task number task title commenter comment easa … · the agency confirms that no further documents...

CRD on comments to 4-Year RMP 2014-2017

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Task Number Task Title Commenter Comment EASA Response

General comment FOCADocument provided via email

Noted

General comment Mr Nemecek

RAG Member for Slovakia"no comment" Noted

General comment Mr Regan

ADR & ATM/ANS TAG member for Ireland

"no comment" Noted

General comment ADR TAG meeting of 20 June 2013

no comments made, RMP accepted and confirmed Noted

General comment Mr Meerman

ADR subSSCC reportSSCC Member

RMP should better display horizontal involvement of all possible tackled domains and stakeholders

The column "affected rules" is purposed to facilitate identifying the domains potentially affected by the task. Additional information on affected rules and stakeholders are provided in the pre-RIA, ToR and the subsequent deliverables (see new cover page template).

General comment 2Mr Philippe De Gouttes

D&M subSSCC report SSCC MemberSub-SSCC provided input prior to the June meeting. This input has already been considered in drafting the RMP 2014-17.

Noted

General comment 3Mr Philippe De Gouttes

D&M subSSCC report SSCC Member

The EAB expressed the need to make sure that safety-related tasks priorities in the rulemaking programme are consistent with the priorities set in the EASp.The rulemaking programme (and its preparatory documents) should show an explicit traceability from the safety-related RM task upstream to the EASp items (e.g. in “Driver” column).

3 tasks identified as candidates for outsourcing:- RMT.0285/0286, Active RFID;- Engine endurance testing;- CS-25 Cyber Security– -Recognized need to address data security;– -Cannot be done under routine “omnibus” NPA, due to complexity and possible controversy.These proposals to be further developed by industry i.a.w. EASA stakeholder-led process.

Consistency with EASp is ensured by internal consultation. Explicit links to EASp themes/issues may be provided.The proposals for outsourced tasks are acknowledged. The planning of the task on RFID is advanced provisionally and awaiting a concrete proposal for an industry group. The task on engine endurance testing is merged with the task on Initial Maintenance Inspection and also awaiting a concrete proposal for an industry group. The task on CS-25 cyber security will have to be included in the planning, starting with a pre-RIA.

General comment 4Mr Pablo Ulíbarri RamosTAG ATM/ANS Member

199 rulemaking projects need a careful complexity management and a sound level of resources. I understand this has already been considered when preparing the draft RMP but it still poses a noticeable risk to its fulfillment.

Noted


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General comment 6 pertaining to ADR topics Mme Carole Lenck, DGAC

The program indicates year 2012 or 2013 as a starting date for all aerodrome-related tasks. However, except the group on apron management services which has already started, and the DP on RFFS which was sent today, no documents (ToR, concept papers, group composition...) seem to be available yet. Could we have confirmation that no other document has already been published, and that the groups have not started yet (except the group on AMS) ?

The Agency confirms that no further documents on ADR related tasks have been disseminated. Documents such as ToR and concept paper are related to the implementation of the actual task - not to the annual revision of the Rulemamking Programme.

General comment 7 pertaining to CS-25 tasksPatrick Debuchy, IATA, AEA

SSCC Member

The AEA and IATA take note that EASA has a large amount of planned rulemaking projects related to new aircraft certification (CS-25). The AEA and IATA believe there is a need to better prioritize those tasks in collaboration of the affected industry stakeholders. Moreover, the AEA and IATA would like to stress the importance to allocate sufficient EASA resources for those rulemaking task which were identified as top priority by the AEA and IATA (see earlier in this document).

The number of CS-25 rulemaking tasks is high but the Agency is using different methods to cope with these tasks, with limited resources. One method is the concept of omnibus NPAs, allowing the introduction of several non-related, non-controversial issues in one task. The other method is outsourcing of tasks to industry lead groups. In general the Agency allocated its resources to the priority tasks as identified in the rulemaking planning exercise. It takes into account the priorities and comments from all stakeholders

General comment 8 pertaining to ATM/ANSPatrick Debuchy, IATA, AEA

SSCC Member

With regard to various rulemaking tasks in the field of ATM/ANS, AEA and IATA understand that EASA has a legal obligation to transfer the existing SES ATM safety rules into the EASA framework. In this context, AEA and IATA would like to stress the importance for EASA not to reinvent the wheel (i.e. copy and paste the existing rules into the EASA framework without altering their technical content). There is no safety justification for a change in applicable ATM safety regulations.

The comment is duly considered. Moreover, according to Article 8b (6) and (7) of Regulation No 216/2008 the measures necessary for the implemntation of this Article shall be developed using as far as practicable the relevant provisions of SES. At the same time the Agency wishes to note that many of those safety regulations were developed more than 10 years ago and therefore may well contain aspects of careful scrutiny.


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General comment 9Pierre Moreillon, ERAC

SSCC member

a) Mr. Goudou stated that “regulations are there for the industry” and “your priorities will be ours”. I recommend the allocation of priorities in the RMT to be as flexible as possible for various reasons: not only are some external triggers out of control of the SSCC (new regulatory material stemming from ICAO, for instance), but the maturity of some projects should allow a prioritization review of RMTs during the validity period of the RMP in the interest of a competitive position of the European aerospace industry (the SoA issue for instance, RMT 0396 /0488, which I mentioned during the meeting of the SSCC, should be ready to be activated as soon as the interest for having a known regulatory framework exists).

b) Mr. Goudou’s words “the system is too complex” and “simplify, simplify, simplify” underlined a vision which, in my opinion, should lead to an action within the scope of cooperation between EASA and the stakeholders. This process could take place in connection with the ongoing EASA review process according to Art. 62 BR. As long as simplification is restricted by the existence of a BR or an ER and the related RMTs no longer undergo a RIA for this reason, a feedback loop could be helpful to induce corrective action of the BR or the ER, at political level, when the Rulemaking process within EASA leads to the conclusions which Mr. Goudou has expressed in such a clear way.

c) The stakeholders would for sure appreciate the allocation of RMTs to specific domains (ADR, FS, etc…) through a process identifying at early stage horizontal effects on all possible stakeholders, displaying these effects and including the respective stakeholders in the Rulemaking process. A publication process of the draft RMP enabling stakeholders who are not represented in the SSCC could offer a solution ensuring broad access and inputs into the rulemaking programming process.

