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NPA-OPS 59 Aerodromes (RFFS) (1.220) new proposal after OPSG 06-5. Capt. Claude Godel OST 07-1. 06-5 Action 22 (NPA LIST).
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NPA-OPS 59 Aerodromes (RFFS) (1.220)new proposal after OPSG 06-5 Capt. Claude Godel OST 07-1
06-5 Action 22(NPA LIST) ·NPA-OPS 59 RFFS - NPA to be amended to incorporate changes suggested and supported at OST 06-5, before going to OST 07-1 for endorsement, then first RST review and public consultation OPSG REMINDER (OST 06-5 Notes) Changes suggested: “Pressurization Alternate” to be reworded and moved to a footnote to the table.
REMINDER (Yesterday’s discussion) NPA 59 is not part of the ten NPAs deemed mature or important enough for EU-OPS inclusion
REMINDER of the AIM • The operators are missing a clear JAR OPS policy regarding the minimum RFFS category that must be available on an aerodrome required to be specified in the operational flight plan. • NPA 59 proposes such a policy. • First attempt in NPA 24 APRIL 2004 • Number of presentations of NPA 59 to OST: at least 6 times! • Known remaining dissenting position at this stage: 1 • Extract of JAR 11: “(1) The decision that the NPA is mature for consultation will be taken by the Central JAA in co-ordination with the relevant Sectorial Teams.”
ICAO Up-date 1 • Latest proposal by the “Aerodrome Panel group”: • Complete suppression of the remission factor for less than 700 movements • Replace “normally using” by “planned to” • The new Standard in Annex 14 would then read: • Level of protection to be provided • 9.2.3 - Level of protection provided at an aerodrome for rescue and fire fighting shall be equal to the aerodrome category determined using the principles in 9.2.4. • 9.2.4 – the aerodrome category shall be determined from table 9.1 and shall be based on the longest aeroplanes planned to use the aerodrome and their fuselage length.
ICAO Up-date 1bis Without any operational counterpart in JAR OPS or Annex 6, this will be interpreted by some NAAs as: “you are only authorized to plan a category N aeroplane towards a category N (or higher) aerodrome.” This would lead many operators to cancel some flights that they flew for years. To our knowledge, there are no data to show the need for such a backward evolution.
ICAO Up-date 2 Fortunately the ICAO WG on Panels didn’t endorse that version for the moment. Some voices start to say that there is no evidence for a “ safety benefit that would be commensurate to the investment.” Others say: “other members considered this to be more an operational matter which was considered to be within the ambit of Annex 6. The aerodrome would specify the level of protection provided and it would then be the aircraft operator’s responsibility to decide whether or not to operate a particular aircraft into the aerodrome.”
OPSG position • Annex 14 is for aerodrome managers. • “… It is not intended that these specifications limit or regulate the operation of an aircraft.” Chapter 1, Annex 14 • Operators need their own rule material in JAR OPS 1 / EU-OPS1 and, later, in the IRs and Annex 6.
KEY POINTS OF THE NEW RULE • The rule is applicable: • At flight preparation • To the aerodromes required to be specified in the operational flight plan Once in flight, diversion to any aerodrome remains a Captain’s decision. There is no requirement for aerodromes along the route which may be used as en route alternates (e.g. in case of technical or medical diversion) because they are not required to be specified in the operational flight plan.
The Table (1) Two Categories for all-cargo aeroplanes. (2) Three Categories for all-cargo aeroplanes. (3) Or Two Categories below the Aeroplane RFFS Category, if this is less than RFFS Category 4 but not lower than Category 1. (4) For an ETOPS en-route alternate aerodrome, a published RFFS Category equivalent to Category 4, available at 30 minutes notice, is acceptable. (5) An En-Route Alternate Aerodrome required to be adequate and specified in the operational flight plan (e.g. the 3% ERA). (6) The Temporary Downgrade Column can only be included in the Operations Manual with the approval of the operator’s authority (See ACJ to Appendix 1 to JAR-OPS 1.220). (7) If an individual aerodrome serves more than one purpose, the highest required category corresponding to that purpose at the time of expected use must be available.
KEY POINTS • The table is proposed with two columns: • Column 1 is the new standard which must be published in the operator’s Ops manual. • Publication (and use) of Column 2 in an operator’s Ops manual, needs acceptance by its’ Authority. Column 2 is only for temporary downgrade of an aerodrome RFFS category. Note: once under EASA rule, column 2 would, or would not, be part of the table.
KEY POINTS (comments) • Column 1: • The new requirement is N-1 for DEP and DEST, N-2 for DEST ALT and category 4 (unchanged) for ETOPS alternates. OPSG thought that this is acceptable for the major CAAs. • According to a study of Today’s networks, it should not hamper the airline activity. • There are no existing data showing that more lives would have been saved without the present remission factor in Annex 14. • In relation with the requirements of Annex 14 for the aerodrome managers, it should also lead to an automatic increase in the aerodrome RFFS categories.
KEY POINTS (comments) • Column 2 : • Column 2, if accepted by the operator’s Authority, permits some more flexibility in case of temporary RFFS downgrade (eg. Notam). OPSG has based this proposal on three major arguments: • N-2 is still considered sufficient by RFFS experts for all “external” fires (Gear, engines,…) • Annex 14 included, until now, a statistical approach (e.g. less than 700 movements = 1 category remission…). Same logic applies in case of exceptional and temporary downgrade. • A long-established practice in many major airlines has not produced any data to contradict this assumption
KEY POINTS (comments) • (1) 2 Categories for all-cargo aeroplanes • (2) 3 Categories for all-cargo aeroplanes “The principal objective of an RFFS is to save lives” (Annex 14), that explains why there is a special alleviation for cargo aircraft.
KEY POINTS (comments) (d) Selection and specification in the operational flight plan of an aerodrome with an RFFS category below that stated in Table 1 requires acceptance by the Authority on a case-by-case basis. Paragraph (d) leaves a door open for some special situations like isolated islands or exceptional flights.
KEY POINTS (comments) (e) In flight, the commander may decide to land at an aerodrome where the Aerodrome RFFS Category is lower than specified above, if in his judgement and after due consideration of all the prevailing circumstances, to do so would be safer than to divert. Paragraph (e) goes without saying but, as otherwise the question will be raised, OPSG likes to confirm it.
CONCLUSION OPSG understands that a large majority is now convinced of the need of NPA 59. The Public Consultation will allow people to express any dissenting position. But the JAA NPA process should not be slowed down any more. Add-on after Yesterday’s discussion: The result of the JAA Public Consultation would, in any case, represent a good indication for the EASA people in charge of dealing with the issue in the future.