Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 EASA NPA 2009 – 02a Under Review following CRD Implementing Rules for Air Operations of Community Operators - Explanatory Note and Appendices Applicability: The first of seven separate NPAs aimed at developing an Opinion on the Implementing Rules for Air Operations of Community Operators and a Decision on the related Acceptable Means of Compliance (AMC) and Guidance Material (GM). The scope of this rulemaking activity is outlined in the Terms of Reference (ToR) OPS.001 and is described in more detail below. This particular NPA provides an explanation of the contents of the other 6 by means of an introduction. Options: For all elements of this NPA 2009 – 02, there may be time and motivation to include, in the first publication, amendments related to improving the standard of de-icing / anti-icing, through operators’ procedures and programmes, and also through the requirements for Authorities. Otherwise, amendments can be proposed after publication of the Implementing Rules for Operations and Authority Requirements. Impact: Any changes to these proposed regulations and associated supporting material will be immediately applicable on publication of the rules (pending any legal or practical periods allowed for adjustment). A.IV. Contents of draft Opinions and Decisions Para 14: The intention is to retain elements and spirit of JAR OPS 1 Section 2 material as extant in JAA TGL 44; thus allowing the better elements of ACJ 1.345 to be maintained. Para 21: Implementing Rules are to reflect state of the art and best practices in the field of operations; therefore reference is valid to the most respected and used documents such as AEA Recommendations. Para 44: Subpart D of Part OPS, OPS.SPA, contains requirements for specific operations that require a specific approval. Thus giving a vehicle to include de-icing / anti-icing as a special approval operation, such as the transport of dangerous goods. Para 56: To maintain the necessary level of flexibility it is imperative that only essential airsight GmbH - 30 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B EASA.2009.OP.21 safety elements are contained in the rule, leaving nonessential implementation aspects to CS or AMC, so as to provide for a sufficient flexibility as required by the principle of subsidiarity. Such is the fundamental reason for the ‘performance based approach’ to rulemaking that the Agency has followed. Careful thought must be given to the essential aspects of de-icing / anti-icing regulation; allowing too much flexibility in interpreting the rules will harm the aim of harmonization. Para 67: The Agency wishes make use of as many AMCs as possible by encouraging industry to promote their best-practices for that cause. This opens the way for inherent acceptance of, for example, the AEA Recommendations to be amended and adopted as AMC material. Appendix 1 para 9: On 31 July 2007, the Agency published the Advance Notice of Proposed Amendment (ANPA) 200711 to consult stakeholders on appropriate measures to be taken to address potential safety hazards associated with the residues of fluids used for the ground deicing and antiicing of aircraft. In the Comment Response Document (CRD) 43 , the Agency described the outcome of the consultation and the possible course of action to address these potential safety hazards. One of the proposed actions was to consider the input from stakeholders on “OPS.GEN.100 Ice and other contaminants” and the associated AMC2 and GM1, 2, and 3. The Agency welcomes any comment on how to improve the existing material. It should be noted that, for the time being, the regulation of ground deicing / antiicing service providers is out of the Agency’s remit. Confirmation that the direct regulation of de-icing / anti-icing service providers, by EASA, is not a short term option. However, the Study can include feedback from the CRD to the mentioned references above and furthermore include recommendations for amendment as appropriate to feedback gathered during the Study. Appendix II para 6: There is one important change compared to EUOPS/JAROPS 3 insofar as the operations manual, when first presented to the competent authority, needs to be fully approved. Previously, this was only the case for certain parts. This change has been introduced following the new AMC procedure explained in paragraph 56 of the explanatory note, as means of compliance are now part of the approval for commercial operators. These means of compliance are usually described as procedures in the manual. Therefore, the procedures defined in EASA AMC effectively carry the same status as regulations: limiting de-icing / anti-icing operators’ programmes to only one AMC would ensure harmonisation amongst operators and probably the same for service providers who carry out many of these procedures.. airsight GmbH - 31 -
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Interim Report - Introduction - EASA

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