Noted


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General comment 10CANSO sent on behalf of Vanessa

Rullier by Andrea Gartemann

CANSO desires that any proposed rules demonstrate a clear benefit in providing additional detail over and above that is already provided in the Essential Requirements. Any proposed rules are focused on maintaining and improving Safety. The effort to fulfill the regulatory requirements should be proportionate to the resulting safety benefit. A proper regulatory impact assessment including cost- and safety-benefit analysis must be carried over to justify any new rule. CANSO asks for a deeper consultation and involvement of stakeholders in the rulemaking preparatory and decision processes led by EASA, especially in the development of the European Aviation Safety Plan (EASp). CANSO would also welcome feedback from standardization inspections. The European ATM/ANS sector has been subject to major regulatory changes over the recent years. The setting-up of the recent SES rules has represented a significant amount of efforts and resources for ANSPs, and the implementation of these rules also incurs and will incur costs. This is why any new proposed rules must be proportionate and fully justified by real safety needs. CANSO recommends EASA to continue to improve: 1. the prioritisation and the project management of its rulemaking tasks 2. its experience in the ATM sector. CANSO supports the harmonisation of the SES and EASA frameworks and considers that this is not necessarily achieved through the setting-up of additional rules. Harmonisation through commonly accepted standards and practices, for safety and organization management systems and through the respect of human factors is a supportive, high-level goal. This is likely to be better achieved by introducing agreed concepts and methods rather than a new regulation. ANSPs are acutely aware of the need to deliver safety, and do not require regulation for every aspect of their business. Of Course, safety

Noted

General comment 11Fiona Lombardi, ATM/ANS Member for

Switzerland

Frankly, I have some difficulties towards getting the information that are relevant to my area of expertise. As a member of the ATM/ANS TAG, in order to prepare the upcoming meeting, I would appreciate a more focused overview of the rulemaking program 2014-17 covering the ATM/ANS field.

EASA submitted an excellent paper (see attachment) to SSC 49. I am wondering if this wouldn’t be a better tool to discuss the ongoing activities as well as the next steps. Is this document still up-to-date? Do you have a more recent version?

Additionally, I notice that most of the activities mentioned in chapter 2 “Agency’s Rulemaking programme” of the that document are not even mentioned in the Excel Matrix “Draft 4 year RM programme 2014-17”. Is it meant to be so?

The comment is duly considered. In order to facilitate the preparation for the ATM/ANS TAG meeting 1-2013, the Agency submitted to the TAG members the said report; “EASA: regulatory activities in the field of ATM/ANS” (initially prepared for the SSC 50). It was seen as a helpful information providing a general overview of the changes proposed to the Rulemaking Programme 2013-2017.

The draft Rulemaking Programme (the Excel document sent to ATM/ANS TAG members and observers with the e-mail dated 16 May 2013) includes separate worksheets per domain (R.2 Environmental Protection, R.3 Flight Standards, R.4 Product Safety, R.5 ATM/Airports) purposed to allow a more focused overview of the specific domains.


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CANSO sent on behalf of Vanessa Rullier by Andrea Gartemann

Recommendation for additional RMT:In consequence to the question that was raised with the ATCO NPA (2012-18) CANSO supports the drafting of a Concept of Operations and Equipment for Remote Tower Control with high priority.

The comment has been duly considered and a related RMT on "Technical requirments for remote TWR Oprations" has been added to the draft RMP 2014-2017.

ATM/ANS TAG meeting 19 June 2013 adding it as a new RMT was actively supported by several TAG members. The consensual view of the ATM TAG meeting has been duly considered and a related RMT on "Technical requirments for remote TWR Oprations" has been added to the draft RMP 2014-2017.

General comment 13CANSO sent on behalf of Vanessa


Recommendations of the prioritisation of the RMT in Annex I SESARCANSO recommends to clearly indicate the relationship with the SESAR roadmaps and to indicate the status of this table as being subject to alignment with the SESAR progress and that any EASA plan for RMT will be aligned and subject to later consultation.Especially for the subjects “datalink” and “data exchange” rules already exist, while “VCS”, “3 and 5 nm operations” and “AMAN” are no more subject to the latest roadmap update.

The comment is duly concidered. The Agency however has to notice that it is not (yet) in a position to fully indicate the relationship of the proposed RMP and the SESAR roadmaps. The forthcoming activities and governance related to SESAR deployment should help a lot in this sense. The Agency notes also the more detailed advice concerning the specific subjects related to the Annex 1 of the RMP.

General comment 15

Alfonso Arroyo, DG MOVE E.3., indicated that Philippe Cornelis would

be sending comments of general/strategic nature as described:

No comments on specific tasks but rather of a general/strategic nature. These comments deal with subjects such as, for instance (non-exhaustive list):

• Potential division of rulemaking tasks with the FAA: EASA and the FAA would elaborate different tasks each and the results would be mutually implemented, and to the extent possible within the same timeframe.• RM tasks should be classified in a more clear way according to a risk-based hierarchy. Prioritisation of tasks according to such criteria should be visible in the tables.• Explore the possibility to implement a more streamlined process to transpose ICAO amendments to EU rules without resorting to a full utilisation of the EASA RM procedure.• Reflect in the table the human resources utilisation associated to each task.

Noted.

General comment 12


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RMT.0017 (21.022) 21A.163 POA privilegesMr Jean-Marc Billaud, SSCC Member,

Dassault aviation

The priority of this task should be higher. The issue here is level playing field with US industry.This task should consider extending the limits under which a part or product can be maintained under Part 21 POA. Forcing a POA organization to switch to Part 145 procedures generates quite a burden for the organization and is not a safety benefit as those maintenance procedures are not the usual ones for the organization.Should involve new privileges: issuance of CoA, issuance of EASA forms 45 and 27.

The current start date of Q1/2016 can at the moment not be brought forward due to resource restrictions and tasks of a higher priority.

RMT.0023 (21.046) Replacement partsPatrick Debuchy, SSCC Member, IATA,

AEAhigh priority

The current start date of Q3/2015 can at the moment not be brought forward due to resource restrictions and tasks of a higher priority.

