European Union Aviation Safety Agency
Notice of Proposed Amendment 2019-02
Class D compartments
RMT.0070 (26.003)
EXECUTIVE SUMMARY
The objective of this NPA is to address the issue of potential uncontrollable fires in the Class D compartments of large
aeroplanes used for commercial air transport (CAT). This includes any fires that result from thermal runaways of lithium
batteries.
This NPA proposes, through an amendment of Part-26/CS-26, to require operators, whose in-service large aeroplanes used
for CAT contain Class D cargo or baggage compartments, to apply to those aircraft:
— the standards applicable to Class C compartments, if the aeroplanes are involved in the transport of passengers, or
— the standards applicable to either Class C or Class E compartments, if the aeroplanes are only involved in all-cargo
operations.
If a regulation is introduced to amend Part-26 to require these changes, the resulting conversions of the Class D
compartments would need to be performed within three years of the entry into force of that regulation.
The proposed changes are expected to increase safety by mitigating the risk of uncontrollable fires in Class D cargo or
baggage compartments, and to improve harmonisation with the Federal Aviation Administration (FAA).
Action area: Aircraft environment
Affected rules: Part-26, CS-26
Affected stakeholders: Air operators and POA holders
Driver: Safety Rulemaking group: No
Impact assessment: Full Rulemaking Procedure: Standard
17.9.2010 22.11.2013 (NPA 2013-23) 2019/Q3 2021/Q2 2021/Q2
1.3.2019 (NPA 2019-02)
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Table of contents
Table of contents
1. About this NPA...................................................................................................................... 3
1.1. How this NPA was developed ................................................................................................... 3
1.2. How to comment on this NPA .................................................................................................. 3
1.3. The next steps .......................................................................................................................... 3
2. In summary — why and what ................................................................................................ 4
2.1. Why we need to change the rules — issue/rationale .............................................................. 4
2.2. What we want to achieve — objectives ................................................................................... 5
2.3. How we want to achieve it — overview of the proposals........................................................ 5
2.4. What are the expected benefits and drawbacks of the proposals .......................................... 5
3. Proposed amendments and rationale in detail ....................................................................... 6
3.1. Draft regulation (amending Part-26) ........................................................................................ 6
3.2. Draft certification specifications (amending CS-26) ................................................................. 6
4. Impact assessment (IA).......................................................................................................... 8
4.1. What is the issue ...................................................................................................................... 8
4.2. What we want to achieve — objectives ................................................................................. 10
4.3. How it could be achieved — options...................................................................................... 10
4.4. Methodology and data ........................................................................................................... 11
4.5. What are the impacts ............................................................................................................. 11
4.6. Conclusion .............................................................................................................................. 13
4.7. Monitoring and evaluation ..................................................................................................... 14
5. Proposed actions to support implementation ...................................................................... 16
6. References .......................................................................................................................... 17
6.1. Affected regulations ............................................................................................................... 17
6.2. Affected decisions .................................................................................................................. 17
6.3. Other reference documents ................................................................................................... 17
7. Appendix 1: Retirement curves ............................................................................................ 18
8. Appendix 2: Tables .............................................................................................................. 19
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1. About this NPA
1. About this NPA
1.1. How this NPA was developed
The European Union Aviation Safety Agency (EASA) developed this NPA in line with Regulation
(EU) 2018/11391 (‘Basic Regulation’) and the Rulemaking Procedure2. This rulemaking activity is
included in the European Plan for Aviation Safety (EPAS)3 under rulemaking task (RMT).0070 (26.003).
The text of this NPA has been developed by EASA and is hereby submitted to all interested parties4 for
consultation.
1.2. How to comment on this NPA
Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/5.
The deadline for submission of comments is 1 June 2019.
1.3. The next steps
Following the closing of the public commenting period, EASA will review all the comments received.
Based on the comments received, EASA will consider the need for amendments to Commission
Regulation (EU) 2015/6406 and, if necessary, issue an opinion.
The opinion would be submitted to the European Commission, which will use it as a technical basis in
order to take a decision on whether or not to amend the Regulation.
If the Commission decides that the Regulation should be amended, EASA will issue a decision that
amends CS-267 and proposes certification specifications (CSs) and to comply with the amendments
introduced into the Regulation.
The comments received on this NPA and the EASA responses to them will be reflected in a comment-
response document (CRD). The CRD will be published and appended to any opinion or decision that is
linked to this NPA.
1 Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of
civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005,
(EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European
Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European
Parliament and of the Council and Council Regulation (EEC) No 3922/91 (OJ L 212, 22.8.2018, p. 1) (https://eur-
lex.europa.eu/legal-content/EN/TXT/?qid=1535612134845&uri= CELEX:32018R1139).
2 EASA is bound to follow a structured rulemaking process as required by Article 115(1) of Regulation (EU) 2018/1139.
Such a process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’.
See MB Decision No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied
by EASA for the issuing of opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-
agency/management-board/decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3 https://www.easa.europa.eu/document-library/general-publications?publication_type%5B%5D=2467
4 In accordance with Article 115 of Regulation (EU) 2018/1139 and Articles 6(3) and 7 of the Rulemaking Procedure.
5 In case of technical problems, please contact the CRT webmaster (
[email protected]).
6 Commission Regulation (EU) 2015/640 of 23 April 2015 on additional airworthiness specifications for a given type of
operations and amending Regulation (EU) No 965/2012 (OJ L 106, 24.4.2015, p. 18) (https://eur-lex.europa.eu/legal-
content/EN/TXT/?qid= 1537864675699&uri=CELEX:32015R0640).
