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Title Requirements for ATM/ANS providers and the safety oversight thereof (Explanatory Note)
NPA Number NPA 2013-08 (A)
Federal Office of Civil Aviation FOCA ([email protected]) has placed 9 unique comments on this NPA:
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341 A. Explanatory Note -
IV. Overview of the proposed changes - CHAPTER 1 — GENERAL OVERVIEW OF THE CHANGES (Part III)
12 -
15 FOCA fully supports the effort of harmonising the regulations comprising the EASA
remits and especially with the ICAO Annex 19 (SMS Framework).
344 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 3 — COVER REGULATION — Main changes and
explanation - Invitation to comment (a)
23 FOCA supports the proposal to exclude "coffein" & "tobacco" from psychoactive
substances.
354 A. Explanatory Note - IV. Overview of the
proposed changes -
CHAPTER 3 — COVER REGULATION — Main changes and explanation - Invitation to comment
(b)
28 FOCA suggests to synchronize the entry into force of the regulation related to this NPA
with the FABEC RP3 tasks to avoid conflicting/non-necessary developments in the
meantime.
• Are there any procedures already established on the future communication and
cooperation of EASA with the Member States until the entry into force of this regulation?
• Consistency needs to be ensured between this NPA and the upcoming rulemaking
tasks (RMT.0161, .0162, .0469, .0470).
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• When and how will the placeholders in this NPA be integrated? ATM/ANS.AR.C.030,
ATM/ANS.AR.C.035, ATS.OR.210, ATS.OR.215.
355 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 4 — Annex I — Requirements for
competent authorities - Invitation to
comment (a)
29 The requirement should reflect a total system approach as it is an horizontal issue (also
compare with ADR.AR.A.025).
According to EASA, the idea is to have the same material in the remits Air OPS/FCL, ATM/
ANS and eventually the earlier EASA domains such as Production/Maintenance.
356 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 4 — Annex
I — Requirements for competent authorities - Invitation to comment (b)
35 FOCA supports Option 2 as it allows for a maximum flexibilty for the authority.
However, there are still many issues to be further developed with regard to the subject of
CBO (compliance based), RBO (risk based) and PBO (performance based) and a common
understanding yet to be established. As FOCA understands these
concepts and applies them to some extent already, oversight is planned based on either
risks at the stakeholders services or on the basis of their performance. Therefore, focus
also needs to be put on the safety analyst bodies of the oversight authorities. When RIA
Section 6 requires some initial training to NSA's personnel, this implies that not only the
auditors but the analysis personnel of the authority would need to be trained accordingly.
The Authorities need to establish a solid risk and performance monitoring body (in FOCA
there is a specialized analyst section responsible for the SRM), or to set up these
competences on the level of audit management.
357 A. Explanatory Note -
IV. Overview of the proposed changes -
CHAPTER 4 — Annex I — Requirements for competent authorities - Invitation to comment (c)
36 The GM is too prescriptive on how changes should be dealt with by the ANSP and NSA.
The sections ATM/ANS.AR.C.020 and ATM/ANS.OR.A.035 as well as AMC need to be
harmonized.
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358 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 5 — Annex II — COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-
ATM/ANS.OR) - Invitation to comment (b)
42 FOCA supports the proposal to remove the ISO9001 from the AMC. However, the
authority shall be given the competence to repeal the validity of a ISO 9001 certification if
doubts arise on the appropriateness of this certification.
359 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 5 — Annex II — COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-
ATM/ANS.OR) - Invitation to comment (c)
43 FOCA supports that the ATM/ANS.OR.B.025 remains in the future regulation.
ATM/ANS.OR.B.015 prescibes that the personnel needs to be trained and
be competent. Interpretation should be avoided that only ongoing-training will be
considered as mandatory.
It's essential that the providers set up guidlines on what the basic skills for personnel for
the specific functions are. Based on this, a gap-analysis should be conducted for newly
employed personnel. ATM/ANS.OR.B.025 ‘Human resources seems to assure such a
proceeding.
360 A. Explanatory Note - IV. Overview of the proposed changes - CHAPTER 6 — SPECIFIC REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (Part-ATS)
- Invitation to comment (a)
45 FOCA supports the option that EASA will include the standards from ICAO Annex 19 and
not develop a own legislation for those requirements.
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Title Requirements for ATM/ANS providers and the safety oversight thereof (Implementing Rule)
NPA Number NPA 2013-08 (B)
Federal Office of Civil Aviation FOCA ([email protected]) has placed 55 unique comments on this NPA:
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Page Comment Attachments
485 COVER REGULATION - Article 2
9 - 13 Article 2 (definitions)
number 32: "established by a Competent authority": please use either Competent
Authority or competent authority, typo/inconsistent use number 26: "Hazard means any means..." : typo ("any means" is redundant)
936 COVER REGULATION - Article 2
9 - 13 The difference between definitions provided at ICAO level and the definitions provided
at EU level could result to safety issues. Therefore, differences should be avoided as far as
possible.
938 COVER REGULATION - Article 3
13 - 14
sdArt. 3 par. 1 letter c and d:
o When mentioning “the Treaty” (of Lisbon), even though it is obvious, it would be useful
for Third States to know to which treaty it is refered to. The same comment applies
to “the Agency”.
o Furthermore, the formulation of letter c is problematic for Switzerland: According to
SES Regulation, we are considered as a Member State, but with the text proposed here,
the Agency (EASA) will be considered as the competent authority for certification and
oversight. This not acceptable for Switzerland.
494 COVER REGULATION - Article 6
15 Art. 6 par. 1 (a): "...operating regularly at not more than": FOCA suggests to delete the
preposition "at" (see ATM/ANS.OR.A.015 (b) (2))
510 COVER REGULATION - Article 7
15 - 16
Art. 7 par. 5: Please delete the requirement of notification to other Member States.
Notification to other Member States would create an administrative burden, without any
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obvious benefit. EASA has confirmed at the occasion of a presentation on AltMoCs at
the RAG meeting on 3 July 2013 that the notification via EASA resp. the publication on
the dedicated website of EASA is considered to be sufficient.
525 ANNEX I - REQUIREMENTS FOR COMPETENT AUTHORITIES IN
ATM/ANS (Part-
ATM/ANS.AR) - SUBPART A — GENERAL REQUIREMENTS - ATM/ANS.AR.A.010 Information to the Agency
19 Need for harmonisation with ADR.AR.A.25 (horizontal task)
527 ANNEX I - REQUIREMENTS FOR COMPETENT AUTHORITIES IN
ATM/ANS (Part-
ATM/ANS.AR) - SUBPART A — GENERAL REQUIREMENTS - ATM/ANS.AR.A.015 Immediate reaction to safety problem
20 ATM/ANS.AR.A.015 (d):
Notification to the Agency and other Member States seems to create an administrative
burden, without any obvious benefit. What is EASA's intent and handling with such
notification? If Member States have to notify to the Agency, the aim and the further
proceeding with this information should be transparent to the national authorities.
Furthermore, it is not clear what kind of safety concerns will fall under the scope of this
article.
529 ANNEX I - REQUIREMENTS FOR COMPETENT
AUTHORITIES IN ATM/ANS (Part-
ATM/ANS.AR) - SUBPART A — GENERAL REQUIREMENTS -
20 ATM/ANS.AR.A.020 (c): Need for harmonisation with ADR.AR.A.40
Notification to Agency and other Member States seems to create an administrative
burden, without any obvious benefit. How does EASA proceed with such notifications? If
Member States have to notify to the Agency, the aim and the further proceeding with this
information should be transparent to the national authorities.
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ATM/ANS.AR.A.020 Safety directives
531 ANNEX I - REQUIREMENTS FOR
COMPETENT AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART A — GENERAL REQUIREMENTS -
ATM/ANS.AR.A.025 Oversight reporting
20 FOCA fully supports that an Annual Safety Oversight Report is no longer requested.
556 ANNEX I - REQUIREMENTS FOR COMPETENT
AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART B — MANAGEMENT (ATM/ANS.AR.B) -
ATM/ANS.AR.B.005 Management system
21 Need for harmonisation with ADR.AR.B.005
563 ANNEX I - REQUIREMENTS FOR COMPETENT
AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART B — MANAGEMENT (ATM/ANS.AR.B) - ATM/ANS.AR.B.010
Allocation of tasks to qualified entities
21 - 22
Need for harmonization with NPA-2011-20
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566 ANNEX I - REQUIREMENTS FOR COMPETENT AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART B — MANAGEMENT
(ATM/ANS.AR.B) - ATM/ANS.AR.B.020 Oversight records
22 - 23
Need for harmonization with NPA-2011-20.
