Proposal No (for EASA use only):..

European Aviation Safety Agency Rulemaking Directorate

Rulemaking Proposal Form

1. PERSON/ORGANISATION PROVIDING THE PROPOSAL: Name : Organisation : Address: Country: Contact: Phone : Fax : E-mail : Date : 2. Operations Procedures Steering Group Joint Aviation Authority Transition EASA Cologne Germany OPSG Chairman Captain Claude Godel +33 141 568008 +33 141 568009 clgodel@airfrance.fr May 3, 2007

RULE NUMBER (Basic Regulation/IR/CS/AMC, etc) (e.g. CS 25.XXX) (If new rule state New Rule and appropriate regulation/code) Amendment to EU OPS/JAR OPS 1.220 Authorisation of Aerodromes

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SUBJECT TITLE Authorisation of Aerodromes Rescue and Fire Fighting Services (RFFS)

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DESCRIPTION OF PROBLEM / BACKGROUND The guidance to operators in EU-OPS/JAR-OPS 1 on the subject of acceptable Rescue and Fire Fighting Services (RFFS) at an aerodrome is deficient. This proposal attempts to address this shortcoming. Existing routes today utilise aerodromes that do not always meet the ICAO Annex 14 RFFS levels specified for the type of aircraft using the aerodromes. This document explores the risks and draws conclusions about the acceptability of this risk for aircraft operations at aerodromes where this is the case, in particular: At aerodromes that are normally used that never meet the RFFS levels specified by ICAO. At aerodromes nominated as alternate aerodromes, i.e. not the normal aerodrome. At aerodromes where the RFFS is temporarily downgraded. to any supporting documents i.e. Accident

Include reference reports/analysis):

