General. Note: In addition to the comments which were received on the specific proposals, some commentors made comments or suggestions of a general nature. The responses to these are shown below.

Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 094 Transport Canada 108 CAA Hungary 114 CAA Iceland Commentors expressed 1 231 Air 2000 general agreement with the Noted -- -- 273 LFV Norway proposals 293 LFV Sweden 310 Brit. Aerospace A generalized complaint that Noted -- No change intended at the 2 the JAR uses 3 numbering moment systems 137 CAA UK Editorial comment Noted -- -- 136 CAA UK Changes to Subpart N should Noted FCL/OPS co-ordination group to -- take full account of JAR-FCL deal with this. 3 027 CAA Czech Several comments concerning Attended to -- -- Subpart K under ‘K’ 239 Martinair Maintenance Postholder to be Attended to -- -- a separate person under ‘C’

NPA-OPS-15 Comment/Response Document Page 1 Subpart A. Refer to NPA-OPS-12

JAR-OPS 1/3.001(a)(2) Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 34 CAA Finland Parachuting should be an Agree It is intended to regulate for Additional para. (a)(2) to 1 19 Finnish Aeronautic exempted category parachuting under Parts 2 and 4 exempt parachutists 2 25 Heli Air Zagel Should be no limit on number Disagree Wide agreement that 6 is a 26 Agrarflug Helilift of pax reasonable limit provided that -- parachutists and firefighters are exempted 3 32 Skyjet AG Authority could approve more Disagree Ditto above -- than 6 pax 4 36 Transport Canada Exclude firefighters and all Agree Aerial Work to be regulated under Firefighters exempted crew of Aerial Work Parts 2 and 4 under new para. (a)(2) 5 38 INAC Not presently limited by law Disagree Portugal’s members agree that number can remain at 6 if -- firefighters and parachutists exempted 6 46 LFV Sweden Redefine AW and CAT, Disagree The text is not intended as a increase number to 9 definition of CAT or AW; it is -- provided to allow the continuation of existing activities until the production of JAR-OPS 2 and 4 7 17 FR Aviation Should be regulated in JAR- Disagree See item 6 above -- 43 GAMTA OPS 2 and 4 49 DGAC France 8 10 CAA Iceland 13 CAA Malta Support of the proposal Noted -- -- 16 LBA 22 MOT Austria (Malta suggests that the 27 BAZL FOCA example given in para.5 of the

NPA-OPS-15 Comment/Response Document Page 2 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 30 CAA Slovenia introduction should become 33 CAA Denmark an IEM) 35 RLD 44 ENAC Italy 47 LFV Norway 12 Lynton Aviation 23 EHA 41 BHAB 9 45 BMV Bonn Proposes different text Disagree The words ‘immediately before, during or immediately after’ were -- used to ensure clarity and unambiguity of meaning 10 48 CAA UK Proposes different text Disagree The proposed additional text does not improve clarity. The proposal -- is a duplication of the condition that persons carried must be connected with the Aerial Work activity.

JAR-OPS 1/3.125 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 1 6 CAA Hungary 7 N/k 10 CAA Iceland Support of the proposal Noted -- -- 16 LBA without comment 30 CAA Slovenia 33 SLV Denmark 35 DGAC NL 37 Transport Canada 44 ENAC Italy 2 40 ALPA USA Support of proposal but Agreed Additional Section 2 50 DGAC France suggest additional provisions material agreed and

NPA-OPS-15 Comment/Response Document Page 3 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response to allow for loss or theft. included 3 3 UK Flying Club Retain original text Agreed Avoid unnecessary administration See Annex 1 and 2 to 4 PDG Heli Ltd. (Falsification cannot be avoided) comment No:5 5 Note: activity vis-à-vis ICAO? 11 Lynton Av. Ltd 21 Maersk Air 39 IAOPA 42 BHAP 4 14 CAA Malta Allow copies to be carried for Partly See items above and comment 15 Sabena all documents (at the choice agreed No:20 ‘at the choice of’ is 20 AEA of the operator) considered unnecessary addition 24 EHA 29 Express 5 1 and 2 Bxl national airport For some documents copies Noted -- Proposal amended 8 and 9 Bond Helicopter Ltd should be acceptable accordingly. Legal opinion 18 British World Airline is that ICAO requires the original of some of the documents. 6 31 Skyjet AG, CH Useless to regulate; depends Noted on national law 7 28 FOCA Original of Flight Crew Not agreed Would cause problems at the time Add: ‘original or copy’ licence to be carried (subpara. of renewal of licence. b)

Subpart B. Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 276 DGAC Lux 1 002 139 AEA IEM 1.065(a): Delete Agreed Subject is already covered in para 256 CAAd Finland 2 of IEM 1.065 Deleted 2 201 DGAC France IEM 1.065(a) alternative Agreed

NPA-OPS-15 Comment/Response Document Page 4 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response suggestion to delete The following Subpart B comment/responses are an abbreviation of a lengthy and comprehensive explanation put to the OC as Working Paper 20.4B/00. For the full response, reference should be made to this WP. Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 3 096 ORCG 1.037(a): add ‘and maintain’ Agreed Will avoid doubt Words added. Substance of comment 4 200 DGAC France 1.037(a): Emphasise Flight Noted and incorporated by Safety Prevention programme discussed development of new paras. (b) and (c) 1.037(a)(2): Small operators, Occurrence Reporting Scheme is 5 115 Operator with few aeroplanes, will not an integral part of the Acc. be able to establish trends and Not agreed. Prevention and Flt. Safety Prog. -- should not be required to The Scheme will support the establish an occurrence operator’s ability to address reporting scheme. deficiencies and Flt. Safety. 041 IFALPA 1.037(a)(2): Reporters should Voluntary scheme removes 6 057 ALPA Germany have the right to remain Partly obligation to report. Complete Text amended to require 122 ECA anonymous or that the whole agreed anonymity would make info. operators to accept 173 OPSG scheme should be confidential difficult to disseminate anonymous reports and voluntary. 1.037(a)(4): new subpara. Most operators would appoint 7 LBA needed; ‘the appointment of a Agreed such a person but the JAR does Text amended accordingly person accountable for not actually require it. managing the prog.’ 041 IFALPA IEM 1.037(a)(2): upgrade to Value of this suggestion is negated 8 057 ECA AMC Not agreed by development of JAR-11 -- 173 SNPL proposals IEM: change the overall To restrict distribution as 9 039 Manufacturer objective from ‘dissemination Not agreed suggested might prevent the info. -- to other persons’ to reaching the interested parties ‘reporting to the Authorities’

