空客发布了:FOT-999-0028-20-00。
Since the start of the COVID-19 crisis a large number of passenger aircraft are grounded, inducing a dramatic reduction of the express cargo transport.
In the meantime the demand for humanitarian aid material has increased a lot.
As a result many airlines would like to restart the operation of their aircraft with only cargo on board.
And even if the Airbus aircraft already provides a significant cargo capacity in lower deck, there is a clear trend to try and use the cabin area as well.
Some airlines already started initiatives, but according to the number of technical requests received in the past days, we understand that the operation is not easy to put in place.
How to load the aircraft? How to obtain the approval from airworthiness authorities? What can be done with a passenger aircraft?
Operators require support from aircraft manufacturers and from authorities.
During this session I will
- Explain what aircraft usage is already approved,
- What we could do to enhance the cargo capacity which require an approval from airworthiness authorities
- What is necessary to enable transport of cargo on non approved locations.
Note: this presentation is not dedicated to a particular aircraft type. The principles are the same for all aircraft types.
Apart from the underfloor cargo compartments, the Airbus aircraft already offers several stowage locations in the cabin, which are approved for the transport of items:
- Overhead stowage compartments,
- Underseat space
- Galleys: stowage boxes and trolleys
- Stowage closets
Such spaces already enable an interesting additional capacity:
For example the combined capacity of the overhead compartments, underseat space, and galley compartments is around 4 tons on an A320*, around 10 tons on an A330*.
*values given for information only. Real values depend on the aircraft real cabin layout
With the COVID-19 crisis there is no passenger onboard anymore, releasing a lot of space in the cabin, on the seats themselves. And one can even imagine removing the seats to free the floor area.
Unfortunately such usage of the aircraft cabin is not approved: during the certification of a passenger aircraft there is no requirement to demonstrate that the seats or cabin floor are capable to support cargo loads. This is not considered as a normal use of the aircraft.
From an airworthiness perspective, using the seats or the cabin floor to transport cargo is a significant change in the aircraft operation. The EASA considers that it is a major change and requires to get an formal approval by demonstrating the compliance to relevant airworthiness specifications.
However the regulations offers the possibility to the operator to ask an exemption of the demonstration of certain airworthiness specification in exceptional cases.
So, How to enable the transport of cargo inside the aircraft cabin?
Monday 30th of March Airbus published a Flight Operations Transmission (FOT) in order to provide :
- the manufacturer guidelines for the transport of cargo in the cabin in approved locations,
- additional information to support the approval of transport in not approved locations
This week as well the EASA published guidelines for the National Competent Authorities on how to manage requests in exemption for not approved locations.
The EASA document teaches us that the request in exemption is limited in its usage:
-
A period of time: duration of the COVID-19 outbreak or 8 months maximum
-
A defined scope: use of cabin seats when related to the transportation of medical supplies (e.g. masks, gloves, clothing,etc.) provided they are not classified as dangerous goods.
-
Specific certification requirements:CAT.OP.MPA.160 “Stowage of Baggage and Cargo”
On the contrary other cargo usage such as
- Transport of cargo on the longer term
- Transport of cargo other than medical supplies
- Transport of cargo on the cabin floor
Cannot be exempted from a complete demonstration through a Major MOD approval
Airbus goal is to facilitate the airline operations in particular during this crisis time, but the safety of the flight is not an option and remains the first requirement.
Airbus considers that the requirements published by the EASA shall be fulfilled in the first place.
Therefore Airbus has put in place a task force to investigate and:
- improve the support to Airbus Operators for the exemption process in the case of medical supply transport on cabin seats
- Provide an approved solution for the transport of cargo by applying for a Major MOD
On a priority based approach Airbus published first, through the FOT, the manufacturer requirements essential for the operator to start the exemption process.
The next step is to provide additional guidance, in the coming days, to improve our support to the exemption process
Looking at the EASA guidance material we have identified areas where we can further support:
1. The EASA requires that the exact cargo weight and position is reflected in the operational documentation.
Indeed, the load and trim sheet, whether it is computerized or not, is not designed to account for a cargo load in the cabin. The adaptation of the load control process and/or of the W&B documentation is necessary
2. The EASA requires that the cargo does not exceed the structural loading limits, as published in the weight and balance manual.
Because the loading of cargo was not foreseen until now, the weight and balance manual does not provide all the limitations necessary to demonstrate the compliance. For instance the cabin floor track allowable loads are not published in the WBM.
3. The EASA requires that the Operator sets-up an adequate fire fighting crew and adapted processes.
The Airbus documentation such as the CCOM does not provide relevant information for a cabin empty of passengers.
While the set-up of the fire fighting crew is not linked to manufacturer’s requirement, we intend to provide additional guidance.
For those 3 items The task force intention is to provide a complement to the FOT
Airbus intends also to support the airlines who needs a more permanent/increased cargo capacity in the cabin.
The solution is still under definition but the aim is to provide the mean to secure cargo in the cabin
- easily
- and using existing material already available for cargo transport in lower holds.
The task force goal is to have a solution approval in the coming weeks.