There is no standard or recommended practice for RFFS in ICAO Annex 6, Operation of Aircraft, nor is there any reference to the RFFS table found in Annex 14. The conclusion drawn from this omission is that ICAO believes that this does not compromise operational safety. If ICAO believed that there was a need for any operational Standards and Recommended Practices (SARPS), there would be a recommendation in Annex 6. The OPSG has proactively taken full account of Annex 14 RFFS SARPS in the compilation of this NPA, but this work must not be misunderstood as an attempt to redefine the standards therein.
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This proposal has taken as guidance the RFFS categories as defined in ICAO Annex 14. However, the standards in Annex 14 are applicable to the regulation and management of aerodromes and there is no direct crossover to the regulation of aeroplane operators. This difference is explained in this document, but it is important to note that the proposals included in this NPA are intended to be used by aeroplane operators. Aerodrome management must continue to comply with the Standards And Recommended Practices contained in ICAO Annex 14 and in accordance with the regulatory authority of their country. ICAO Annex 14, Aerodromes contains RFFS standards and recommended practices applicable to the management of aerodromes for aeroplanes normally (departure and destination) using the aerodrome. However, Annex 14 clearly states that: This annex contains standards and recommended practices and certain facilities and technical services normally provided at an aerodrome. It is not intended that these specifications limit or regulate the operation of an aircraft. Annex 14 is intended to manage the risk which an aerodrome is exposed to frequently, which it does by prescribing the required amounts of fire fighting foam, equipment and manpower based on the size of the largest aeroplane normally using the aerodrome. Annex 6 is intended to manage the risk, which an operator is exposed to infrequently. One is not intended to regulate the other nor is one intended to undermine the other. The JAA OPSG has given full consideration to the latest amendments of Annex 14 in the compilation of this proposal. Some aerodromes, through poor planning, financial or organisational reasons, regardless of the number of movements of the largest aeroplanes, keep the aerodrome RFFS category permanently below the Annex 14 standard. ICAO definitely wants to eliminate this practice. Aeroplane operators should not be penalised for this situation, but they must ascertain if the provision of RFFS is adequate for the intended operation, this NPA proposes to do that. Operators based at such an aerodrome and who use it frequently, may be unhappy with the situation described above and may approach the aerodrome and its authority to request that they raise the RFFS to the correct Annex 14 level. In any case EU-OPS/JAR-OPS rules should not be used to implement a higher or a lower standard of RFFS, which is the responsibility of the aerodrome authority and should be in accordance with Annex 14 and the rules of the aerodrome managements national authority. Enforcement of the RFFS standards required by Annex 14 is the responsibility of the authority in charge of the aerodrome. Annex 14 does not stipulate any RFFS category for alternate aerodromes. The main reason being that the aerodrome RFFS level has to be selected to meet the traffic that normally operates at that aerodrome. By definition, alternate aerodromes are designated in the flight plans only as likely to be used. The aerodrome has no information about the number of flights and size of aeroplane for which this aerodrome is designated as an alternate. Furthermore, it is not possible to estimate the number of flights and size of aeroplane that will divert to this aerodrome. It is also impossible to be sure that the number of movements used to raise an aerodrome RFFS level, will be reached solely by diverting aeroplanes. Thus, effectively, Annex 14 can only deal with the aerodromes
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normally used for departure and destination. This proposal continues the logic of Annex 14 to the extent that alternate aerodromes are so infrequently used for diversion that the exposure to the risk of a lower RFFS category is very limited (low probability of diversion to that aerodrome multiplied by very low risk of a diverting flight needing to use the RFFS). The risk assessment looks at this in more detail. In addition, the proposed rule is limited in application to the alternate aerodrome that is selected and specified in the operational flight plan at the planning stage. Any aerodrome selected in flight as an emergency alternate is covered in the proposal to provide the commander with the flexibility to land as soon as possible if required. In a similar manner to that in which Annex 14 is not to regulate operations, EUOPS/JAR-OPS rules shall not be used to justify any misuse of the Annex 14 rules by aerodrome management. The JAA OPSG understands the concerns of the operator and their national authority and would like to emphasise that EUOPS/JAR-OPS rules shall never be established, nor used, to justify a lower standard for an aerodrome. The aeroplane operator can only make decisions based on company operations and the risks and probabilities therein. The JAA OPSG concluded that if ICAO wanted the RFFS standards and recommended practices from Annex 14 to apply to the operation of aeroplanes they would transpose them into Annex 6. Since this is not the case, it is clear from ICAO that operations should not be constrained by such a rule. Standards vary around the globe and in addition there are situations where an aerodromes normal RFFS level is reduced on a temporary basis. This NPA defines the required level of emergency services for the safety of passengers whilst maintaining sufficient flexibility to cater for the operational variability that will be experienced in worldwide operations. There are three situations considered in this proposal. The first concern is that not all aerodromes in all areas of the world follow the RFFS standard as defined in Annex 14. Secondly, aerodrome operators do not provide the RFFS category if their aerodrome is only nominated as an alternate. If large aeroplanes seldom use an aerodrome, it may be unable to justify the higher RFFS category economically. The third case under consideration is where an aerodrome RFFS category is temporarily downgraded. The problem is to assess the risk to operations in these circumstances particularly associated with those aerodromes that are infrequently used. 5. OBJECTIVE OF PROPOSAL (How does the proposal intend to address the problem? Include recommendations from Working Groups, research studies, etc. (where available)) The purpose of this proposal is to provide clarity concerning the issue of the minimum RFFS category required for an operator to authorise use of an aerodrome specified in the operational flight plan. EU-OPS/JAR-OPS 1.220 does not at present prescribe any RFFS category. This situation has resulted in many questions from operators. Therefore, the intended effect is to provide a clear rule for aeroplane operators on the minimum RFFS category acceptable in certain circumstances. The intention of this proposal is to remove the present ambiguity, which exists in EU-OPS/JAR-OPS 1, by providing an operational rule with a clear definition for operators and flight crews of what constitutes an acceptable level of RFFS.

Proposal No (for EASA use only):..

6. SCALE OF THE ISSUE (Aviation sectors affected (number of aircraft, organizations, persons) Global. Affects all Commercial Air Transport. 7 7.1 IMPACT SAFETY IMPACT

Safety will be improved by the introduction of a mandatory minimum standard of RFFS applicable to all operators and authorities, because it removes the possibility of misinterpretation. A risk assessment has been carried out as detailed in the Justification paragraph. 7.2 ECONOMIC IMPACT

The OPSG estimates that there will be no adverse economic impact since this proposal confirms established best practice. 7.3 OTHER IMPACTS (Environmental, social, harmonization, aviation requirements outside EASA scope, issues of equity & fairness)