NPA-OPS-15 Comment/Response Document Page 5 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 001 AEA 056 DGAC Lux IEM para 4: questions the 10 138 need for or the meaning of the Agreed Little reason to keep the para. Para. deleted. 193 Operators para. 275 Suggest that occurrences 11 41 IFALPA should remain in the database; 173 ECA the significance may not be Agreed Text amended accordingly apparent until later. 12 034 Dassault 1.085(b)(1): suggest align the Partly Meaning of ‘fault’ could include Word order changed (see 098 ORCG text with JAR-21 and/or agreed ‘failure’ JAR-21) and ‘fault’ include the word ‘fault’. introduced. 003 AEA Not all crew members would 140 DGAC Fr be competent to identify an 202 DGAC Lx ‘airworthiness’ problem. Partly Words “.. which he 13 277 Operator Suggest words ‘perceive’ or agreed believes may affect …” 227 IAOPA ‘believe’ or, alternatively included; ‘airworthiness’ 248 ERA delete ‘airworthiness’. retained. 098 ORCG Also four of these suggest additional para. to avoid the Agreed Additional words inserted. need for every crew member to report the same occurrence. - One comment included suggestion that it is wrong to Point taken but, on balance, it is 14 028 teach all crew members to Not agreed thought that most commanders make report; if they fail, this and operators would prefer to -- might absolve the operator of teach the need for reporting. ensuing responsibility. Need for crew members to The commander of any aeroplane 15 116 Operator (small a/c) report should not apply to Not agreed should know if one of the crew -- small aeroplane operators. have noticed something untoward. 1.085(b)(2); suggest delete 1.420 refers to incidents and this words ‘endangered or could para. relates to faults etc. which 16 099 ORCG have endangered’; all Not agreed might become incidents if not --

NPA-OPS-15 Comment/Response Document Page 6 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response incidents should be reported reported. under 1.420(a)

NPA-OPS-15 Comment/Response Document Page 7 Subpart C

Item Comment Commentor JAR-OPS Summary of Comment Operatio Reason for the Resulting Number paragraph ns Response change to Committe NPA text e Response 1 058 SNPL 1.175 (g) Deletion of "capable of exercising Not Not necessary to specifically operational control" is not acceptable agreed mention the capability; NPA text _ reflects the capability adequately 2 113 HQ Maintenance 1.175 (j)+ -No discriminant of 20 empl. (Delete Not NPA text is more prescriptive than Div (k) k) agreed maintenance proposal _ 278 DGAC - Lux. -2 persons minimum to cover four Not -For very small organisations 1 areas agreed person could be enough 3 130 CAA-UK 1.175 (j) Combination for flight ops or crew Noted training with maintenance is Combination flight ops/crew - acceptable training with maintenance should 301 CAA D " " " " but only for very small Noted only be made for small organisations organisations (economical reasons) 302 RLD-NL " Strongly opposing combination of Noted and subject to acceptance by the fl.ops with maintenance (balance Authority. Proper qualification of may be lost) the person is necessary. 239 Martinair " For size of Martinair no combination Noted (general) with maintenance is acceptable 4 004 Finnair 1.175 Appx Experience in aviation Delete Agreed Experience in military aviation is a Delete "civil" 141 AEA 2 para (a) "civil" valid one 203 DGAC-F 5 117 Skyjet (ZRH) 1.175 Appx Managerial competency in civil Agreed This change is necessary to start a see summary of 2 para (a) aviation acceptable to the Authority very small organisation the comment as appropriate (experience not necessary) 6 232 Air 2000 1.175 Appx technical or operational… (editorial) Not techn./operational means and/or 2 para (a) agreed which is the intention _ 7 059 SNPL 1.175 Appx Do not accept complete deletion of Not Requirement is covered in 1.175(g) 2 para (b)(3) old (b)(3) agreed as amended by NPA. _ See item 1 above

NPA-OPS-15 Comment/Response Document Page 8 Item Comment Commentor JAR-OPS Summary of Comment Operatio Reason for the Resulting Number paragraph ns Response change to Committe NPA text e Response 8 229 FOCA 1.175 Appx "unless acceptable to the Authority Not Flexibility is necessary and 2 (b)(3) new concerned " should be deleted agreed Authority is enititled to refuse if it ? wishes 9 233 Air 2000 1.175 Appx Change sequence to: "crew member Agreed To follow sequence of (c)(1) and See summary 2 (c)(3)(iii) and ground staff" (c)(2). Editorial 10 274 NCAA AMC 1.175 Agreement to NPA, based on Noted _ _ (i) experience in Scandinavia 11 112 HQ Maint. Div AMC 1.175 Give separate requirements for Nom. Noted The expertise needed for Nom. PH See comment (i) item 1.2 Postholder Maintenance. New item Maintenance indeed is different No.113 1.3 and is covered by para. 3 of same AMC 12 093 Britannia AMC 1.175 Britannia object to the requirement to Noted Comment not clear (i) 1.1-1.5 have airline experience _ 13 204 DGAC-F AMC 1.175 …the relevant parts of the operations Agreed Is covered by comment No. 112 See 112 (i) item manual 1.2(c) 14 118 Skyjet (ZRH) AMC 1.175 The exception mentioned at the Agreed The text in 1. mentions also Similar to the (i) beginning of 1. should be applicable "licensing". Therefore items 2, 3, one proposed in to all items. Re-numbering is propsed etc, should be covered by the the comment No. exception as well 118 15 004 Finnair AMC 1.175 - "management capabilities in Noted Change under 5 above covers this See comment 141 AEA (i) items 1.4 a…" 004 279 DGAC-Lux and 1.5 - sufficient work experience (5 Not The proposal would not really _ years considered sufficient) agreed change the requirement and the rewording under 14 will introduce the necessary flexibility 16 194 Monarch AMC 1.175 "…should hold, or has held within Not If this were agreed, both the See comment (i) item 2 the last five years, a valid…" Agreed Postholder and his Deputy could No. 194 be without a current licence. Intention is that one of them should be current.

