Change to EASA Certification Memorandum Will Affect Portable Wireless IFE Sector
EASA Certification Memorandum CM-21.A-CS-001 issue 02 provides specific guidance for the classification of design changes to cabin interiors of Large Aeroplanes.
AirFi’s dedication battery safety means we are one step ahead with a software update that ensures all current and future customers are in full compliance to these new EASA requirements already.
What is the change?
An update made to the EASA Certification Memorandum CM-21.A-CS-001 issue 02, on April 30th, 2021, has notably re-classified any PED charging station in an aircraft stowage compartment as a “major change” during battery recharging that may involve multiple PEDs that cannot be observed. This is to deter potential thermal runaway incidents. Do you know what it means if you’re using portable wireless IFE systems with batteries, that may also connected to charging outlets in the aircraft?
What Does it Mean for Portable Wireless IFE Systems?
There have been strict regulations around the carriage of Lithium batteries in the cargo hold of aircraft for quite some time, but less specific guidance has been provided for Lithium batteries in devices that are carried into the cabin by passengers and crew.
Battery-powered portable wireless IFE solutions (pioneered by AirFi in 2014) have become increasingly popular with airlines around the world and numerous providers have subsequently launched their own versions of hardware. More recently, to simplify operations and overcome the battery life limitations of such systems, many suppliers have begun to offer “semi-embedded” portable IFE solutions – characterised by portables boxes “fixed” into aircraft stowage areas and connected to the aircraft power supply.
It is estimated that by the end of 2021 there could be more than 300 aircraft flying with semi-embedded portable IFE systems, characterized by portable, battery-powered boxes placed in overhead bins and connected to aircraft power.
What has AirFi done to ensure compliance?
It is reasoned that a Power Supply modification in a closed compartment can be classified as minor if an Operational Limitation states that battery recharging of PEDs is not performed during any phase of flight. This Operational Limitation will eliminate the possibility of thermal runaway due to recharging of the battery.
As the leading provider of portable wireless IFE and crew solutions to airlines and the inventor of the “semi-embedded” installation method, AirFi has been following this news closely. We have already made the necessary changes to the software logic to ensure compliance with this latest EASA CM. This means that all our portable boxes that are installed into overhead bins and connected to aircraft power – what we call our Fully Automated Semi-Embedded (FASE) aircraft-powered solution – will continue to provide and comply with, all necessary safety requirements particularly those relating to batteries.
The small, yet powerful portable boxes which power AirFi’s wireless onboard network solutions contain Lithium batteries, but they also contain four very important sensors which constantly feed information about the aircraft’s position and stage of flight into the units. Already, these sensors are used to power AirFi’s proprietary moving map and enable autonomous operations which include switching the system on and off, switching the GSM module on and off, and switching WiFi on and off. With this new autonomous software logic update, the four sensors will also work in unison to provide multi-factor verification for when it is safe, according to EASA, for the battery charger to switch on – which is only when the aircraft has wheels on the ground.
As a reassurance to all current and future customers, this function provides the Operational Limitation required by EASA to eliminate the possibility of thermal runaway occurrences.
What do the experts say?
ADSE is an independent Consulting and Engineering company from the Netherlands, active in the market areas of aerospace, defense, infrastructure, and rail transport with customers spanning OEMs, operators, MROs, supply chain and governments. ADSE has deep expertise in aviation regulations and certification, we well as an EASA Design Organisation Approval (DOA) EASA.21J.481. ADSE has supported numerous operators in obtaining operational allowance for the use of PEDs on board of their aircraft based on the latest applicable industry standards and operational regulations.
We asked Sander van Lochem, Avionics Specialist at ADSE Consulting and Engineering, a few questions about this new safety guidance and what it why it is so important.
1. Question: Can you please describe what the new EASA guidance is advising with regards to battery changing onboard?
ADSE Response: EASA published Certification Memorandum CM–21.A–CS–001, Issue 02)on 30 April 2021. This concerns aircraft (system) certification and addresses battery charging on board.