Harmonisation The proposal is more restrictive than Annex 6. The proposal is consistent with FAA regulations. Environmental Fuel savings arising from the ability to choose closer destination alternates with the consequence that less fuel is carried and burned resulting in lower emissions at departure aerodromes. 8. PROPOSED TEXT (If developed)

EU-OPS/JAR-OPS 1.220

Authorisation of Aerodromes by the Operator

[(See IEM OPS 1.220)] [(See EU-OPS/JAR-OPS1.192)] [(See Appendix 1 to EU-OPS/JAR-OPS 1.220)] [(See ACJ to Appendix 1 to EU-OPS/JAR-OPS 1.220)] An operator shall only authorise use of aerodromes that are adequate for the type(s) of aeroplane and operation(s) concerned.

Proposal No (for EASA use only):.. [Appendix 1 to EU-OPS/JAR-OPS 1.220 Authorisation of Aerodromes - Emergency Services] [(See ACJ to Appendix 1 to EU-OPS/JAR-OPS 1.220)] [a. Definitions: 1) RFFS Category: Rescue and Fire Fighting Services Category as defined in ICAO Annex 14. 2) Aeroplane RFFS Category The Category derived from ICAO Annex 14 Table 9 -1 for a given aeroplane type. 3) Aerodrome RFFS Category: The published RFFS Category for a given aerodrome. b. The Operations Manual shall contain the Aeroplane RFFS Categories for the types of aeroplane to be operated. c. At the planning stage, if the Aeroplane RFFS Category is not available at one or more of the aerodromes required to be specified in the operational flight plan, an operator shall ensure that the available Aerodrome RFFS Category at those airports meets at least the criteria in Table 1 (Minimum Aerodrome RFFS Category) at the time of expected use.]

Proposal No (for EASA use only):.. [Table 1 - Minimum Aerodrome RFFS Category AERODROMES (Required to be specified in the operational flight plan)(7) Departure and Destination Aerodrome Take-Off Alternate, Destination Alternate and other Adequate En-Route Alternate Aerodromes(5) ETOPS En-Route Alternate Aerodromes Minimum Aerodrome RFFS Category Published Aerodrome RFFS Category (Normally available) One category(1) below the Aeroplane RFFS Category, but not lower than category 1. Two categories(2) below the Aeroplane RFFS Category, but not lower than category 1. RFFS Category 4 (3) equivalent at 30 minutes notice(4) Temporary Downgrade as published via Notam(6) Two categories(2) below the Aeroplane RFFS Category, but not lower than category 1. RFFS Category 4(3)

No downgrade

(1)

Two Categories for all-cargo operations. Three Categories operations. for all-cargo

(2)

(3)

Or Two Categories below the Aeroplane RFFS Category, if this is less than RFFS Category 4 but not lower than Category 1. For an ETOPS en-route alternate aerodrome, a published RFFS Category equivalent to Category 4, available at 30 minutes notice, is acceptable. An En-Route Alternate Aerodrome required to be adequate and specified in the operational flight plan (e.g. the 3% ERA). See ACJ to Appendix 1 to EUOPS/JAR-OPS 1.220. If an individual aerodrome serves more than one purpose, the highest required category corresponding to that purpose at the time of expected use must be available.

(4)

(5)

(6)

(7)

Proposal No (for EASA use only):.. d. Selection and specification in the operational flight plan of an aerodrome with an RFFS category below that stated in Table 1 requires acceptance by the Authority on a case-by-case basis. e. In flight, the commander may decide to land at an aerodrome where the Aerodrome RFFS Category is lower than specified above, if in his judgement and after due consideration of all the prevailing circumstances, to do so would be safer than to divert.

ACJ to Appendix 1 to EU-OPS/JAR-OPS 1.220 - Authorisation of Aerodromes Emergency Services Temporary Downgrade A downgrade of aerodrome RFFS category notified by Notam. In the scope of this ACJ, temporary should be limited to 72 hours without further reference to the Authority.]