7 Certification Specifications and Guidance Material for Additional airworthiness specifications for operations (CS-26).
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2. In summary — why and what
2. In summary — why and what
2.1. Why we need to change the rules — issue/rationale
Almost 500 large aeroplanes fitted with Class D cargo or baggage compartments are currently
registered in EASA Member States.
The risk of uncontrollable fires in this type of compartment was evaluated in NPA 2013-238, and the
overall cost-benefit ratio of a mandatory conversion from a Class D compartment into a Class C or
Class E compartment was considered at that time to be low enough not to propose a regulatory
change (EUR 49.1 million in 2013 values for the industry, 0.07 accidents avoided and 5 lives saved).
In parallel, the carriage of lithium batteries in cargo or baggage compartments has increased over
recent years, together with the identified risk of thermal runaways and the subsequent fires related
to those batteries.
For this reason, EASA published Safety Information Bulletin (SIB) No. 2017-04R19 in December 2017
and decided to review the assessment performed in 2013 and the conclusion reached with
NPA 2013-23.
This NPA presents the updated assessment made by EASA and its new proposal based on the
conclusions of this assessment.
Note:
— A Class D cargo or baggage compartment is one in which a fire should be completely contained
without endangering the safety of the aeroplane or the occupants and without being accessible
to crew members. Such compartments depend on oxygen deprivation to prevent and suppress
combustion, and on the capability of liners to resist flame penetration.
— A Class C cargo or baggage compartment is one equipped with a smoke or fire detector system
and with a fire extinguishing or suppression system that is controllable from the cockpit.
— A Class E compartment is similar to a Class C compartment, but it is not equipped with a built-
in fire extinguisher and is used only for the carriage of cargo.
Related safety issues
The following safety recommendations, addressed to the FAA by the National Transportation Safety
Board (NTSB), are considered in the frame of this RMT: A-88-12210, A-88-123 and A-97-05611. The NTSB
recommended that the installation of smoke detection and fire suppression systems in all Class D
cargo or baggage compartments should be mandated.
In response, and in order to remove the risk of uncontrollable fires in Class D compartments of already
in-service aeroplanes, the FAA issued on 19 March 1998 the final rule FAR Part 121 Amdt 121-269.
This Amendment introduced the following requirements:
8 https://www.easa.europa.eu/sites/default/files/dfu/NPA%202013-23.pdf
9 https://ad.easa.europa.eu/ad/2017-04R1
10 https://www.ntsb.gov/safety/safety-recs/recletters/A88_121_128.pdf
11 https://www.ntsb.gov/safety/safety-recs/recletters/A97_56_77.pdf
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2. In summary — why and what
(a) Class D compartments in certain transport category aeroplanes already in service and used in
transport of passengers must meet the fire or smoke detection and fire suppression standards
for Class C compartments;
(b) Class D compartments in certain transport category aeroplanes already in service, and used only
for the carriage of cargo, must meet the standards of either Class C compartments or the
standards of Class E compartments.
2.2. What we want to achieve — objectives
The overall objectives of the EASA system are defined in Article 1 of . This proposal will contribute to
the achievement of the overall objectives by addressing the issues outlined in Section 2.1.
The specific objective of this proposal is to mitigate the risk of a serious incident or accident caused
by a fire that starts in a Class D compartment of a large aeroplane.
2.3. How we want to achieve it — overview of the proposals
It is proposed to introduce a requirement into Part-26 to state that (within three years of the
amendment of the Regulation) all the in-service large aeroplanes that are used for CAT should have
their Class D cargo or baggage compartments converted into:
(a) Class C compartments, if they are involved in the CAT of passengers, or
(b) either Class C or Class E compartments, if they are only involved in the CAT of cargo.
It is also proposed to amend CS-26 to provide specifications to be used to show compliance with the
new requirement in Part-26.
2.4. What are the expected benefits and drawbacks of the proposals
The proposal is expected to increase both safety and harmonisation with the FAA.
The cost generated by the proposal would be financed for the most part by the operators of the
affected aeroplanes.
The environmental impact is expected to be low to negligible.
No adverse social impact is expected.
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3. Proposed amendments and rationale in detail
3. Proposed amendments and rationale in detail
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
— deleted text is struck through;
— new or amended text is highlighted in blue;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
3.1. Draft regulation (amending Part-26)
PART-26
ADDITIONAL AIRWORTHINESS SPECIFICATIONS FOR OPERATIONS
(…)
SUBPART B
LARGE AEROPLANES
(…)
26.157 Conversion of Class D compartments
Operators of large aeroplanes used in CAT, type certified on or after 1 January 1958, shall ensure that,
not later than [three years after the entry into force of this regulation]:
(a) for aeroplanes, the operation of which involves the transport of passengers, each Class D cargo
or baggage compartment, regardless of its volume, complies with the specifications applicable
to a Class C compartment; and
(b) for aeroplanes, the operation of which involves the transport of cargo only, each Class D cargo
compartment, regardless of its volume, complies with the specifications applicable to either a
Class C or a Class E compartment.
3.2. Draft certification specifications (amending CS-26)
(…)
Book 1
SUBPART B — LARGE AEROPLANES
(…)
CS 26.157 Conversion of Class D compartments
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3. Proposed amendments and rationale in detail
(a) Compliance with 26.157(a) of Part-26 can be demonstrated by showing compliance with
CS 25.857(c) and CS 25.858 of CS-25.