NPA-OPS-15 Comment/Response Document Page 9 Item Comment Commentor JAR-OPS Summary of Comment Operatio Reason for the Resulting Number paragraph ns Response change to Committe NPA text e Response 17 111 HQ Maint. Div AMC 1.175 add: "as appropriate" Not The NPA text leaves enough (i) item 3.1 agreed flexibility; the word ‘relevant’ is _ used and item 14 above is also of relevance to this point. 18 110 HQ Maint. Div AMC 1.175 Delete para 3.3 as it is not necessary Not The acceptance of comment No. (i) item 3.3 to have knowledge on all types agreed 118 (see item 14 above) allows _ operated alleviations in particular cases and some knowledge is necessary – not full technical competence. 19 078 SNPNC AMC 1.175 Add a sentence that the Nom. Agreed See comment 205 DGAC-F (i) item 4 Postholder Training should be 078 or 205 assisted concerning Cabin Crew training. 20 228 IAOPA-EU AMC 1.175 "…current Type Rating Instructor on Agree? 249 ERAA (i) item 4 a type…" (Alleviation for small/start- ? up AOC holders) 21 023 Eurocontrol AMC 1.175 add (d) on reporting occurances Not 1.2(a) and (c) cover the case (I) item 1.2 according to Eurocontrol agreed _ requirements 22 119 Skyjet (ZRH) IEM 1.175 Text should be more precise and Not Impossible to be so precise See comment (j) and (k) specify: "…employed for tasks agreed No. 119 related to flight operation or maintenance by an operator…"

NPA-OPS-15 Comment/Response Document Page 10 Subpart D Note: Items 1 to 21 which follow are taken from OC WP 20.4/00 which should be examined for the complete response (see also items 3 onwards of Subpart B above) Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response 12.1 24 30 46 1 67 ‘Occurrence’ not used as a 100 Numerous 1.420(a) Terminology; Agreed term of its own. 129 suggest that the terms should Terminology aligned with 150 repeat those used in Annex 13 Annex 13 178 198 244 284 Terminology; suggest use of EC Directive text somewhat 2 295 SLV the text of the EC Directive Not agreed unclear and already agreed to -- follow Annex 13 (see 1 above) 1.420(b)(1); all reporting (b)(1) forms an essential link with 3 101 ORCG instructions should be in .420 Not agreed crew responsibilities which could -- (cross reference unnecessary) include incident reporting The para.(b)(4) mentions the .420(b)(2); aeroplane ‘organisation responsible’; this 4 35 Dassault manufacturer should also be Noted would include the manufacturer. No change informed (compare JAR-21) Also ORCG’s draft ACJ specifies what is meant by ‘organisation responsible’. 102 .420(b)(2); suggest remove Agreed Words removed words ‘malfunction or defect’

103,104 The 72 hour deadline for a 5 ORCG report should be in a separate Agreed Amended accordingly para. and clarification reqd.

NPA-OPS-15 Comment/Response Document Page 11 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response

129 Delete reference Agreed Deleted 12.2 AEA .420(b)(3); delete the last Without the sentence, there is a 6 150 Finnair sentence (report to Authority) Not agreed risk that an entry in Tech Log No change 284 DGAC Lx would be thought sufficient. .420(b)(4); replace ‘fault’ Partly 7 36 Dassault with ‘failure’ and ‘aircraft’ agreed ‘Fault’ would include ‘failure’ Text amended to with ‘aeroplane’ ‘aeroplane’ 105 ORCG .420(b)(4); replace 8 ‘manufacturer’ with Agreed ‘organization responsible’ Text amended accordingly 265 Austro Control Definition too narrow .420(c); ‘Serious incident’ 9 - LBA in committee and ‘Accident’ reporting Agreed Various changes to the should be associated para. 47 .420(c)(1); suggest add a time Partly Separate para.(c)(2) added 10 66 Several limit of 48 hrs to this para. agreed with a deadline specified 179 .420(c)(1); suggest additional 11 264 BAe words to allow for the fact Agreed Text amended accordingly 308 Austro Control that the commander may be a casualty .420(c)(1); delete words 12 106 ORCG ‘resulting in serious injury’ Agreed Text changed etc. This is implicit in definition .420(c)(1); should require 13 37 Dassault reporter to inform other Agreed Text changed agencies .420(d)(1); may be 14 12.3 AEA impractical to expect Agreed in Text modified to meet the 150.3 Finnair commander to submit a principle intent of comment written report

NPA-OPS-15 Comment/Response Document Page 12 Item Comment Commentor Summary of Operations Reason for the Resulting change to Number Comment Committee Response NPA text Response Commander remains the right Text changed to nominate 15 264.2 Austro Control .420(d)(3)(ii); insert ‘or the Agreed in person but may not be the one to the operator in the operator’ part find the damage commander’s absence 16 264.3 Austro Control .420(d)(5); insert ‘or the Not agreed Text already includes ‘in his -- operator’ absence the operator’ 17 133 CAA UK .420(d)(5); use same text as in Partly Not useful to use the whole text The last line of 1.1245 1.1245 agreed included 31 .420(d)(6); JAR-1 should The list is not intende to be 48 IFALPA include definitions for the Noted exhaustive, examples only 18 68 conditions listed 129.4 supported by several Already addressed elsewhere 180 Also include ‘loss of a/c nav. Not agreed (either in normal incident reports accuracy’ or in Air Traffic incidents) .420(d)(6); how is the 19 308.1 BAe commander aware of high Point taken Removed from list radiation? Suggests that 1.420 should Para.(d)(1), ‘Air Traffic Incidents’ 20 026 Eurocontrol cover wider issues such as Air Not agreed is sufficient for JAR-OPS -- Traffic Movement (ORCG’s draft ACJ covers ATC occurrences aspects) Would recreate difficulties which 21 129.1 OPSG Suggests change of title of Not agreed were encountered when 1.420 to ‘Incident Reporting’. ‘Occurrences’ were addressed in -- separate JARs

NPA-OPS-15 Comment/Response Document Page 13 Subpart E Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 1 00049 IFALPA A1-1.430 (h) Conversion not to be Partly accepted Suggested to be allowed in draft 00181 ECA used for planning pending the AWO ANPA which contains some more harmonisation criteria. The option only to allow conversion for DEST will be considered in the harmonisation. ANPA should be awaited. Margins are unchanged if conversion is for DEST only. 2 00069 SNPL A1-1.430 (h) Conversion not to be Partly accepted See above. Not allowing conversion 00216 DGAC-F used for planning and pending the AWO above 1500 m would effectively not for vis > 1500 m harmonisation raise the minima. 3 00013 Finnair A1-1.430 (h) Add ”forecasted and/or” Partly accepted (for 00151 AEA DEST only) pending 00285 DGAC-Lux the AWO harmonisation 4 00237 Air 2000 A1-1.430 (h), Change ”expressed” to Accepted Agrees that ”reported” would be ”If the RVR is expressed, note ”passed, reported, stated more clear reported as being or given” above..” 5 00252 ERA A1-1.430 (h), The note is not Accepted Agrees that there is a need to ”If the RVR is expressed, note understood and needs explain this not better. The change reported as being above clarification in the ANPA from RVR to the the maximum values RVR/Visibility may enhance the assessed by the understanding further. aerodrome operator, e.g. ”RVR more than 1500 m”, it is not…