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JUSTIFICATION (Why should your proposal be adopted?, How and to what extent is it likely to address the problem?) At present EU-OPS/JAR-OPS 1 allows the practice of operating to aerodromes without any defined level of RFFS. EU-OPS/JAR-OPS 1.220 allows interpretation as to the adequacy or otherwise of an aerodromes RFFS category. This has led to a variety of standards, as the interpretation can be different from operator to operator and from NAA to NAA. This proposal has been developed with the intention of filling a gap in the regulations and removing the possibility of different interpretations by setting one standard for all operators. The group considered the option to adopt the Annex 14 RFFS standards as a requirement for operators and thereby to limit RFFS category N aeroplanes to RFFS category N aerodromes. However, it was agreed this approach would be unnecessarily restrictive. It would close some routes, require operators to carry large amounts of fuel for alternate aerodromes and force diversions when there was a temporary reduction of RFFS. Making fewer aerodromes available for use and increasing the number of diversions would have a negative impact on safety. Therefore, the JAA OPSG decided to find a sensible level of RFFS to maintain safety while providing sufficient operational flexibility for operations. Annex 14 states that it is not intended to set standards for operations, only for aerodromes. An aerodrome must set a standard of RFFS adequate for all the types of movements, which it normally receives; whereas, an aeroplane operator views his exposure to risk somewhat differently, especially in the case of an alternate aerodrome which is rarely used.

The JAA OPSG made an assessment of how to apply standards intended for aerodromes to operations. The group concluded that the mission of RFFS is to save lives in the event of an accident, especially if it involves fire. The risk is that such an accident occurs. The group examined the following criteria in assessing the level of RFFS to propose.
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Frequency of exposure or number of movements Aerodrome hazards The opinion of fire fighting experts Existing RFFS policy of respected European operators Risk Assessment

Frequency of exposure or number of movements The JAA OPSG agreed that the frequency of exposure (number of movements) to the risk should be used as the key criteria in allocating a level of RFFS to an aerodrome based on its estimated utilisation. Historically, this method was used in ICAO Annex 14 to apply a remission factor based on a number of movements. This philosophy was based on the assumption that the probability of an accident occurring increases with the number of movements. Therefore, an individual aerodrome with thousands of movements has a higher probability of an accident or incident than an aeroplane operator with only a few movements at that aerodrome. In the case of an alternate aerodrome where the operator of the aeroplane has very few, if any, movements the probability of an accident is low. In accepting a lower RFFS category at such an aerodrome the aeroplane operator is exposed to the risk of a reduced level of manpower and fire fighting foam being available to deal with a fire, but the low frequency of movements means that the exposure is low. Aerodrome hazards The JAA OPSG considered if there were particular aerodromes with a higher risk of an accident. Aerodromes are graded A, B and C, based on the operational procedures, with A being the easiest and acceptable to all flight crew with no special training and C being the most challenging and requiring additional preparation and training for nominated pilots only. The OPSG believe that this is sufficient mitigation to cover the additional difficulties. The difficulties to operate on aerodromes category B and C have no link with the aerodrome RFFS category. The opinion of fire fighting experts The JAA OPSG consulted with aerodrome fire fighting experts from Paris ADP RFFS Management. When questioned about the JAA OPSG proposal, specifically 2 RFFS categories below the Annex 14 standard for the operator, the chief manager and the head of training of the Paris airport RFFS gave following answers: 2 RFFS categories below the Annex 14 standard is acceptable for an aeroplane not normally using the aerodrome. 2 RFFS categories below Annex 14 standard is sufficient to deal with all external fires (e.g. Wheel, engine, .. fires) If the aerodrome RFFS category of an aerodrome is downgraded or stays below the RFFS category of the largest aeroplane normally using it for a long
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time, the Authority regulating the aerodrome will impose and publish official access limitations. (in compliance with Annex 14). It is in the common interest of the aeroplane operator and the RFFS management to keep some flexibility by allowing such exceptional alleviations. For example, the temporary absence of one fireman (e.g. sickness) can downgrade the aerodrome RFFS category by one level even though the complete capacity of the fire fighting media and equipment remains available and manned. In this case if the aerodrome was using the 1 RFFS category below the Annex 14 standard alleviation because there were fewer than 700 movements, allowing an exceptional use of 2 RFFS categories below Annex 14 standard would not be dangerous. The French law (Dcret n 2001-26 du 9 janvier 2001) allows 24 movements per 3 months of any higher aeroplane category (even if the aerodrome RFFS category is 3 or 4 RFFS categories below the Annex 14 standard). This in line with the general principle of using statistics when determining aircraft safety levels. The proposed NPA does not raise any other comment.