(b) Compliance with 26.157(b) of Part-26 can be demonstrated by showing compliance with:
(1) either CS 25.857(c) and CS 25.858 of CS-25;
(2) or CS 25.857(e) of CS-25.
(…)
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4. Impact assessment (IA)
4. Impact assessment (IA)
4.1. What is the issue
Safety risk assessment
EASA is aware of numerous occurrences (27) of thermal runaways of lithium batteries that were
reported by operators. These events took place on the ground and did not lead to any accidents.
Recent testing (refer to SIB No. 2017-04R112) showed that if a thermal runaway event occurs in a large
portable electronic device that is carried together with flammable material (e.g. hairspray) in an item
of checked baggage, there would be a low probability that a Class D cargo or baggage compartment
could contain the resulting fire, and a medium to low probability that a Class C compartment could
contain it. The consequence of such a fire could therefore be catastrophic if it happened in flight in a
Class D compartment. In a Class C or a Class E compartment, however, the earlier awareness of the
start of the fire should help to mitigate its consequences.
The probability of a fire occurring in a Class D compartment, per departure, was estimated over the
1996-2015 period, based on:
(a) 27 known occurrences involving thermal runaways of lithium batteries in aviation environments
(on board, in the airport facilities, etc.);
(b) 1 reported occurrence of a fire in an aeroplane equipped with a Class D compartment; and
(c) the worldwide CAT cycles in the corresponding period (516 292 182 CAT flights).
This combination results in an average probability of an uncontrolled fire event of 5.42 × 10-8 per
departure.
Who is affected
Air operators of large aeroplanes equipped with Class D compartments are primarily affected by this
issue. Design and production organisations (type certificate (TC) holders or supplemental type
certificate (STC) holders) could be affected if they are requested to design and produce design changes
to support operators in upgrading their Class D compartments.
Since September 2007 (when Amendment 3 of CS-25 was published), EASA has not accepted any
applications for approvals of large aeroplane types whose designs have included Class D
compartments.
The issue therefore affects large aeroplanes manufactured based on an approved design for which an
application to EASA was made prior to the above-mentioned change to CS-25.
The number of large aeroplanes operated by EASA Member State operators that are equipped with
Class D cargo or baggage compartments and are still in service (including temporary storage) is
estimated to be 467 (as of November 2018). Around two-thirds of this fleet is composed of Airbus
A320/A319 and Boeing 737 type aeroplanes.
12 https://ad.easa.europa.eu/ad/2017-04R1
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4. Impact assessment (IA)
Table 1: Number of large aeroplanes with Class D cargo compartments13
Number
Manufacturer Type
of A/C
Airbus A319/A320 158
Boeing 737 154
Embraer ERJ-145 27
BAE Systems (Avro) RJ 27
Boeing (McDonnell-Douglas) MD-80 24
BAE Systems (Jetstream) Jetstream 41 22
328 Support Services Dornier 328 21
Fokker Fokker 100 20
Embraer EMB-120 6
Fokker Fokker 70 5
BAE Systems (HS) ATP 3
Grand Total 467
How could the issue/problem evolve
EASA has established a general retirement curve based on the age of aeroplanes. The retirement curve
is based on a formula that, for each year, calculates the probability of retirement of an aeroplane,
based on its age. The formula is based on historical data on the age of aeroplanes at the time when
they were withdrawn from service.
Figure 1: the expected evolution of the number of in-service large aeroplanes, initially equipped with
Class D cargo or baggage compartments, operated by EASA Member State operators14.
500
450
400
350
Aircraft in service
300
250
200
150
100
50
0
Year
13 Aircraft in service and in temporary storage, operated by EASA Member State operators on 2 November 2018.
14 Darker shades of red from 2025 show the period when Class D cargo compartments have to be converted.
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4. Impact assessment (IA)
Note: because there is currently no requirement in the EU legal framework that forbids operators to
downgrade existing Class C or Class E compartments into Class D compartments, the size of the
affected fleet may be greater than estimated.
4.2. What we want to achieve — objectives
The operational objective of this proposal is to improve the protection of occupants of large
aeroplanes operated in CAT by reducing the probability of uncontrollable fires in their Class D cargo
or baggage compartments.
4.3. How it could be achieved — options
The probability of containing a fire that results from the thermal runaway of a large portable electronic
device in a Class C compartment is greater than in a Class D compartment. In addition, thanks to its
installed smoke or fire detection systems, a Class C or E compartment would alert the pilots and
provide them with earlier awareness of a fire in the cargo or baggage compartment. This awareness,
if achieved, would lead to a reduction in the severity of such an event, and therefore to a reduced risk
of an accident.
The options proposed are therefore — besides the option to not change the regulation (Option 0) —
either a voluntary conversion (Option 1) or a mandatory conversion (Option 2) of the existing Class D
compartments.
Table 2: Selected policy options
Option Short title Description
No
0 Baseline No policy change (no change to the rules; risks remain as outlined in the
option issue analysis).
1 Voluntary Promote the voluntary conversion of Class D compartments to Class C or
conversion Class E compartments
2 Mandatory Require the conversion of Class D compartments into Class C or Class E
conversion compartments before a given date
(Part-26)
Assuming that operators have to comply with the new rule by 1 January 2025, Table 7 shows the
estimated number of large aeroplanes in service that would be fitted with Class D cargo or baggage
compartments, and the risk of a catastrophic fire for the whole estimated service life of the remaining
affected fleet.
