General. Note: in Addition to the Comments Which Were Received on the Specific Proposals, Some Commentors Made Comments Or Suggestions of a General Nature
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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 Portugal 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 Air Malta 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 Alitalia 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 Finnair 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.