The requirement adresses "oversight records". It might be worth considering whether the
scope should be extended to the licensing area and state the conditions for record keeping
for licences.
569 ANNEX I - REQUIREMENTS FOR COMPETENT AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART C — OVERSIGHT,
CERTIFICATION, AND ENFORCEMENT (ATM/ANS.AR.C) - ATM/ANS.AR.C.010 Certification,
declaration, and verification of ATM/ANS
23 - 24
According to the text [in particular the Appendix I] no certification is possible with "open
findings". This requirement is almost impossible to comply with and was a EASA-finding in
many Member States. In FOCA's opinion it should be possible to issue a certificate with
conditions. These conditions should be set in relation to the open findings (e.g. in
agreement with the Corrective Action Proposal). If a certificate is no longer valid as soon
as a non-compliance exist, then no viable ANS provision could be achieved. Otherwise,
the Corrective Action Proposal process would not make sense.
Special attention must be given that all OR and AR requirements regarding certification
are harmonised across the various NPAs, notably NPA 2012-018, NPA 2013-08, NPA on
Apron Management Services, NPA on Aerodromes, in order to allow one organisation to be
certified for more than one activity e.g. all operational units will have to be certified as
ANSPs and Training Organisation.
576 ANNEX I - REQUIREMENTS FOR
COMPETENT AUTHORITIES IN
ATM/ANS (Part- ATM/ANS.AR) - SUBPART C — OVERSIGHT, CERTIFICATION, AND
ENFORCEMENT (ATM/ANS.AR.C) -
24 - 25
Need for harmonisation with ADR.AR.C.005
FOCA supports OPTION 2 (see also corresponding comment to the RIA).
FOCA would like to raise the attention to the fact that the requirement does not state
whether electronical files are approved as evidence. Is this intended by EASA - if yes - on
what grounds?
Furthermore, it seems that the audit function and corrective action process are not
adressed separately. Is this intended by EASA and - if yes - on what grounds?
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ATM/ANS.AR.C.015 Oversight
578 ANNEX I - REQUIREMENTS FOR
COMPETENT AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART C — OVERSIGHT, CERTIFICATION, AND
ENFORCEMENT (ATM/ANS.AR.C) - ATM/ANS.AR.C.020 Changes — ATM/ANS providers
26 The paragraph refers to "changes" whereas the Explanatory notes refer to "organizational
change". The purpose/intent of this paragraph is unclear. May also be covered by
ATM/ANS.OR.A.035 or vice versa.
FOCA recommends to merge the section ATM/ANS.AR.C.020 and ATM/ANS.OR.A.035 into
a single section. The current separation is artificial and readability and comprehensivness
is strongly compromised (as the two sections are located in two different parts of the NPA
(Annex I / Annex II))
580 ANNEX I - REQUIREMENTS FOR COMPETENT
AUTHORITIES IN ATM/ANS (Part- ATM/ANS.AR) -
SUBPART C — OVERSIGHT, CERTIFICATION, AND ENFORCEMENT (ATM/ANS.AR.C) - ATM/ANS.AR.C.025 Findings, corrective
actions, and enforcement
measures
26 - 27
Documentary evidence may include:
Replace “inspection records and internal audit results” with “internal quality control
results (inspection, audit and tests)
Justification:
Quality Control consists of three different methods (inspections, audits and tests). All
three methods are considered to be internal quality control activities.
FOCA suggests to add to (c) the following:
staff recruitment (pre-employment check or background check)
581 ANNEX II - COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
34 General remark to Annex II:
There is no explicit obligation for the ANSP to run a systematic compliance management
in the frame of a SMS. It might be possible that EASA considers the need for a compliance
management on the level of corporate governance. However, this should be mentioned
appropriately. In FOCA's opinion, a modern company should run a proper compliance
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SUBPART A — GENERAL COMMON REQUIREMENTS (ATM/ANS.OR.A) - ATM/ANS.OR.A.005 Scope
management by demonstrating (and assuring) compliance not only at a specific moment
of time (time of the audit).
582 ANNEX II - COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
SUBPART A — GENERAL COMMON REQUIREMENTS (ATM/ANS.OR.A) - ATM/ANS.OR.A.035 Changes
36 The subpart (b) refers to "any other change" which inherently includes also "changes to
functional systems". It is highly recommended to combine the section ATM/ANS.AR.C.020
and ATM/ANS.OR.A.035. The current separation is artificial and readability and
comprehensivness is strongly compromised.
583 ANNEX II - COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
SUBPART A — GENERAL COMMON REQUIREMENTS (ATM/ANS.OR.A) - ATM/ANS.OR.A.040 Changes to the functional system
36 To be developed under RMT.0469 and RMT.0470
584 ANNEX II - COMMON
REQUIREMENTS FOR THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
SUBPART A — GENERAL COMMON REQUIREMENTS
37 -
38 FOCA supports the intention to oblige not only personnel but also the ANSP to report.
The meaning of "follow-up report" and "relevant" should be further detailed.
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(ATM/ANS.OR.A) - ATM/ANS.OR.A.060 Safety reporting
585 ANNEX II - COMMON
REQUIREMENTS FOR THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
SUBPART B — MANAGEMENT (ATM/ANS.OR.B) -
ATM/ANS.OR.B.010 Organisational structure
38 It should be considered whether "post holders" should be further detailed (who can be a
post holder? A supervisor? Or only member of the senior staff?).
Furthermore, the organizational structure should - in addition to the definition of
responsibilities - also include the definition of accountabilities.
586 ANNEX II - COMMON REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) -
SUBPART B — MANAGEMENT (ATM/ANS.OR.B) -
ATM/ANS.OR.B.020 Contracted activities
39 add "service" to [...]contracted or purchased activity, system, or constituent conform to
the applicable requirements.
The final responsability has to be clearly defined. The GM1 ATM/ANS.OR.B.020 8 (a) in
regard to hazard identification and risk assessment shall be under the responsability of
the ATM / ANS provider.
587 ANNEX II - COMMON REQUIREMENTS FOR THE PROVISION OF
ATM/ANS (Part-ATM/ANS.OR) - SUBPART B —
MANAGEMENT (ATM/ANS.OR.B) - ATM/ANS.OR.B.035 Record keeping
40 A list of records has to be established in the SMS and approved by the Competent
Authroity; this requirement is only mentioned in the EXP Note, but not in the hard law.
588 ANNEX II - COMMON REQUIREMENTS FOR THE PROVISION OF
40 It might be considered to add an obligation to the ANSP to store out of date manuals for a
certain time. This would allow to retrace changes.
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ATM/ANS (Part-ATM/ANS.OR) - SUBPART B — MANAGEMENT (ATM/ANS.OR.B) - ATM/ANS.OR.B.040
Operations manuals
FOCA suggests to clearly state whether manuals shall be "accepted" or "approved" by the
competent authority.
589 ANNEX II - COMMON
REQUIREMENTS FOR THE PROVISION OF ATM/ANS (Part-
ATM/ANS.OR) - SUBPART C — SPECIFIC ORGANISATIONAL REQUIREMENTS FOR ANS AND ATFM
PROVIDERS AND THE NETWORK MANAGER
(ATM/ANS.OR.C) - ATM/ANS.OR.C.015 Security management
41 -
42 FOCA suggests to add "tests" in the following sentence: "...should establish a schedule of
audits, inspections AND TESTS...".
Furthermore "security" shall also be added ("...should take into account the safety AND
SECURITY performance ...").
