There has been a lot of speculation as to the details of the Boeing/FAA meeting last Friday, the presentation of a proposed solution to the battery issues, and whether this proposal will be acceptable to the FAA to get the 787 back into the air quickly. The short answer is that few people yet know all the facts, and the answer remains far from certain.
But there are some facts that have emerged from news stories, market intelligence we are gaining from from airlines, and other industry players. The proposed Boeing fix is reportedly not an interim fix, but designed as a permanent fix to the battery issue. These include:
- Changes to the design of the battery to include additional shielding and space between battery cells. These changes should reduce the probability of a thermal runaway and subsequent fire;
- A new container for the box that is more robust than the current design to prevent a fire from spreading and containing any flammable electrolyte that might leak from a damaged battery;
- A new smoke evacuation system that is designed to keep additional oxygen from feeding the battery in the case of a failure to reduce the possibility of fire, that includes adding tubing to the battery containment box.
This solution has been appropriately nicknamed the “Super Box” by BB&T analyst Carter Leake. Boeing is heavily lobbying in Congress in an effort to put pressure on regulators to accept its solution and return the 787 to service as quickly as possible. But the answer will likely not come as quickly as Boeing would like.
The investigation by the National Transportation Safety Board (NTSB) in the US and by its counterparts in Japan are continuing, and will likely not be ready until mid-March. The FAA will certainly wait for additional input from the NTSB and its counterpart in Japan before moving forward.
A key problem is that neither the NTSB nor Japanese can determine the exact cause of the battery failure. A potential fault tree analysis indicates several potential causes to the runaway failure of the battery. More worrisome are reports from Japan are that regulators and the battery manufacturer (Yuasa) have been unable to duplicate the heat levels that occurred on board despite their extensive tests of the battery. This likely indicates that an external electrical charge, and a potential issue with the electrical system on the aircraft, may have been a factor contributing to the severity of the battery failures, and an element that must be addressed to ensure that the probability of a battery failure and fire is eliminated.
The FAA has backed itself into a corner, as the agency’s head indicated that they want to be 1000% sure that any problems have been solved. The language of the Airworthiness Directive also indicates that the aircraft must remain grounded until problems with the battery are fixed.
The question now: is Boeing’s proposed fix good enough? We don’t think so.
The probability of a severely adverse event must typically be shown to be one in a billion (10 to the ninth power) in certification studies to gain approval, with the appropriate engineering analyses supporting those low probabilities. Boeing clearly missed that estimate with two fires occurring within days of each other, indicating a flaw in their initial analysis and design. The FAA will be examining Boeing’s next submission with a fine tooth comb to fully understand the potential for an “at risk” event. The question the regulators will decide is whether a fire could be prevented if it occurs, and be suppressed, which we believe they will, or simply be contained, which the Boeing solution addresses without active fire suppression.
Boeing’s decision to internationally outsource elements of its production will have an impact on the certification of any changes to the aircraft. Because several international players are involved in the design, and international operators subject to local jurisdiction, the FAA must carefully coordinate with Japan and EASA, given the Japanese batteries with a British-owned control system integrated by a French company that coordinates with the US designed electrical system.
With the Japanese unable to replicate the battery failures in standalone tests, it is unlikely that Japanese regulators would accept the Boeing solution, that focuses on the battery, but not the electrical system, as that would result in what would be viewed as an unjustified loss of face in focusing on the contractor in Japan rather than finding the true cause of the problem. What if the FAA were to approve the fix, only to have the Japanese continue to restrict the aircraft from service?
The political and economic ramifications would be significant. Despite the FAA taking the lead for an aircraft certified in the US, this will be a coordinated international effort, and a decision with international ramifications. Should a major disagreement exist, the international system of reciprocity in aircraft certification that has worked well for many years could be threatened. While Boeing can easily lobby Washington, it may also need to be lobbying Tokyo and Brussels as well.
Airbus has read the writing on the wall and moved to “plan B” for the A350, substituting Nickel-cadmium batteries for the planned Lithium-ion batteries. Perhaps they anticipate a change in regulatory requirements from EASA for future programs, or merely want to reduce program risk. But with a significantly lower electrical load, it is much easier for the A350 to switch than the 787, which would require conventional batteries 500 pounds heavier than its Lithium-ion solution.
The question today is whether the FAA will stick to its guns, and require a full solution to the battery and electrical system issue, even if it keeps the 787 on the ground, or bow to political pressure and accept Boeing’s “Super Box” solution. Or might the FAA accept the Boeing solution as a temporary measure, and require something further for the long-term?
Our intelligence sources indicate that the tea leaves are not favorable for the Boeing “Super Box” solution to be approved as a permanent solution, despite its massive lobbying effort on the Hill. This decision is not insulated from political influence, and anything can happen in Washington, whether sensible or not. In the interim, the entire world is watching the FAA and will pass judgment on its credibility based on the outcome of this investigation.