One of the subjects of the Certification Memorandum CM-21.A-CS-001, issue 2, is the certification of the installation of Personal Electronic Device (PED) charging station / stowage compartment. The introduction of these facilities, designed to stow PEDs or just the batteries thereof during their battery recharge process, may increase the risk of having an (undetected) thermal runaway event that may involve multiple PEDs. The propagation of a PED fire to other PEDs may result in a fire event that may have catastrophic consequences for the aircraft. This also includes the installation of In Seat Power Supply Systems when they are installed or allow charging in fully enclosed stowage compartments. The battery charging is then taking place out-of-sight of either the passenger or (cabin) crew.
Therefore, the Certification Memorandum advises aircraft certification activities involving these charging stations / stowage compartments to follow a classification of Major to carefully address the risk of battery thermal runaways during charging. This means that during the certification efforts, EASA needs to be involved in the process.
2. Question: How does this guidance vary from previous guidances or existing rules? What does it mean for portable inflight entertainment solutions?
ADSE Response: The Certification Memorandum (CM) provides specific non-binding guidance for the classification of design changes to cabin interiors of Large Aeroplanes. The rigor of the certification activities is dependent on this classification. The guidance is used in addition to the existing certification regulations and specifications.
As explained under Q1, one of the topics addressed in the CM is the installation of charging stations for batteries used on e.g., Personal Electronic Devices. A PED is any kind of electronic device, typically but not limited to consumer electronics, brought on board the aircraft by crew members, passengers, or as part of the cargo, that is not included in the configuration of the certified aircraft. Portable Inflight Entertainment Devices belong to this group of PEDs.
These devices often hold rechargeable batteries. If charging of these batteries is done in a charging station designed to stow multiple batteries during charging, the certification classification must be set to major.
The consequence for portable inflight entertainment solutions is such that the certification of the charging solutions for the batteries of such systems will be under scrutiny of EASA and cannot be installed via a minor modification. Hence, the time for certification will probably go up and additional requirements can be imposed to avoid (undetected) thermal runaways.
3. Question: This guidance is just that – a guidance. It is not a strict rule? Can you explain?
ADSE Response: At this moment, the content of the Certification Memorandum is guidance material on a particular subject and, as non-binding material, may provide complementary information and guidance for compliance demonstration with current standards. A kind of extra clarification for interpretation of the certification requirements.
4. Question: Does this type of guidance generally become a “rule” down the line?
ADSE Response: Future updates of existing regulations (e.g., Part-21) might incorporate some parts of this CM if EASA deems it to be necessary.
5. Question: Why was this action taken? Do you believe it is necessary/important?
ADSE Response: Thermal runaway of (PED) batteries is a major concern in aviation operations. Via the CM, EASA obviously indicates it is important to address the risks involved carefully. The thermal runaway issue that may influence providers of aircraft-powered wireless streaming hardware is only one topic in a list of many more (technically unrelated) ones in the same Certification Memorandum.
6. Question: Do you expect any further updates to the April 30 EASA guidance?
ADSE Response: The Certification Memorandum was published by EASA as a proposed CM in December 2019. Industry and the general public could react on the proposed CM until the end of January 2020. These comments have been published on the EASA website and the Certification Memorandum has now (30th of April 2021) been published as a FINAL Certification Memorandum.
As a final CM, the content is now considered as the general course of action of the EASA on the specific certification items and must be used as guidance on a particular subject and, as non-binding material, may provide complementary information and guidance for compliance demonstration with current standards.
EASA Certification Memoranda are living documents into which either additional criteria or additional issues can be incorporated as soon as a need is identified by EASA. All CM are reviewed periodically (no later than two years after its publication), to ensure its currency with the regulatory material. Following the review, the CM could be revised, or cancelled (if no longer valid) and its content included in a rulemaking task.
If any technology changes surface that leads to changes to the content of the current CM, it will be updated.
Based in Holland with satellite offices and sales partners around the world in APAC, Europe, the Americas and Africa, AirFi is the leading provider of flexible, low-cost and quick-to-deploy inflight e-commerce, entertainment, and connectivity solutions. AirFi helps airlines improve their bottom lines, streamline crew procedures and enhance the passenger experience through fully customizable and integrated passenger and crew-facing digital solutions. Since 2011, more than 70 airlines globally have trusted AirFi to deliver our proven solutions – ranging from Inflight Entertainment (IFE), to mobile point-of-sale solutions (Connected Crew) and our low-bandwidth and low cost Inflight Connectivity solution (LEO). Email us on firstname.lastname@example.org to know more.
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