Europe adds to FAA’s Max advice

The European Union Aviation Safety Agency (EASA) has published a Proposed Airworthiness Directive (PAD) , signalling its intention to approve the Boeing 737 MAX’s return to Europe’s skies “within a matter of weeks” – probably about mid-January.

But Europe is specifying a few requirements that the US Federal Aviation Administration (FAA) has not demanded.

It was on 20 November that the FAA approved the aircraft’s return to America’s skies, but US carriers have many preparations to complete before resuming commercial services with the Max. American Airlines reckons it will be ready by the end of December.

EASA, however, wants to see the application of some operational measures that the FAA does not require. It insists, nevertheless, that the Max airframes in America and in Europe will be the same. The agency explains: “The [PAD] requires the same changes to the aircraft as the FAA, meaning that there will be no software or technical differences between the aircraft operated by the United States operators and by the EASA member states operators.”

The EASA PAD is a consultation document, and all responses have to be received by 22 December. EASA executive director Patrick Ky is at pains to point out that the agency, while cooperating with the FAA on correcting the anomalies in the Max’s manoeuvring characteristics augmentation system (MCAS) (see immediately preceding blog entry), insisted on looking independently at the whole issue.

Ky explained: “EASA’s review of the 737 MAX began with the MCAS but went far beyond. We took a decision early on to review the entire flight control system and gradually broadened our assessment to include all aspects of design which could influence how the flight controls operated. This led, for example, to a deeper study of the wiring installation, which resulted in a change that is now also mandated in the [PAD].” That, basically, is a requirement to bring the venerable 737’s design up to date, and is a signal that the days of “grandfather rights” – a dispensation to build the 737 Max as earlier versions of the 737 were constructed rather than as new aircraft have to be designed – are numbered.

The Max airframe design came through all the handling tests satisfactorily, as Ky explained: “We also pushed the aircraft to its limits during flight tests, assessed the behaviour of the aircraft in failure scenarios, and could confirm that the aircraft is stable and has no tendency to pitch-up even without the MCAS.”

Two principle differences between the FAA and EASA requirements are explained as follows: “EASA explicitly allows flight crews to intervene to stop a stick-shaker from continuing to vibrate once it has been erroneously activated by the system, to prevent this distracting the crew. EASA also, for the time being, mandates that the aircraft’s autopilot should not be used for certain types of high-precision landings [and approaches such as RNP-AR]. The latter is expected to be a short-term restriction.”

The crew intervention mentioned would allow the pilots to pull the stick-shaker circuit breaker. The stick-shaker – a system designed to alert pilots to an approaching stall – was one of the distractions that faced the Lion Air and Ethiopian Airlines crews before they lost control of their aircraft, despite the fact that the shaker was triggered by a false warning.

The FAA doesn’t see the need for this intervention, because the modifications have ensured that a single sensor failure will not trigger the stick-shaker any more.

Boeing and EASA say they have agreed to continue tests to see if they can further strengthen the aircraft’s systems’ resilience to angle of attack (AoA) sensor failures – the causal trigger for the two fatal Max accidents, and Boeing has also made this promise: “Boeing will also conduct a complementary Human Factor assessment of its crew alerting systems within the next 12 months, with the aim of potentially upgrading these to a more modern design approach.”

Muilenburg: Returning Max to service ‘will be an international decision’

Boeing CEO Dennis Muilenburg says the successful return to service of the company’s 737 Max series depends on international consensus among the many national aviation authorities (NAA) that will see the aircraft operating in their countries.

Not just the US FAA.

As a reminder, the 737 Max series fleet was grounded in March as a result of findings from the investigations into to the Lion Air and Ethiopian Airlines fatal crashes, respectively in October 2018 and March this year.

Speaking this week at Boeing’s Seattle Delivery Centre, Muilenburg declined to predict a return-to-service date, explaining: “Dates are uncertain because we are going for a global recertification.” That means unanimity – near or absolute – has to be achieved.

Boeing aircraft being prepared for delivery at Boeing Field, Seattle

He emphasised the point: “If we do not coordinate this [return to service] we may see some disaggregation, and I don’t think that’s a future any of us wants to see.”