JAR-OPS Subpart E Appendix 1 to JAR-OPS 1.440 Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 6 00245 Martinair Agrees withs the Noted

NPA-OPS-15 Comment/Response Document Page 14 proposal 7 0014 Finnair (h)(1) Remove the requirement Rejected Certification is done on a limited ----- 0152 AEA for verification at each number of runways/facilities. 00262 CAAd, runway for Cat III ops Experience has shown that Finland unexpected type/equipment specific problems can arise. An efficient exchange of information between operators will reduce the burden of the proving. This requirement is harmonised with FAA AC 120-28D 8 00217 DGAC-F (h)(1) Should only be Rejected See comment 00152 above plus the applicable to DEST not fact that planning minima for a Cat to ALTN and applicable III ALTN will be limited to Cat I to the aerodrome not the values. particular runway 9 00282 DGAC-Lux (h)(1) A number of approaches Noted The previous text comprising is not relevant without a conficence level and success rate spec for level of was considered to be too confidence. complicated. The proposed text is a simplified way of obtaining a comparable result. The requirement is harmonised with FAA AC 120- 28D.

NPA-OPS-15 Comment/Response Document Page 15 JAR-OPS Subpart E, AMC to Appendix 1 to JAR-OPS 1.440 Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 10 00015 Finnair 1.3 ”Models” should be Accepted Models are not used in JAR-OPS If an operator has 00153 AEA defined different variants of the 00263 CAAd, same type of aeroplane Finland utilising the same … … systems on the same type/classes of aeroplane … of each variant.

NPA-OPS-15 Comment/Response Document Page 16 Subpart G

JAR-OPS 1.510 Item Comment Commentor Summary of Comment Operations Committee Number Response 050 IFALPA The proposal should address all Cat I instrument approaches and not 1 070 SNPL just those with missed approach gradients greater than 2.5% 182 ECA 2 246 Martinair Suggests deletion of references to JAR-25 and JAR-AWO 3 016 Finnair Reference to work of ARAC PERF HWG Accepted in principle 154 AEA 4 218 DGAC Ditto 5 038 Dassault Ditto

The PERFSC has considered these comments and accepts that the proposed regulation should address all Category I instrument approaches, and not just those with missed approach gradients greater than 2·5%. However, recent discussions within the ARAC Aeroplane Performance Harmonisation Working Group (PERF HWG) have also included a focus on how to regulate obstacle clearance accountability during the go-around. These discussions are on-going and have the potential for further development of JAR-OPS 1.510.

Martinair Comment No. 000246 Relating To JAR-OPS 1.510 The PERFSC agree that the references to JAR 25 and JAR-AWO can be deleted. Finnair Comment No. 000016 Relating To JAR-OPS 1.510. AEA Comment No. 0000154 Relating To JAR-OPS 1.510 The PERFSC agrees with the comment. The ARAC PERF HWG discussions are on-going and have the potential for further development of JAR-OPS 1.510. DGAC Comment No. 000218 Relating To JAR-OPS 1.510 The PERFSC agrees with the DGAC comments and will aim to develop these proposals during the ARAC PERF HWG discussions which are on-going and have the potential for further development of JAR-OPS 1.510. Dassault Comment No. 000038 Relating To JAR-OPS 1.510 The PERFSC agrees with the comment with respect to deleting reference to JAR-AWO 243

NPA-OPS-15 Comment/Response Document Page 17 Subpart K

Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 1 155, 287 AEA, MOT Lux. AMC OPS Agreed without comments Noted -- As per FRSG proposal 1.720(c)/1.725(c) Referred to FRSG (to be circulated as new NPA) 2 266 Austro Control idem Refer to Annex 6 Part I Noted -- As per FRSG proposal dated July 1998 Referred to FRSG (to be circulated as NPA)

3 219, 220, 288, DGAC-F, MOT Lux., JAR-OPS 1.760 To make the rule and the Noted For response to items 3 to 10, see 017, 156 Finnair, AEA (a) IEM consistent, reword Referred to OSG Page 19, below JAR-OPS 1.760 and delete -- subpara. 3 and 4 of the IEM 4 247, 267 Martinair, Austro IEM OPS 1.760 Delete bullet 1 from the Noted -- Control IEM, since it duplicates the Referred to OSG rule 5 299, 300 LBA JAR-OPS 1.760 Disagree in total with the Noted -- and IEM NPA text; retain the Referred to OSG original text 6 191, 231 AIA, Air 2000 idem Agreed Noted -- Referred to OSG 7 051, 071, 183 IFALPA, SNPL, ECA IEM OPS 1.760 Disagree that the period Noted -- during which the first aid Referred to OSG oxygen may be necessary should be half of the flight time before landing after a cabin depressurisation 8 268 Austro Control IEM OPS 1.760 Propose some improvement Noted -- to the text of the IEM Referred to OSG

9 027 CAA-Cz IEM OPS 1.760 In IEM OPS 1.760 the Noted -- AMC OPS 1.770 AFM is quoted for Referred to OSG (b)(2)(v) emergency descent conditions, while in AMC OPS 1.770 (b)(2)(v) AOM is quoted 10 164, 269, 033, Various AMC OPS 1.770 -- Referred to Oxygen --

NPA-OPS-15 Comment/Response Document Page 18 Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 120, 121, 226, (b)(2)(v) Study Group 230, 253, 309