Out of the 467 aeroplanes that were in service in 2018, it is expected that 263 will have been retired
by the end of 2024. The last aeroplane of the remaining affected fleet of 204 aeroplanes will have
been retired by 2047.
The current average aircraft age of 23.9 years (Table 6) is going to gradually increase to 48.5 years by
2047. The average annual flight hours and the average annual departures show strong correlations
with the age of the aeroplanes (Table 4 and Table 5), and these correlations were taken into account
when forecasting the future flight hours and departures.
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4. Impact assessment (IA)
4.4. Methodology and data
Methodology applied
Cost-effectiveness analysis was used to calculate the net cost associated with preventing one fatality.
Cost-effectiveness analysis ranks regulatory options based on the ‘cost per unit of effectiveness’, i.e.
the cost per fatality avoided.
In order to avoid a result that concentrates only on a single type of benefit (i.e. the number of fatalities
avoided), the net cost of each option was calculated, taking into account the benefit of avoided
aeroplane damage, as well as airport delays and diversions. The environmental impacts of additional
CO2 emissions were monetised and taken into account as part of the total net costs.
To make the results comparable, all monetary values are expressed in 2018 euros. For future costs
and benefits, a standard discount rate of 4 % was applied, and past costs were inflated by the same
rate. Discounted euro values are marked with the PV (present value) abbreviation in the columns to
the right of the undiscounted figures.
The benefits are accrued during the period while the aircraft with updated cargo compartments are
in service (2025–2047) and the installation costs are incurred in the last year of the transitionary
period, which is 2024. Operating costs (extra fuel burn, maintenance, etc.) occur over the same period
as the benefits (2025–2047).
Data collection
The current fleet of aircraft with Class D cargo or baggage compartments was estimated using
information from FlightGlobal’s Flight Fleets Analyzer. Detailed information was also provided by
some aeroplane TC holders to identify the potentially affected aeroplanes, including the serial and line
numbers of some types.
4.5. What are the impacts
Safety impact
Option 0
At the level of an individual aeroplane, the risk of an uncontrolled fire may increase over the years if
no actions are taken, mainly due to the expansion of the transport of lithium batteries. At the level of
the fleet of aeroplanes equipped with Class D compartments, although the size of the fleet should
decrease over time, there is a possibility that this decrease may be slowed down if no measures are
taken to prevent the conversion of Class C or Class E compartments into Class D compartments. The
overall risk is therefore difficult to estimate, and it may even increase.
Option 1
Some operators may be more sensitive to voluntary actions than others. In particular, operators that
face significant economic constraints may be less receptive to voluntarily converting their Class D
compartments.
The promotion of voluntary actions by operators to convert Class D compartments could, however,
provide a strong indication to operators that they should not convert Class C or Class E compartments
into Class D compartments.
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4. Impact assessment (IA)
This option is therefore likely to bring a slightly greater positive safety impact than Option 0.
Option 2
Mandating the conversion of Class D compartments into Class C or Class E compartments would
ensure that by the compliance date, all the affected aeroplanes would have been either converted or
removed from service. It may also accelerate the retirement of affected aeroplanes, which are already
quite old, and their replacement by newer (and hence safer) aeroplanes.
Option 2 would, in general, bring a greater positive safety impact than Option 1.
The related design changes are already available, therefore the compliance period could be relatively
short.
Environmental impact
The conversion of a Class D compartment into a Class C or Class E cargo or baggage compartment has
only a minor impact on the environment, since such a conversion would introduce only a slight weight
increase for the aeroplane. The average weight increase per aeroplane is in the range of 20 to 100 kg.
This weight increase would result in an associated greater consumption of fuel and additional gaseous
emissions (Table 8 and Table 9), which would accumulate over the lifetime of the aeroplane. Since the
affected aeroplanes and their flight hours represent a small and decreasing share of the total annual
traffic from 2025 to 2047, the environmental impact is estimated to be low to negligible.
As mentioned earlier, a mandated conversion may accelerate the retirement of affected aeroplanes
and their replacement by newer and more environmentally friendly ones.
Social impact
Not applicable.
Economic impact
Whether it is voluntary or mandated, the conversion of Class D cargo or baggage compartments into
either Class C or Class E compartments might lead to non-negligible costs for the operators who have
to implement the changes. Depending on the possible transition period of the amending Regulation
(which for this analysis is assumed to be three years, with a potential entry into force in 2021 and
applicability in 2024), 204 out of 467 aeroplanes would need to be converted. (The other 263
aeroplanes are expected to have been retired from service by the end of 2024).
Since for most of the affected aeroplane types, the design changes are already available (as required
for compliance with the FAA regulations), the cost of development of a modification is negligible for
the aeroplane TC/STC holders. Most of the cost would therefore be on the operators who need to
implement changes to their aeroplanes with Class D compartments or to replace the affected
aeroplanes.
The cost of the conversion would be around EUR 90 00015 for the upgrade kit and the installation per
aeroplane. Because most operators would likely perform this conversion during a scheduled C-check,
there would be no revenue lost due to time out of service.
15 EUR 90 000 is based on the average of the range that the FAA used in 1998: ‘Nominal equipment and installation unit
(i.e. each airplane) costs range from $13 000 to $101 000 depending on the airplane model’.