Muilenburg is confident the combined hardware and software changes Boeing has developed for the Max will satisfy the FAA and the multinational Joint Operations Evaluation Board (JOEB).

The primary causal factor of the Lion Air crash was erroneous triggering of its manoeuvring characteristics augmentation system (MCAS) by a faulty angle of attack (AoA) sensor, according to the Indonesian final accident report. It is at the MCAS that Boeing’s efforts have been directed.

More on MCAS later.

Boeing test pilot and VP Operations Craig Bomben, who flew the 737 Max first flight and has coordinated development activity on the type since the accidents, described the essential difference between the original MCAS and Boeing’s proposed replacement: “We’ve moved from a very simple system to an intelligent system.”

In both the accidents MCAS – triggered by a faulty or damaged AoA sensor which wrongly indicated a high AoA – reacted by providing nose-down stabiliser rotation that took the pilots by surprise. They did not understand the reason it kicked in. Their efforts to reverse the strong nose-down pitch did not succeed, and because both these events occurred just after take-off, the loss of height quickly resulted in impact with the surface.

Bomben said the new “intelligent” system has two AoA sensors instead of one, and if their readings differ by 5.5deg or more, MCAS is not triggered at all.

But if it is correctly triggered, the system now “operates only once per AoA event”, according to Bomben, and when it does trigger stabiliser movement, it memorises how much displacement has taken place, so if it were triggered again it would take account of existing stabiliser displacement and will not apply more than a safe cumulative limit.

But why is MCAS – which is unique to the Max – required at all? Boeing insists it was not fitted as an anti-stall system, because the aircraft already has stall warnings and stick-shakers.

The purpose of fitting MCAS, Bomben explained, was to compensate for a slight change in the low-airspeed aerodynamics of the 737 Max compared with the NG.

MCAS was only designed to trigger in an unlikely (but obviously possible) combination of circumstances that can cause the aircraft’s centre of lift to move slightly further forward, altering the weight-balance equation. It only happens when the Max is at low airspeed with the flaps up, and is being flown manually.

At low airspeed (200kt or thereabouts) – and flapless – the aircraft would be at a high angle of attack and close to the stall. FAA regulations require that one of the cues to the pilot of the approaching stall is that there should be a linear increase in the required column force versus displacement response.

In the Max, however, at a certain point in this sequence the centre of lift shifts forward a little, providing a slight nose-up pitch force, therefore the stick force does not continue to increase, so MCAS is designed to kick in with some nose-down trim to restore the linear increase.

If MCAS doesn’t kick in, the aircraft is still easily controlled without it, but the required progressive stick-force cueing is lost.

In technical and regulatory terms, MCAS seems to be a lot of fuss for very little purpose, but the painful fact is that the original MCAS played its part in bringing down two aeroplanes and killing 346 people.

Muilenburg’s confidence in the fix is, so far, based on more than 100,000 hours of development work on the new solution, plus 1,850 flight hours using the new software, 1,200 hours of refining the results in the simulator, and 240 hours of regulatory scrutiny in the simulator.

Meanwhile, if Muilenburg cannot predict when the world will approve the 737 Max’s return to the air, what is happening to its production at present? The aircraft had won more than 5,000 orders, and fewer than 400 have been delivered.

The Max series, despite the grounding, continues to roll off the production line at Boeing’s Renton plant near Seattle, at a rate of 42 per month. The factory is capable of turning out 57 a month, but Boeing is keeping the rate lower for now. Despite this, Renton has seen no staff layoffs, says Boeing.

The completed aircraft, however, go into storage at Moses Lake or San Antonio desert sites, because the manufacturer’s own sites at Renton, Everett and Boeing Field are full.

Muilenburg said every 737 Max grounded or in store awaiting modification will have an individual entry into service programme, and that in the meantime the engines, systems and cabin of all the aircraft are regularly being run and maintained.

But will they still have that “new plane smell” when the airlines take delivery?

A Max in production at the Renton plant, its unique split winglet close to the camera