By Scott Hamilton
Jan. 16, 2020, © Leeham News: Certification of the Boeing 777X is far off. The airplane’s first flight hasn’t occurred. There is no date announced when it will, but sources suggest it could be this month.
The fallout from the 737 MAX crisis and its certification process isn’t fully understood. Neither Boeing nor the Federal Aviation Administration announced what the 777X process will be.
It’s assumed that the discoveries about the MAX certification process will result in a revision to the FAA’s approach to 777X certification.
There are questions circulating in the aviation community whether the FAA will revisit every certification step done so far for the 777X and what it will look like in the future.
A new question arises: will the 777X be certified as a derivative of the 777 Classic—the path Boeing wants. Or will the FAA decide that enough changes are designed into the 777X that it needs an entirely new type certificate?
Boeing launched the MAX, and the 777X, as mere derivatives of the predecessor airplanes, the 737NG and the 777 Classic.
The 737’s changes focused mainly on new engines, some aerodynamic clean up, some announced flight control changes and, as the world now knows, the MCAS.
By contrast, the 777X has new engines, a new composite wing, commercial aviation’s first folding wingtips, a fuselage stretch and some upgraded systems.
It also has larger passenger windows, similar to the 787. The 777X, however, retains a metal fuselage.
In the wake of the MAX crisis, LNA is told that the overarching question is whether these changes are extensive enough to prompt the FAA to require a new type certificate rather than certifying the X as a derivative.
If the FAA chooses the former, it could add a year or more to the certification process. Boeing sold the X to airlines on a delivery schedule based on an amended type certificate. A new type certificate not only delays the delivery schedule, but adds costs to the airline.
The stress-test blow out of a door on the 777X last year adds another question. The failure reportedly was within 1% of the required safety margin. Boeing initially said this wouldn’t affect the certification timeline. LNA is told, however, that this remains unclear—another potential impact of the MAX crisis.
GE Aviation is certifying the GE9X for the 777X as a new engine, not a derivative of the GE90.
JATR certification review
A Joint Authorities Technical Review (JATR) board was created to review the MAX certification process. JATR included regulators from 10 authorities. They are the US, European Union, Japan, Brazil, Canada, Australia, Indonesia, Singapore, United Arab Emirates and China.
JATR said its “recommendations raise the foundational issue of whether a process that has historically served the industry well for decades based largely upon compliance needs to be revisited to address not only compliance but also safety. As systems become more complex and may interact in unforeseeable ways, the likelihood increases that regulations and standards will not address every conceivable scenario.
“To the extent they do not address every scenario, compliance with every applicable regulation and
standard does not necessarily ensure safety. Moreover, as systems become more complex, the certification process should ensure that aircraft incorporate fail-safe design principles. These principles prioritize the elimination or mitigation of hazards through design, minimizing reliance on pilot action as primary means of risk mitigation.”
The FAA website last year indicated it takes 3-5 years for certification of a derivative and 5-7 years for a new airplane.
Boeing successfully lobbied Congress to allow the FAA to grant more responsibility for inspections to Boeing through what’s called the ODA program. The FAA retained ultimate approval.
In a change to production Boeing has been working on for years under the code name Black Diamond, Boeing wanted to further compress certification time. The objective was to have only five years from program launch to entry-into-service of a new airplane. Cost reduction as well as streamlining production and certification is part of Black Diamond.
This is why Boeing officials kept saying they could target EIS of the New Midmarket Airplane for 2025 even as program launch kept slipping to the right. (Whether this was realistic was a matter of debate.)
The FAA has a set of regulations called the Changed Product Rule (CPR).
Derivatives by definition change this and that. Under the CPR, the changes are reviewed. Systems and parts of the airplane that are unchanged are not.
JATR concluded in its October 2019 report that in the case of the MAX, the CPR “process lacks an adequate assessment of how proposed design changes integrate with existing systems and the associated impact of this interaction at the aircraft level. A more fulsome assessment process would apply to establishing the certification basis as well as to finding compliance throughout the certification process.”
No announcement has been made by the FAA how this may affect its review and certification of the 777X.
What does all this mean?
This means there is a great deal of uncertainty surrounding the certification of the 777X.
The 777X already is at least a year behind schedule because of technical design issues with the engines. EIS is now targeted for 2022 vs the original EIS of this year.
Another delay of a year or more due to a new-vs-derivative certification of the aircraft likely places key orders in jeopardy.
Emirates Airline late last year canceled orders for 35 777Xs. Etihad Airways previously canceled orders for 19 of 25 (even though Boeing still lists them on its website). The carrier is understood to want to cancel the remaining six orders.
Passenger traffic for Cathay Pacific Airways of Hong Kong has fallen through the floor in the wake of the civil-political turmoil there. China Southern Airlines, with its hub in nearby Guangzhou, left the SkyTeam Alliance and now code shares with airlines from OneWorld, which Cathay also belongs to. China Southern is expected to divert traffic from Cathy for passengers seeking to enter China. These events may mean Cathy no longer needs its 777X order.
Certification delays could further pressure the viability of the 777X program.