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4. Impact assessment (IA)
Multiplying this cost for the 204 large aeroplanes estimated to be affected leads to a forecasted
undiscounted cost for a fleet-wide retrofit of EUR 18.4 million. The 2018 present value of the retrofit
using a 4 % discounting rate is EUR 14.5 million.
The discounted cost of the additional fuel burn at a EUR 2.40 per gallon price is EUR 1.4 million in the
2025–2047 period (Table 8). During the forecasted 1 million departures in the 2025-2047 period, 44
false alarms16 may be expected, resulting in flight diversions with a cost of EUR 3 500 each, amounting
to EUR 104 000 at the present value of additional costs. In the same period, the maintenance cost of
the system (annual EUR 200 per aircraft for the replacement of the fire bottles every five years) is
EUR 155 000 (PV) (Table 10).
The monetised benefits of avoiding a catastrophic accident include aeroplane and ground damage
avoided and accident investigation costs saved. The average resale value of an aeroplane in the
relevant fleet is EUR 3.1 million, based on data from Ascend. The cost of an accident investigation is
estimated to be EUR 7.1 million according to the FAA values, and the avoided ground damage is
EUR 0.5 million. These avoided costs were multiplied by the number of projected accidents in each
year and then discounted to 2018 euro values (see Table 11). The total present value of the savings in
the 2025-2047 period is EUR 389 000.
Question to stakeholders on economic impacts
Stakeholders are invited to provide quantified justifications regarding the possible economic impacts
of the options proposed, or alternatively, to propose another justified solution to the issue, including
the estimated EUR 90 000 cost of the upgrade kit and installation per aeroplane.
General Aviation and proportionality issues
The issue at stake concerns large aeroplanes that are operated for CAT. Hence, there is no impact on
General Aviation.
No proportionality issue among the affected operators is expected.
4.6. Conclusion
Comparison of options
Option 0 would not bring any safety benefit.
Option 1 could result in a reduction in the risk of uncontrollable fires in the affected fleet to a certain
extent.
However, Option 1 cannot exclude the possibility that certain operators might downgrade existing
Class C or Class E compartments into Class D compartments. This could increase the size of the affected
fleet, and therefore the risk of uncontrolled fires.
Option 2 would significantly mitigate the risk of uncontrollable fires in this type of compartment. If a
thermal runaway of batteries occurred in one of these converted aeroplanes, it would then be better
contained in a Class C or Class E compartment.
16 Estimated 44 false alarms per 1 million departures (FAA sources).
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4. Impact assessment (IA)
Table 3 below summarises the cost of the mandatory conversion of a Class D compartment into a Class
C or a Class E compartment.
These costs are compared with the costs established in 2013 and the current costs, in a scenario in
which the additional risk generated by lithium batteries is not considered.
Table 3: Net cost per fatality prevented (2025–2047)17
In the case of a mandatory conversion, the net cost per fatality prevented is lower in comparison with
the previous assessment made in NPA 2013-23, although the risk is higher because of the issue of
lithium batteries. This cost, which would be financed for the most part by operators, could be spread
over a 3-year transition period.
Considering the additional risk generated by lithium batteries, EASA is currently of the opinion that
the mandatory conversion of Class D compartments to Class C or Class E compartments is the best
option to mitigate the potentially catastrophic consequences of an uncontrolled in-flight fire in a large
aeroplane equipped with a Class D compartment.
Question to stakeholders
Stakeholders are also invited to provide any other quantitative information that they may find
necessary to bring to the attention of EASA.
As a result, the relevant parts of the impact assessment might be adjusted on a case-by-case basis.
Sensitivity analysis
Because there is currently no requirement in the EU legal framework that forbids operators to
downgrade existing Class C or Class E compartments into Class D compartments, the size of the
affected fleet, and therefore the risk of uncontrolled fires, may be greater than estimated.
4.7. Monitoring and evaluation
The monitoring of the effects brought about by the proposed amendments to Part-26/CS-26 will
consist of monitoring the trend in the number of large aeroplanes converted from Class D
compartments into either Class C or Class E compartments before the end of the transition period.
17 All monetised costs are expressed in 2018 present values applying a 4 % annual discount rate. Calculations are based on
the relevant fleet operated by EASA Member State operators (see Table 1 and Figure 1).
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4. Impact assessment (IA)
In addition, the changes made to Part-26/CS-26 might be subject to interim/ongoing/ex post
evaluation that will show the outcome that is obtained after the application of the new rules, taking
into account the earlier predictions made in this impact assessment. The evaluation would provide
evidence-based judgement of the extent to which the proposal has been relevant (given the needs
and its objectives), effective and efficient, coherent, and has achieved added value for the EU. The
decision as to whether an evaluation will be necessary should also be taken based on the results of
the monitoring.
