alternative means of compliance (altmoc) · nco, ncc & spo 6. questions and ... alternative...

Alternative means of compliance (AltMOC)

Workshop implementation of the Air Ops Regulation (EU) No 965/2012. Francisco Arenas Alvariño RuleMaking – Air ops.

TE.GEN.00409-001

Introduction

2014

Nº 965/2012 2

ARO.GEN.120 Means of compliance

(a) The Agency shall develop Acceptable Means of Compliance

(b) Alternative means of compliance may be used

Defined by an organisation or by the competent authority.

The competent authority shall evaluate the Alt-MOC and notify the Agency if it is in accordance, with the IR.

•EASA web: http://easa.europa.eu/document-library/acceptable-means-compliance-amcs-and-alternative-means-compliance-altmocs

Creation of a dedicated mailbox

[email protected]

mailto:[email protected]

Example of questions received altmo@

“The Competent Authority A” received an AltMOC request on AMC1 SPA.LVO.120 sub (e). This AMC derogates from EU-OPS App1 to OPS 1.450 (e)(3) “Authority may authorise a reduction in the above command experience requirements for flight crew members who have Category II or Category III command experience.” We would like clarification on the following: is the reduction on command experience for flight crew as in EU-OPS left out AMC1 SPA.LVO.120 sub(e) on purpose and with good reasons? And if so what are these reasons? Your answer will be important for “Competent authority A” to respond to the AltMOC request.

2014 Workshop Regulation (EU) Nº 965/2012 3

Summary

2014

Workshop Regulation (EU) Nº 965/2012 4

•Summary of this presentation:

1. Levels of the regulatory material (1)

2. Alt-MOC principles-Regulation (5) ~ (3)

3. Alt-Moc Authority: (2)

4. Alt-MOC Stakeholder: (2)

5. NCO, NCC & SPO

6. Questions and discussion

4.2 Agency involvement (1)

3.2 Agency involvement (1)

Please download.

http://1drv.ms/1tWBz6b

24/09/2014 PORTUGAL. Workshop Regulation (EU) Nº 965/2012 5

1-Levels of Regulatory material.

Levels of Regulatory material in the EASA system: The Basic Regulation itself, adopted by the European Parliament and the Council, binding in all its elements.

Implementing Rules to the Basic Regulation, adopted by the European Commission; and

Soft law, adopted by EASA. Certification Specification (CS);

Aceptable Means of compliance (AMC);

Guidance Material (GM).


BR

IR •Cs, AMC, GM

http://easa.europa.eu/regulations#regulations-basic-regulation

http://easa.europa.eu/regulations

http://easa.europa.eu/document-library/acceptable-means-of-compliance-and-guidance-materials

2- AltMOC principles


AMC

non-binding

Alternative

means

MAY be used

Compliance with

rules MUST be

demonstrated

A process must be established on the level of

the operator, the Competent Authority

and the Agency to ensure:

• No negative effect on safety

• Transparency

• Harmonisation

•presumption of compliance with the rules AMC1 ORO.GEN.120 (a)

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Alternative means of compliance (AltMOC)

those means that propose an alternative

to an existing acceptable means of compliance

Or

those that propose new means to establish compliance with Regulation (EC) No 216/2008 and its Implementing Rules for which no associated AMC have been adopted by the Agency

DO NOT presume compliance with the rules, hence the need for the evaluation by the Competent Authority.

IR AMC

AltMOC

IR AMC

AltMOC

AltMOC proposed by the authority


(c) Evaluation system to monitor AltMOCs under its oversight

(e) Competent authority can propose AltMOC, provided that:

When the AMC are complied with, the related requirements of the Implementing Rules are met.

AltMOC is available to all operators under its oversight

Notify EASA, incl. description and assessment of AltMOC

2014

•KEY POINTS OF THE REGULATION

AltMOC proposed by the operator

ORO.GEN.120 Means of compliance

(b) Subject to prior approval by CA, operator can propose AltMOC, if it


(d) CA evaluates AltMOC, this can include an inspection. If AltMOC is

deemed compliant with the rules, the CA needs to :

provides full description to competent authority, incl. revision of manuals, procedures & safety assessment.