Mr Jean-Marc Billaud, SSCC Member, Dassault aviation

The impact of this task could be quite significant for business aviation where each cabin is unique to one airplane and involves several different seats in different positions. Industry should be involve in this task.

Noted. NPA will be published soon for comments. The EIR Group is working in parallel on specific adaptations of CS-25 for business aviation (see RMT.0264(MDM.066)) which could be applied to Part-26/CS-26.

Patrick Debuchy, SSCC Member, IATA, AEA

not required - There is no safety need for a retroactive rule on 16g seats. 9g seats will be phased out as aircraft are retired.

Not accepted, due to the need for Harmonisation with FAA requirements. However, as recommended in the RIA, the present Draft NPA limits applicability to in-production aircraft only, in order to minimize the impact.

RMT.0075 (26.008)

Fuel tank flammability reduction of already

certificated large aeroplanes


not required - In line with the conclusions of the in-depth review done by EASA, there is no safety case to require retrofit of in-service aeroplanes.

Not accepted. The different reviews performed by the Agency concluded on a remaining safety risk. The cost of retrofit was however very high compared to the safety benefits. However, the Agency has acknowledged the lack of harmonisation between the US and the EU and is also concerned by this remaining safety risk for the European fleet in the absence of full retrofit requirements. It has therefore decided to proceed with the rulemaking task to address the remaining risk.

RMT.0106 (21.039 e)

Additional airworthiness specifications for a given type of aircraft and type

of operation

Mr Liam Sisk, E&M subcommittee report SSCC member

minor/ low priorityThis task is necessary to complete the Operational Suitability Data package. In itself it does not add any obligations but only provides the necessary certification specifications for certification.

Seat crashworthiness improvement on Large Aeroplanes - Dynamic

testing 16g

RMT.0069 (26.002)


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RMT.0148 (ATM.001 a)Requirements on Air

Navigation Service Provision


importantThe Agency is pleased to note the indicated support and will follow the proposed timescale as presented at the Sub-SSCC meeting on the 5th June 2013.

RMT.0153 (ATM.003 a)/ RMT.0154(ATM.003

b)

Requirements on Air Traffic Controller licensing



RMT.0157 (ATM.004 a)/RMT.0158 (ATM.004 b)

Requirements on Competent Authorities in

ATM/ANS



Mr Meerman/ADR subcommittee report

SSCC Memberhigh priority

The Agency is pleased to note the indicated support and will follow the proposed timescale as presented at the Sub-SSCC meeting on the 5th June 2013.

Mme Carole Lenck, DGAC

Do we have an idea of what kind of equipment will be included in the scope as regards aerodromes (visual aids, RFF equipement - which kind : fire clothes, vehicles, extinguishing agents, etc.) ? As different kinds of equipments may be concerned, will subgroups be created to appeal to specific expertise in each domain ? As regards RFF equipment as for other equipments, it should be kept in mind that they can be subject to standards or regulations not specific to aerodrome domain. For example, fire clothes respect general EN or ISO standards, and conditions of their correct maintenance is ensured by work regulation.Besides, para 2 c) of Article 8a) of Basic Regulation mentions safety critical aerodrome equipments. How is the notion of "safety critical" defined ? To which equipment would it correspond ?

The Agency will take the comment in duly consideration in the execution of the said rulemamking task. Moreover, and in full agreement with the comment, the appropriate recognition of applicable industry standrads is one of the foreseen basic principles in the task.


minor - The task should not be launched before a common understanding is shared.The concept paper will be welcomed for trigerring the exchange of views.

The Agency has noted the comment and agrees to the extent that the concept paper is an important element of such a challenging rulemaking task. However, no decision has been made whether the concept paper should be discussed and used first within the rulemaking task or prior to it (as suggested here).

ATM/ANS systems and constituents and ADR

equipment

RMT.0161 (ATM.005 a)/ RMT.0162 (ATM.005 b)


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RMT.0180 (E.010)Initial Maintenance

Inspection

Mark Chatterton, SSCC Member, (on behalf of ASD, AIA, Rolls-Royce and

wider Industry

The proposal to include the Initial Maintenance Inspection within CS-E, whilst clearly satisfying the harmonisation objective, it will result in little change since all products validated by the FAA require the IMI test to be completed anyway

The current CS-E 740 Endurance Test in its current form, for turbine engines, can be traced back 60+ years. In that time turbine engines have changed beyond all recognition, such as pure jet-to high bypass ratio, single-to-multiple shafts, mechanical-to-electronic control, uncooled-to-cooled blades, etc. In order to meet the requirement of the endurance test it is necessary to significantly modify engine components and the engine control system in order to satisfy the requirements of the endurance test, that is the engine is no longer fully representative of the certification bill of materials – inevitably reducing the value of the test and undermining its purpose

This issue has already been broached with EASA, FAA and TCCA propulsion representatives, all of which have been supportive of the proposal to update the CS-E 740 Endurance Test to make it relevant to current/future turbine engines. A wide ranging industry group is already considering this very issue, whilst also taking a broader view of other existing engine tests and what they seek to achieve, such as Initial Maintenance Inspection (IMI) and ETOPS.

It is proposed the scope of the current Initial Maintenance Inspection (IMI) contained within the current 2014-2017 rulemaking programme task be extended to include the definition of a revised and relevant CS-E 740 Endurance Test, whilst also seeking to meet other EASA objectives of; simple and cost effective. It is essential the task take a broader view to ensure the endurance test is an integral part of the other key benchmark tests required for engine certification/validation, such as IMI and ETOPS testing

I i d h IMI k i id ifi d k h h ld h

In accordance with the discussions in the D&M sub-SSCC the Agency has agreed in principle to merge this task with the task on engine endurance testing and to execute this task using an industry lead group.

RMT.0188 (FCL.002 a)/ RMT.0189 (FCL.002 b)

Updating EASA FCL implementing rules


high priorityto correct some mistakes in the existing rules and to move towards competency based training

Noted

RMT.0190 (FCL.004 a)/RMT.0191 (FCL.004

b)

Requirements for relief pilots


not required - The EASA OPS and FCL rules include the option of a cruise relief co-pilot (CRCP) in line with existing safe practices. There is no need for further EASA rules in this field.