11 157 AEA JAR-OPS 1.800 Agreed Noted -- --

12 270 Austro Control JAR-OPS 1.800 Add a note to JAR-OPS Noted The proposed note is not No change 1.800, as per ICAO Annex necessary; a ‘rule’ should not say 6.2.4, to clarify that break- what is not required. in areas are not a requirement 13 052, 184, 072, IFALPA, ECA, SNPL, AMC OPS 1.830 Maintain the original text Not agreed Due to the space available in the Insert the word “readily” 089, 166, 271, ITF, ICCA, Austro (b)(2) in bullets 1, 1h and 2 raft, survival equipment cannot be in bullet 1 before 080 Control, SNPNC contained therein; the NPA text “available with”. allows that the survival equipment may be contained in a pack readily Insert the verb “be” in available with the raft. bullet 1 since it was The amount of water provided in wrongly deleted. the survival kit is a minimum quantity to be used for medical purposes. This does not prevent operators to increase the quantity as appropriate; in addition, the NPA text provides for alternative or additional means of producing drinkable water 14 134 CAA-UK AMC OPS 1.830 Clarification on glucose Noted NPA text didn’t change the intent In bullet 1h introduce the (b)(2) tablets to be carried of the AMC; editorial changes only word "of" before "glucose tablets" 15 158 AEA AMC OPS 1.830 Agree with NPA Noted -- -- (b)(2) 16 190 AIA AMC OPS 1.830 Change “First aid Not agreed JAR-OPS 1.830 requires that None (b)(2) equipment” into “First aid additional survival equipment for kit”. Specify the content of the flight to be undertaken must be the first aid kit for survival carried; it is to the operator to purposes specify which first aid equipment may need for this purpose. 17 189 AIA AMC OPS 1.830 Disagree with additional Not agreed JAR-OPS 1 is based on ICAO None

NPA-OPS-15 Comment/Response Document Page 19 Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response (b)(2) and survival equipment for Annex 6 which requires survival AMC OPS 1.835 commercial air transport equipment for long overwater (c ) aeroplanes and ask some flights and for flight over specific clarification designated land areas; harmonisation with FAA regulation and practices is beyond the scope of NPA 18 053, 073, 185, IFALPA, SNPL, ECA, AMC OPS 1.835 Propose to retain the Not agreed The amount of water provided in None 272 Austro Control (b)(2) existing text the survival kit is a minimum quantity to be used for medical purposes. This does not prevent operators to increase the quantity as appropriate; in addition, after an emergency landing, any drinking supply on board may be used by the survivors 19 074, 272 SNPL, Austro Control AMC OPS 1.835 Disagree that snow shovel Not agreed The snow shovel and ice saw are None (c) and ice saw are deleted considered unnecessary, since they from the survival were not used in practice for many equipment years and other means are easily available on board for the same purpose. Subpart L Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response 20 018, 159, 020 Finnair, AEA, SNPL JAR-OPS 1.865 Introduce the transition Noted Introduction of the transition No change; the comment period until 01.01.2001 in period in the rule would introduce has been overtaken by the rule (first option) the temporary exemption time mechanism in JAR-OPS 1; this is not convenient since it complicates the rule for a short period of practical application. EQSC suggests to leave the text of JAR-OPS 1.865(e) as proposed by NPA and refer to the preamble of

NPA-OPS-15 Comment/Response Document Page 20 Item Comment Commentor JAR-OPS Summary of Operations Reason for the Resulting change to Number paragraph Comment Committee Response NPA text Response JAR-OPS 1 to delay implementation of this paragraph to 1.1.2001 as allowed by TGL no.16 21 135 CAA-UK JAR-OPS 1.865 Transfer the TGL no.16 Noted This procedure has been used on None into an exemption policy other occasion for JAR-OPS No action is necessary 27 CAA (Czech) (second option) requirements (ELT, ACAS, etc.) since TGL no.16 may be considered as a JAA exemption policy

NPA-OPS-15 Comment/Response Document Page 21 Subpart K (Oxygen items deferred to OSG by EQSG)

Item Comment Commentor JAR-OPS Summary of Comment Operations Reason for the Resulting change to Number paragraph Committee Response NPA text Response 1 219, 288, DGAC-F, MOT JAR-OPS To make the rule and the IEM Partially agreed It was not intended to change the In JAR-OPS 1.760 changed the 017, 156 Lux., Finnair, 1.760 (a) consistent, reword JAR-OPS 1.760 requirement in Section 1; subpara 3 word “provided” with “shall be AEA and delete subpara. 3 and 4 of the and 4 only explained the most sufficient”, to clarify that the IEM. probable conditions for the requirement address the calculation of the quantity of first aid oxygen. To avoid any contradiction calculation of first aid oxygen. to the rule, the IEM has been In addition, the text has been reworded. amended to require at least 2 portable dispensing units. IEM-OPS 1.760 has been reworded to specify the conditions under which the calculation of first aid oxygen is made. 2 247, 267 Martinair, Austro IEM OPS Delete bullet 1 from the IEM, since Agreed Editorial mistake in the NPA text. The content of subpara. 1 of the Control 1.760 it duplicates the rule. IEM is deleted (A new text has been introduced to clarify the meaning of the rule). 3 299, 300 LBA JAR-OPS Disagree in total with the NPA Not agreed The NPA text has been proposed to The new text of subpara. 1 of IEM 1.760 and IEM text; propose to retain the original answer the concerns of some industry OPS 1.760 together the one in text. representatives which indicated that subpara 2 are provided to calculation of first aid oxygen in harmonise the meaning of accordance with JAR-OPS 1.760 requirement in JAR-OPS 1.760. would impose to carry a huge amount of oxygen bottles on board. The scope of the proposed IEM-OPS 1.760 was to specify the applicable criteria and conditions for the calculation of first aid oxygen. In the calculation of first aid oxygen, the operator should consider that full coverage to all passengers on board is provided by the supplemental oxygen as calculated i.a.w. Appendix 1 to JAR-OPS 1.770 for any period when

NPA-OPS-15 Comment/Response Document Page 22 Item Comment Commentor JAR-OPS Summary of Comment Operations Reason for the Resulting change to Number paragraph Committee Response NPA text Response the cabin altitude remains above 15000ft. Therefore the proposed text is not intended to reduce the amount of first aid oxygen available for supply to passengers who require it after the emergency descent. 4 191, 231 AIA, Air 2000 idem Agreed with the NPA. Noted -- None

Item Comment Commentor JAR-OPS Summary of Comment Operations Reason for the Resulting change to Number paragraph Committee Response NPA text Response 5 051, 071, IFALPA, SNPL, IEM OPS Disagree that the period during Agreed The sentence in subpara 4 of the IEM See the IEM as reworded. 183, 220 ECA, DGAC-F 1.760 which the first aid oxygen may be was introduced as an assumption for necessary should be half of the the calculation of first aid oxygen, flight time before landing after a under the most probable conditions cabin depressurisation. which may occur after a cabin depressurisation. Since the meaning of the sentence has been misunderstood by more than one commentor, it is agreed to remove it and the reword the IEM. 6 268 Austro Control IEM OPS In subpara. 3: take into account the Agreed in The conditions for the calculation of The concept has been expressed 1.760 route to be flown. principle first aid oxygen should consider the in other words in the reworded minimum en-route altitude. subpara. 4. In subpara. 2b: make reference to Appendix 1 to JAR-OPS 1.770. Agreed Reference to Appendix 1 to JAR- As suggested by the commentor. OPS is more accurate. 7 027 CAA-Cz IEM OPS In IEM OPS 1.760 the AFM is Noted The prevailing reference should be See the reworded subpara. 4 of the 1.760 quoted for emergency descent the AFM; nevertheless, to avoid IEM. AMC OPS conditions, while in AMC OPS contradictive information, reference 1.770 (b)(2)(v) 1.770 (b)(2)(v) AOM is quoted. to AFM has been removed from IEM OPS 1.760, since the operator should know where to find the emergency descent profile and conditions.

