### Proposed **FQIS Wire**

**Separation on Cargo**  **Aircraft A4A**  **/ F AA**  **Meeting**
December 1, 2015December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Introduction FA A intends to issue rulemaking r equiring US fr eight er oper ator s to do additional fuel safety modifications to meet lat es t air cr aft certification re quir ements. Fuel safety has alr eady been impr oved with other modifications, overhaul pr ocesses, re pair pr ocesses, and maint enance pr ogr am changes. Airbus and Boeing indicat e that service bulletins fo r additional modifications will be intrusive, expensive and will not significantly impr ove safety . Competitive position of US fr eight er oper ator s will be harmed because for eign re gulator s will not be r equiring additional modifications.December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Discussion US fr eight er oper ator s ha ve already spent t ens of millions on fuel t ank safety impr ovements UPS alone has spent $35.5 million to do 51 SFAR88 AD’ s on the four fleet types pot entially affect ed. Fr eight er oper ator s alr eady ha ve recurring expenses for E AP AS maint enance pr ogr am ta sks that continue to help ensur e fuel t ank safety . Fr eight er oper ator s have already invested in improved and mor e expensive fuel t ank component CMM r epair and overhaul pr ocesses.December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Discussion Initial FRM rulemaking did not account f or safety benefits of SFAR88 modifications, component r epair pr ocess, and wiring maint enance pr ogr am impr ovements. Ther e ha ve been no incidents since the above changes wer e implement ed. This pr ovides dir ect evidence that FAA pr ojections for additional incidents wa s over state d and that SFAR88 changes have work ed. Foreign regulatory agencies did not mandat e r etrofit inerting and will not mandat e additional actions on their fr eight er oper ator s. (E ASA SIB 2014, China CAN 2012 No.30, JCAB AIM P art III - 3)December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** NTSB Safety R ecommendation Closur es The NTSB pr eviously issued the f ollowing Safety R ecommendations r elated to flammability

, Wiring and Wiring Maint enance • A - 00 - 106 – Assess wiring criticality and separ ation • Closed – Accept able Action: EA PA S/FTS Rulemaking • A - 00 - 108 – Re pair of pot entially unsafe wiring conditions • Closed – Accept able Action: EA PA S/FTS Rulemaking • A - 98 - 038 – Separ ation of FQIS wir es to the max ext ent possible • Closed – Accept able Action: SFAR 88 Rulemaking • A - 98 - 039 – Re quir e sur ge pr ot ection syste ms for FQIS wir es • Closed – Accept able Action: SFAR 88 Rulemaking • A - 96 - 174 – Preclude flammable fuel air mixtur es in fuel t anks • Closed – Accept able Action: FRM Rulemaking All applicable NTSB Safety R ecommendations ar e closed with Accept able Actions ta ke n by FAADecember 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Proposed Wire Separ ation Issues

• Wire separ ation Service Bulletins do not meet new design crit eria • 757 ex ample: • Only about 5% of FQIS wir es can be separ ated to 2 inches. • Majority of bundles will achieve only up to 0.5 inch spacing. • Ex emptions being pr ovided for each bulletin. • Consider able access and intrusive work for a s ymbolic gestur e 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 ar e very costly . UPS has estimat ed $16 million fo r the four fleet types affect ed.December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Global Competitive Envir onment Air car go industry is curr ently in an extremely competitive global mark et . Additional lower deck capacity on passenger air cr aft, especially thr ough Middle E ast hubs, has significantly impact ed fr eight yields. Sever al cargo carrier s ha ve ceased oper ations and man y other s ha ve park ed some air cr aft. US carrier s c ompet e dir ectly with for eign car go oper ator s . Additional costs on US car go oper ator s, that will not be incurr ed by for eign oper ator s, will mak e us less competitive and will cost US jobs.December 1, 2015 **Pr oposed FQIS Wir**  **e Separ ation on Car** **go Air cr**  **aft** Conclusion

• No unsafe c ondition exists. • Service experience has shown that the fuel t ank safety issues have been addr essed with significant pr evious modifications and r ecurring maint enance. • Existing impr ovements in fuel safety modifications, overhaul pr ocesses, r epair pr ocesses, and maint enance pr ogr am t asks pr ovide the needed safety .
• Foreign Re gulatory Authorities, OEMs, and airlines do not support that a safety issue re mains.

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

• Proposed modifications ar e expensive, intrusive and do not pr ovide an y a significant benefit .
• Unilater al action by FAA will mak e US car go oper ator s less competitive in the global mark etplace and ma y r esult in volume shifting to f or eign carrier s with corr esponding loss of US jobs.