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pilot licensing, air operations and operational
suitability. We would like to thank each one of you for having gone to the time and effort to provide meaningful comments which will help us to improve the proposals. The work on the implementing
measures for pilot licensing is already quite advanced, while we are at the very early stages
of reviewing the comments on the other NPAs.
Due to the exceptional circumstances and in order
to ease the potential weight of comment response
documents and resulting text proposals, we will apply advanced working methods for the comments on the requirements for authorities, organisations, air operations and operational suitability.
While taking into account the individual comments received, we will provide a summary of the responses to the comments in order to concentrate
on improving the text. We are developing a tabular format to clearly show the changes made, as well as related justifications. The plan is to include
references to EU-OPS/JAR-OPS 3 and ICAO SARPS, as applicable.
We plan to publish the comment response tables and resulting text using a phased approach between
March and December 2010. To meet the legal
deadlines we will have to stick to the 2 months publication period for the comment response tables,
as provided for in the Agency’s Rulemaking procedure. This will probably mean that the publication
periods for individual packages will not overlap. However, the Agency will regularly inform stakeholders about the comment review progress.
Regarding the structure, the total system approach and consequently the horizontal structure of the authority and organisation requirements are maintained.
This includes the general requirements and additional requirements for aero-medical centres and approved training organisations as well as commercial operators and non-commercial operators
of complex motor-powered aircraft. Taking into account the views of stakeholders, we will adapt the sub-structure of Part-OPS by separating the requirements into dedicated parts for Commercial
Air Transport, non-commercial operations (i.e. recreational and business aviation), Special Approvals (e.g. low visibility operations, dangerous
goods, etc.) and other operations (e.g. aerial work, training flights and test flights). The change is depicted below.
The approach established by EASA and the Commission
also touches upon a number of important
GEN
CAT
CAT
OTHER
OPERATIONS
OTHER
OPERATIONS
SPA
Present structure as included in the NPA on air operations
GEN
CAT
OTHER
OPERATIONS
SPA
Envisaged structure after comment review
principles for processing the related NPAs. These include producing proposals that are aligned as closely as possible to existing standards (ICAO SARPs, Community law and adopted JARs) and that can be easily adopted during the Comitology process.
Consideration is given to safety and regulatory principles (e.g. changes stemming from the Basic Regulation) and proportionality to avoid undue burden for general aviation and small/medium enterprises. The EASA proposals will provide the necessary balance in terms of safety and level playing
field as well as hard and soft law. As is the case today, the draft implementing rules and Agency measures (CS, AMC, GM) are being developed in parallel.
Jules Kneepkens
10. 2009
03
Europeaean Aviation Safety Agency
EASANEWS
Second Extension_ A phased approach for publishing
NPAs will also be used for the ATM/ANS and aerodromes implementation measures. EASA has proposed 3 distinct terms of reference to address the extension of scope to ATM/ANS and will concentrate
its rulemaking activities now on Air Navigation
Service Provisions, Air Traffic Controller Licensing
and requirements for competent authorities in ATM/ANS. In the field of aerodromes, EASA has already
initiated the preparatory work and envisages no further prioritization for the development of the implementation measures at this stage. The EASA proposals will build on existing rules and material and will take account of the available expertise (Eurocontrol,
GASR). The horizontal rule structure of authority and organisation requirements proposed under the first extension will be followed.
This coordinated approach by EASA and the Commission
which is welcomed by the Management Board, provides a clear way forward in the further processing of the first extension tasks following the extensive debate in reaction to the associated NPAs. It embraces 4 key elements: the modification
of the proposed rule structure with implementing
measures which are readily understandable
by those who have to comply with them, prioritisation of the work, alignment with existing standards and proposals for transition measures. The second extension will benefit from the clarification
　
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