Task has been initiated already and the Agency considers it to be an important task to be carried on.

RMT.0200 (FCL.009 a)/RMT.0201 (FCL.009

b)

Training for flying by sole reference to standby

instruments


not required - There is no need for an isolated rulemaking task. This issue should rather be reviewed in the context of a wider review of pilot training requirements.

Noted - the pre RIA will be reviewed again.


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RMT.0256 (MDM.062 a) former OPS.013 a)/ RMT.0257 (MDM.062 b former OPS.013 b)

Revision of operational approval criteria for performance-based

navigation


high priorityto allow airlines to benefit from new technology. However harmonization needs to be ensured with FAA and ICAO.

The Agency is pleased to note the indicated high priority for the task. Moreover, also the ICAO Doc 9997 suggests that regulators should assess or not whether a specific approval process is needed for each type of PBN operations.

RMT.0287 (MED.001 a)/RMT.0288 (MED.001 b)

Updating EASA FCL Medical implementing

rules (Part-MED and relevant Subpart Part-

ARA and Part-ORA)


high priority to correct some mistakes in the existing rules and to move towards competency based training

Noted. Mistakes corrected. First steps taken to introduce competency based training for aero-medical examiners. However, neither part Part-ARA nor Part-ORA contain rules for training of aero-medical examiners.

RMT.0211/0558 (M.020)

Detection of recurrent defects on components

which underwent maintenance


not required There is a Safety Recommendation on this subject (SR UNKG-2008-089)

RMT.0217/0546 (M.029)

CAMO and Part-145 responsibilities


minor/ low priority

Questions received by the Agency show that these responsibilities are still not clear.

In addition, there is a Safety Recommendation on this subject (SR UNKG-2010-072)

RMT.0225 (MDM.028 a)/ RMT.0226

(MDM.028 b)/RMT.0227 (MDM.028 c)

Development of an Ageing Aircraft Structure

plan


AEA and IATA agree that EASA needs to launch rulemaking on ageing aircraft (RMT.0225/R The NPA for this task is already published. The Agency will carefully review all the comments on the NPA, including the wish from industry to harmonise with FAA. A review group will be established to review the comments with stakeholders.

RMT.0231 (MDM.030 a) /RMT.0232 (MDM.031 a)

it is more likely he means the below (task

.0331)

Commercial air transportation aeroplane operations at night or in IMC using single engine turboprop aeroplane/ UAS further regulation

The RMT number is actually RMT.0232/233 (MDM031(a)&(b)). In addition this comment is not related to this task, but apparently to the next one (331/332).

RMT.0331 (OPS.060 a)/RMT.0332 (OPS.060

b)

Devices for reducing the effect of smoke and toxic fumes in large transport

aircraft

Noted. Low priority but cannot be dismissed at this stage without further evaluation as it is related to a safety recommendation.


Devices for reducing the effect of smoke and toxic fumes in large transport aircraft. We understand that this recommendation asks for providing anti fumes systems to passengers. We have the supplemental oxygen who is dealing with that purpose and feel it is not a priority issue.


10/24


RMT.0243 (MDM.042)

The identification of existing defences in

maintenance processes to detect major

configuration differences


not required There is a Safety Recommendation on this subject (SR PORT-2004-005)


high priority Task already on-going.


to stop anti-competitive behaviour from some OEMs with regard to restrictions to the use of essential safety documentation, EASA should issue a policy statement mirroring the FAA statement

Task already on-going.

RMT.0116Real weight and balance

of an aircraftP&M TAG

There was only one comment on the draft 2014-2017 programme which was from France, who stated they are happy to have RMT.0116 (Real weight and balance of an aircraft) on the programme, however they asked to advance the task by one year to 2014. It was suggested to them if they could move another task back to facilitate this one, however there were no suggestions, or further comments

Noted. The schedule of this task is dependent on the availability of the industry stndard that will be prepared by the EUROCAE WG-88. The schedule of this task will be adapted taking this into consideration, but from the time being it is not possible to advance it.

RMT.0255/0552 (MDM.059)

Miscellaneous of Part 66Mr Liam Sisk, E&M subcommittee

report SSCC memberimportant

The particular subject of this task for which they are interested is the issue of "Type training for legacy aircraft".

RMT.0256 (MDM.062 a) former OPS.013 a)/ RMT.0257 (MDM.062 b former OPS.013 b)

Revision of operational approval criteria for performance-based

navigation


high priority to allow airlines to benefit from new technology. However harmonization needs to be ensured with FAA and ICAO.


RMT.0258 (MDM.063 a former OPS.029

(a))/RMT.0258 (MDM.063 a former

OPS.029 (b))(now deleted from

RMP 2013-16)

Child restraint devicesPatrick Debuchy, SSCC Member, IATA,

AEAnot required - This issue should be reviewed and harmonized at a global (ICAO) level, no need for specific EASA rules

The Agency will await the ICAO deliberations on child restraint devices, since ICAO has responded positively to the request by EASA to develop a global policy on child restraint devices.

RMT.0264 (MDM.066) Executive Interior Accomodation



Noted. Task outsourced to the Executive Interiors Rulemaking (EIR) group.

RMT.0252 (MDM.056) Instructions for

continuing airworthiness (ICA)


11/24


RMT.0269 (MDM.072 a)/ RMT.0270 (MDM.072 b)

Carriage of Special Categories of Passengers


With regard to the EASA rulemaking task on Special Categories of Passengers (SCPs) (RMT.0

The deliberations of the Rulemaking Group are building on operational experience, as well as the need to develop harmonised procedures on carriage of SCPs. The current deliberations of the group do not foresee a change in the existing requirements, but rather additional AMC/GM to explain the existing requirements.

RMT.0275/0556 (MDM.075)

Specialised tasks other than NDT (please include

painting)


important Noted.

RMT.0278/0536 (MDM.078)

Importing of aircraft from other regulatory system and Part-21 subpart H

review


Important This task has already started.

RMT.0279/0557 (MDM.079)

First installation of prototype STCs on an

aircraft by a maintenance organization


important Noted.

RMT.0281 (MDM.082)New training / Teaching

technologiesPatrick Debuchy, SSCC Member, IATA,

AEA

high prioritythere is an urgent need to overhaul the outdated EASA requirements in the field of maintenance training in order to take into consideration new aircraft technologies and developments in evidence based training.

