NPA 59 Appendix 1 to JAR OPS 1.220 Authorisation of Aerodromes by the Operator Required Rescue and Fire Fighting Categ

1. NPA 59Appendix 1 to JAR OPS 1.220 Authorisation of Aerodromes by the OperatorRequired Rescue and Fire Fighting Category Capt. Claude Godel OST 06-2

2. Reminder of the intent of the proposed NPA The intent of the NPA is to fill a gap in JAR OPS 1 which doesn’t give any precise instruction to the operators in regard of the minimum RFFS level which must be available at the expected time of use of an aerodrome. This minimum level must remain safe, that is why the proposal is based on values which are established practice for many years in most of the major airlines. But it must also permit continuation of operations by taking in account the reality of the actual RFFS level on some airports or the temporary down-grading which can occur on some others. OPSG

3. Reminder of the intent of the the proposed NPA • The new rule should be considered like a MEL item: • Annex 14 gives the optimal RFFS category for each aeroplane. If an aeroplane becomes a « normal » user of an aerodrome, the airport authority of that aerodrome must implement the RFFS category which corresponds to that aeroplane in the Annex 14 table. • but if, at flight preparation, the operator has an information telling him that the optimal level will not be available at the expected time of use, the new rule will give him the maximum acceptable alleviation. OPSG

4. Annex 14 versus JAR OPS The first page of ICAO Annex 14 reads: The requirements of Annex 14 are definitively intended for the airport authorities. OPSG

5. Examples of existing OPS Manuals Air France GEN OPS EXP pg 03.01.03 REGLES DE PROGRAMMATION Aérodromes de départ et de destination OA.NI s'assure que le niveau SSLIA des aérodromes de départ et de destination n'est pas inférieur de plus de 2 unités au niveau normal de protection requis pour les types avions concernés. OA.NI ensures that the RFFS aerodrome category of DEP and DEST aerodrome is not more than 2 units below the category normally required for the type of aeroplane. OPSG

6. Examples of existing OPS Manuals • Lufthansa Ops Manual: • 1. Fire fighting Category below required minimum • The use of an aerodrome with reduced RFFS capacity must be governed by the following regulations.These regulations are based on the assumption that a fire in its initial stage,e.g. brake fire, is controllable even with less than minimum fire fighting capacity as specified in the table : • A319/320/ B737 minimum 4, • A 321 min 5, • A 306 min 6, • A340/B747 min 7 OPSG

7. Outcome of OST 06-1 • OPSG was tasked to re-write chapter 4 in order to make it clear that the Authority acceptance for N-2 did only apply to the Departure and Destination aerodrome. • OST members felt that ETOPS operations should not be affected by the new rule and therefore not need an Authority acceptance for continuing to use RFFS category 4 as a minimum. • OST members were tasked to to send written comments to OPSG before 9th February : • one comment received from Boeing explaining that only the departure and destination aerodromes are addressed by Annex 14. Therefore, in order to harmonize with FAA, it would be wise to have the same requirement for all alternates. • one comment received from AEA which was against the idea of a new need for an Authority acceptance when the proposed rule is already a long time established practice of most of the airlines. OPSG

8. What OPSG did after OST 06-1 • OPSG : • Introduced definitions in order to clarify the text • Reversed the logic of the Departure and Destination chapter: N-2 is the JAR OPS acceptable alleviation unless the Authority of the operator is more restrictive. • Split the Alternate chapter away from the preceding: the bottom line for all alternates is now the already accepted rule applying to ETOPS alternates. This brings FAA harmonization and avoids any necessity of an authority acceptance or approval for something already in use. • Deleted chapter 2 which looked redundant as it is always the operator’s responsibility to check the adequacy of an aerodrome. OPSG

9. The new version of the Appendix to JAR OPS 1.220 • Appendix 1 to JAR-OPS 1.220 • Authorisation of Aerodromes - Emergency Services • (1) Definitions: • a) RFFS Category: Rescue and Fire Fighting Services Category as defined in ICAO Annex 14. • b) Aeroplane RFFS Category: for a specific type of aeroplane, the category resulting from ICAO Annex 14 Table 9-1. • c) Aerodrome RFFS Category: the published RFFS category for an aerodrome. OPSG