Notify the operator & possibly amend the certificate

Inform other Member States that AltMOCs were accepted

Notify EASA on content of AltMOC & send all documents

2014

•KEY POINTS OF THE REGULATION

What all this means??

Are the alt-MOC for Authority and Operators very different one each other?


3- Alt-MOC

Summary Review:

1. Levels of the regulatory material

2. AltMOC principles

3. AltMOC Authority.

Agency involvement.

4. AltMoc: For a Stakeholder.

Agency involvement.

5. Example

6. NCC, NCO&SPO Questions and discussion

2014

Workshop Regulation (EU) Nº 965/2012 12

Requirements set by ARO.GEN.120:

An Evaluation of the Alt-MOC (ARO.GEN.120(c))

Availability.(ARO.GEN.120 (e)(1))

Notification to the agency. (EASA form)

ARO.GEN.120 (e)(2))

Description of Alt-MOC. ARO.GEN.120 (e) Last paragraph.

Revision to procedures(amendment to manuals)

Assessment demonstrating the IR is meet

2014. Workshop. Regulation (EU) Nº 965/2012 13

3- AltMoc : Authority

EASA “Form for notification to the Agency of AltMOC”

2014 Workshop. Regulation (EU) Nº 965/2012 14

3.2- Agency involvement

1-Description (box 09)

2-New manuals (box11)

3-Demonstration the IR is meet (box10)

Others

Summary Review:




Agency involvement.


Agency involvement. 5. Example

6. NCC, NCO & SPO Questions and discussion

3- Alt-MOC


Evaluation (authority)

Notification to the applicant (authority)

Notification to agency (EASA form)(authority)

Inform member states. (authority)(BOX13)

Full description Alt-MOC (operator)(BOX09)

Revision to manuals/procedures (operator)(BOX11)

Assessment demonstrating implement rule is met (operator)(BOX10)

RISK ASSESMENT (operator)

(AMC1 ORO.GEN.120(a))

2014 Workshop Regulation (EU) Nº 965/2012 "

16

3.2 - AltMOC: Operator with AOC

EASA “Form for notification to the Agency of AltMOC”

2014 Workshop. Regulation (EU) Nº 965/2012 17

3.2- Agency involvement

1-Description (box 09) Operator

2-The new manuals (box11) Operator

3-Demonstration the IR is meet (box10) Operator

Others

Evaluation by INAC (Rule: “all Relevant documentation”. Is it relevant?)

Summary Review:




Agency involvement.


Agency involvement.

5. Example

6. NCC, NCO & SPO Questions and discussion

3- Alt-MOC


Example FAST JETS Airlines

An AOC operator, proposed an ALT-MOC for CAT.POL.MAB.105(c) and AMC1 CAT.POL.MAB.105(C).

They would like to establish the commander’s acceptance for the Mass&Balance by Voice recognition to the Ground Ops frequency.

FAST AIRLINES already use AMC2 CAT.POL.MAB.105(c). MASS AND BALANCE DOCUMENTATION

SENT VIA DATA LINK


What FAST AIRLINE provide to Comp Auth

The fee&form of the Competent authority

ACARS PROCEDURES SUPPORTING DOCS


Summary Review:




Agency involvement.


Agency involvement.

5. Example

6. Questions and discussion

3- Alt-MOC


Example of questions received altmo@

“The Competent Authority A” received an AltMOC request on AMC1 SPA.LVO.120 sub (e). This AMC derogates from EU-OPS App1 to OPS 1.450 (e)(3) “Authority may authorise a reduction in the above command experience requirements for flight crew members who have Category II or Category III command experience.” We would like clarification on the following: is the reduction on command experience for flight crew as in EU-OPS left out AMC1 SPA.LVO.120 sub(e) on purpose and with good reasons? And if so what are these reasons? Your answer will be important for “Competent authority A” to respond to the AltMOC request.


