EASA OPS Rulemaking Proposals (NPA 2009-2 etc)
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Join Date: May 2009
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EASA OPS Rulemaking Proposals (NPA 2009-2 etc)
EASA NPA 2009-1, which includes the future EASA OPS rules, has a comment deadline of 31st July. It is linked with EASA NPA 2008-2 (Authority and Organization Requirement). It will replace EU-OPS in the near future See Rulemaking | Notices of Proposed Amendment (NPAs)
Reading through the EASA NPAs I wonder whether EASA rulemaking staff has ever seen an airplane? It seems a complete mess which will put flight safety at risk and will lead to a lot of unnecessary administrative burden for the airline industry i.a.
1) the EASA NPAs are very confusing
2) Important EU-OPS safety requirements have been downgraded to guidance material for example the definition of adequate aerodromes!
3) A lot of differences have been introduced resulting in a complete drift away from EU-OPS. It seems EASA has decided to throw away years of professional work by JAA and replace it with a bureaucratic monster which might put the lifes of EU passengers and crew at risk.
In conclusion this EASA rulemaking is a disaster in making. We should all submit one comment to EASA and the Commission as well as MEPs: urge them to stick to EU-OPS and only introduce changes where there is a safety reason!
Reading through the EASA NPAs I wonder whether EASA rulemaking staff has ever seen an airplane? It seems a complete mess which will put flight safety at risk and will lead to a lot of unnecessary administrative burden for the airline industry i.a.
1) the EASA NPAs are very confusing
2) Important EU-OPS safety requirements have been downgraded to guidance material for example the definition of adequate aerodromes!
3) A lot of differences have been introduced resulting in a complete drift away from EU-OPS. It seems EASA has decided to throw away years of professional work by JAA and replace it with a bureaucratic monster which might put the lifes of EU passengers and crew at risk.
In conclusion this EASA rulemaking is a disaster in making. We should all submit one comment to EASA and the Commission as well as MEPs: urge them to stick to EU-OPS and only introduce changes where there is a safety reason!
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The industry and other aviation stakeholders did express their concerns during the rulemaking development at EASA at various occassions. Well-founded and constructive concerns were ignored. Those NPAs are the result of a flawed EASA rulemaking process combined with a lack of expertise at EASA on flight ops matters.
In this context, I would like to draw your attention on the Commission Opinion on the evaluation of EASA (C(2009)3220final, 5/5/2009) which states '
‘The Commission is concerned by the potential consequences of the provisions of notice of proposed amendments on air operations (OPS) recently published by the Agency. The Commission believes that it is of paramount importance to guarantee that implementing rules to be adopted in this field reproduce the existing relevant legislation (EU-OPS Regulation 3922/91). This will ensure continuity and coherence with such legislation and therefore certainty for the industry. It will also allow the Agency to immediately start carrying out the related standardization inspections. All effort should be deployed to avoid any delay in the adoption of the implementing rules’
The fact that the Commission has publicly expressed its concerns on those EASA NPAs should not be a suprise. Completely changing EU-OPS both in concent and concepts can not be justified on safety grounds and was never intended by the EU legislator (Council and European Parliament).
Let's hope it will have the desired effect. In the mean-time we should all submit our comments before 31/7/2009 urging EASA to realign its rulemaking with EU-OPS.
In this context, I would like to draw your attention on the Commission Opinion on the evaluation of EASA (C(2009)3220final, 5/5/2009) which states '
‘The Commission is concerned by the potential consequences of the provisions of notice of proposed amendments on air operations (OPS) recently published by the Agency. The Commission believes that it is of paramount importance to guarantee that implementing rules to be adopted in this field reproduce the existing relevant legislation (EU-OPS Regulation 3922/91). This will ensure continuity and coherence with such legislation and therefore certainty for the industry. It will also allow the Agency to immediately start carrying out the related standardization inspections. All effort should be deployed to avoid any delay in the adoption of the implementing rules’
The fact that the Commission has publicly expressed its concerns on those EASA NPAs should not be a suprise. Completely changing EU-OPS both in concent and concepts can not be justified on safety grounds and was never intended by the EU legislator (Council and European Parliament).
Let's hope it will have the desired effect. In the mean-time we should all submit our comments before 31/7/2009 urging EASA to realign its rulemaking with EU-OPS.
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I have first hand experience of this.
I was invited to provide the comments on an EASA NPA by my organization. I was also nominated to sit on a steering commitee relating to this new personnel licensing rule. Each NAA received an invitation to submit a nominee.
By virtue of my previous work experience, I have seen a number of safety drawbacks to the particular NPA in the form it was submitted (basically a carbon copy of UK internal policy), and was one of potentially only 2 or 3 people outside EASA who have a working knowledge of the proposed rule. By virtue of the same previous experience, I was able to write a 3 page report on the safety related issues that should be considered prior to finalization of the new procedure - with the express intent of stopping private pilots killing themselves at the morbid rate they currently do.
I received no formal reply to any of my comments, and even though I was one of only a very few people who have a working knowledge of the proposed rule, my nomination to sit on the commitee was rejected - why? Because EASA had decided that only EASA staff would sit on the committee due to the limited number of positions available. This smacks of a political infrastructure out to protect only its own interest, and to do nothing to forward flight safety. A sad day for aviation, and a sad day for the pilots who will kill themselves and their passengers due to the circumvention of valid safety concerns raised by experienced professionals. I believe that EASA top management should be held accountable for the first death(s) that result from their ignorance of my comments, and they should find themselves in court on manslaughter charges.
And that ladies and gentlemen is my first hand experience of the body that will be regulating all of us.
RIX
I was invited to provide the comments on an EASA NPA by my organization. I was also nominated to sit on a steering commitee relating to this new personnel licensing rule. Each NAA received an invitation to submit a nominee.
By virtue of my previous work experience, I have seen a number of safety drawbacks to the particular NPA in the form it was submitted (basically a carbon copy of UK internal policy), and was one of potentially only 2 or 3 people outside EASA who have a working knowledge of the proposed rule. By virtue of the same previous experience, I was able to write a 3 page report on the safety related issues that should be considered prior to finalization of the new procedure - with the express intent of stopping private pilots killing themselves at the morbid rate they currently do.
I received no formal reply to any of my comments, and even though I was one of only a very few people who have a working knowledge of the proposed rule, my nomination to sit on the commitee was rejected - why? Because EASA had decided that only EASA staff would sit on the committee due to the limited number of positions available. This smacks of a political infrastructure out to protect only its own interest, and to do nothing to forward flight safety. A sad day for aviation, and a sad day for the pilots who will kill themselves and their passengers due to the circumvention of valid safety concerns raised by experienced professionals. I believe that EASA top management should be held accountable for the first death(s) that result from their ignorance of my comments, and they should find themselves in court on manslaughter charges.
And that ladies and gentlemen is my first hand experience of the body that will be regulating all of us.
RIX