Other fire fighting experts were also consulted. The former JAA OPSG Chairman came to the same conclusions after a previous study when he questioned British Airway's Fire Protection Manager, a former fire professional who had attended the relevant ICAO panel meetings as an IATA observer, and some independent researchers at Cranfield and Greenwich Universities were also consulted. Existing RFFS policy of major European operators The existing RFFS policies of 3 major European airlines (Air France, Lufthansa and British Airways) were considered. The long established practice of these major airlines in Europe without adverse incidents based on the recent history of operational experience is the use of 1 (temporarily 2) categories below the Annex 14 RFFS category for operations at departure and destination aerodromes. The JAA OPSG believes that this gives enough operational flexibility without compromising operational safety. This is common practice in many major airlines and has not produced any data to contradict the assessment that this practice is safe. The airlines considered all have excellent safety records, quality and safety management systems and are universally regarded as safe and responsible operators. Therefore this NPA accordingly allows a 1 (temporarily 2) categories below the Annex 14 RFFS category for operations at departure and destination aerodromes.

Risk Assessment This risk assessment is based on the principles found in International Standard IEC 300-3-9 Dependability Management Part 3: application Guide Section 9: Risk analysis of technological systems. This standard describes a structured process that identifies both the likelihood and the extent of adverse consequences arising from a given activity, facility or system. Therefore we can use this to assess the adverse consequences (physical harm to people, property or the environment) of the proposed activity.
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The risk analysis attempts to answer three fundamental questions: What can go wrong (by hazard identification)? How likely is this to happen (by frequency analysis)? What are the consequences (by consequence analysis)?

