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NPA-OPS 57 Subparts L and D Alignment to ICAO Annex 6, Part I Amendment 29. OST 06-2 27 March 2006, Cologne Dirk Sajonz (EQSG Chairman). SUMMARY. Regulatory Background Regulatory impact assessment Text proposals OPSG comments CNS/ATM SG comments. REGULATORY BACKGROUND (I).
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NPA-OPS 57 Subparts L and D Alignment to ICAO Annex 6, Part I Amendment 29 OST 06-2 27 March 2006, Cologne Dirk Sajonz (EQSG Chairman) EQSG
SUMMARY • Regulatory Background • Regulatory impact assessment • Text proposals • OPSG comments • CNS/ATM SG comments EQSG
REGULATORY BACKGROUND (I) • Amendment to JAR-OPS 1, Subparts L and D to align it with Amendment 29 to ICAO Annex 6, Part I (RVSM requirements and Navigation Database management). • EQSG was tasked by OST. Work was developed in coordination with OPSG and CNS/ATM SG. • RVSM: • Introduction of new ACJ to JAR-OPS 1.241 to reflect approval process. • Introduction to Appendix 1 to JAR-OPS 1.872 • JAR-OPS 1.872 is already in compliance with ICAO Standards EQSG
REGULATORY BACKGROUND (II) • NAV Database Management: • New ICAO Annex 6, Part I Chapter 7.4 introduced a new Standard for the operator and the responsible authority as regards their responsibilities for the accuracy and integrity of the used NAV data. • EASA issued the type 2 Letter of Acceptance (LoA) for NAV Data suppliers. • However, scope of type 2 LoA is limited to airborne navigation systems and no type 2 LoA can be issued for ground based navigation systems. • For the above, the ICAO paragraph was split into two requirements: one for air and another for ground. EQSG
REGULATORY BACKGROUND (III) • NAV Database Management: • New ICAO Annex 6, Part I Chapter 7.4: “…7.4 Electronic navigation data management 7.4.1 An operator shall not employ electronic navigation data products that have been processed for application in the air and on the ground unless the State of the Operator has approved the operator’s procedures for ensuring that the process applied and the products delivered have met acceptable standards of integrity, and that the products are compatible with the intended function of the equipment that will use them. The State of the Operator shall ensure that the operator continues to monitor both process and products. Note.— Guidance relating to the processes that data suppliers may follow is contained in RTCA DO-200A/EUROCAE ED-76 and RTCA DO-201A/EUROCAE ED-77. 7.4.2 An operator shall implement procedures that ensure the timely distribution and insertion of current and unaltered electronic navigation data to all aircraft that require it…” EQSG
REGULATORY IMPACT ASSESSMENT (I) • The RIA was only developed for the introduction of new Standard in Chapter 7.4 of ICAO Annex 6, part I, as the other material is either of editorial character or is already fully reflected in Section 1 of JAR-OPS 1. • Objectives of the proposal: • Align JAR-OPS 1 with ICAO Annex 6, Part I new requirements for RVSM and “Electronic Navigation Data Management”. • RIA will evaluate the regulatory consequences of the introduction of the new ICAO standards for “Electronic Navigation Data Management”. • Relevant Decisions: As postulated in the ICAO Convention, JAA OST understands the ICAO Amendment 29 to Annex 6, Part I as firm mandate. EQSG
REGULATORY IMPACT ASSESSMENT (II) • Who and/or what is affected: Aircraft operators, navigation database suppliers and NAAs. EASA and the associated working parities (EUROCAE, RTCA) are also involved. • Options: • Do nothing With this option, JAA Member States would have to file a difference to ICAO Standards. The existence of type 2 LoA for Navigation database suppliers will not be reflected into JAR-OPS 1. • Comply with ICAO Annex 6, part I Chapter7.4 Preferred OPTION of EQSG. EQSG