This task already started 1 year ago.

RMT.0285 (MDM.088 a)

Passive & Transmitting RFID and Readers

installed on aircraft or portable


high priorityThis kind of technology is more and more used by all kind of users (cargo, maintenance, etc.). There is a need to have a realistic approach and to take into considerations the experience gained up to now.

See response to comment from the D&M sub-SSCC.

RMT.0291 (OPS.004 b)Implementing rules for the regulation of third

country aircraft


not required - there is no need for an additional process, authorization should be based on The Basic Regulation in Articile 9 foresees the authorisation of third country operators and the related Opinion has been adopted in November 2012. RMT.0291 is developing the associated AMC/GM to those Implementing rules.


12/24



high priorityto correct mistakes and problems arising during the implementation of EASA OPS

Mr Thomas Leoff/FS subcommittee report SSCC Member

Foreseen method is Agency, FS sub-SSCC recommends to consider ad-hoc group support if need occurs;

RMT.0294 (OPS.007 a)/RMT.0295 (OPS.007

b)

Data Link Recording Retrofit for aircraft used

in CAT


not required - we think that taken into account the ground recording of communications by ATCCs, the impact of such a retrofit on old design aircraft, this task has to be deleted.

The task has to be kept due to the obligation to align with other EU legislation. However, it has not the highest priority at this stage.

RMT.0318/0319 Single engine Helicopter

ops over hostile environment


Agency awaits result of a study to determine work method. FS sub-SSCC strongly suggests to have a group, due to the multiple aspects and complexity of this task.

Noted

important

Air OPS update of rulesRMT. 0292/0293


Noted


13/24


RMT .0327 (OPS.058 a) (RMT.0328 (OPS.058 b)

Transfer of JAA cabin safety tasks


not required - senior cabin crew incapacitation): no safety justification, existing EU-OPS provisions are sufficient to mitigate known risks

The EN and the RIA of NPA 2012-12 explain the reasons and the background of the task on ‘Incapacitation and replacement of SCCM’. The JAA initiated an NPA on the issue which was discussed at Air Safety Committee in 2007. The Committee concluded that the task be transferred to EASA for introduction into the future IR. The task was on the agenda of the meeting between the Agency and its Consultative Body - the Flight Standards sub-committee of the SSCC in May 2011, and it was agreed to include it in the Rulemaking Programme 2012-2015. NPA 2012-12 ‘Incapacitation and replacement of SCCM’ does not represent a new requirement, the purpose of this NPA is to clarify the interpretation of the operational requirement ORO.CC.200(e) (former OPS 1.1000(d) and JAR-OPS1.1000(d)). The commentator’s proposal to maintain the transposed text would allow continuation of diverse interpretations by EU operators resulting in non-compliance with Commission Regulation (EU) No 965/2012.NPA 2012-12 ‘Incapacitation and replacement of SCCM’ has not provided any new or unknown guidance on replacement of incapacitated/unavailable SCCM; the proposal reflects known operational practices that are currently applied by operators. Further to the basic clarification proposal of NPA 2012-12 ‘Incapacitation and replacement of SCCM’, it is the operator’s responsibility to develop detailed procedures on replacement of incapacitated/unavailable SCCM; operator’s procedures are subject to approval by the National Aviation Authority of the respective Member State.

RMT.0347 (now merged with RMT.

0577 and RMT.0578)

Policy on flight continuation after in-

flight shutdown


not required - There is no safety case for further rules in this area. This is a matter for individual airline (company based) procedures within their Safety Management System.

This will be part of the overall review of the ORO.FC requirements.

RMT.0352 (OPS.075 a)Operator's description of non-revenue flights (IRs)

minor/low priorityAlso in this case performance based rules are essential in particular since this issue is already adequately covered through operator procedures

RMT.0353 (OPS.075 b)Operator's description of

non-revenue flights (CS/AMC/GM)

minor/low prioritythe today IR Ops asks for the operator to make approved by his Authority the procedure for non revenue flight that are different from CAT ones. This allows to manage various situation when a CAT operator has to perform non revenue flights. It has to be noted that Maintenance Check Flights have been subject to an NPA which is on its way.

Noted. The task also responds to an accident.Patrick Debuchy, SSCC Member, IATA,

AEA


14/24


RMT.0354 (OPS.076 a)/ RMT.0355 (OPS.076 b)

Cabin crew language skills for safety-related

communications with passengers (IRs &

AMC/GM)


not required - There is no safety case for additional rules in this areaThis task is related to safety recommendations which are required to be addressed to the Agency. However, the Agency recognises that a global approach would be desireable and endavours to bring this issue to ICAO.

RMT.0368 (MDM.091)Protection against the use

of contaminated halonsMr Liam Sisk, E&M subcommittee

report SSCC memberminor/low priority This task is necessary to align with ICAO SARPS.

Mr Pablo Ulíbarri Ramos, TAG ATM/Ans Member

this task deals with airborne equipment and should be moved to the OPS section

The Agency has noted the comment but cannot fully support it. This rulemaking task will affect (mainly\) the airspace usage Regulation No 1332/2011, as well as Part-ACS, Part NCC and Part NCO. Therefore the Agency has anticipated to deal with it within its ATM domain.




high priorityto gain credit from new technology. In addition, there is a need to review outdated requirements in the field of training, assessment and operational demonstration.

Noted. This will be part of the ToR.

Mr Philippe De Gouttes/D&M subcommittee report SCC Member

Noted.

Noted.

several aspects (practicality, liability, confidentiality, etc. ) of data sharing to be reviewed (using this RMT) referring to provisions of AMC6 to SPA.LVO.105 (a), (e)

It could be reviewed but the current text is already a compromis text and may not gain sufficient support for further changes.

RMT.0379/0380

RMT.0381/0451 now in RMT.0379/0380

high priority


All Weather Operations

HUD/EVS/SVS/CVS, now All Weather Operations

RMT.0376 (ATM.010

Carriage of ACAS II equipment on aircraft

other than aeroplanes in excess of 5700kg or 19

Pax


15/24



This task involves new technologies on which Industry can bring significant expertise. It is recommended to have this task as “group” instead of “Agency”

Accepted.


high priority to gain credit from new technology. In addition, there is a need to review outdated requirements in the field of training, assessment and operational demonstration.