590 ANNEX II - COMMON REQUIREMENTS FOR THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) - SUBPART C — SPECIFIC
ORGANISATIONAL REQUIREMENTS FOR
ANS AND ATFM PROVIDERS AND THE NETWORK MANAGER (ATM/ANS.OR.C) - ATM/ANS.OR.C.020
Financial strength
42 It should be specified whether the economic and financial capacity of an ANSP needs to be
verified by the oversight authority on a yearly basis or only on the occasion of the
provision of an ANS certificate.
It needs to be considered that an ANSP could be owned or controlled by the state (or even
be part of the federal organisation) which is also responsible for the application of the
regulation 1035/2011. Accordingly, it should be considered that Member States have the
possibility to opt out from the obligation to check the economic and financial capacity
under this Regulation (or to limit the scope of the economic and financial oversight) if it is
by majority owned or controlled by the State.
As referred to in point 2.2.2 the ANSP shall produce an annual plan for the forthcoming
year including its expected short-term financial position as well as any changes or impacts
on the business plan.
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Besides the possible conflicts which could result under the aspects of the corporate
governance, the conditions related to the economic and financial capacity and its
oversight should be differentiated since a Member State could be able to guarantee the
financial strength of the ANSP even if the annual or 5 year plan would show a
negative balance .
592 ANNEX II - COMMON
REQUIREMENTS FOR
THE PROVISION OF ATM/ANS (Part-ATM/ANS.OR) - SUBPART C — SPECIFIC ORGANISATIONAL
REQUIREMENTS FOR ANS AND ATFM PROVIDERS AND THE NETWORK MANAGER (ATM/ANS.OR.C) - ATM/ANS.OR.C.030
Open and transparent
provision of services
42 Open and transparent provision of services shall also be mandatory for other than ANS
ant ATFM providers. Replace Air Navigation service and air traffic flow
mananagment provider with "ATM / ANS providers".
594 ANNEX II - COMMON REQUIREMENTS FOR THE PROVISION OF ATM/ANS (Part-
ATM/ANS.OR) - SUBPART C — SPECIFIC ORGANISATIONAL REQUIREMENTS FOR
ANS AND ATFM
PROVIDERS AND THE NETWORK MANAGER (ATM/ANS.OR.C) - ATM/ANS.OR.C.035 Contingency plans
42 Contingency plans shall also be mandatory for other than ANS and ATFM providers.
Replace Air navigations service and air traffic flow mananagment provider with "ATM /
ANS providers".
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Page Comment Attachments
596 APPENDIX I TO ANNEX II (Part-ATM/ANS) - DECLARATION OF PROVISION OF FLIGHT
INFORMATION SERVICES
44 - 45
Voice-ATIS might be abbreviated "V-ATIS" as already applied for Data Link ATIS.
Please check for consistent use of words: Sometimes plural, sometimes singular form
used in case of "FIS" (flight information service vs. Flight information services)
599 ANNEX III - SPECIFIC REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (Part-ATS) - SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR
THE PROVISION OF AIR TRAFFIC
SERVICES (ATS.OR) - Section 1 — General requirements - ATS.OR.115 Open and transparent
provision of service
46 What about fatigue detection? Prevention and mitigation are only one part of fatigue,
detection is missing.
603 ANNEX III - SPECIFIC REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC
SERVICES (Part-ATS) - SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC
SERVICES (ATS.OR) - Section 2 — Safety of
46 - 48
In relation to lit. 1 (ii) FOCA is not sure if responsibility is the correct word. A policy
should also refer to accountability. Responsibility reflects a wider context. Many
subjects are responsible for the safe operation, but only one person is accountable for a
certain task.
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Page Comment Attachments
services - ATS.OR.205 Safety management system
610 ANNEX III - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (Part-ATS)
- SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) - Section 2 — Safety of services -
ATS.OR.205 Safety management system
46 -
48 Lit.(1) requires "to ensure that due consideration is given to all aspects of the provision of
ATS (risk assessment and mitigation)." Firstly, it is not clear to us why the scope of risk
management is reduced to ATS. Secondly, the provision means that not only safety but
also production is part of risk management (all aspects of provision of ATS). In our
opinion, safety risk management is certainly necessary and together with the policy to
assure acceptable safety, it probably will meet its purpose.
The definition of expression "safety level" is in our view unclear. Please include expression
" safety level" in defintion section of NPA.
617 ANNEX III - SPECIFIC REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (Part-ATS) - SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (ATS.OR) -
Section 2 — Safety of services - ATS.OR.205 Safety management system
46 - 48
(c) SAFETY ASSURANCE Lit.(iv): On the occasion that an ANSP can categorise an
occurrence regarding safety significance and possible implications, it probably has
conducted some investigation already. However, the provision requires to investigate only
when a certain safety significance is evident. This looks somehow like a recursion.
Further, FOCA wonders why the provision in the SMS framework only mentions the need
for immediate investigation.
Basically, to us it is not clear whether risk management is considered as a part of safety
assurance or vice versa. This is is a fundamental question which probably exceeds the
content of this NPA. Generally, it could be said that the whole SMS itself is safety
assurance on a corporate level. The essential part of the SMS to assure safety is the
combination of proper collection and analysis of any information in order to balance
production versus protection to establish and maintainan a acceptable level of safety for
any service provided. This function is called (integrated) risk management; whereby risks
are considered as positive or negative deviation from a target (like chance and risk).
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Proposal 1: Lit.(iv) should require occurrence investigation in a more generic way.
Proposal 2: The GM might indicate the expected detail and different levels of occurrence
investigation, i.e. For any occurrence at least severity has to be determined. For
occurrences, which are considered to have significant safety implications, a further
investigation and mitigation process should start immediately (root cause analysis (in the
triangel of human-procedure-equipment), corrective action, preventive action).
667 ANNEX III - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (Part-ATS) - SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) - Section 2 — Safety of
services - ATS.OR.220 Licensing and medical certification requirements for air traffic controllers
48 The numbering of the implemeting rule is not consistent with the explanatory material.
Please refer to the document available
668 ANNEX III - SPECIFIC REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (Part-ATS)
- SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) -
49 (b) prevent and mitigate the risk that ATC service is provided by ATCOs with impaired
cognitive judgement due to problematic use of psychoactive substances. Justification: Any
use of psychoactive substances is likely to impare the cognitive judgement of ATCOs.
Therefore the impact is not limited to the "problematic" use of psychoactive substances.
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Page Comment Attachments
Section 3 — Human factors principles for the provision of air traffic control service - ATS.OR.305 Scope
669 ANNEX III - SPECIFIC REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (Part-ATS) - SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) -
Section 3 — Human factors principles for
the provision of air traffic control service - ATS.OR.315 Responsibilities of air traffic control service
providers with regard to the problematic use of psychoactive substances by ATCOs
49 The air traffic control service provider shall develop and implement a policy, with related
procedures, to prevent and mitigate any effect of problematic use of psychoactive
substances by ATCOs on the provision of air traffic control service under the responsibility
of the provider.
If any effect of the use of psychoactive substances is to be prevented no mitigation is
necessary due to the fact that the use in itself is prohibited.
The use of psychactive substances in itself is very likely to impaire the cognitve
judgement of ATCOs. Therefore ATCO shall be prevented from exercising the privileges of
his/her licence when under the influence of psychoactive substances.
674 ANNEX III - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF
AIR TRAFFIC SERVICES (Part-ATS) - SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF
50
(a) […] shall develop obtain, implement, […]
A service provider should have the possbilitiy to purchase such a system instead of
developing itself. Either by buying the rostering software from a third company and
by implementing this system of rostering accordingly, or by outsourcing the whole
rostering to a third company (outsourcing).
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AIR TRAFFIC SERVICES (ATS.OR) - Section 3 — Human factors principles for the provision of air traffic control service
- ATS.OR.330 ATCOs’ rostering system(s)
678 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF
METEOROLOGICAL SERVICES (Part-MET) - SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR
THE PROVISION OF METEOROLOGICAL
SERVICES (MET.OR) - Section 1 — General requirements - MET.OR.100 Quality of the data &
information
52 Alternative wording: accessible. The current term "attainable" is also acceptable and clear
enough.
690 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL
SERVICES (Part-MET) - SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL
SERVICES (MET.OR) - Section 1 — General
52 FOCA suggests to keep the wording of the currently applicable Annex 11, 6.4.1.2:
"Automatic recordings shall be retained for a period of at least thirty days. When the
recordings are pertinent to accident and incident investigations, they shall be retained for
longer periods until it is evident that they will no longer be required."