Appendix 1 to OPS 1.450 Low visibility operations — Training and qualifications

(e) Type and command experience.

1. Before commencing Category II operations, the following additional requirements are applicable to commanders,or pilots to whom conduct of the flight may be delegated, who are new to the aeroplane type/class:

(i) 50 hours or 20 sectors on the type, including line flying under supervision; and

(ii) 100 m must be added to the applicable Category II RVR minima when the operation requires a Category II

manual landing or use of HUDLS to touchdown until:

(A) a total of 100 hours or 40 sectors, including LIFUS has been achieved on the type; or

(B) a total of 50 hours or 20 sectors, including LIFUS has been achieved on the type where the flight crew

member has been previously qualified for Category II manual landing operations with a Community operator;

(C) for HUDLS operations the sector requirements in paragraphs (e) 1. and (e) 2. (i) shall always be applicable,

the hours on type/class does not fulfil the requirement.

2. Before commencing Category III operations, the following additional requirements are applicable to commanders, or pilots to whom conduct of the flight may be delegated, who are new to the aeroplane type:

(i) 50 hours or 20 sectors on the type, including line flying under supervision; and

(ii) 100 m must be added to the applicable Category II or Category III RVR minima unless he has previously qualified for Category II or III operations with a Community operator, until a total of 100 hours or 40 sectors, including line flying under supervision, has been achieved on the type.

3. The Authority may authorise a reduction in the above command experience requirements for flight crew members who have Category II or Category III command experience.


Answer from altmoc@

Paragraph EU-OPS Appendix 1 to OPS 1.450 (e)(3) was not transposed into AMC1 SPA.LVO.120 since it was considered to fall under the alt-MOC procedure.

In principle, the flexibility allowed in the EU-OPS environment subject to an acceptance of the competent authority (“the Authority may authorise a reduction..”) is superseded by the introduction of the alt-MOC Procedure in Reg.(EU)965/2012.

Please be aware that a commander carrying out a new aeroplane type rating is subject to the mandatory elements described in the OSD which might have provisions to qualify the pilot for Low Visibility. Although there is no OSD requirement to evaluate LVO training if it is not part of the standard

equipment for operations, some manufactures might decide to do it.


Question of Alt MOC publicity.


Answer from EASA focal point

Item #14 on the form asks if the Authority have the AltMoC made public via for example their website or other form of distribution.

If an Authority does not want EASA to publish a reference to their AltMoC on EASA website, they should indicate this in Item #15 of the form.

Please note that EASA only publishes some very basic information on AltMoCs, see screenshot below:

Also, we are currently only publishing this very basic information for AltMoCs which have been assessed by EASA and for which no technical objections were established at the current stage.

Should your counter parts in Finland would like to discuss this in more details, please forward them my email. I am happy to contact them.


What Means for TRAFI availability?

The AltMOC-Authority must be available to all organisations and persons under its

oversight ARO.GEN.120 (e)(1). What about AltMOC-Operator??

NCC operator. What is required?. See AMC1 ORO.GEN.120 (a).

Can an NCO operator proposed ALT-MOC (ORO.GEN is require for NCO?)

Can Trafi or a Finnish Operator use the Alt-MOC proposed by another member state, or foreign operator? See GM1 ARO.GEN.120.

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¿¿Questions?? & discussion

AMC provide legal certainty, contribution to uniform implementation, and presumption of compliance with the rules. AltMOC:

Propose an alternative to an existing AMC

Propose means to establish compliance with BR or IR if no AMC has been adopted by the Agency

DO NOT presume compliance evaluation by CA needed. IF used, compliance MUST be demonstrated process established by operator, CA and Agency to ensure no negative effect on safety, transparency and harmonization. Treatment of AltMOC has two different scenarios:

a) proposed by operator

b) proposed by authority. Some NAAs have issued guidance (see UK CAA). For guidance, see rules and AMC/GM. The operator has to send a risk assessment.

AMC and AltMoC - Summary -

End slide

alternative means of compliance (altmoc) · nco, ncc & spo 6. questions and ... alternative...

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