Noted. This will be part of the ToR.

RMT.0385 (OPS.087 a) / RMT.0435

(OPS.087(b))/ RMT.0441

(OPS.087(c))1

(SACA and SAFA)Patrick Debuchy, SSCC Member, IATA,

AEAnot required - in line with the performance based oversight approach, there is no need to expand the SAFA concept to Community carriers (SACA).

The scope of the Basic Regulation is wider than the scope of the SAFA Directive — which is limited to third-country aircraft engaged in commercial operations and thirdcountry aircraft of a maximum takeoff weight of more than 5 700 kg engaged in noncommercial operations. Consequently Part-ARO.RAMP will apply to all aircraftsubject to the Basic Regulation used by community (SACA — Safety Assessment of Community Aircraft) and third-country operators (SAFA), both commercial and noncommercial. This RMT will establish a comprehensive and uniform system for conducting ramp inspections. This is also of benefit for operators.

RMT.0393 (OPS.097 a)/RMT.0394 (OPS.097

b)

Airworthiness and operational aspects for

maintenance check flights


minor/ low priorityIn this context, AEA/IATA also would like to stress the need for performance based rules in line with the official comments to the NPA 2012-08.

Noted.

Mr Pablo Ulíbarri Ramos, TAG ATM/ANS Member

this task requires a close coordination with Eurocontrol Noted - Task is already initiated


no view Noted.

RMT.0412 (FCL.013 a)/ RMT.0413 (FCL.013 b)

Updating the authority and organisations

requirements pertaining to Part-FCL



Noted - Task is already initiated

/

RMT.0407 (ATM.021 b)

p

Harmonised Transition Altitude


16/24


RMT.0417 (OPS.009 b)Sterile flight deck

proceduresPatrick Debuchy, SSCC Member, IATA,

AEA

not required - Superfluous rulemaking programme. This is a matter for airline (company based) procedures, as part of their Safety management System (SMS) activities, no need for further rules in this area

Not accepted. This comment was made by IATA/AEA several times during the rulemaking process. For the Agency the justification for this rulemaking can be summarised as follows:1. The Regulatory Impact showed the need for rulemaking action to reduce the safety risk;2. The 'European Action Plan for the Prevention of Runway Incursions' introduces the concept of the sterile flight deck. This Action Plan has been signed by the Agency and IATA, and has been supported by the Agency, IATA and AEA;3.Two Safety Recommendations, addressed to the Agency, recommend, among other measures, that the Agency highlights the concept of the sterile flight deck.For further details see NPA 2012-06. In the meantime Opinion No 05/2013 has been published. This is the task to publish the related AMC/GM

RMT.0422 (OPS.095 a)/ RMT.0423

(OPS.095 b), deleted now in inventory

Portable electronic devices


high priority - Review of PED policies (new task proposed): there is a need to review PED p The Agency awaits the deliberations of the FAA ARC and will then decide on how to proceed.

RMT.0424 (MED.002)Systematic review of

medical rules for aircrew and cabin crew


high priority to correct some mistakes in the existing rules and to move towards competency based training

Noted. Regular update.

RMT.0427Establishment of ATCO CQB for initial training


not required In line with recommendations of the ATM High Level Group this RMT is not required

This task is driven not only by safety recommendations, but also by findings coming from Annual Standardisation reports, the need to correctly transpose ICAO Doc 8335 on inspector qualifications, as well as the need to update the management system requirements included in Part-ARO. This tasks ensures consistency between the different domains, e.g. between FCL and OPS rules.


these tasks, that will feed the result of NPA 2013-08, start late (2016) and the results will only be seen in 2020. Is this reasonable, taking into account SES II+ and what may derive therefrom?

Noted.

RMT 0445/0446

Technical requirements and operational

procedures for Airspace


17/24



minor

The Agency has noted the comment but cannot fully support it. This rulemaking task, including its safety objectives and timescale, are stemming directly and very clearly from the Basic Regulation. Moreover, its successful completion is seen necessary e.g. in order to support the important SES (and global) objective of PBN implementation.

RMT.0447/RMT.0448Requirements for the use

of ground based safety nets


minor - This needs to be consistent with the SESAR safety net methodology and development

The comment is duly noted The Agency agrees with the low priority in the sense that the task has been estimated to start only in 2016. If the SESAR deployment processes related to safety net methodologies and development will necessitate changes in the rulemaking programming, the Agency will duly reconsider the planning of the task.

RMT.0453 Ditching Parameters

without Engine PowerPatrick Debuchy, SSCC Member, IATA,

AEAnot required - There is no need for more rules in this field in particular since chances of a successful ditching are extremely low.

Noted

RMT.0464/ RMT.0468 Requirements for ATSCANSO sent on behalf of Vanessa


minor - It is not clear in how far this task is the left-over of SERA Part B work and how it separates from the RMT described in line 152-155 in the excel table. For all three RMT the minor priority due to already existing provisions is relevant.

The Agency has duly noted the comment but cannot fully support the priority indicated. This rulemaking task is regarded as an elementary part of the requirements on ATM/ANS service provision and the oversight thereof. It is agreed that the relation of this task and the amendment to the SERA Regulation has to be clear, but this should not impact the overall planning on RMP level.

Mme Carole Lenck, DGAC Has the working group finished its work, or are additional meetings still planned ?Related rulemaking group has finished its work. No further group meetings at the NPA preparation phase are foreseen.


important The Agency is pleased to note the indicated priority for the task. The NPA will be published by Q3/2013.

RMT.0445/0446

Requirements for Apron Management Services at

aerodromes (IR)/ Requirements for Apron Management Services at aerodromes(CS, AMC and

GM)

RMT.0465/.0485

procedures for Airspace design including

procedures design


18/24


Mme Carole Lenck, DGAC

Following the EASA exploraty groups in year 2009, additional work on this subject was conducted by GASR (Group of aerodrome during regulators) in october 2010 during their WG n° 59 (participants : Sweden, UK, Spain, France). The corresponding deliverable could serve as a basis for this RMT.

