated to 2 inches.

• Majority of bundles will achieve only up to 0.5 inch spacing.

• Exemptions being provided for each bulletin.

• Considerable access and intrusive work for a symbolic gesture with no 

significant safety benefit.

• OEM analysis does not classify modifications as safety critical

• SBs will not be issued as Alert Service Bulletins.

• Proposed modifications are very costly. UPS has estimated $16 million for the four 

fleet types affected.
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Global Competitive Environment

Air cargo industry is currently in an extremely competitive global market.

Additional lower deck capacity on passenger aircraft, especially through Middle East 

hubs, has significantly impacted freight yields.

Several cargo carriers have ceased operations and many others have parked some 

aircraft.

US carriers compete directly with foreign cargo operators.

Additional costs on US cargo operators, that will not be incurred by foreign operators, 

will make us less competitive and will cost US jobs.
December 1, 2015

Proposed FQIS Wire Separation on Cargo Aircraft 

Conclusion

• No unsafe condition exists. 

• Service experience has shown that the fuel tank safety issues have been 

addressed with significant previous modifications and recurring maintenance.

• Existing improvements in fuel safety modifications, overhaul processes, repair 

processes, and maintenance program tasks provide the needed safety.

• Foreign Regulatory Authorities, OEMs, and airlines do not support that a safety issue 

remains.

• FAA is alone in believing that a safety issue still exists. 

• Proposed modifications are expensive, intrusive and do not provide any a significant 

benefit.

• Unilateral action by FAA will make US cargo operators less competitive in the global 

marketplace and may result in volume shifting to foreign carriers with corresponding 

loss of US jobs.