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5. Proposed actions to support implementation
5. Proposed actions to support implementation
— Focused communication for advisory body meeting(s) (TeB, STeB)
(Advisory body members)
N/A
— Providing supporting clarifications in electronic communication tools EASA - NAAs (EUSurvey,
SINAPSE or equivalent)
(Primarily targeted audience: the Competent Authority)
N/A
— EASA Circular
(Primarily targeted audience: the Competent Authority, Industry)
N/A
— Detailed explanation with clarification and indicated hints on the EASA web
(Industry, Competent Authority)
N/A
— Dedicated thematic workshop/session
(Industry, Competent Authority)
N/A
— Series of thematic events organised on the regional principle
(Industry, Competent Authority)
N/A
— Combination of the above selected means
(Industry, Competent Authority)
N/A
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6. References
6. References
6.1. Affected regulations
Commission Regulation (EU) 2015/640 of 23 April 2015 on additional airworthiness specifications for
a given type of operations and amending Regulation (EU) No 965/2012 (OJ L 106, 24.4.2015, p. 18)
(https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1538170107669&uri=CELEX:32015R0640)
6.2. Affected decisions
ED Decision 2015/013/R of 8 May 2015 adopting Certification Specifications for additional
airworthiness specifications for operations ‘CS-26 — Issue 1’
(https://www.easa.europa.eu/document-library/agency-decisions/ed-decision-2015013r)
6.3. Other reference documents
— SIB No.: 2017-04R1 ‘Safety Precautions Regarding the Transport by Air of Portable Electronic
Devices containing Lithium Batteries carried by Passengers’ issued on 19 December 2017
(https://ad.easa.europa.eu/ad/2017-04R1)
— NPA 2013-23: Additional airworthiness specifications for operations: Fire hazard in Class D cargo
compartments
(https://www.easa.europa.eu/sites/default/files/dfu/NPA%202013-23.pdf)
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8. Appendix 1: Retirement curves
7. Appendix 1: Retirement curves
How quickly will a new safety requirement mandated by Part-26 spread through the fleet?
The most important factor in the evolution of the fleet in this case is the rate of retirement of the
aeroplanes. Using historical data on retirements, EASA has defined a third-degree polynomial curve
that can be used to predict future retirements as a function of aircraft age.
The retirement curve shows the share of ‘surviving’ aircraft, in other words the percentage of the
affected fleet that remains in service at any given age.
A review of the literature and a comprehensive analysis of the data (30 years) shows that retirement
patterns have remained remarkably stable. Although projections based on past data should always be
interpreted cautiously, there is no indication that these trends would change in the coming years or
decades.
Applying the retirement curve requires the following steps:
— the current fleet is broken down into age categories;
— the current number of aircraft in each age category is projected back to year zero of the
retirement curve (e.g. if we have 131 24-year old aircraft and we know that 53.6 % of those
survive until the age of 24 years, then the original number of them was 131 ÷ 0.536 = 244);
— the retirement curve is applied to obtain the number of aircraft that remain in the fleet for the
next year (if 48.1 % survive until the age of 25 years, then we get 244×0.481=117).
Calculating the difference between the two numbers (131–117=14) shows the number of aircraft that
were retired.
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8. Appendix 2: Tables
8. Appendix 2: Tables
Table 4: Correlation between aircraft age and annual flight hours18
2 500
2 000 y = -66.697x + 3296.4
R² = 0.8397
Annual hours
1 500
1 000
500
0
0 10 20 30 40 50 60
Aircraft age
Table 5: Correlation between aircraft age and annual departures19
2 000.0
1 800.0
1 600.0 y = -51.93x + 2573.6
R² = 0.752
Annual departures
1 400.0
1 200.0
1 000.0
800.0
600.0
400.0
200.0
0.0
0 10 20 30 40 50 60
Aircraft age
18 Based on the total lifetime flight hours of the relevant fleet.
19 Based on the total lifetime cycles of the relevant fleet.
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8. Appendix 2: Tables
Table 6: Aircraft registered in EASA Member States and equipped with a Class D compartment20
Number Average
Manufacturer Type
of A/C age
328 Support Services Dornier 328 21 25.2
Airbus A319 61 37.1
Airbus A320 97 20.6
BAE Systems (Avro) RJ 27 20.7
BAE Systems (HS) ATP 3 24.0
BAE Systems (Jetstream) Jetstream 41 22 28.4
Boeing 737 (CFMI) 138 22.2
Boeing 737 (JT8D) 1 29.0
Boeing 737 NG 15 20.0
Boeing (McDonnell-Douglas) MD-80 24 26.8
Embraer EMB-120 6 22.9
Embraer ERJ-145 27 24.2
Fokker Fokker 100 20 28.6
Fokker Fokker 70 5 22.2
Grand Total 467 23.9
20 Aircraft in service and in temporary storage, operated by EASA Member State operators on 2 November 2018.
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8. Appendix 2: Tables
Table 7: Estimated evolution of the fleet and the risk with Class D compartments
Aircraft with
Total
Year class D Accidents Fatalities
departures
cargo comp.