NPA-OPS-15 Comment/Response Document Page 23 Item Comment Commentor JAR-OPS Summary of Comment Operations Reason for the Resulting change to Number paragraph Committee Response NPA text Response 8 164, 120, Ausburg AMC OPS Change 17 sec in place of 20 sec. Agreed Figure provided in advisory material AMC modified accordingly. 121, 253, Airways, 1.770 (b)(2)(v) associated to FAR 25.841, acceptable 230, Tyrolean for type certification of the aeroplane. Airways, ERAA Change VRA to VMO or the speed specified in the AFM. Agreed Reference to the AFM is feasible for the safety of the flight. Ask for 10 min oxygen between FL150 and FL130. Not agreed This would change the reference requirement, which is out of the scope of the NPA.

Item Comment Commentor JAR-OPS Summary of Comment Operations Reason for the Resulting change to Number paragraph Committee Response NPA text Response 9 033, 230 Brymon Airways As above No time delay before starting the Not agreed No time delay is unrealistic; to None Bombardier emergency descent (in addition to perform the required actions before the proposed change of VRA to starting the emergency descent, pilots VMO). need some time; this is recognised also by type certification compliance demonstration procedures. 10 226 Airbus As above Add in the title “ not certificated to Agreed Editorial As proposed by the commentor fly above 25000ft. 11 309 Not known As above In para 2a delete “at his own Agreed Not necessary for the purpose of the None discretion”. AMC. 12 269 Austro Control As above Change “estimated mass” to Not agreed Already rejected by OC when the test None “critical mass”. provided by EQSC was endorsed for NPA.

NPA-OPS-15 Comment/Response Document Page 24 Subpart M Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 019 Finnair Flt. In accepting that the Cabin Partially The Cabin Defect Log is intended to (Para. 1); … Where a means of 160 Ops. Defects Log can be an Accepted record all cabin items which require recording defects or malfunctions in 1 221 AEA extension of the Tech Log, attention; the wording used should not the cabin or galleys that affect the safe 289 DGAC alternative wording is exclude non-safety related entries. operation of the aeroplane or the 109 Conseiller Ops suggested. safety of its occupants, separate from JAA Maint … etc. Div v. Details of any failure, defect or 2 040 Dassault Amend AMC OPS 1.915 2 Agreed Compare JAR-21.3 malfunction to the aeroplane … … Aviation Section 3v to align with JAR- emergency systems and any failure, 21 defect … etc.

Note; the changes (which are noted above) to the text distributed at NPA have been agreed with the JAA’s Maintenance Division.

NPA-OPS-15 Comment/Response Document Page 25 Subpart N JAR-OPS 1.970 RECENT EXPERIENCE Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 1. 000054 IFALPA The recency requirements for See comment Nil. 000186 ECA commander and co-pilot should be 3 below. the same and should include the co- pilot carrying out at least 3 take-offs and landing as a pilot. 2. 000054 IFALPA Supports 6 take-offs and landings (a Noted This is more restrictive and is not Nil. minimum of 3 on simulators) in the supported at all. The JAR-OPS rule preceding 60 days as pilot-flying; conforms with the ICAO including 3 instrument departures requirement. and 3 instrument approaches; one manual; and 125 hours per six months. 3. 000222 DGAC France For a co-pilot, to have served at the Accepted. Co-pilots recency in JAR-OPS 1.970 JAR-OPS 1.970, controls for 3 take-offs and landing is should comply the requirements of Para (a) (2) not considered sufficient. The ICAO. It is proposed that the text be “...... unless he has operated the requirement should be to have amended to read “...... unless he has controls as a pilot for three take- operated the controls. operated the controls as a pilot for offs and landings...... ” three take-offs and landings...... ” Note: There must be the flexibility for simulator use for co-pilot recency as for commander. JAR-OPS 1.980 OPERATION ON MORE THAN ONE TYPE OR VARIANT Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 1. 000296 Luftartsverket- The period of validity for proficiency Noted. A solution to this problem cannot be Note 1: This has been raised 000161 Sweden check for validation or renewal of achieved by amendment of JAR- several times in JAR-OPS 1/JAR 000290 AEA type rating should be the same as for OPS. The anomaly arises from the FCL co-ordination meetings 000020 DCA the operator’s proficiency check. In wording of JAR-FCL which takes including February 2000. Luxembourg this respect JAR FCL should be co- account of the problems of PPL Note 2: DGAC France and CAA Finnair ordinated with JAR-OPS and not administration. UK have a particular interest. vice versa. There is no reason why the flexibility in JAR-OPS 1 is not reflected in JAR FCL.

NPA-OPS-15 Comment/Response Document Page 26 Subpart O

JAR-OPS 1.1010 CONVERSION AND DIFFERENCES TRAINING Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 1. 000171 ICCA Text to include a statement that Noted The NPA-OPS 15 proposed text Nil. & conversion and differences training states that conversion and differences 000085 be specified in the OM and be training be approved by the approved by the Authority. Authority. JAR-OPS 1 Subpart ‘P’ already requires that cabin crew training be specified in the OM. Further reference is not considered necessary. The NPA-OPS 15 proposed text is consistent with the relevant text of JAR-OPS 1.1005 & JAR-OPS 1.1015.