a. Risk Analysis Personnel In accordance with the guidelines the risk analysis process will follow a defined sequence of steps. The JAA OPSG as a group has in its membership much of the knowledge to complete this analysis, but supplemented this by consulting fire experts. b. Scope Analysis The reason for this risk assessment is that at present there is no guidance or regulation in existence either in ICAO Annex 6 or EU-OPS/JAR-OPS 1 for aeroplane operators as to the standard of RFFS that they should apply in using aerodromes. There is only an ICAO standard for aerodrome managers and this is limited in application to the aerodrome for aeroplanes normally using that aerodrome as a destination. There is therefore a gap in the operational regulation which operators have frequently asked to be filled. This risk assessment attempts to make a judgement on minimum standards of RFFS that should be specified based on the usage of the aerodrome to be assessed. c. Hazard identification and initial consequence evaluation The RFFS category of an aerodrome prescribes manpower, equipment and fire fighting media, based on the width and length of the largest aeroplane normally (departure and destination) using the aerodrome. The assumption is that more passengers and fuel on larger aeroplanes will require more manpower, equipment and media to fight a fire. The objective of aerodrome RFFS is to save lives in the event of an aircraft accident or incident occurring on, or in the vicinity of an aerodrome. As a rapid intervention force the response time is to be 2 minutes, but not exceeding 3 minutes from initial call, to producing foam at a minimum of 50% of the discharge rate. During aeroplane certification all large passenger aeroplanes must demonstrate the ability to evacuate completely in 90 seconds. There is therefore no correlation between the size of the aeroplane and the length of time an evacuation will take. Furthermore, there is not necessarily a linear relationship between the size of the aeroplane and the size of any fire. However, it is likely that an evacuation will take longer on a large aeroplane especially if a fire that may render some exits unusable complicates it. The RFFS will be required to fight the fire for long enough to allow the evacuation and move the passengers away from the danger area, this may take several minutes. It is not intended to save the hull, only to save lives. The hazard is therefore identified as a situation where an aeroplane has an accident with a fire that the available RFFS is unable to fight for long enough to save the lives of all the passengers. The size of the aeroplane could be a factor, but likewise the size of the fire could be the issue. This will always be an unknown. Hence, Annex 14 uses size of the aeroplane as a logical criterion, but it assumes that a large aeroplane equals a large fire and this link will not always be true. In evaluating the consequence of not being able to fight the fire for long
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enough to evacuate the aeroplane the conclusion could be a loss of life. However, whatever the size of the fire and the category of the RFFS there will always be some fire fighting capability available to suppress the fire and assist the evacuation. d. Risk estimation The risk is that an aeroplane has an accident with a fire that the aerodrome RFFS cannot fight for long enough to allow evacuation and life is lost. This scenario could occur with maximum RFFS facilities, since it is possible for a small aeroplane to have a big fire. There is no historical data to make us believe that this risk is significant. However, exposure to this risk is limited in this proposal by limiting movements and thereby reducing frequency of exposure to aeroplanes at aerodromes with lower RFFS categories. e. Frequency analysis It is impossible to assess whether an aeroplane will ever have an accident or incident with a fire that it is not possible for the available RFFS to fight. There does not appear to be any historical evidence of this. The principle applied in this proposal is to limit the frequency of exposure to the risk associated with a lower category of RFFS. Allowing the most reduction to aerodromes, which are used as alternates and / or infrequently used, achieves this. Further reduction is allowed for ETOPS flights because of the increased standard of system reliability required for ETOPS aeroplanes, which further reduces the likelihood of a diversion. Finally, this document proposes lower RFFS in case of temporary depletion, but in this case by defining temporary, limits exposure to 72 hours. f. Consequence Analysis The consequence of an aeroplane landing with a fire at an aerodrome with reduced RFFS was discussed with the Chief Fire Officer of Aeroport De Paris (ADP), the company responsible for the management of the Paris aerodromes. In his expert opinion RFFS 2 categories below the Annex 14 standard for the size of aeroplane would be sufficient to fight all external fires such as wheel fire, engine fire etc. Historically category 4 has been allowed for ETOPS en-route alternates and this is based on the capability of category 4 RFFS to completely contain a fire of the size, of a wheel fire possibly caused by a brake over heat on landing. A larger fire could be suppressed, but for a shorter period of time. ETOPS has additional system reliability, which reduces the likelihood of a diversion. g. Risk calculation The risk is that using the proposed RFFS categories causes a fatality. There is no data available, as a result of events, upon which to base a calculation of risk. However, the JAA OPSG estimates that since the proposal is more restrictive than existing operational rules and established practice the risk is extremely remote. h. Uncertainties The uncertainty is that there is a possibility of an uncontrolled fire on every size of aeroplane, but it is an extremely remote possibility. An example is the accident involving a British Airtours B737-200 at Manchester in 1985. During the takeoff roll, the aircraft suffered an uncontained failure of the left engine, which tore a fuel line and ignited a massive fire. Although the takeoff was successfully aborted, 55 passengers and crew could not escape the aircraft before being
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overcome by smoke and fumes. It should also be noted that this accident occurred at an aerodrome (Manchester) with an RFFS level significantly greater than that required for a B737. i. Verification The JAA OPSG believes that the experts consulted inside and outside the group adequately addressed the problem. The JAA OPSG in consultation with fire experts has carried out hazard identification and risk estimation. The frequency analysis has been based on the experience of the group, as has the consequence estimation. Summary of the risk, consequences, frequency and mitigations 1. What is the risk?

The risk is that the aeroplane has an accident with a fire that the available RFFS cannot contain for long enough to facilitate the evacuation of passengers. 2. What are the consequences of being exposed to the risk?

In the worst case the consequence of being exposed to this risk is that some aeroplane occupants are not able to evacuate and there is a loss of life. The RFFS category proposed in this NPA is still considered capable of containing this risk with an acceptable probability. 3. What is the frequency of exposure and how do the proposed mitigations reduce exposure to the risk? The highest exposure to the risk is at the departure and destination aerodromes because these are used most frequently; hence, at these aerodromes, the proposed RFFS category is higher. Where other aerodromes are less likely to be used because they are en-route alternates or because of the increased reliability of ETOPS flights, the exposure is reduced further and thus in the opinion of the group a lower level of RFFS is acceptable to cover this greatly reduced exposure to the risk. For the same reason the temporary downgrade of an aerodromes normal RFFS level is limited to 72 hours in order to limit the number of flights exposed to the risk. Departure and Destination Aerodrome The JAA OPSG has confirmed with ICAO that the RFFS requirements in Annex 14, volume I, Chapter 9 are for aeroplanes normally using the aerodrome and this phrase does not include an aeroplane using the aerodrome as a destination alternate or an en-route alternate. By definition, a diversion to an aerodrome is not normal use of that aerodrome. Hence, Annex 14 only addresses the departure and destination aerodromes. This methodology is consistent with U.S. FAR 139 If Annex 14 were to be simply applied to operations: it would allow an aeroplane to fly many times per day to an aerodrome A with aerodrome B as the nominated alternate. The probability of diverting to aerodrome B is not remote and Annex 14 would not prevent a diversion to B even with an available RFFS category of almost zero. The proposed NPA would never allow such an operation. Therefore this proposal seeks to bring some safe and operational clarification.