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Page Comment Attachments
requirements - MET.OR.105 Retention of information
698 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL
SERVICES (Part-MET) - SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) - Section 2 — Specific
requirements - Chapter 1 —
Requirements for meteorological watch offices - MET.OR.200 Watch and other meteorological
information
52 - 53
The definition of "meteorological watch office" in ICAO Annex 3 Chapter 3.4 is more
precise. Unlike ICAO Annex 3 MET.OR.200 does not cover all responsibilities of a
meteorological watch office . Therefore, FOCA suggests to use the ICAO Annex 3
definition.
700 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL
SERVICES (Part-MET) - SUBPART A —
ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL
SERVICES (MET.OR) - Section 2 — Specific
54 Content of ICAO Annex Chapter 3.3 g) "exchange meteorological information with other
meteorological offices" is missing / must necessarily be included.
Cmt# Segment description
Page Comment Attachments
requirements - Chapter 2 — Requirements for aerodrome meteorological offices - MET.OR.215
Forecasts and other meteorological
information — General
705 ANNEX IV - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (Part-MET) - SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR
THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) - Section 2 — Specific requirements -
Chapter 2 — Requirements for aerodrome meteorological offices - MET.OR.220 Aerodrome forecasts (TAF)
54 Suggestion: a) … expected meteorological conditions at an aerodrome and its vicinity for a
specified period. As the descriptor "VC" (in the vicinity) already exists, it would be more
practical.
706 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (Part-MET)
- SUBPART A — ADDITIONAL
54 ICAO Annex 3 Chapter 6.3.3 is missing / needs to be adapted accordingly (see
FOCA comment to GM2 MET.OR.225)
Cmt# Segment description
Page Comment Attachments
ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) - Section 2 — Specific
requirements - Chapter 2 —
Requirements for aerodrome meteorological offices - MET.OR.225
Aerodrome forecasts — Landing (TREND)
707 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF
METEOROLOGICAL SERVICES (Part-MET)
- SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF
METEOROLOGICAL SERVICES (MET.OR) - Section 2 — Specific requirements - Chapter 2 — Requirements for aerodrome
meteorological offices - MET.OR.230 Area forecasts for low-level flights
55 ICAO Annex 3 Chapter 6.5.2 is missing / should be adopted. GAMET and SIGWX are no
longer mentioned , FOCA suggests to include it.
708 ANNEX IV - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF
56 -
57 In comparison to ICAO Annex 3 Chapter 4.1.3 "Runway Visual Range (RVR)" is missing,
please adapt accordingly.
Cmt# Segment description
Page Comment Attachments
METEOROLOGICAL SERVICES (Part-MET) - SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR
THE PROVISION OF METEOROLOGICAL
SERVICES (MET.OR) - Section 2 — Specific requirements - Chapter 3 —
Requirements for meteorological stations - MET.OR.255 Observation of meteorological elements
710 ANNEX IV - SPECIFIC REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (Part-MET)
- SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) -
Section 2 — Specific requirements - Chapter 5 — Requirements for World Area Forecast Centre (WAFC) -
MET.OR.265 World
57 - 58
Content of ICAO Annex 3, Chapter 3.2 e) "to establish and maintain contact with VAACs
for the exchange of information on volcanic activity in order to coordinate the inclusion of
information on volcanic eruptions in SIGWX forecasts" is missing resp. should be included.
Cmt# Segment description
Page Comment Attachments
Area Forecast Centre (WAFC) responsibilities
711 ANNEX IV - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (Part-MET)
- SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) - Section 2 — Specific requirements -
Chapter 6 — Requirements for
Tropical Cyclone Advisory Centre (TCAC) - MET.OR.270 Tropical Cyclone Advisory Centre
(TCAC) responsibilities
58 Content of ICAO Annex 3, Chapter 3.7 a) "monitor the development of tropical cyclones in
its area of responsibility, using geostationary and polar-orbiting satellite data, radar data
and other meteorological information;" is missing resp. should be included.
714 ANNEX VII - SPECIFIC REQUIREMENTS FOR
THE PROVISION OF COMMUNICATION,
NAVIGATION, AND SUREVEILLANCE SERVICES (Part-CNS) - SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR
63 Please rephrase this paragraph. The use of references impairs the readability and could
eventually lead to omissions. Furthermore, FOCA would like to point to the following:
providers of communication, navigation and surveillance services are not necessarily air
traffic service providers (therefore ATS.OR.205 and ATS.OR.225 are not appropriate
references).
Cmt# Segment description
Page Comment Attachments
THE PROVISION OF COMMUNICATION, NAVIGATION, AND SURVEILLANCE SERVICES (CNS.OR) - Section 1 — General
requirements - CNS.OR.115 Safety of
services
712 ANNEX VII - SPECIFIC
REQUIREMENTS FOR THE PROVISION OF COMMUNICATION, NAVIGATION, AND SUREVEILLANCE SERVICES (Part-CNS)
- SUBPART B — TECHNICAL
REQUIREMENTS FOR THE PROVISION OF COMMUNICATION, NAVIGATION AND SURVEILLANCE
SERVICES (CNS.TR) - Section 1 — General requirements - CNS.TR.105 Working methods and operating procedures
63 - 64
We suggest to remove the requirements from Annex II and place them in this section to
improve readability.
716 ANNEX XII -
SPECIFIC REQUIREMENTS FOR ATM/ANS PROVIDERS REGARDING PERSONNEL
TRAINING AND COMPETENCE
69 Records should also be made available to the competent authority on request.
FOCA suggests to include a link to the already defined safety related systems in order to
define the training requirements based on the systems. Justification: This would ensure
that when a new system is introduced the training requirements for ATSEP would also
have to be defined.
Cmt# Segment description
Page Comment Attachments
ASSESSMENT REQUIREMENTS (Part-PERS) - SUBPART A — TECHNICAL AND ENGINEERING
PERSONNEL - Section 1 — Air Traffic Safety
Electronics Personnel - Chapter 1 — General - ATSEP.OR.015
Training and competence assessment programme
720 ANNEX XII -
SPECIFIC REQUIREMENTS FOR
ATM/ANS PROVIDERS REGARDING PERSONNEL TRAINING AND COMPETENCE
ASSESSMENT REQUIREMENTS (Part-PERS) - SUBPART A — TECHNICAL AND ENGINEERING PERSONNEL - Section
1 — Air Traffic Safety Electronics Personnel - Chapter 2 — Training requirements - ATSEP.OR.100 Training requirements
— General
69 -
70 The time element is missing / When should they have successfully completed the training
? There mustn't be any intervention on safety related systems until a training has been
successfully completed.
Cmt# Segment description
Page Comment Attachments
724 ANNEX XII - SPECIFIC REQUIREMENTS FOR ATM/ANS PROVIDERS REGARDING PERSONNEL
TRAINING AND COMPETENCE
ASSESSMENT REQUIREMENTS (Part-PERS) - SUBPART A —
TECHNICAL AND ENGINEERING PERSONNEL - Section 1 — Air Traffic Safety Electronics Personnel - Chapter 2 — Training requirements
- ATSEP.OR.110
Qualification training
70 This requirement is too detailed. ATSEP.OR.110 (b) could be considered guidance material
(GM). The focus should remain on the technical domain, human factor should be
addressed as a general requirement in the SMS.
739 ANNEX XII - SPECIFIC REQUIREMENTS FOR
ATM/ANS PROVIDERS REGARDING PERSONNEL TRAINING AND COMPETENCE ASSESSMENT REQUIREMENTS
(Part-PERS) - SUBPART A — TECHNICAL AND ENGINEERING PERSONNEL - Section 1 — Air Traffic Safety
Electronics Personnel
70 This requirement could be placed earlier in the requirement list of the proposed
regulation. Awareness of the potential safety impact at the operational level is extremely
relevant for the global safety.