The comment is duly considered and the Agency agrees that the GASR work provides a helpful reference for the RMT.


minor Noted.


high priority - agree that this is an urgent taskThe Agency is pleased to note the indicated high priority for the task. The work is on-going. The NPA is planned to be published by Q2/2014.


high priority - simplification of the draft GM is now the priorityThe Agency is pleased to note the indicated high priority for the task. The work is on-going. The NPA is planned to be published by Q2/2014. The Agency also sees that the GM material is necessary and must provide clear guidance.

RMT.0473Technical requirements

and operational procedures for MET


important Noted. The work is on-going and proceeds as planned.

RMT.0475Safety related roles and functions in ATM/ANS


not required

The Agency notes that CANSO does not support this RMT and agrees in the sense that it cannot be launched at this stage. In order to get a better view of the regulatory needs the Agency is performing an external study aiming at identifying the essential issues and possible options. Possible further steps, including pre-RIA, will be undertaken only following this study and further consultation with the Agency's consultative bodies. The RMT will be postponed therefore with two years.

RMT.0466/.0467 Heliports

RMT.0469/.0470Requirements for Safety

assessment of changes to functional systems


19/24


RMT.0476Maintaining SERA IR

(stemming from ICAO SL)CANSO sent on behalf of Vanessa

Rullier by Andrea Gartemannhigh priority The Agency is pleased to note the indicated high priority for the RMT.

RMT.0477/ RMT.0478Technical requirement

and operation procedures for AIS/AIM


minorThe Agency has noted the low priority suggested for the RMT but does not see this as a justification to postpone it further. The purpose of ths RMT is to transpose ICAO Annex 15 and to enable making use of emerging information technologies.

RMT.0479/RMT.0480Technical requirement

and operation procedures for CNS


minorThe Agency has noted the low priority suggested for the RMT and agrees in the sense that its implementation is planned to start only in 2015.


minor

The Agency has noted the comments concerning the RMT and agrees that the technical requirements for ATFM services would be best addressed if/when the Regulation 255/2010 will be amended. Therefore the RMTs in question has been removed from the draft RMP.

Typos in the excel file: in the Technical requirement and operation procedures for ATFM , it should say ATFM instead of ATFT


minor

The Agency has noted the comments concerning the RMT and agrees that the technical requirements for ASM services would be best addressed if/when the Regulation 2150/2005 will be amended. Therefore the RMTs in question has been removed from the draft RMP.


there is a mayor slippage in the dates. What is the reason for this delay?Based on the most consensual view with the Agency consultative bodies the title and timescale of the RMT have been changed with a purpose to align it with the recently established ICAO work plan on ATCO fatigue management.

The Agency has noted the comments concerning the RMT and agrees that the technical requirements for ATFM services would be best addressed if/when the Regulation 255/2010 will be amended. Therefore the RMTs in question has been removed from the draft RMP.

Technical requirements and operational

procedures for ASM RMT.0483/0484

RMT.0481/.0482Technical requirement

and operation procedures for ATFM

these tasks, that will feed the result of NPA 2013-08, start late (2016) and the results will only be seen in 2020. Is this reasonable, taking into account SES II+ and what may derive therefrom?


Development of a


20/24



no view - however ICAO developments should be supported

Based on the most consensual view with the Agency consultative bodies the title and timescale of the RMT have been changed with a purpose to align it with the recently established ICAO work plan on ATCO fatigue management, as is also suggested in the comment.

ATM/ANS TAG meeting 19 June 2013 … consensus was found after discussion based on the ICAO task-force workBased on the most consensual view with the Agency consultative bodies the title and timescale of the RMT have been changed with a purpose to align it with the recently established ICAO work plan on ATCO fatigue management.

RMT.0516Updating Parst ARO and

Part OROPatrick Debuchy, SSCC Member, IATA,

AEAnot required - We feel other (non-rulemaking) means should be explored to ensure an uniform level of oversight within Europe.

This task is driven not only by safety recommendations, but also by findings coming from Annual Standardisation reports, the need to correctly transpose ICAO Doc 8335 on inspector qualifications, as well as the need to update the management system requirements included in Part-ARO. This tasks ensures consistency between the different domains, e.g. between FCL and OPS rules.


this task should refer to regulation (EU) No 390/2013 (RP2) instead of regulation (EU) No 619/2010 (RP1)

Noted.


high priorityCANSO believe that EASA should focus on the development of leading indicators of safety that drive the right behaviors, rather than additional lag indicators for RP2

The Agency is pleased to note the indicated high priority for the task. The content of the work is about AMC/GM which has to follow what is stemming from the actual Commission Regulation.


high priorityto allow airlines to benefit from new technology. However harmonization needs to be ensured with FAA and ICAO.



high priority The Agency is pleased to note the indicated high priority for the task.

RMT.0521/0522 Review of the

Airworthiness Review process


minor/ low priorityThe survey submitted by the Agency to NAAs and Stakeholders show that there are a significant number of issues to address and clarify.

RMT.0518

RMT.0491

Development of AMC/GM for SKPI (ATM

performance IR) for RP2

Development of a methodology for safety

risk assessment with regards to ATCO fatigue

Provision of requirements in support of global PBN

operationsRMT.0519


21/24


RMT.0537/0538 Privilege for CAMOs to issue Flight Conditions

and Permit to Fly


high priority Noted.

RMT.0544/0545 Review of Part-147Mr Liam Sisk, E&M subcommittee

report SSCC memberminor/ low priority

The Agency believes that there is a need to review how effective has been the implementation of Part-147 (Basic Regulation Article 24). The Agency will issue a survey among NAAs and Stakeholders and, based on the feedback, it will decide whether rulemaking action is necessary.

RMT.0548New training / Teaching

technologiesPatrick Debuchy, SSCC Member, IATA,

AEA

high prioritythere is an urgent need to overhaul the outdated EASA requirements in the field of maintenance training in order to take into consideration new aircraft technologies and developments in evidence based training.

This task already started 1 year ago.

RMT.0560Halon - Update of part 26

to comply with ICAO standards


minor/ low priorityThere is only a viable alternative for lavatories.