2018 467 634,224 0.034 3.523
2019 427 560,968 0.030 3.116
2020 387 491,049 0.027 2.728
2021 347 425,196 0.023 2.362
2022 309 364,034 0.020 2.022
2023 272 308,052 0.017 1.711
2024 237 257,587 0.014 1.431
2025 204 212,806 0.012 1.182
2026 175 173,703 0.009 0.965
2027 148 140,108 0.008 0.778
2028 124 111,704 0.006 0.620
2029 104 88,058 0.005 0.489
2030 86 68,665 0.004 0.381
2031 70 52,980 0.003 0.294
2032 58 40,460 0.002 0.225
2033 47 30,586 0.002 0.170
2034 38 22,883 0.001 0.127
2035 31 16,936 0.001 0.094
2036 25 12,390 0.001 0.069
2037 20 8,951 0.000 0.050
2038 16 6,374 0.000 0.035
2039 12 4,465 0.000 0.025
2040 10 3,071 0.000 0.017
2041 7 2,071 0.000 0.012
2042 6 1,362 0.000 0.008
2043 4 865 0.000 0.005
2044 3 523 0.000 0.003
2045 2 293 0.000 0.002
2046 2 144 : :
2047 1 56 : :
2048 0 : : :
2049 : : :
∑2018–2047 4,040,567 0.2191 22.4
∑2025–2047 999,455 0.0542 5.6
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8. Appendix 2: Tables
Table 8: Shadow prices per tonne of CO2 equivalent emitted (EUR)
Year of emission Central guidance
2000-2009 22
2010-2019 26
2020-2029 32
2030-2039 40
2040-2049 55
2050- 83
Table 9: Cost of additional fuel burn and shadow prices of emission with climatic effect
HEATCO shadow HEATCO shadow
Shadow price of
Aircraft with Cost of additional Additional CO2 price of price of
Total flight Additional fuel Cost of additional high altitude
Year class D fuel burn emission greenhouse gas greenhouse gas
hours burn (US gallon) fuel burn (PV) emission
cargo comp. (undiscounted) (9.8kg/US gallon) emission emission
(per tonne)
(undiscounted) (PV)
2018 467 810,354
2019 427 716,628
2020 387 627,188
2021 347 542,969
2022 309 464,763
2023 272 393,197
2024 237 328,696
2025 204 271,474 179,549 € 430,427 € 327,089 1,760,325 € 64 € 112,661 € 85,613
2026 175 221,520 146,511 € 351,224 € 256,636 1,436,410 € 64 € 91,930 € 67,173
2027 148 178,614 118,133 € 283,195 € 198,969 1,158,188 € 64 € 74,124 € 52,079
2028 124 142,346 94,146 € 225,692 € 152,469 923,016 € 64 € 59,073 € 39,908
2029 104 112,164 74,184 € 177,837 € 115,520 727,305 € 64 € 46,547 € 30,236
2030 86 87,416 57,816 € 138,600 € 86,569 566,835 € 80 € 45,347 € 28,323
2031 70 67,410 44,584 € 106,879 € 64,189 437,105 € 80 € 34,968 € 21,001
2032 58 51,446 34,025 € 81,568 € 47,103 333,590 € 80 € 26,687 € 15,411
2033 47 38,860 25,702 € 61,613 € 34,212 251,982 € 80 € 20,159 € 11,193
2034 38 29,047 19,211 € 46,054 € 24,589 188,350 € 80 € 15,068 € 8,045
2035 31 21,474 14,203 € 34,048 € 17,479 139,245 € 80 € 11,140 € 5,719
2036 25 15,691 10,378 € 24,878 € 12,280 101,743 € 80 € 8,139 € 4,018
2037 20 11,318 7,486 € 17,946 € 8,518 73,393 € 80 € 5,871 € 2,787
2038 16 8,045 5,321 € 12,755 € 5,821 52,164 € 80 € 4,173 € 1,905
2039 12 5,623 3,719 € 8,915 € 3,912 36,460 € 80 € 2,917 € 1,280
2040 10 3,858 2,552 € 6,117 € 2,581 25,017 € 110 € 2,752 € 1,161
2041 7 2,594 1,716 € 4,113 € 1,669 16,820 € 110 € 1,850 € 751
2042 6 1,700 1,124 € 2,695 € 1,051 11,020 € 110 € 1,212 € 473
2043 4 1,074 710 € 1,703 € 639 6,963 € 110 € 766 € 287
2044 3 644 426 € 1,020 € 368 4,173 € 110 € 459 € 166
2045 2 355 235 € 563 € 195 2,303 € 110 € 253 € 88
2046 2 171 113 € 271 € 91 1,110 € 110 € 122 € 41
2047 1 63 42 € 100 € 32 410 € 110 € 45 € 14
2048 0 : : : : : : : :
2049 : : : : : : : :
∑2018–2047 5,156,701 841,883 € 2,018,213 € 1,361,981 8,253,927 € 566,265 € 377,671
∑2025–2047 1,272,906 841,883 € 2,018,213 € 1,361,981 8,253,927 € 566,265 € 377,671
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8. Appendix 2: Tables
Table 10: Cost of false alarms and fire bottle replacement21
False alarms
Aircraft with resulting in Fire bottle Fire bottle
Total Cost of diversions Cost of diversions
Year class D diversions replacement cost replacement cost
departures (undiscounted) (PV)
cargo comp. (44 per million (undiscounted) (PV)
departures)
2018 467 634,224
2019 427 560,968
2020 387 491,049
2021 347 425,196
2022 309 364,034
2023 272 308,052
2024 237 257,587
2025 204 212,806 9 € 32,772 € 24,904 € 40,845 € 31,039
2026 175 173,703 8 € 26,750 € 19,546 € 34,913 € 25,511
2027 148 140,108 6 € 21,577 € 15,159 € 29,574 € 20,778
2028 124 111,704 5 € 17,202 € 11,621 € 24,839 € 16,780
2029 104 88,058 4 € 13,561 € 8,809 € 20,701 € 13,447
2030 86 68,665 3 € 10,574 € 6,605 € 17,131 € 10,700
2031 70 52,980 2 € 8,159 € 4,900 € 14,078 € 8,455
2032 58 40,460 2 € 6,231 € 3,598 € 11,507 € 6,645
2033 47 30,586 1 € 4,710 € 2,615 € 9,362 € 5,198
2034 38 22,883 1 € 3,524 € 1,881 € 7,592 € 4,054
2035 31 16,936 1 € 2,608 € 1,339 € 6,137 € 3,150
2036 25 12,390 1 € 1,908 € 942 € 4,930 € 2,434
2037 20 8,951 0 € 1,379 € 654 € 3,944 € 1,872
2038 16 6,374 0 € 982 € 448 € 3,149 € 1,437
2039 12 4,465 0 € 688 € 302 € 2,476 € 1,087
2040 10 3,071 0 € 473 € 200 € 1,913 € 807
2041 7 2,071 0 € 319 € 129 € 1,447 € 587
2042 6 1,362 0 € 210 € 82 € 1,101 € 430
2043 4 865 0 € 133 € 50 € 833 € 312
2044 3 523 0 € 81 € 29 € 625 € 225
2045 2 293 0 € 45 € 16 € 458 € 159
2046 2 144 0 € 22 €7 € 315 € 105
2047 1 56 0 €9 €3 € 197 € 63
2048 0 : : : : : :
2049 : : : : : :
