RedBelt
3rd Apr 2020, 09:52
Maximum distance from an adequate aerodrome for two-engined aeroplanes without an ETOPS approval
Some years ago, during the change from EU-OPS/JAR-OPS legislation to European rules, EASA fostered the participation of stakeholders as in any legislation change.
At the time, this was under EU-OPS 1.245 which basically stated, for Class A aeroplanes (§ 1.) that if the aircraft had 20 seats or more and more than 100.000 lbs (45.360 Kg) it was limited to 60 minutes away from an adequate aerodrome, otherwise an ETOPS approval would be required for the operator.
The point in case was (§ 2.) for aircrafts with a maximum approved passenger seating configuration of 19 or less and also less than 100.000 lbs (45.360 Kg), which includes the majority of business jets specially the ones that nowadays can fly over 6000 NM.
2. Performance Class A aeroplanes with:
(i) a maximum approved passenger seating configuration of 19 or less; and
(ii) a maximum take-off mass less than 45 360 kg,
the distance flown in 120 minutes or, if approved by the Authority, up to 180 minutes for turbo-jet aeroplanes, at the one-engine-inoperative cruise speed determined in accordance with subparagraph (b) below;
The FAA, for Part 91 do not establish any requirements for this kind of operation but, for Part 135 it states the aircraft can fly up to 180 minutes without ETOPS approval (CFR Part 135.364 also AC 135-42).
Considering all the possible adequate aerodrome alternates in the world and a typical business jet, the “no-fly” zones are very few if 180 minutes is considered (hash orange lines). This means for all the FAA registered aircrafts operating under Part 135, this represents practically no limitation (see picture).
https://cimg2.ibsrv.net/gimg/pprune.org-vbulletin/859x468/180_min_circles_16a68304b5a6cc59db6d5fb1bc4f7a8e2b0eef0b.jpg
180 minutes exclusion zones considering a OEI of 370 TAS
For EASA the case was different from the beginning. Only aircrafts with a maximum approved passenger seating configuration of 19 or less and also less than 100.000 lbs (45.360 Kg) were allowed to operate without an ETOPS approval but only up to 120 Minutes, from 120 minutes up to 180 minutes an operational approval by the National Aviation Authority was required.
The company that I was working for at the time was most probably the first company in EASA to seek operational approval for this kind of operation. We witnessed the confusion between this kind of operation and pure ETOPS. This confusion was and still is present in aircraft manufactures, National Aviation Authorities (NAA) and operators in general.
The reason?
Very simply the association of the word ETOPS and the extreme similarity with the concept with both operations.
FAA does not have different ETOPS rules based on class/category of airplanes, EASA does!
So, most of the knowledge about ETOPS nowadays is derived from all those operators, regulators and Aircraft Manufactures in the pure concept of ETOPS (SPA.ETOPS.100 and AMC 20-6).
EU-OPS 1.245 was changed to CAT.OP.MPA.140 with exactly the same title, one of the proposals during this change was for the operations “approved by the Authority, up to 180 minutes” to have a distinct name to differentiate then from ETOPS (covered by SPA.ETOPS.100 and AMC 20-6). Several names were proposed nevertheless business aviation had very little weight and nobody could see any major problem.
There are several implications of this difference in concepts and regulations from the FAA and EASA that can be summarized in a mixture of requirements and rules from pure ETOPS (covered by SPA.ETOPS.100 and AMC 20-6) and operations under CAT.OP.MPA.140 (d).
The above problem, in my opinion might have a better chance to be solved with Regulation (EU) 2019/1387. The weight restriction for operations under CAT.OP.MPA.140 (d) was removed, so aircrafts like the Airbus 318 (versions up to 19 seats) will start operating under this confusing concept and as we all know Airbus have a complete different leverage compared to Aircraft Manufactures of pure business jets like Gulfstream or Bombardier.
Some years ago, during the change from EU-OPS/JAR-OPS legislation to European rules, EASA fostered the participation of stakeholders as in any legislation change.
At the time, this was under EU-OPS 1.245 which basically stated, for Class A aeroplanes (§ 1.) that if the aircraft had 20 seats or more and more than 100.000 lbs (45.360 Kg) it was limited to 60 minutes away from an adequate aerodrome, otherwise an ETOPS approval would be required for the operator.
The point in case was (§ 2.) for aircrafts with a maximum approved passenger seating configuration of 19 or less and also less than 100.000 lbs (45.360 Kg), which includes the majority of business jets specially the ones that nowadays can fly over 6000 NM.
2. Performance Class A aeroplanes with:
(i) a maximum approved passenger seating configuration of 19 or less; and
(ii) a maximum take-off mass less than 45 360 kg,
the distance flown in 120 minutes or, if approved by the Authority, up to 180 minutes for turbo-jet aeroplanes, at the one-engine-inoperative cruise speed determined in accordance with subparagraph (b) below;
The FAA, for Part 91 do not establish any requirements for this kind of operation but, for Part 135 it states the aircraft can fly up to 180 minutes without ETOPS approval (CFR Part 135.364 also AC 135-42).
Considering all the possible adequate aerodrome alternates in the world and a typical business jet, the “no-fly” zones are very few if 180 minutes is considered (hash orange lines). This means for all the FAA registered aircrafts operating under Part 135, this represents practically no limitation (see picture).
https://cimg2.ibsrv.net/gimg/pprune.org-vbulletin/859x468/180_min_circles_16a68304b5a6cc59db6d5fb1bc4f7a8e2b0eef0b.jpg
180 minutes exclusion zones considering a OEI of 370 TAS
For EASA the case was different from the beginning. Only aircrafts with a maximum approved passenger seating configuration of 19 or less and also less than 100.000 lbs (45.360 Kg) were allowed to operate without an ETOPS approval but only up to 120 Minutes, from 120 minutes up to 180 minutes an operational approval by the National Aviation Authority was required.
The company that I was working for at the time was most probably the first company in EASA to seek operational approval for this kind of operation. We witnessed the confusion between this kind of operation and pure ETOPS. This confusion was and still is present in aircraft manufactures, National Aviation Authorities (NAA) and operators in general.
The reason?
Very simply the association of the word ETOPS and the extreme similarity with the concept with both operations.
FAA does not have different ETOPS rules based on class/category of airplanes, EASA does!
So, most of the knowledge about ETOPS nowadays is derived from all those operators, regulators and Aircraft Manufactures in the pure concept of ETOPS (SPA.ETOPS.100 and AMC 20-6).
EU-OPS 1.245 was changed to CAT.OP.MPA.140 with exactly the same title, one of the proposals during this change was for the operations “approved by the Authority, up to 180 minutes” to have a distinct name to differentiate then from ETOPS (covered by SPA.ETOPS.100 and AMC 20-6). Several names were proposed nevertheless business aviation had very little weight and nobody could see any major problem.
There are several implications of this difference in concepts and regulations from the FAA and EASA that can be summarized in a mixture of requirements and rules from pure ETOPS (covered by SPA.ETOPS.100 and AMC 20-6) and operations under CAT.OP.MPA.140 (d).
The above problem, in my opinion might have a better chance to be solved with Regulation (EU) 2019/1387. The weight restriction for operations under CAT.OP.MPA.140 (d) was removed, so aircrafts like the Airbus 318 (versions up to 19 seats) will start operating under this confusing concept and as we all know Airbus have a complete different leverage compared to Aircraft Manufactures of pure business jets like Gulfstream or Bombardier.