Noted. But the task is necessary in order to align Agency's provisions with ICAO Annex 6

This topic isto be addressed in a wider maner.Systems may be part of the solution but are

Partially accepted the European Action Plan for Prevention of Runway Excursions10 (EAPPRE) (Edition 1.0 - January 2013) provides recommendations on the use of ‘all practicable means available ranging from the design of aircraft, airspace, procedures and technologies, to relevant training for operational staff associated with runway excursion prevention.’"Rulemaking for the approval of on-board real-time crew alerting systems" is one of the recommendations.

Significance of the Safety Issue and expected safety benefits lead the Agency to give high priority to this task in order to reach the proposed timescale.

not required - in line with the AEA position on ROPS, we believe it is premature to consider retroactive rulemaking

Not accepted.Review made by the Agency concludes that Runway Overrun Awareness and Avoidance Systems can be installed on newly produced aeroplanes (production cut-in and new designs).Please refer to NPA 2013-09 for further details on the different relumaking options analysed

high priority Noted.

FS sub-SSCC supports issuing a SIB - as a preliminary measure Draft SIB currently under consultation with Member States and industry.


Reduction of runway excursions (retrofit CS-26)

RMT .0569/RMT.0570

RMT.0573/0574 Mr Thomas Leoff/FS subcommittee

report SSCC Member

Fuel planning and management important

task,


22/24



not required - To be deleted from draft RMP 2014 – 2017, considered as low priority due to lack of safety data

Please, refer to the Executive Summary and to the point 2.1 of the Pre-RIA RMT.0575 & RMT.0576 Passenger seating and briefing which provide explanation on the background of this task. The Agency has been tasked by the European Commission to initiate this task with a high priority.


not required - There is no need for more rules in this field. This issue is adequately covered through airline procedures.

Please, refer to the Executive Summary and to the point 2.1 of the Pre-RIA RMT.0575 & RMT.0576 Passenger seating and briefing which provide explanation on the background of this task. The Agency has been tasked by the European Commission to initiate this task with a high priority.

RMT.0586 Tyre pressure monitoring

systemMr Liam Sisk, E&M subcommittee

report SSCC member

S/C questioned the justification for this proposal since the event(s) which prompted this task represented very poor maintenance standards and that responsible operators have no tyre related issues due to proper application of best practice re tyre inflation pressures and monitoring of same

Noted. As indicated in the pre-RIA, there are several regulatory options, and retrofit of the TPMS may not be retained. Note that it is also envisaged to improve the regulations in order to better enforce adequate tyre maintenance procedures.

important Noted

Foreseen method is Agency, FS sub-SSCC recommends to consider ad-hoc group support if need occurs;

Noted


SSCC Memberhigh priority

The Agency is pleased to note the indicated high priority for the task and indeed will initiate it still in Q4/2013.

Ms. Carole Lenck, DGAC

According to EASA DP, determination of the level of protection and medical standards will be addressed. Will additional subjects be included in the scope ? As regards RFF equipments, will they be addressed by ADR equipment group, or by RFF group ?

See comment for .061 abd 162

The RMT on RFFS is purposed to address the services on RFF but not to include the specific RFF equipment.


no view Noted.

RMT.0575/0576 Passengers seating and

briefing

RMT.0587/0598

Rescue and Firefighting Services

Regular update of Part-FCL


RMT.0589/0590


23/24



SSCC Memberhigh priority - task stemming from ICAO amendments The Agency is pleased to note the indicated high priority for the task.

UK CAA

The UK supports EASA in developing new and upgrading its rules, arising from changes made to ICAO SARPs. We believe that the task should also include the development of new rules reflecting best practice in Europe and elsewhere, where such practices exceed or differ from ICAO SARPs (provided that an equivalent level of safety can be assured).

Justification: ICAO SARPs are intended for worldwide implementation. The UK, together with several European and other states, in places has practices that exceed ICAO SARPs. The adoption of EASA rules should reflect good practice and promote continuous improvement.

Proposed text: Add text to the task description “… and to reflect good practice in member states”.

The Agency is pleased to note the indicated support for the task. As regards implementing the task, the good practise in Member States is definitely an important reference of it but would not be necessary to address on the level of the RMP.


no view Noted.


this task (Part-DAT) should be closely linked to the ADQ IR (regulation (EU) No 73/2010) and the future ADQ-2.

The Agency fully agrees that there is an important link between the elements mentioned in the comment. Moreover, the European Commission has confirmed that the objectives of the said ADQ2 mandate should now be included in the Agency's rulemaking activity.


minor - understood as “ADQ2”, involvement of ANSP strongly recommended

The Agency takes note of the priority indicated. Rulemaking group is the method chosen to implement the RMT.On 09 July 2013 the Agency disseminated to the consultative bodies for consultation the draft ToR with a requrest for nominations to the rulemaking group. ANSPs are naturally expected to propose experts to be involved in the work.

RMT.0591 / .0592

Technical requirement and operation procedures for the provision of data for airspace users for the purpose of air navigation

RMT.0593/.0594

Maintaining Aerodromes IR


24/24


important Noted

FS sub-SSCC sees the need to establish a data-driven update process in order to ensure actuality of the LOs at all times

Noted

RMT.0609 (ATM.001 a)/RMT.0610 (ATM.001 b)

Requirements on Air Navigation Service

Provision (former SERA Part C)


important The Agency is pleased to note the indicated priority for the task.

ADR Safety recommendation given to

Agency


SSCC Memberhigh priority The Agency is pleased to note the indicated high priority for the task.

this task has to be linked to the on-going PBN IR, lead by Eurocontrol, and the related EASA rulemaking tasks on PBN.

The Agency thanks for the comment but is not yet in a position to confirm the contents of the said RMTs.

Annex I - SESAR tasks: Typos: the excel document contains the following: “Gound” for “Ground”, “Constistuents” for “Constituents”, “Voive” for “Voice” and “Introdction” for “Introduction”.

The Agency will introduce the indicated corrections.

New task New task on cyber

threatsJean-Marc Billaud, SSCC Member,

Dassault aviation

This subject was proposed to be addressed in an “omnibus” NPA, but was eventually removed from it because not simple enough.Nevetheless, the subject is an issue and it is suggested to open a task to address it.

See response to comment from the D&M sub-SSCC.

SESAR TASKS

RMT.0595Technical Review of Learning Objectives


PBN Curved approach operations
