MEMORANDUM IN SUPPORT OF PETITION TO US DEPARTMENT OF TRANSPORTATION (DOT), FEDERAL AVIATION ADMINISTRATION (FAA) AND NATIONAL TRANSPORTATION SAFETY BOARD (NTSB) RE SAFETY OF BOEING 787 BATTERIES OF FLYERSRIGHTS.ORG & AVIATION CONSUMER ACTION PROJECT
BY PAUL S. HUDSON, PRESIDENT OF FLYERSRIGHTS.ORG, EXECUTIVE DIRECTOR, AVIATION CONSUMER ACTION PROJECT, MEMBER OF FAA AVIATION RULEMAKING ADVISORY COMMITTEE
May 8, 2013
In January 2013, all Boeing 787 airliners were grounded due to overheating leading to fires and subsequent failure of lithium ion batteries used on this aircraft. 1
On January 18th DOT Secretary Ray LaHood stated, “Those planes won’t fly until we’re 1,000% sure they are safe to fly.”
On April 19th, while the National Transportation Safety Board (NTSB) was still investigating the Boeing 787 battery fires, the FAA approved a Boeing proposed 787 battery fix, but indicated it was reviewing the three (3) hour distance from the nearest landing site that this aircraft is approved for. 2
FlyersRights.org, the largest airline passenger organization calls on DOT Secretary LaHood and the FAA Administrator Michael Huerta to require Boeing 787 be limited to no more that two hour(s) (ETOPS 120) from the nearest emergency landing site, unless its lithium ion batteries are replaced with a failsafe electrical power system proven to meet current FAA safety standards or until this aircraft has proven itself with at least 24 months of trouble free service. This is the standard used by the Joint Aviation Authorities in the 1990s to even consider allowing twin engine aircraft to be certified to fly up 3 hours from the nearest airport. 3
Lithium ion batteries have a long history of overheating, catching fire, exploding, and spewing molten metal. The two batteries used on the Boeing are large, over 60 lbs. Should they overheat and catch fire they could easily bring down the airliner, especially if it was not within easy reach of an airport available for an emergency landing. Moreover, industry wide certification standards for lithium ion batteries that are permanently installed do not currently exist. See Exhibit 1.
According to independent experts, the proposed Boeing battery fix that has received preliminary approval by the FAA is wholly inadequate to ensure the safety of the traveling public.
See Exhibit 2 (opinion of battery safety expert David Zuckerbrod);
Exhibit 3 (opinion of MIT materials professor Donald Sadoway;
Exhibit 4 (comments of former DOT Inspector General Mary Schiavo).
These known dangers have led the FAA to impose severe restrictions and outright bans on the use and carrying of lithium batteries much smaller than the 787 batteries on US airliners. 4.
Smoke and fire in US airliners is not unusual and causes about 250 emergency landings per year, and has resulted in 100% fatal crashes in the recent past . 5
The Boeing 787 is different from other airliners in that it requires five times the electric power of the present Boeing 777 to operate, has only two instead of four engines, and uses a battery known for its volatility and overheating.
Without robust testing that has yet to be done and without operational experience this fix is unproven as safe and should result at most in limited re-certification of the 787 for use only within 120 minutes of emergency landing facilities. Two hours would allow the Boeing 787 to fly transatlantic, nearly all overland routes, and many Pacific routes but not over the North Pole or trans Pacific or south Atlantic routes over 1,000 miles from a landing site.
From the limited information available, the Boeing fix does not appear to include:
a) any battery cooling apparatus at least in the rear section of the plane,
b) temperature gauges to warn pilots and ground monitoring of battery overheating or trigger cooling of overheating batteries, See Exhibit 2, 3.
Moreover, contrary to the Boeing assertions, battery fires would not necessarily be prevented by its venting system, and Boeing does not even contend that battery failure would be prevented by its band aid fix involving a containment vessel and insulation between cells.
The steel case that it claims will suppress a fire weighs 150 pounds thereby largely negating a principal advantage for using the lighter but highly volatile over older but safer cadmium batteries. See Exhibit 2, Zuckerbrod
Finally, a review of the NTSB April forum and investigative hearing transcripts and podcasts indicates:
a) the FAA has not done battery testing of the 787 battery at its tech center, but only on commonly shipped batteries in air cargo.
b) the FAA gave Boeing an extremely broad, if not unprecedented, Delegation of Authority (DOA) for the design, testing protocols, actual testing for the 787 battery certification without direct FAA supervision. Such broad based self regulation is problematic.