∑2018–2047 4,040,567 44 € 153,916 € 103,840 € 238,067 € 155,275
∑2025–2047 999,455 44 153,916 103,840 238,067 155,275
21 Present values (PV) are discounted values expressed in 2018 euros applying a 4 % discount rate.
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8. Appendix 2: Tables
Table 11: Benefits of accidents avoided22
Aircraft with Investigation Investigation Ground property Ground property
Total Aircraft damages Aircraft damages
Year class D Accidents Fatalities costs costs damage damage
departures (undiscounted) (PV)
cargo comp. (undiscounted) (PV) (undiscounted) (PV)
2018 467 634,224 0.034 3.523 € 104,912 € 104,912 € 243,674 € 243,674 € 17,198 € 17,198
2019 427 560,968 0.030 3.116 € 92,794 € 89,225 € 215,528 € 207,239 € 15,211 € 14,626
2020 387 491,049 0.027 2.728 € 81,228 € 75,100 € 188,665 € 174,431 € 13,315 € 12,311
2021 347 425,196 0.023 2.362 € 70,335 € 62,528 € 163,364 € 145,230 € 11,530 € 10,250
2022 309 364,034 0.020 2.022 € 60,218 € 51,474 € 139,865 € 119,557 € 9,871 € 8,438
2023 272 308,052 0.017 1.711 € 50,957 € 41,883 € 118,356 € 97,280 € 8,353 € 6,866
2024 237 257,587 0.014 1.431 € 42,610 € 33,675 € 98,967 € 78,215 € 6,985 € 5,520
2025 204 212,806 0.012 1.182 € 35,202 € 26,751 € 81,762 € 62,132 € 5,771 € 4,385
2026 175 173,703 0.009 0.965 € 28,734 € 20,995 € 66,738 € 48,765 € 4,710 € 3,442
2027 148 140,108 0.008 0.778 € 23,176 € 16,283 € 53,831 € 37,821 € 3,799 € 2,669
2028 124 111,704 0.006 0.620 € 18,478 € 12,483 € 42,917 € 28,994 € 3,029 € 2,046
2029 104 88,058 0.005 0.489 € 14,566 € 9,462 € 33,833 € 21,977 € 2,388 € 1,551
2030 86 68,665 0.004 0.381 € 11,358 € 7,094 € 26,382 € 16,478 € 1,862 € 1,163
2031 70 52,980 0.003 0.294 € 8,764 € 5,263 € 20,355 € 12,225 € 1,437 € 863
2032 58 40,460 0.002 0.225 € 6,693 € 3,865 € 15,545 € 8,977 € 1,097 € 634
2033 47 30,586 0.002 0.170 € 5,059 € 2,809 € 11,751 € 6,525 € 829 € 461
2034 38 22,883 0.001 0.127 € 3,785 € 2,021 € 8,792 € 4,694 € 621 € 331
2035 31 16,936 0.001 0.094 € 2,801 € 1,438 € 6,507 € 3,340 € 459 € 236
2036 25 12,390 0.001 0.069 € 2,050 € 1,012 € 4,760 € 2,350 € 336 € 166
2037 20 8,951 0.000 0.050 € 1,481 € 703 € 3,439 € 1,632 € 243 € 115
2038 16 6,374 0.000 0.035 € 1,054 € 481 € 2,449 € 1,118 € 173 € 79
2039 12 4,465 0.000 0.025 € 739 € 324 € 1,715 € 753 € 121 € 53
2040 10 3,071 0.000 0.017 € 508 € 214 € 1,180 € 498 € 83 € 35
2041 7 2,071 0.000 0.012 € 343 € 139 € 796 € 323 € 56 € 23
2042 6 1,362 0.000 0.008 € 225 € 88 € 523 € 204 € 37 € 14
2043 4 865 0.000 0.005 € 143 € 54 € 333 € 125 € 23 €9
2044 3 523 0.000 0.003 € 87 € 31 € 201 € 72 € 14 €5
2045 2 293 0.000 0.002 € 48 € 17 € 112 € 39 €8 €3
2046 2 144 : : : : : : : :
2047 1 56 : : : : : : : :
2048 0 : : : : : : : : :
2049 : : : : : : : : :
∑2018–2047 4,040,567 0.2191 22.4 € 668,349 € 570,326 € 1,552,339 € 1,324,667 € 109,560 € 93,492
∑2025–2047 999,455 0.0542 5.6 € 165,295 € 111,528 € 383,921 € 259,041 € 27,096 € 18,282
22 Present values (PV) are discounted values expressed in 2018 euros applying a 4 % discount rate.
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