Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B
EASA.2009.OP.21
that the organisation has put in place an appropriate quality system for the control of
the processing of data. This will ease the obligation on the operator to do the same
control and facilitate the issuing by the national competent authorities of the approval
for the operators to fly in dedicated airspace where reduced separations are
implemented.
There is no obligation on operators to buy their data only from organisations holding
the letter of acceptance. Operators can either make the verifications themselves or
use another competent organisation for this purpose and convince directly their
responsible authority that they can be allowed to fly in P-RNAV airspace. The
decision whether or not to apply for an EASA letter of acceptance is therefore entirely
up to the navigation database supplier concerned. However, by applying, the
organisation automatically declares to accept all the obligations that are linked to the
letter of acceptance and which are described in the applicable conditions and
guidance material. On the other hand the issuance of a letter of acceptance does not
give any rights to its holder except the confirmation by the Agency that the
organization concerned is in compliance with the applicable and published conditions
and guidance.
This Rule is included here because of the similarity with de-icing / anti-icing in respect of the
critical nature of the navigation data and the consequences if it is in error, and also the
reliance of the operator on a third-party to provide such data.
Also EASA has an opinion and found a solution to a similar problem as that of de-icing / antiicing;
within this solution is the tacit acceptance of pooled auditing of service providers by
Industry.
It may be possible for EASA to form an Opinion on the use of pooled auditing of de-icing /
anti-icing service providers as an acceptable means of complying with OPS 1.035. Such
audits can be based on a checklist which is derived from a document containing “conditions”
and “guidance”. Such a document could be derived by the Industry, such as AEA
Recommendations, backed up with a checklist such as the DAQCP audit.
Due to the multitude of de-icing / anti-icing service providers compared with database
suppliers a solutions would need to be found to “qualify and license” Industry auditors to
ensure that the “acceptance” process of service providers was standardised.
The DAQCP currently operates from the airline membership perspective and involves only
those destinations and service providers with whom member airlines have business. It may
be necessary for a universal scheme to consider membership from the service providers
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