REGULATORY IMPACT ASSESSMENT (III) • Impacts: No negative impact has been detected as result of the introduction of this new ICAO standards into JAR-OPS 1. No additional financial burden for the operators, since they will have to purchase NAV data products from the suppliers. • Consultation: This proposal has been developed in coordination with OPSG and CNS/ATM SG. Their comments are explained later. EQSG
TEXT PROPOSALS (I) • JAR-OPS 1.872 Equipment for operation in defined airspace with Reduced Vertical Separation Minimum (RVSM) (See JAA Administrative & Guidance Material, Section 1, Part 3, TGL 6) (See Appendix 1 to JAR-OPS 1.872) (See JAR-OPS 1.241)… (2) An altitude alerting system. The threshold for the alert shall not exceed ± 90 m (300ft); … NPA-OPS 57 D and L ICAO Alignment for OST 06-2.doc EQSG
TEXT PROPOSALS (II) • (New) ACJ OPS 1.241 Operation in defined airspace with Reduced Vertical Separation Minimum (RVSM) See JAR-OPS 1.241 See JAR-OPS 1.872 1. In order to be approved for the RVSM operation, the Operator should ensure that: … NPA-OPS 57 D and L ICAO Alignment for OST 06-2.doc EQSG
TEXT PROPOSALS (III) • (New) Appendix 1 to JAR-OPS 1.872 Equipment for operation in definedairspace with Reduced Vertical Separation Minimum (RVSM) NPA-OPS 57 D and L ICAO Alignment for OST 06-2.doc EQSG
TEXT PROPOSALS (IV) • (New) JAR-OPS 1.873 Electronic navigation data management (See ACJ OPS 1.873) • An operator shall not employ electronic navigation data products that have been processed for application in the air unless they have been obtained by a supplier holding a Type 2 Letter of Acceptance … NPA-OPS 57 D and L ICAO Alignment for OST 06-2.doc EQSG
TEXT PROPOSALS (V) • (New)ACJ OPS 1.873 Electronic navigation data management See JAR-OPS 1.873 Type 2 Letter of Acceptance (LoA) demonstrates compliance with EUROCAE/RTCA document ED-76/DO-200A Standards for Processing Aeronautical Data. Those documents contain guidance relating to the processes that the supplier may follow. • Editorial change to JAR-OPS 1.241: introduction of reference “(See ACJ OPS 1.241)” NPA-OPS 57 D and L ICAO Alignment for OST 06-2.doc EQSG
OPSG COMMENTS • Most of the OPSG comments have been agreed and included in the final rule proposal. • The OPSG suggestion to delete paragraphs 3, 4 and 5 from ACJ OPS 1.241 (already included in the JIPs) was not agreed. It was considered beneficial to inform the operators about the responsibilities of the State of the operator and the State of Registry • OPSG questioned the need to maintain a reference to TGL 6. Your comments are welcome EQSG
CNS/ATM SG COMMENTS (I) • Most of the CNS/ATM SG comments have been agreed and included in the final rule proposal. • CNS/ATM SG (EUROCONTROL Rep.) highlighted that the Appendix 1 to JAR-OPS 1.872 defines Altimetry System Error (ASE) and the Altimetry System performance requirements in a different way to TGL 6. OST comments are welcome. More comments regarding this issue may come from public consultation period. EQSG
CNS/ATM SG COMMENTS (II) • CNS/ATM SG suggested to introduce the following note in the new paragraph JAR-OPS 1.873: “…Note: If the operator’s supplier (e.g. RNAV manufacturer) has not yet received LOA Type 2 the operator should develop and describe a method to demonstrate an acceptable level of integrity of the navigation data base content and its compatibility with the system onboard the aircraft. The operator should implement navigation database integrity checks using manual verification procedures or appropriate software tools, at each Airac Cycle. The objective of this integrity check is to identify any significant discrepancies between the published charts/procedures and the navigation database content. Integrity checks may be conducted by a designated third party, under the operator responsibility. An acceptable methodology is described in annex C of this AMC 20-XX (Airworthiness and Operational approval for RNAV(GNSS) approach operation). A means has to be provided for those operators were ho LOA type 2 is available…” • This suggestion was not agreed because notes are not permitted in the JAA rulemaking system (JAR 11). • In case the supplier does not hold a type 2 LoA, ICAO Standards will apply. EQSG