Cmt# Segment description
Page Comment Attachments
- Chapter 2 — Training requirements - ATSEP.OR.115 System and equipment rating training
742 ANNEX XII - SPECIFIC
REQUIREMENTS FOR ATM/ANS PROVIDERS REGARDING
PERSONNEL TRAINING AND COMPETENCE ASSESSMENT REQUIREMENTS (Part-PERS) -
SUBPART A — TECHNICAL AND
ENGINEERING PERSONNEL - Section 1 — Air Traffic Safety Electronics Personnel - Chapter 2 —
Training requirements - ATSEP.OR.120 Continuation training
71 The use of the word "appropriate" should be avoided as it allows for interpretations
resp. possibilities are left open. The training should be performed with the objective to
maintain the required competences.
942 ANNEX XII - SPECIFIC
REQUIREMENTS FOR ATM/ANS PROVIDERS
REGARDING PERSONNEL TRAINING AND COMPETENCE ASSESSMENT
REQUIREMENTS (Part-PERS) -
71 ATSEP.OR.130 par. (a) (3): is unclear, what is the intention of this requirement?
Cmt# Segment description
Page Comment Attachments
SUBPART A — TECHNICAL AND ENGINEERING PERSONNEL - Section 1 — Air Traffic Safety Electronics Personnel
- Chapter 3 — Competence
assessment requirements - ATSEP.OR.130 Assessment of initial
and ongoing competence
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Title Requirements for ATM/ANS providers and the safety oversight thereof (Acceptable Means of Compliance (AMC) & Guidance Material (GM))
NPA Number NPA 2013-08 (C)
Federal Office of Civil Aviation FOCA ([email protected]) has placed 59 unique comments on this NPA:
Cmt# Segment description Page Comment Attachments
177 AMC/GM to ANNEX I — Requirements for competent
authorities in ATM/ANS (Part-
TM/ANS.AR) — SUBPART B — MANAGEMENT (ATM/ANS.AR.B) — AMC1 ATM/ANS.AR.B.005(a)(2) Management System
9 Need for harmonisation with ADR.AR.B.005
"The training programme should include ..//.. at least modules on following
elements:"
Cmt# Segment description Page Comment Attachments
178 AMC/GM to ANNEX I — Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART B —MANAGEMENT (ATM/ANS.AR.B) — GM1 ATM/ANS.AR.B.005(a)(2)
Management system
10 - 11
GM1 ATM/ANS.AR.B.005(a)(2); sufficient personnel: The expression "complexity of
activities" [under (b)(2)(i)] needs to be further detailed, by mentioning the relevant
factors determining the complexity (e.g. crossing runways, terrain, steep approaches
etc.)
The term "declared" is not clear to us. Does "declared" means the same as
"designated"?
179 AMC/GM to ANNEX I —
Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART B —
MANAGEMENT (ATM/ANS.AR.B) — AMC1 ATM/ANS.AR.B.010 Allocation of tasks to qualified entities
11 Need for harmonization with NPA-2011-20
180 AMC/GM to ANNEX I —
Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART B —
MANAGEMENT (ATM/ANS.AR.B) — GM1 ATM/ANS.AR.B.010 Allocation
of tasks to qualified entities
11 Need for harmonization with NPA-2011-20.
The GM does not seem to adress the two points contained in the corresponding AMC.
In addition, FOCA suggests to add a sentence on whether a qualified entity may
issue licences on behalf of the competent authority.
181 AMC/GM to ANNEX I — Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART C
— OVERSIGHT, CERTIFICATION, AND ENFORCEMENT
(ATM/ANS.AR.C) — GM1 ATM/ANS.AR.C.015 Oversight
11 Typo in the 2nd word -> "arrangements" instead of "arrangemnets"
The sentence is incorrec t, there must be a word missing.
183 AMC/GM to ANNEX I — Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART C — OVERSIGHT,
11 - 12
FOCA supports "OPTION 2", towards a performance-based oversight.
Within the requirements and AMC terms like schedule, programm and plan are used.
FOCA suggests to use always the same term, in order to avoid confusion (e.g. use
"programme").
Cmt# Segment description Page Comment Attachments
CERTIFICATION, AND ENFORCEMENT (ATM/ANS.AR.C) — AMC1 ATM/ANS.AR.C.015(c) Oversight
185 AMC/GM to ANNEX I — Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART C
— OVERSIGHT, CERTIFICATION, AND ENFORCEMENT
(ATM/ANS.AR.C) — GM1 ATM/ANS.AR.C.020 Changes to ATM/ANS providers
12 Subpart (b) (2)
The specification of 10 days is not necessary, since this is already a part of the
procedure to be established. The timeframe necessary to confirm the non-approval
may differ from state to state. Moreover, it shall be reserved to the authority if an
acknowledgement is necessary or not.
Subpart (c ):
The meaning is unclear. The NSA may perform audits on providers compliance at all
times and on all subjects regardless if this is subject to a change. It is assumed that
the audit needs to be conducted after the change implementation. In this regard, it
shall be verified whether the provider is compliant with the approved change
baseline rather than the regulatory requirements. Therefore, provide improved
guidelines in GM or clarify in EXP notes.
186 AMC/GM to ANNEX I —
Requirements for competent authorities in ATM/ANS (Part-TM/ANS.AR) — SUBPART C — OVERSIGHT, CERTIFICATION, AND ENFORCEMENT (ATM/ANS.AR.C) — GM1
ATM/ANS.AR.C.025 Findings, corrective actions, and enforcement measures
12 -
13 Documentary evidence may include:
Replace “inspection records and internal audit results” with “internal quality control
results (inspection, audit and tests)
Justification:
Quality Control consists of three different methods (inspections, audits and tests). All
three methods are considered to be internal quality control activities.
FOCA suggests to add to (c) the following:
staff recruitment (pre-employment check or background check)
187 AMC/GM to ANNEX II —
General organisation
common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART A — GENERAL COMMON REQUIREMENTS (ATM/ANS.OR.A) — AMC1
18 -
19 The subpart (b) refers to "any other change" which inherently includes also "changes
to functional systems". It is highly recommended to combine the section
ATM/ANS.AR.C.020 and ATM/ANS.OR.A.035. The current separation is artificial and
readability and comprehensivness is strongly compromised.
Cmt# Segment description Page Comment Attachments
ATM/ANS.OR.A.035(b) Changes
188 AMC/GM to ANNEX II — General organisation common requirements for
the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART A — GENERAL COMMON REQUIREMENTS
(ATM/ANS.OR.A) — GM1 ATM/ANS.OR.A.035(b) Changes
19 The subpart (b) refers to "any other change" which inherently includes also "changes
to functional systems". It is highly recommended to combine the section
ATM/ANS.AR.C.020 and ATM/ANS.OR.A.035. The current separation is artificial and
readability and comprehensivness is strongly compromised.
190 AMC/GM to ANNEX II — General organisation common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) —
SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1 ATM/ANS.OR.B.015
Management system
20 - 21
Replace should with may "An EN ISO 9001 certificate, issued by an appropriately
accredited organisation, addressing all the elements required in this Subpart
[should] may be considered as a sufficient...] to give States the empowerment to
review and audit ANSP's QMS. The current requirement in EU1035/2011 is
interpreted in different ways.
194 AMC/GM to ANNEX II —
General organisation common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1
ATM/ANS.OR.B.015(a)(1) Management system
21 This GM belongs to "Organisation structure" as far as the definition of resp. /
account. is concerned
196 AMC/GM to ANNEX II —
General organisation common requirements for
the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — AMC1
21 -
22 (iv) "….which would not have been otherwise detected" This is a very stringent
formulation. Is the employee to be punished if the circumstance may have been
detected otherwise?
Suggestion: "......which supports the ANSP to improve the safety levels of its
provision"
Cmt# Segment description Page Comment Attachments
ATM/ANS.OR.B.015(a)(2) Management system
198 AMC/GM to ANNEX II — General organisation common requirements for
the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — AMC1
ATM/ANS.OR.B.015(a)(3) Management system
22 (3) the terminology in this subparagraph should be in line with the terminology to be
used in ATM/ANS.OR.A.040. "(Safety) Reviews" have been used until today as the
means to judge whether a change to a functional system is safe for operation.
