I am no expert on the process either but my thoughts on everything:
- ‘additional testing that has been requested in relation to the APB application by the Federal Aviation Administration (FAA)’ – I must have missed it but I was unaware the FAA were even looking at an application re the APB let alone requiring additional testing. I thought (obviously wrongly) Boeing required the additional testing in respect of potential issues between anti-corrosion compounds, and then once this was clear Boeing would be making the application to the FAA.' - I think you will find FAA and Boeing would be in constant dialogue throughout the process so what Boeing are requesting would be in anticipation of questions that may arise from the FAA.
- “The Company has provided a number of updates to the market over the reporting period regarding the additional testing that has been requested in relation to the APB application by the Federal Aviation Administration (FAA) towards certification of the draft Boeing service bulletin, which remains a key priority.” So Service bulletin by Boeing or AMOC by FAA?I thought we were going for an AMOC to be issued by the FAA yet it seems all we need is a Boeing Service bulletin presumably prepared after their in depth corrosion analysis." - My understanding was the service bulletin was always the pathway and opens the door to all operators using that aircraft model to utilise this to meet an airworthiness directives, such as compliance to monitoring of cracking for the APB.
Chat GPT probably says it better than me:AMOC stands for "Alternative Method of Compliance," while a service bulletin is a document issued by an aircraft or equipment manufacturer or other relevant authority.
AMOC (Alternative Method of Compliance):AMOC is a term used in aviation, particularly in the context of airworthiness directives (ADs). An AD is a mandatory directive issued by aviation authorities (such as the Federal Aviation Administration - FAA in the United States or the European Union Aviation Safety Agency - EASA in Europe) to address potential safety issues or deficiencies in aircraft, engines, or components. When an AD is issued, it outlines specific requirements or actions that aircraft operators or owners must follow to ensure the continued airworthiness of the affected equipment.However, in some cases, a particular operator or aircraft owner may find that it is difficult or impractical to comply with the specific requirements of the AD. In such situations, they can request an AMOC from the aviation authority. The AMOC is an approved alternative way to comply with the intent of the original AD while maintaining an equivalent level of safety. It allows for flexibility in meeting the AD requirements as long as the alternative method proposed by the operator or owner is proven to be equally effective in ensuring safety.
Service Bulletin:A service bulletin is a document issued by an aircraft or equipment manufacturer, an aviation authority, or other relevant organizations to provide information, guidance, or recommended actions related to maintenance, repairs, or improvements to aircraft or aviation components. Service bulletins are not mandatory, but they are considered important by aircraft operators and maintenance providers to ensure the safe and reliable operation of the aircraft.Service bulletins typically contain:
Detailed instructions for inspections, repairs, or modifications.Information about known issues or potential problems with specific equipment.Recommendations for necessary updates or changes to ensure continued airworthiness.Instructions on how to comply with airworthiness directives (ADs) issued by aviation authorities.While compliance with ADs is mandatory, compliance with service bulletins is generally voluntary. However, it is common practice in the aviation industry for operators to follow service bulletins to maintain their aircraft in the best possible condition and to address potential issues before they become critical.
In summary, an AMOC is a formal authorization granted by aviation authorities to use an alternative method to comply with the requirements of an AD, while a service bulletin is a non-mandatory document providing guidance and recommendations for maintaining and improving the airworthiness of an aircraft or its components.
3. "SMS Chief Technical Officer Trevor Lynch-Staunton P. Eng said ongoing testing has made favourable progress on the CIC issue with Boeing. Thetargeted solution requires no sensor system changes, only some minor changes to the Service Bulletin ahead of the anticipated FAA certification" - So all the testing appears to have validated all that CVM has to offer and we are now just waiting on some wording changes to the Service Bulletin– who is doing this Boeing or FAA.? How long to write some new words?It almost seems to be that the original CVM FAA approval for the wifi application has been of no benefit – with this APB application requiring fresh testing and then lo and behold it gives rise to the fact that there are no CVM sensor system changes required. So why wasn’t CVM accepted as approved as it was for the wifi? Boeing writes the service bulletin as they instruct operators how to maintain their aircraft. The original WIFI approval has helped approve the core of the technology - if you can imagine every application will have a different sensor design and configuration. The fact that the SHM issues paper, developed on the back of the wifi approval has contributed to ticking off alot of the core questions i.e. sensor durability, environmental testing (how they perform at differing temperatures) - all those questions may have taken longer to tick off with out this ealier work.
It wasn't accepted as approved for the wifi I think partly because of the differing location of the application - this area takes 3 days to open up and is pretty critical to the structure of the aircraft, but admittedly this has taken alot longer than first thought - WIFI took 4 years from memory though.
I think at some stages they are going to run out of questions and that is when the pace of applications will hopefully pick up.
That's my take anyways - the fact SMN are stating that the approval is anticipated and the delays are not material to the continuation of conversations with interested operators is enough to calm my nerves right now but there has been a number of false starts over the years and I get the frustration.