APPENDIX 1 TO JAR-OPS 1.1015 RECURRENT TRAINING Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 1. 000076 SNPL The 3 yearly interval for practical Not accepted. The majority of the FCCCSG did not Nil. 000084 ITF checks (ie exit operations and fire- consider that a reduction of the 3 000223 DGAC (France) fighting) was inadequate and should yearly criteria was justified or had be reduced to either every 2 years or been substantiated by the comments to annually. received. The cabin crew organisations did not accept the Group’s decision. DGAC considered that 2 years was a reasonable compromise. The majority of the Group were also satisfied that JAR- OPS 1 Subpart ‘O’ was in compliance with ICAO Annex 6,

NPA-OPS-15 Comment/Response Document Page 27 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response Chapter 12. (Comment Number 16 also refers.) 2. 000172 ICCA The interval of 3 years is of primary Not accepted. As above. Nil. concern in respect of maintaining the required level of competence. 3. 000172 ICCA In order to ensure maintenance of the Not accepted. The statement is not supported at all. Nil. 000081 SNPNC required skills and competence No documented evidence has been recurrent training should be provided submitted to support the claim that an annually. acceptable level of competence is not being maintained. Many items of recurrent training are required to be addressed on an annual basis. 4. 000172 ICCA Cabin crew do not necessarily Not accepted. It is accepted that for some cabin Nil. operate doors in normal operations. crew, especially cabin crew operating Therefore some cabin crew will have wide-bodied aircraft types, door no experience of operating an exit for operation is not achieved during up to 3 years. normal operations. However, JAR- OPS 1.1015 does require annual training for exit ‘touch drills’. 5. 000076 SNPL The interval of 3 years is not Not accepted. The statement is not supported. The Nil. sufficient for new entrant cabin crew initial training required by JAR-OPS in respect of fire-fighting. 1.1010 combined with the conversion and differences requirements of JAR- OPS 1.1010 provides for comprehensive fire fighting training for new entrant cabin crew. (Comment Number 1 also refers.) 6. 000081 SNPNC Vital that exit operation and fire- Noted. The proposed amendment regarding Nil. fighting be completed yearly. the need for exit operation to be Proposed that for exit operation this conducted in normal and emergency be achieved in the normal and modes including the required actions

NPA-OPS-15 Comment/Response Document Page 28 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response emergency modes, including the and forces, is not considered to be actions and forces required to operate relevant to this NPA-OPS 15 the associated evacuation means. proposal. However, the Group did consider that there was some merit in this specific proposal and that it should be re-submitted through the NPA process. 7. 000081 SNPNC It is proposed to change the three Noted. Not relevant to this NPA-OPS 15 Nil. yearly requirement for life-raft proposal. The SNPNC proposal training from a demonstration of the should be subject to the NPA equipment to the actual use of the process. equipment. 8. 000081 SNPNC It is proposed to amend the fire- Noted. Not relevant to this NPA-OPS 15 Nil. fighting requirements to add the proposal. The SNPNC proposal word ‘actual’ fire. should be subject to the NPA process. 9. 000084 ITF Many operators conduct such Noted. The JAR-OPS 1 requirements are a Nil. training on a more frequent basis. minimum standard and do not preclude operators from providing additional training. 10. 000084 ITF The current proposal will lower Not accepted. This statement is not substantiated. Nil. European standards. The cabin crew safety standards of many JAA states has been significantly enhanced by the introduction of the JAR-OPS 1 Subpart ‘O’ requirements. 11. 000084 ITF The standard is lower than the Not accepted. The comment that the JAR-OPS 1 Nil. requirements of FAR 121. requirements falls below the FAR 121 requirements is not accepted. The FAA does not restrict the number of aircraft types that a cabin

NPA-OPS-15 Comment/Response Document Page 29 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response crew member can operate on as required by JAR-OPS 1.1030, nor does it specify a recency requirement as in JAR-OPS 1.1020. Any comparison on training intervals required by JAR-OPS 1 and FAR 121 should take into account these additional requirements of JAR-OPS 1. 12. 000162 AEA FAA requirements are not Noted. It is agreed that the FAA does not Nil. 000291 DCA (Lux) comparable with JAR-OPS 1 since in restrict the number of aircraft types 000021 Finnair FAR 121.417 there is no restriction that a cabin crew member can on the number of aircraft types nor is operate on as required by JAR-OPS there any criteria for recency. 1.1030, nor does it specify a recency requirement as in JAR-OPS 1.1020. Any comparison on training intervals required by JAR-OPS 1 and FAR 121 should take into account the additional requirements of JAR-OPS 1. 13. 000084 ITF The current requirement is not Noted. Compliance with the very detailed Nil. compliant with criteria contained in guidance in the ICAO Cabin the ICAO Cabin Attendant Safety Attendant Training Manual is not Training Manual. mandatory for ICAO Contracting States. It is ICAO Annex 6, Chapter 12 that requires compliance and this is achieved by JAR-OPS 1 Subpart ‘O’. 14. 000084 ITF A complete review could be Noted. The JAA NPA OPS 15 letter dated Nil. conducted to establish precise and 25th June 1999 states that “It was 000081 SNPNC specific requirements for the agreed that the FCCCSG would in recurrent training items listed. due course, return to the task of

NPA-OPS-15 Comment/Response Document Page 30 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response reviewing para. (c) of the Appendix. An interim minor change is included in this NPA in order to invite comment and the FCCCSG will return to the discussion when comments have been received”. This item had been reviewed in-depth by the Group in 1997 and the majority of the Group considered that any such proposal from the cabin crew organisations should be subject to the NPA process. The cabin crew organisations did not agree with this position. There would appear to be no movement by the majority of the Group to reduce the frequency of three yearly recurrent training requirement. However, there was some degree of support for reviewing the detail of the actual training requirements in order to determine if specific enhancements might be made, (eg item 6 above). 15. 000162 AEA The current requirement to remain Noted. The majority of the Group accepted Nil. 000291 DCA (Lux) unchanged at 3 years as outlined in this comment but this position was 000021 Finnair the NPA-OPS 15 proposal. not agreed by the cabin crew organisations. 16. 000162 AEA The JAA FCCCSG have conducted a Noted. It is confirmed that the FCCCSG Nil. 000291 DCA (Lux) review of JAR-OPS 1 against ICAO (Subpart ‘O’ Group) conducted a 000021 Finnair and have concluded that JAR-OPS 1 comprehensive review in 1997 of the requirements are well above the JAR-OPS 1 Subpart ‘O’