10. The new version of the Appendix to JAR OPS 1.220 (2) The operator’s Operations Manual shall contain the aeroplane RFFS categories for the types of aeroplane to be operated. OPSG

11. The new version of the Appendix to JAR OPS 1.220 (3) The aerodrome RFFS Category available at the time of expected use shall be: a) For departure and destination aerodromes, not more than 2 categories below the aeroplane RFFS category (3 categories for all-cargo aeroplanes) and in any case not lower than category 1, unless the Authority of the operator imposes a more restrictive requirement. b) For all alternate aerodromes required to be “adequate” in JAR-OPS 1, not less than Annex 14 table 9.1 Category 4, or 2 categories below the aeroplane RFFS category if this is less than category 4, but not lower than category 1. For an en-route alternate aerodrome, a published RFFS equivalent to category 4, available at 30 minutes notice, is acceptable. OPSG

12. The new version of the Appendix to JAR OPS 1.220 (4) In flight, the commander may decide to land at an aerodrome where the aerodrome RFFS category is lower than specified in (3) above, if in his judgement and after due consideration of all the prevailing circumstances, to do so would be safer than to divert. OPSG

13. New ICAO Annex 14 text (October 2005): 9.2.3 Recommendation.— From 1 January 2005, The 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 and 9.2.5. 9.2.4 The aerodrome category shall be determined from Table 9-1 and shall be based on the longest aeroplanes normally using the aerodrome and their fuselage width. Rational ICAO Annex 14 ICAO Annex 14 is applicable to the management of aerodromes not to the operators. Up to now there is no rule for the operator in Annex 6. The required level of protection is a statistical calculation based on the biggest aeroplane “normally using” the aerodrome. Allowing a higher category aeroplane to land for the first time has the virtuous effect of starting statistics for an increase in the aerodrome category. Nothing precludes a two category higher aeroplane to take off and land. OPSG

14. Rational OPSG discussion • The proposal to limit to N-2 on the operator’s side : • Is not in contradiction with ICAO Annex 14. As stated in the pre-amble, Annex 14 is not intended to limit or regulate the operations of an aircraft. For that we have JAR OPS 1. • Is not unsafe since admitted, for years, by many, when not all, the major airlines facing the reality of a great number of aerodromes • Improves safety as it fixes a reasonable bottom line for flight planning towards aerodromes insufficiently “equipped with necessary emergency services” when there was no rule material until now. • Provides an operational answer to many questions raised by the operatorsespecially when they have to fly to a “non normally used aerodrome” or when the RFFS services are exceptionally not at their normal category. OPSG

15. Rational RFFS examples “official category” as published on the AIP: Iqualuit 5 Goose Bay 8 Yellowknife 6 Dar es Salam 8 Ouagadougou 8 Cotonou 8 Douala 8 Bangui 8 Kinshasa 7 Asmara 7 Accra 8 Kano 8 Port Harcourt 8 Freetown 8 Monrovia 8 Reminder: B747,A340, B777 are classified Category 9 OPSG

16. Rational OPSG discussion The proposal of category 4 for the en-route alternates is the already approved bottom line permitting normal (ETOPS) flight planning. It results of an extensive study done by the FAA and published under HBAT 99-15 “Level of Rescue and Fire Fighting Services (RFFS) for ETOPS En Route Alternates” It states: “The Boeing study concludes that the probability of an engine in-flight Shutdown (IFSD) during the cruise, portion of an ETOPS flight resulting in a diversion to an ETOPS en route alternate, and a subsequent brake fire on landing that would require fire fighting services would be less than one in one billion (<10-9). “ OPSG considers that a fully operational aeroplane diverting to his alternate for reasons linked to his Destination aerodrome (weather, insufficient fuel,..) is in a less exposed situation regarding RFFS than an ETOPS twin diverting to his ETOPS alternate on one engine. Therefore applying the same minimum RFFS level to all alternates (without the 30 min alleviation for the alternates which can need to be available quite immediately) seems reasonable. OPSG

17. Conclusion OPSG conclusion OPSG, therefore, thinks that the draft proposed takes into account , in a balanced , harmonized , realistic manner ,all the comments received during and after the last OST . We recommend to send this NPA to RST so that it can be published and commented by all the interested partners . OPSG