199 AMC/GM to ANNEX II — General organisation common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT
(ATM/ANS.OR.B) — GM1 ATM/ANS.OR.B.015(a)(3) Management system
24 - 25
FOCA is of the opinion that this GM does not sufficiently support the competent
authorities. FOCA would like to see more specific guidance material on the
procedure and on the implementation requirements for an ANSP in order for the
authorities to be able to monitor their performance. Furthermore, it may be
considered to define a certain set of minimum performance indicators which shall
be applicable throughout the EU system.
200 AMC/GM to ANNEX II — General organisation
common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — AMC1 ATM/ANS.OR.B.015(a)(7)
Management system
26 The NPA cover regulation (ATM/ANS.OR.B.015) (a)(7) is more detailled than the
AMC.
Suggestion: Take existing AMC text as cover regulation text and vice-versa.
Senior management should ensure that appropriate communication processes are
established within the ATM/ANS provider and that communication takes place
regarding the effectiveness of the management system. Maintain appropriate records
regarding the effectiveness of the communication incl. feedback from the personnel.
201 AMC/GM to ANNEX II — General organisation
common requirements for the provision of ATM/ANS
(Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — AMC1 ATM/ANS.OR.B.015(c) Management system
26 - 28
Replace "compliance monitoring should" with "compliance monitoring shall"
(otherwise the compentent authorities do not have the necessary empowerment).
Cmt# Segment description Page Comment Attachments
202 AMC/GM to ANNEX II — General organisation common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1
ATM/ANS.OR.B.015(c) Management system
28 - 29
Replace "compliance monitoring should" with "compliance monitoring shall"
(otherwise the compentent authorities do not have the necessary powers).
203 AMC/GM to ANNEX II — General organisation common requirements for
the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — AMC1 ATM/ANS.OR.B.015(d) Management system
29 The AMC introduces the word "complex" which is not addressed in the cover
regulation in this ATM/ANS.OR.B.015(d). It is not clear what impact the definition of
complex ANS/ATS, etc. has on the size and nature of the management system.
Furthermore, the terminology complex ANSP is only provided in this section but
referred to in earlier section (page 27). In general, the proportionality of the
management system versus the size and complexity of the ANSP shall not be
regulated since this shall be driven by the requirement the ANSP has towards its own
management system.
204 AMC/GM to ANNEX II — General organisation
common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) —
SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1 ATM/ANS.OR.B.015(d) Management system
29 Table 1 ASM/ATFM/ASD/DAT Criteria to be complied with (to be considered as not
complex) - Workforce of 20 or less FTE's for each service or in total?
205 AMC/GM to ANNEX II —
General organisation common requirements for the provision of ATM/ANS
(Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1 ATM/ANS.OR.B.020
Contracted activities
30 (a - c) shall instead of should. Justification: It is essential that action (a) - (c) are in
the activity plan of the ATM / ANS provider
206 AMC/GM to ANNEX II — General organisation
30 (a) please specify "ensure complinace montioring". How often should that take
place?
Cmt# Segment description Page Comment Attachments
common requirements for the provision of ATM/ANS (Part-ATM/ANS.OR) — SUBPART B — MANAGEMENT (ATM/ANS.OR.B) — GM1 ATM/ANS.OR.B.020 Contracted activities
211 AMC/GM to ANNEX III — Specific requirements for the
provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205 Safety
management system
31 The distinction between complex and non complex ANSP is introduced in the AMC
only.
The intentions of the cover regulation and the AMC seems to be inconsistent.
ATM/ANS.OR.B.015 lit.(d) describes perfectly the intention of EASA, which FOCA
fully supports, i.e. the SMS should be set up proportionate to any provider's
essential organisational parameters (whereof complexity might be one of them).
Defining only two categories in the AMC and focussing on complexity would only be
equal to a "digital" solution not complying with the basic idea.
FOCA suggests not to divide ANSP's into two categories (complex/ non-
complex) with regard to the definition of the SMS.
214 AMC/GM to ANNEX III —
Specific requirements for the provision of air traffic
services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section
2 — Safety of services — AMC1 ATS.OR.205(a)(1)(i) Safety management system
31 -
32 lit. b (5): In FOCA's opinion, this statement is misleading. Here it means that no one
is to blame for reporting something which is not known to the company.
Consequently, this means that someone might be blamed when reporting anything
known to the company, which does not make sense. The primary intention behind
this concept was probably not to blame someone for her/his possible error/violation
reported by herself/himself (except acts based on gross negligence).
NB: On the other hand, the contrary argument is missing. As an employee I would
also appreciate a statement of my company that it will not tolerate any acts or
behaviour which are based on gross negligence according to their definition.
Rephrase sentence as follows:
(5) not to blame someone for a possible error or violation reported by the person
concerned (except acts based on gross negligence).
...or likewise.
218 AMC/GM to ANNEX III — Specific requirements for the
32 FOCA supports especially the idea of lit. (b).
Cmt# Segment description Page Comment Attachments
provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section
2 — Safety of services — GM1 ATS.OR.205(a)(1)(i)
Safety management system
215 AMC/GM to ANNEX III — Specific requirements for the
provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC
SERVICES (ATS.OR) Section 2 — Safety of services —
GM1 ATS.OR.205(a)(1)(ii);(iii);(iv)
32 FOCA does not agree with the statements referrint "to be considered as safety
objectives". Those provisions explain how the ANSP is planning to meet their safety
objectives (to ensure). Only lit.(iv) implicitly defines one major safety objective, e.g.
to minimise its contribution to the risk of an aircraft accident as far as reasonably
practicable.
224 AMC/GM to ANNEX III —
Specific requirements for the provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC
SERVICES (ATS.OR) Section 2 — Safety of services —
GM3 ATS.OR.205(a)(2) Safety management system
34 Why is "should" used instead of "shall"?. Furthermore we were not able to find the
specific description of the meaning of complexity with regard to ANSP. FOCA would
like to add that "small" doesn't always have to correspond with "not complex".
221 AMC/GM to ANNEX III —
Specific requirements for the provision of air traffic services (Part-ATS) —
34 What is the reason for the use of "should" (instead of "shall")?
Cmt# Segment description Page Comment Attachments
SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205(a)(3)
Safety management system
228 AMC/GM to ANNEX III —
Specific requirements for the provision of air traffic services (Part-ATS) —
SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services —
AMC1 ATS.OR.205(a)(3) Safety management system
34 Is there a specific reason why "should" is used (instead of "shall")?
231 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic
services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services —
AMC1 ATS.OR.205(a)(4) Safety management system
34 - 35
lit.(b) refers to risk management, which FOCA supports. But we assume that the
scope is meant as safety risk management only, which is quite a different thing.
236 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic
services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION
35 - 36
FOCA wonders about focussing only on the (obviously) popular leading and lagging
indicators scheme. Although this might be right, we would expect, that especially in
the GM, safety assurance should be explained a little more "hands on".
This can be explained with the following examples:
1. After setting up a SMS with all components, safety assurance means to ensure,
that people will work accordingly to the SMS. This might look like a simple quality
Cmt# Segment description Page Comment Attachments
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — GM1 ATS.OR.205(c) Safety management system
management task. Actually, internal audit und QMS are possible tools for this step of
safety assurance.
2. If risk management is properly defined, risk controls (perfromance indicators) are
defined and monitored; that means leading and lagging indicators are in place; not
due to safety assurance but based on proper risk management.
To assure application of the whole SMS is one major safety assurance task,
this however this is not mentioned.
237 AMC/GM to ANNEX III —
Specific requirements for the provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205(c)(1)(i) Safety management system
37 Although the expression "safety survey" has also been used in the EU/1035,
EU/1034 it not clear to us what the ultimate objective of the survey is. Which
minimum deliverables do fall in the scope of a survey?
The survey description in (c ) only states content requirements which are necessary
to obtain a document with a proper structure. No indication is given on the survey
content or on procedures.
238 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — GM1 ATS.OR.205(c)(1)(i) Safety management system
38 Although the expression "safety survey" has also been used in the EU/1035/2011,
EU/1034/2011 it not clear tous what the ultimate objective of the survey is. Which
minimum deliverables do fall in the scope of a survey?
The survey description in (c ) only states content requirements which are necessary
to obtain a document with a proper structure. No indication is given on the survey
content or on procedures.
