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NPA-OPS 59 Aerodromes (RFFS) (1.220) new proposal after OPSG 06-2. Capt. Claude Godel OST 06-4. Situation after OST 06-2. An initial proposal by OPSG and the ETOPS WG, based on N-2, was once accepted by OST and appeared shortly in a draft of NPA 15.
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NPA-OPS 59 Aerodromes (RFFS) (1.220)new proposal after OPSG 06-2 Capt. Claude Godel OST 06-4
Situation after OST 06-2 • An initial proposal by OPSG and the ETOPS WG, based on N-2, was once accepted by OST and appeared shortly in a draft of NPA 15. • OST 05-4 considered this proposal no longer acceptable. • A second proposal made by OPSG at OST 06-2 met again a strong dissenting opinion from some CAAs which consider N-1 as a strict bottom line. • Two options remained: • Propose to the Public Consultation a NPA incorporating a strong dissenting position from one part of the OST • Continue the discussion and try to find an acceptable compromise as suggested in JAR 11. • OPSG preferred to work on the second option.
FOREWORD • 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. • ICAO gives some directions in Annex 14, but Annex 14 is applicable to the management of aerodromes not to the operators. • There is a long-established practice in many major airlines allowing operational alleviation of, at least, 2 RFFS categories. • The proposed NPA is the best compromise found by OPSG in order to achieve following goals: • Preserve safety of operations • Provide clear guidance to the operators • Allow enough flexibility for every day operations • Avoid misinterpretation
Explanatory note and RIA After numerous side meetings and discussions OPSG was able to remove the previous dissenting position from the explanatory note and the RIA. Each party made a step towards the other: the bottom line becomes stronger but the Authority may allow some flexibility for exceptional events.
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.
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.
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 and should not, according to a study of Today’s networks, hamper the airline activity. • 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 includes a statistical approach (e.g. 700 movements…). 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) • (4) Planned operations to aerodromes with an RFFS category below that stated in the Table 1 require a specific acceptance by the Authority on a case-by-case basis. • Paragraph (4) leaves a door open for some special situations like isolated islands or exceptional flights.
KEY POINTS (comments) • (5) 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 (5) goes without saying but, as otherwise the question will be raised, OPSG likes to confirm it.
CONCLUSION OPSG considers that the proposed text fulfils the goal and keeps the necessary flexibility for the operator as well as for the Authority which may or may not allow use of column 2. The final question is: “is it better to forbid to an N+1 aeroplane to plan a flight towards an N aerodrome or to oblige the airport management to upgrade it’s RFFS category if the N+1 aeroplane comes more than exceptionally?”