Académique Documents
Professionnel Documents
Culture Documents
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
3.
SUBJECT TITLE Authorisation of Aerodromes Rescue and Fire Fighting Services (RFFS)
4.
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
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.
1
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
2
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
[(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.]
9.
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.
7
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
8
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.
9
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
10
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.
12
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
13
14