239 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL
ORGANISATION
38 - 39
This is not wrong but it belongs more to risk management than to safety assurance;
depending on how those are defined.
The description in this section is not very helpful. The terminology "functional
system" stems from the EU/1035 and EU/1035 and causes confusion. It is not
entirely clear what a "functional system" consists of in practice or what the
Cmt# Segment description Page Comment Attachments
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — GM1 ATS.OR.205(c)(1)(ii) Safety Management system
philosophy behind the term is. Moreover the Guidance needs also to be included in
the section ATM/ANS.OR.A.040 (changes to functional systems) which is still to be
developped.
240 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic
services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205(c)(1)(iii) Safety management system
39 It's obvious at this place that the SMS framework does not consider risk
management as a primary function of an SMS. Otherwise a hazard or risk library
containing information about all functions provided by the ANSP would be listed at
first position.
As already stated previously, safety objectives are in our opinion not a record, but a
target level.
241 AMC/GM to ANNEX III — Specific requirements for the
provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL
ORGANISATION REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205(c)(1)(iv) Safety management system
39 This statement is misleading, because the contrary argument would suggest that all
occurrences reported to the authority must be internally investigated. An ANSP
must investigate any occurrence which is related to the function of its SMS or its
safety performance. Especially ANSP's have to report many occurrences to the
authority, which have little or nothing to do with their performance, i.e. Airspace
Infringements, Level busts, Prolonged loss of communications (PLOC), etc.). Those
occurrences shall be reported by the ANSP but the further investigation lies with
other parties (i.e. authority).
Proposal: "The scope of internal safety investigations does not necessarily
correspond with the scope of occurrences required to be reported to the competent
authority."
396 AMC/GM to ANNEX III — Specific requirements for the
provision of air traffic services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE
40 The measurement of SMS effectivness is very challenging. Without giving any details
regarding "substandard performance" it leaves an extensive room for interpretation
on what and how to measure effectivness. This leaves the ANSP's and competent
authorities without a standardized pan-european approach (a)-(c ) and every
Member State might have a different understanding on the performance parameters.
Where is the link with the European performance scheme?
Cmt# Segment description Page Comment Attachments
PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — AMC1 ATS.OR.205(c)(2) Safety management system
254 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic services (Part-ATS) —
SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE
PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 2 — Safety of services — GM1 ATS.OR.205(d)(2)(3)(4) Safety management system
41 - 42
b.1.ii provides the term "safety critical". There is no definition of this term in the
cover regulation of this NPA. Please provide definition.
Justification: Different interpretations of the term could provoke misunderstandings
between ANSPs and/or competent authorities which can potentially lead to risk
situations.
256 AMC/GM to ANNEX III — Specific requirements for the provision of air traffic
services (Part-ATS) — SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF AIR TRAFFIC SERVICES (ATS.OR) Section 3 — Human factors: principles for the provision of air traffic control (ATC) services — AMC1
ATS.OR.315(b) Responsibilities of providers
of ATC services with regard to problematic use of psychoactive substances by ATCOs
43 - 44
A process shall be established by the ANSP for the detection of such cases. Possibly
the help of medical staff is required to fulfill this task (especially for the testing
process). Personnel and/or medical data shall be kept safe.
300 AMC/GM to ANNEX IV — Specific requirements for the
57 ICAO Annex 3 Chapter 6.3.3 is transposped in the GM. FOCA suggests to include it in
MET.OR.225
Cmt# Segment description Page Comment Attachments
provision of meteorological services (Part-MET) — SUBPART A — ADDITIONAL ORGANISATION REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES
(MET.OR) — Section 2 — Specific requirements —
Chapter 2 — Requirements for aerodrome meteorological offices — GM2 MET.OR.225 Aerodrome forecasts —
landing (TREND)
304 AMC/GM to ANNEX IV — Specific requirements for the provision of meteorological services (Part-MET) —
SUBPART A — ADDITIONAL ORGANISATION
REQUIREMENTS FOR THE PROVISION OF METEOROLOGICAL SERVICES (MET.OR) — Section 2 — Specific requirements —
Chapter 2 — Requirements for aerodrome meteorological offices — AMC1 MET.OR.235(b) Warnings and alerts
57 The calculation is correct. 7.5 m/s equal 27 km/h. However, the calculation does not
correspond with ICAO Annex 3 chapter 7.4.3 (30 km/h). Calculation in ICAO Annex
3 is apparently incorrect. Please check with ICAO.
309 AMC/GM to ANNEX XII — Specific Requirements for
ATM/ANS providers regarding personnel training and competence assessment — SUBPART A — TECHNICAL AND ENGINEERING
ELECTRONIC PERSONNEL — Section 1 — Air traffic safety
59 The entity issuing the authorisation should be defined.
Cmt# Segment description Page Comment Attachments
electronics personnel (ATSEP) — Chapter 1 — General — GM1 ATSEP.OR.005(b) Scope
310 AMC/GM to ANNEX XII —
Specific Requirements for ATM/ANS providers regarding personnel training and competence assessment —
SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL —
Section 1 — Air traffic safety electronics personnel (ATSEP) — Chapter 1 — General — GM1 ATSEP.OR.015(a) Training and competence assessment
programme
60 Has the follow-up training been considered? Maintain the knowledge or ensure
competency when new technology is introduced in the safety related system.
311 AMC/GM to ANNEX XII —
Specific Requirements for ATM/ANS providers regarding personnel training and
competence assessment — SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL — Section 1 — Air traffic safety electronics personnel (ATSEP) — Chapter 1 —
General — AMC1 ATSEP.OR.020 Language
proficiency
60 Unclear level or proficiency requirements. The level of language proficency could also
correlate with the safety criticality of the system the ATSEP will need to work with.
315 AMC/GM to ANNEX XII — Specific Requirements for
ATM/ANS providers regarding personnel training and competence assessment —
63 Reference to Appendix 3a to Annex XI is incorrect → Typo
Cmt# Segment description Page Comment Attachments
SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL — Section 1 — Air traffic safety electronics personnel (ATSEP) — Chapter 2 — Training requirements —
AMC1 ATSEP.OR.110 Qualification training
317 AMC/GM to ANNEX XII — Specific Requirements for ATM/ANS providers regarding
personnel training and competence assessment — SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL — Section 1 — Air traffic safety
electronics personnel (ATSEP) — Chapter 2 —
Training requirements — AMC1 ATSEP.OR.110(a) Qualification training
63 Reference to Appendix 4a to Annex XI is wrong → Typo
319 AMC/GM to ANNEX XII — Specific Requirements for ATM/ANS providers regarding personnel training and competence assessment — SUBPART A — TECHNICAL AND ENGINEERING
ELECTRONIC PERSONNEL — Section 1 — Air traffic safety
electronics personnel (ATSEP) — Chapter 2 — Training requirements — GM1 ATSEP.OR.110(a) Qualification training
63 It is unclear if the ANSP can configure the streams itself. Depending on the size and
the service provided, etc the ANSP could combine or add additional streams.
Cmt# Segment description Page Comment Attachments
321 AMC/GM to ANNEX XII — Specific Requirements for ATM/ANS providers regarding personnel training and competence assessment — SUBPART A — TECHNICAL AND ENGINEERING
ELECTRONIC PERSONNEL — Section 1 — Air traffic safety
electronics personnel (ATSEP) — Chapter 2 — Training requirements — GM1 ATSEP.OR.115 System
and equipment rating training
66 Please add a definition for rating in this context (at the beginnig of the regulation).
322 AMC/GM to ANNEX XII — Specific Requirements for ATM/ANS providers regarding
personnel training and competence assessment —
SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL — Section 1 — Air traffic safety electronics personnel
(ATSEP) — Chapter 2 — Training requirements — GM1 ATSEP.OR.120 Continuation training
66 It migth be of added value to clearly state in the requirement that the knowledge
should be upgraded and reenforced.
323 AMC/GM to ANNEX XII —
Specific Requirements for ATM/ANS providers regarding
personnel training and competence assessment — SUBPART A — TECHNICAL AND ENGINEERING ELECTRONIC PERSONNEL —
Section 1 — Air traffic safety electronics personnel
67 The ATSEP role does not permit the safe and efficient provision of the service. ATSEP
role is to ensure that the safety related systems work properly in order to provide
safe and efficient ATM/ANS. Please change wording.