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It is anticipated that if an aeroplane starts to use an aerodrome as a destination the aerodrome management will increase the aerodrome RFFS category to comply with Annex 14 because this aeroplane would be considered as normally using the aerodrome. An analysis of destinations by operators who are represented on the OPSG revealed that there are very few destinations, which do not comply with the Annex 14 standards for the type of aeroplane operated. Exceptionally such aerodromes were only one category below Annex 14 and discussions with RFFS experts revealed that this would not restrict the capability of the fire service significantly. In this case, the proposals contained in this proposal permit safe but realistic global operations, requiring the operator to ensure that the aerodrome RFFS category is not more than 1 (temporarily 2) level(s) below the Annex 14 table. Alternate aerodrome Alternate aerodromes tend to have lower RFFS standards than would normally be required. These aerodromes are so infrequently used that the owners are unwilling to upgrade their facilities for the small possibility of receiving a diversion. If Annex 14 RFFS categories were adopted for these aerodromes it would have the effect of causing operators to re-route flights nearer to better equipped aerodromes and to carry additional fuel for distant destination alternates. It would also restrict the operating crews options in the event that diversion became necessary. The OPSG believe it is better and safer to have more aerodromes, and aerodromes, which are closer to track, available for a diversion even if some of them are slightly below the Annex 14 standard. If EUOPS/JAR-OPS 1 adopted the Annex 14 standard this would not oblige aerodrome operators to upgrade their RFFS facilities, but the effect would be negative for the aeroplane operator. For nominated alternates 2 categories below the Annex 14 standard is proposed as the JAA OPSG has concluded that the limited exposure to a diversion will not significantly increase the risk. ETOPS En-Route Alternates For ETOPS en-route alternates category 4 is allowed; justified by the increased reliability of ETOPS flights reducing the likelihood of a diversion. Temporarily downgraded RFFS If an aerodrome RFFS category is temporarily reduced for a short time period this should not cause a diversion. The amount of the reduction and the length of time it is allowed have been specified in the proposal. For a destination aerodrome, 2 categories below the Annex 14 standard may be used, but in mitigation this is limited to 72 hours, reducing the exposure to the lower RFFS category. For alternates the lowest category allowed is category 4 (or 2 categories below the aeroplane RFFS category if this is less than RFFS category 4, but not lower than category 1) also limited to 72 hours. 10. OTHER COMMENTS

Adopting this proposal sets a standard for operators to follow. It removes the undesirable situation where different interpretations of EU-OPS/JAR-OPS 1.220 can exist. It also gives operators a framework within which to work by recognising that, in practice, there will be occasions when the RFFS standard will be lower than expected and it sets minimum standards for such circumstances. The disadvantage of this is that, by being prescriptive, there may be occasions when operations may be prohibited by this rule. However, the JAA OPSG felt that the benefits of having clear
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rules outweighed this disincentive. The JAA OPSG would like to recommend mandating of Annex 14 standards for the future, but the fact is that aerodromes have not universally adopted the standard. The present operational regulations leave operators without guidance, so this proposal, whilst not going all the way up to Annex 14 levels, is a big step in the right direction for getting this area of operations regulated. The options proposed in this proposal set a standard, which reflects existing custom and practice, removes any doubt or confusion and the possibility for different interpretations. To summarise the JAA OPSG position is that to facilitate global operations where the application of Annex 14 standards is not universal, RFFS categories of 1 category below Annex 14 for normal operations can be permitted at departure and destination aerodromes with no adverse safety implications. The JAA OPSG also propose standards of RFFS for alternates that are appropriate for aerodromes that are infrequently used and in case of temporary downgrades where the reduction in cover is for a short finite period of time. Therefore, it is the option, which the OPSG recommends. Send your proposal to: RWPD@easa.eu.int .. (For EASA use only ) Date Received:

Acknowledgement Receipt Sent: Initial Assessment: Date Responded to Proposer:

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