NPA-OPS-15 Comment/Response Document Page 31 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response standards of ICAO Annex 6, Chapter requirements in relation to the ICAO 12. requirements specified in ICAO Annex 6, Chapter 12. This review clearly identified that JAR-OPS 1 Subpart ‘O’ exceeds the ICAO requirements of Annex 6, Chapter 12. One shortfall was identified in respect of JAR-OPS 1.1010 which NPA-OPS 15 proposes to amend by requiring that Conversion and Differences training be ‘approved’ by the Authority. 17. 000162 AEA The JAA OC discussed this issue Noted. The JAA OC discussed this at OC Nil. 000291 DCA (Lux) taking into account the JAA 2/99 and determined that NPA-OPS 000021 Finnair FCCCSG review of JAR-OPS 1 and 15 included an explanatory text. The ICAO Annex 6, and determined that subject would be revisited when the 3 year criteria be retained. comments were received. (Comment Number 16 also refers.) 18. 000162 AEA Changing the requirements in this Noted. There is no doubt that increasing the Nil. 000291 DCA (Lux) respect would result in a considerable frequency of training would directly 000021 Finnair cost impact to the disadvantage of result in an increase in the industry’s JAA operators. training costs. It was noted that AEA have not substantiated the level of cost increase. 19. 000162 AEA Future changes to JAR-OPS cabin Noted. This is a matter for JAA Nil. 000291 DCA (Lux) crew recurrent training requirements Headquarters in conjunction with the 000021 Finnair should be based on well founded and JAR 11 Rule Making Procedures for comprehensive cost safety benefit CBA (Cost Benefit Assessment). studies. 20. 000162 AEA Accident analysis does not provide Accepted. No evidence has been submitted Nil. 000291 DCA (Lux) tangible proof that reducing intervals regarding in-service incidents or

NPA-OPS-15 Comment/Response Document Page 32 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 000021 Finnair between recurrent training will accidents in respect of a shortfall in improve safety. cabin crew actions resulting from any inadequacy in the frequency of cabin crew recurrent training. (Comment Number 5 also refers.) No accident recommendation could be identified proposing that exit training and/or fire training be undertaken at more frequent intervals than the current requirements. However, the cabin crew organisations were of the opinion that accident analysis does not necessarily take into adequate account the actual performance of cabin crew during emergencies. 21. 000162 AEA Most AEA airlines are already Noted. No further comment. Nil. 000291 DCA (Lux) conducting more frequent additional 000021 Finnair training as required by JAR-OPS 1. 22. 000162 AEA AEA airlines comply with JAR-OPS Noted. No further comment. Nil. 000291 DCA (Lux) as a minimum and are satisfied with 000021 Finnair the results of their training programmes.

JAR-OPS 1.1030 OPERATION ON MORE THAN ONE TYPE OR VARIANT Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response 1. 000082 SNPNC Primary importance that variants be Partially The Group recommends that the text JAR-OPS 1.1030, Paragraph (b) 000086 ITF considered as different types if accepted. be amended to read “...... in each of “...... in each of the following differences in any of the 3 aspects the three following aspects”. Such aspects....”. (door operation, location and type of an amendment will not in any way

NPA-OPS-15 Comment/Response Document Page 33 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response portable equipment & type specific affect the applicability of the rule but procedures). The current wording may go some way to clarify the could be mis-interpretated. requirement.

2. 000083 SNPNC Proposal to specify exactly what is Noted. The current listing of emergency Nil 000224 DGAC (France) meant by the different types of procedures is not intended to be 000090 ITF specific emergency procedures. exhaustive. The most important aeroplane type specific emergencies have been listed in the NPA-OPS 15 proposal. 3. 0001?8 ICCA When changing aircraft types during Accepted. Since safety equipment may differ IEM OPS 1.1030, Paragraph 4 000225 DGAC (France) a series of sectors the cabin crew between aeroplane types to be “...normal and emergency 0000087 ITF briefing required by AMC OPS 1.210 operated during a series of flights, procedures and safety equipment 000083 SNPC should be complemented by the Group recommends that that text applicable to the actual aeroplane information such as safety be amended to read “...... normal types to be operated”. equipment, relevant to the specific and emergency procedures and types to be operated. safety equipment applicable to the actual aeroplane types to be operated”. 4. 000082 SNPNC Cabin crew members should have Not accepted. The Group considered that this was Nil 000086 ITF minimum experience level on one unnecessary. The NPA comment is aircraft type before commencing not substantiated. training on another aircraft type. 5. 000082 SNPNC Cabin crew operating on more than Noted. This is already required by other Nil 000086 ITF one type must comply with all sections of JAR-OPS 1, eg JAR-OPS 000170 ICCA Subpart ‘O’ requirements for each 1.988 and JAR-OPS 1.175 (j) and aircraft type. (k). 6. 000170 ICCA For operations on more than one Noted. This is already addressed in JAR- Nil aircraft type, the operator shall OPS 1 Subpart ‘P’ (Appendix 1 to specify appropriate procedures and JAR-OPS 1.1045 A 5).

NPA-OPS-15 Comment/Response Document Page 34 Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response restrictions in the OM and that these be approved by the Authority. 7. 000170 ICCA Minimum experience levels should Noted. The criteria for familiarisation is Nil be taken into account when specified in JAR-OPS 1.1012 and designating a new entrant cabin already addresses this issue. For the crew member to a new aircraft first aircraft type to be operated cabin type. crew complete supernumerary flights and must be in addition to the minimum number of required cabin crew. 8. 000169 ICCA IEM OPS 1.1030 should refer to Not accepted. The Group did not accept the need Nil IEM OPS 1.280 in respect of seat for a cross-reference. There are restrictions at emergency exits. many cross-references that could be included in Subpart ‘O’, and in the other JAR-OPS 1 Subparts, but this is not considered necessary.

NPA-OPS-15 Comment/Response Document Page 35 Subpart P

Item Comment Commentor Summary of Comment Operations Reason for the Resulting change to Number Committee Response NPA text Response App 1 to 1.1045 11(a); suggests The form of words suggested 1 107 ORCG inserting a ‘type and level’ of Not agreed does not match anything in -- occurrence 1.420. Occurrences are categorised but without a level or type. 022 DGAC Lx Para. 11(b) of the Appendix; Text amended to incorporate these 026 AEA suggestions that the forms themselves suggestions 2 107 Finnair should be in the Ops Manual and that Agreed 163 ORCG other occurrences should be added after 292 incidents and accidents 3 077 SNPL App 1 to 1.1045 para A. 2.5 Noted Considered to be a matter for - Inflight inspections should only be JIP performed by qualified airline captains employed by the authority 4 055 IFALPA Para A.2.5 Noted Considered to be a matter for - ECA …authorised personnel in accordance JIP with ICAO doc 8335 5 199 Monarch Para A 13 …operational arrangements for (i) text too vague Partly Agreed The amended text makes this leasing, associated procedures and clear management responsibilities

- (ii) change number from A 13 to A 1 Not Agreed or A 16 Comment is not clear 6 254 ERA Para A 13 Not Agreed There are important Remove para as it is of no importance operational implications for day to day operations

NPA-OPS-15 Comment/Response Document Page 36