Cmt# Segment description Page Comment Attachments
(ATSEP) — Chapter 3 — Competence assessment requirements — GM1 ATSEP.OR.125(a) Competence assessment — General
402 AMC/GM to ANNEX XII — Specific Requirements for ATM/ANS providers regarding
personnel training and competence assessment — SUBPART A — TECHNICAL
AND ENGINEERING ELECTRONIC PERSONNEL — Section 1 — Air traffic safety electronics personnel (ATSEP) — Chapter 3 — Competence assessment
requirements — GM1 ATSEP.OR.130(a)(1)
Assessment of initial and ongoing competence
67 unclear provision
328 APPENDIX 1a to ANNEX XII 69 -
73
AMC1
ATSEP.OR.105(a)(1)
2. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 69, in AMC / GM
What if it is not
a national
organisation?
It might be more
appropriate to
leave this open to
any ATM/ANS
organisation
AMC1
ATSEP.OR.105(a)(1)
3. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 69 - 70, in AMC /
GM
Unions should
not be mentioned
in an AMC.
Cmt# Segment description Page Comment Attachments
AMC1
ATSEP.OR.105(a)(1)
4. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 70, in AMC / GM
The example for
the key roles are
not the
qualification or
training.
A clear
description of the
role of the
ATSEP within the
ATM/ANS
should be given
with emphasis on
the safety aspect.
AMC1
ATSEP.OR.105(a)(1)
5. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 70, in AMC / GM
1.5.3: What is
the purpose to
have multiple
bodies?
AMC1
ATSEP.OR.105(a)(1)
8. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 71, in AMC / GM
This section
should include
the explanation
on what is
quality
management
AMC1
ATSEP.OR.105(a)(1)
10. SUBJECT 1:
INDUCTION —
TOPIC 1: BASIND
Page 71, in AMC / GM
Is this means
as the title?
There is no
related AMC
below
Subject 2: AIR
TRAFFIC
FAMILIARISATION
Cmt# Segment description Page Comment Attachments
AMC1
ATSEP.OR.105(a)(1)
AMC1
ATSEP.OR.105(a)(1)
2. SUBJECT 2:
AIR TRAFFIC
FAMILIARISATION
— TOPIC 1: BASATF
Page 72, in AMC / GM
This section is
appropriate but
the reason to
perform ATC
should be given
as well
332 APPENDIX 2a to ANNEX XII 74 - 90
AMC6
ATSEP.OR.105(a)(2)
11. SUBJECT 6:
NAVIGATION —
TOPIC 1:
BASNAV
Page 81 - 82, in
AMC / GM
Incorrect
terrminology
B-RNAV should
be RNAV-5 and
P-RNAV should
be RNAV-1
AMC6
ATSEP.OR.105(a)(2)
12. SUBJECT 6:
NAVIGATION —
TOPIC 1:
BASNAV
Page 82, in AMC /
GM
Wrong numbering
of AMC
Subject 7:
SURVEILLANCE
AMC7
ATSEP.OR.105(a)(2)
1. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
What about the
precision of the
entire system?
It is important to
be aware of the
precision of the
system. The
Cmt# Segment description Page Comment Attachments
Page 82, in AMC /
GM
nominal separation
can differ reality.
AMC7
ATSEP.OR.105(a)(2)
2. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 82, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
3. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 82 - 83, in
AMC / GM
NIL
AMC7
ATSEP.OR.105(a)(2)
4. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 83, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
5. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 83, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
6. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
NIL
Cmt# Segment description Page Comment Attachments
Page 83 - 84, in
AMC / GM
AMC7
ATSEP.OR.105(a)(2)
7. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 84, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
8. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 84, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
9. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 84, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
10. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 84, in AMC /
GM
NIL
AMC7
ATSEP.OR.105(a)(2)
11. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
NIL
Cmt# Segment description Page Comment Attachments
Page 85, in AMC /
GM
AMC7
ATSEP.OR.105(a)(2)
12. SUBJECT 7:
SURVEILLANCE
— TOPIC 1:
BASSUR
Page 85, in AMC /
GM
NIL
Subject 8: DATA
PROCESSING
AMC8
ATSEP.OR.105(a)(2)
1. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 85, in AMC /
GM
NIL
AMC8
ATSEP.OR.105(a)(2)
2. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 85, in AMC /
GM
NIL
AMC8
ATSEP.OR.105(a)(2)
3. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 86, in AMC /
GM
Is 1.3.5 really about
data processing?
Cmt# Segment description Page Comment Attachments
AMC8
ATSEP.OR.105(a)(2)
4. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 86, in AMC /
GM
NIL
AMC8
ATSEP.OR.105(a)(2)
5. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 87, in AMC /
GM
NIL
AMC8
ATSEP.OR.105(a)(2)
6. SUBJECT 8:
DATA
PROCESSING —
TOPIC 1: BASDAT
Page 87, in AMC /
GM
Flow managment
tool if any should be
added (traffic
prediction tool)
Requirement for
sectorisation etc...
337 APPENDIX 3a to Annex XII 91 - 98
AMC1
ATSEP.OR.110
1. SUBJECT 1:
SAFETY — TOPIC 1:
SAFETY MANAGEMENT
Page 91, in AMC / GM
Missing link to information /
requirements based on new ICAO
Annex 19
AMC1
ATSEP.OR.110
2. SUBJECT 1:
SAFETY — TOPIC 1:
SAFETY MANAGEMENT
Page 91 - 92, in AMC / GM
Missing link to information /
requirements based on new ICAO
Annex 19
AMC1
ATSEP.OR.110
3. SUBJECT 1:
SAFETY — TOPIC 1:
Missing link to information /
requirements based on new ICAO
Annex 19
Cmt# Segment description Page Comment Attachments
SAFETY MANAGEMENT
Page 92, in AMC / GM
AMC1
ATSEP.OR.110
4. SUBJECT 1:
SAFETY — TOPIC 1:
SAFETY MANAGEMENT
Page 92, in AMC / GM
Missing link to information /
requirements based on new ICAO
Annex 19
341 APPENDIX 4a to Annex XII 99 -
184 3. NAVIGATION —
NON-DIRECTIONAL
BEACON (NDB)
The navigation streams of the
qualification training (Appendix
4 to Annex XII) need to be
restructured.
GBAS Stations should
become an independent
stream (like ILS and
MLS)
342 APPENDIX 4a to Annex XII 99 - 184
Subject 1:
SECONDARY
SURVEILLANCE
RADAR (SSR)
Multilateration should become
an independant stream.
The following is missing in the
NPA:
Part of Service: Provision of
data from Multilateration
(MLAT)
Subpart of Service: Wide Area
Multilateration (WAM) &
Local Area Multilateration
(LAM)
Multilateration (MLAT) is a
mature technologie wich is
already in use and some
Mulitlateration in not
necessarily based on SSR
(it can also be solely based
based on ADS-B Out).
Cmt# Segment description Page Comment Attachments
implementation projects have
been started.
343 APPENDIX 4a to Annex XII 99 - 184
AMC10
ATSEP.OR.110(a)
3. SUBJECT 1:
SECONDARY
SURVEILLANCE
RADAR (SSR) — TOPIC
3: MULTILATERATION
Multilateration
should become
an independent
stream.
Multilateration is
not necessarily
based on SSR (it
can also be solely
based based on
ADS-B Out).
344 APPENDIX 4a to Annex XII 99 - 184 AMC12
ATSEP.OR.110(a)
7. SUBJECT 4: DATA
PROCESS — TOPIC 1:
SOFTWARE PROCESS
1.4.2 Not clear what is meant
by the 2nd software
development process
AMC12
ATSEP.OR.110(a)
8. SUBJECT 4: DATA
PROCESS — TOPIC 2:
HARDWARE PLATFORM
Should the interoperability
requirements be included in
this subject?
345 APPENDIX 4a to Annex XII 99 -
184 AMC13
ATSEP.OR.110(a)
9. SUBJECT 5: SMC — ANS
STRUCTURE — TOPIC 3: ATM
CONTEXT
AFTCM can be
confused with
ATFCM
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