It raises a host of conflict of interest questions, possible self dealing and exposes the Boeing employees charged with testing and approving their employer’s products for safety to undue pressures.
It is particularly dangerous here given the known dangers of lithium ion batteries combined with the untested use of such large batteries to control the fly-by-wire Boeing 787 with five times the power requirements of its predecessor, the Boeing 777.
In March 2013 we asked the FAA and DOT Secretary LaHood to empanel a special advisory committee with outside battery experts and representatives of passenger and flight crews to review the battery fixes and testing proposed by Boeing and the certification procedures used, but received only silence from the DOT and FAA. See Exhibit 6.
NTSB Chair Hersman did respond and noted that a forum was scheduled and an investigative hearing was to be held on April 23-24 regarding the latest battery fire on a Boeing 787. But no passenger representatives were invited for participation. The Boeing fix has not been vetted by the battery technical community or the industry associations that normally recommend safety testing standards to government safety agencies. Nor have many of the technical details of the Boeing fix been publicly disclosed.
Accordingly, the lifting of the Boeing 787 grounding order to permit flights up to 3 hours from the nearest landing site is both premature while the NTSB is still investigating the cause of the 787 battery fires and does not meet the Secretary’s statement that the grounding will not be lifted until the aircraft is shown to be “1,000% ” safe.
Rather, the FAA should:
a) empanel an ad hoc advisory committee composed of battery safety experts not affiliated with Boeing or the FAA, together with stakeholder representatives of passengers and flight crews (those directly at risk), in addition to Boeing, airlines and aviation liability insurance carriers to make recommendations.
b) open a docket for public comment and post the full technical details of the Boeing proposed battery fix.
The Boeing 787 Dreamliner has been touted as a revolutionary 21st Century airliner with unmatched fuel efficiency, passenger comfort and the capacity to fly to nearly any destination on Earth nonstop. But to realize this potential Boeing must be required to meet or exceed modern aviation safety standards that it has thus far failed to do.
1. FAA Emergency Air Worthiness Directive issued Jan. 16, 2013 after 787 battery fires on ground at Boston, and in air Jan. 14, 2013 in Japan, making four battery failures in one year or 52,000 hrs of operation vs Boeing’s prediction of one failure every 10 million hrs. of operation; Several other batteries replaced showing evidence of battery overheating, Aviation Herald Feb. 6, 2013; Boeing 787 had 5 incidents in 5 days .
3. ETOPS stands for extended operations for two engine aircraft; the Joint Aviation Authorities represent European civil aviation authorities. Normally, two engine aircraft must show trouble free service for 24 months before an application to fly over 2 hours from the nearest airport will be considered. Prior to the January 2013 grounding, the Boeing 787 had ETOPS 180 certification and Boeing has sought to increase this to ETOPS 330 (5 ½ hours from the nearest airport). See ETOPS, Wikipedia showing that the Joint Aviation Authorities vetoed a Boeing attempt to certify an earlier aircraft without operational experience.
4. Special conditions B787-8 airplane Lithium Ion battery installation FAA/Federal Register Oct. 11, 2007
5. E.g. Swissair Flight 111 (1998, Halifax fire due to flammable material in entertainment system caused crash killing 229 on board; UPS Flight 6 (Sept. 3, 2010 smoke in cockpit from cargo of Lithium Ion batteries crashed killing 2 person crew near Dubai, FAA then banned lithium Ion batteries on passenger jets as cargo and warned than Halon fire extinguishers ineffective for lithium ion battery fires. Other recent examples include American Airlines Eagle Flight 3773 July 20, 2012 emergency landing Peoria Ill., United 777-222 Nov. 2012 emergency landing at Gander Newfoundland; private jet carrying Ann Romney emergency landing in Denver Sept. 21, 2012 due to electrical fire; Sunway Airlines Mar. 13, 2013 in Ottawa. See gen. GAO report www.gao/atext/d0433.txt Oct. 2003.
May 8, 2013
Member, FAA Aviation Rulemaking Advisory Committee (1997-present)
4411 Bee Ridge Rd. #274, Sarasota, Florida 34233
240-391- 1923 fax