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NPA OPS-40 Response to OST comments

NPA OPS-40 Response to OST comments. Activities since last OST presentation Review of IFALPA and EQSG contribution Progress on list of severe climate aerodromes. IFALPA contribution Cost of human life is to be considered in the RIA. EQSG contribution. EQ WG comment

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NPA OPS-40 Response to OST comments

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  1. NPA OPS-40 Response to OST comments OST 04-4 presentation

  2. Activities since last OST presentation • Review of IFALPA and EQSG contribution • Progress on list of severe climate aerodromes OST 04-4 presentation

  3. IFALPA contribution • Cost of human life is to be considered in the RIA OST 04-4 presentation

  4. EQSG contribution EQ WG comment “Some parts of the proposed guidance material seem to have more a rule status, by i.e. requesting some additional equipment to be carried, which is more restrictive than the rule proposals.” ETOPS/LROPS WG response Careful review of balance between regulatory and AC material was performed by the WG in accordance with JAR 11 and RST guidelines: “ The balance between the requirements and advisory material should be improved” “The principle of a single document far all advisory material should be kept” ( JAA letter to ETOPS WG chairman dated 07 May 2002) OST 04-4 presentation

  5. EQSG contribution EQ WG comment “EQSG also feel that an RIA is required in order to follow the procedures as laid down in JAR-11.” ETOPS/LROPS WG response Done OST 04-4 presentation

  6. EQSG contribution EQ WG comment “In subparagraph (ii), the text requires that the operator “should” consider the “ … availability of at least one letdown aid (ground radar would qualify) for an instrument approach … “. The EQSG has some difficulty to understand this requirement. First, as the term “should” is used, the paragraph has more or less the character of an ACJ” ETOPS/LROPS WG response Accepted. This requirement is transposed from advisory material as explained above. The word “should” is inappropriate. OST 04-4 presentation

  7. EQSG contribution EQ WG comment “Second, it is not clear what is meant when using the term “letdown aid” ETOPS/LROPS WG response Comment not understood. Same terminology is used in GAI 20x6 and AC 120-42A OST 04-4 presentation

  8. EQSG contribution EQ WG comment Use of “should” in JAR OPS-1.220 must be avoided ETOPS/LROPS WG response Comment agreed. OST 04-4 presentation

  9. EQSG contribution EQ WG comment JAR-OPS 1.220 §2 not worded as a rule ETOPS/LROPS WG response JAR-OPS 1.220 §2 revision is under process: severe climate aerodromes list is introduced OST 04-4 presentation

  10. EQSG contribution EQ WG comment In IEM JAR-OPS 1.244 Terminology “(7) Maintenance personnel” should be deleted ETOPS/LROPS WG response This is “cut and” paste” of GAI 20x6. The ETOPS WG do not object to delete it, if this creates a new problem. OST 04-4 presentation

  11. EQSG contribution EQ WG recommendation 3 and 4 engines aeroplanes: JAR-OPS 1.247 (b) not in harmony with (a) ETOPS/LROPS WG response As the EQSG rightly points out, (b) is an exception to (a). The connection between the two paragraphs could be emphasized by the introduction of the word “However” in (a). The WG disagrees to move the provisions regarding retrofit of the cargo protection to an other place because it is part of the exception. OST 04-4 presentation

  12. EQSG contribution EQ WG comment JAR-OPS 1.865 IFR/VFR communication and navigation equipment: Change for ETOPS/LROPS is not needed as already covered by the rule ETOPS/LROPS WG response It is a matter of interpretation. The present wording does not necessarily cover en-route diversions. The ETOPS/LROPS WG prefers to clarify the application of this rule for ETOPS/LROPS. OST 04-4 presentation

  13. EQSG contribution EQ WG comment Do not use the word “section” ETOPS/LROPS WG response We leave it to the wisdom of the RST and OST OST 04-4 presentation

  14. EQSG contribution EQ WG comment Lay out of paragraphs and numbering Few anomalies noted ETOPS/LROPS WG response Although a careful review was performed, it may happen that a few anomalies have still escaped. The form of the document reconciles two constraints: - be a single ACJ (see TOR) - be arranged and segregated in a manner suitable for each interested party OST 04-4 presentation

  15. EQSG contribution EQ WG comment MEL considerations should be in a separate document ETOPS/LROPS WG response This contradicts the instructions received to maintain a single ACJ OST 04-4 presentation

  16. EQSG contribution EQ WG comment VHF/HF data link SATCOM ETOPS/LROPS WG response This is an adaptation to new technology of the communication provisions of GAI 20x6. Status of advisory material is appropriate Words are self explanatory OST 04-4 presentation

  17. EQSG contribution EQ WG comment Automated system monitoring consideration with regard to crew decision is superfluous ETOPS/LROPS WG response Objective of comment is not understood. This is advisory material. Why crew decision making should not consider aircraft status monitoring OST 04-4 presentation

  18. EQSG contribution EQ WG comment Additional considerations for 120 minutes approved diversion time ETOPS/LROPS WG response Comment not agreed. This paragraph is in Appendix C4 which relates to ETOPS approval with diversion times between 90 and 180 minutes. This 15% alleviation exists in GAI20x6 (f)(1) (ii) OST 04-4 presentation

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