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 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


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


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.

Operators based at such an aerodrome and who use it frequently. This proposal has taken as guidance the RFFS categories as defined in ICAO Annex 14. However. which an operator is exposed to infrequently. which is the responsibility of the aerodrome authority and should be in accordance with Annex 14 and the rules of the aerodrome management’s national authority.Proposal No (for EASA use only):…………. Aeroplane operators should not be penalised for this situation. but it is important to note that the proposals included in this NPA are intended to be used by aeroplane operators. it is not possible to estimate the number of flights and size of aeroplane that will divert to this aerodrome.. 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. The main reason being that the aerodrome RFFS level has to be selected to meet the traffic that normally operates at that aerodrome. Aerodromes contains RFFS standards and recommended practices applicable to the management of aerodromes for aeroplanes ‘normally’ (departure and destination) using the aerodrome. One is not intended to regulate the other nor is one intended to undermine the other. will be reached solely by diverting aeroplanes. The JAA OPSG has given full consideration to the latest amendments of Annex 14 in the compilation of this proposal. equipment and manpower based on the size of the largest aeroplane normally using the aerodrome. but they must ascertain if the provision of RFFS is adequate for the intended operation. Furthermore. 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. It is not intended that these specifications limit or regulate the operation of an aircraft. In any case EU-OPS/JAR-OPS rules should not be used to implement a higher or a lower standard of RFFS. Enforcement of the RFFS standards required by Annex 14 is the responsibility of the authority in charge of the aerodrome. keep the aerodrome RFFS category permanently below the Annex 14 standard. alternate aerodromes are designated in the flight plans only as likely to be used. By definition.” Annex 14 is intended to manage the risk which an aerodrome is exposed to frequently. However. ICAO definitely wants to eliminate this practice. which it does by prescribing the required amounts of fire fighting foam. 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. The aerodrome has no information about the number of flights and size of aeroplane for which this aerodrome is designated as an alternate. ICAO Annex 14. this NPA proposes to do that. Annex 14 clearly states that: “This annex contains standards and recommended practices… and certain facilities and technical services normally provided at an aerodrome. This difference is explained in this document. Annex 14 can only deal with the aerodromes 2 . Some aerodromes. Annex 14 does not stipulate any RFFS category for alternate aerodromes. Thus. regardless of the number of movements of the largest aeroplanes. Annex 6 is intended to manage the risk. through poor planning. It is also impossible to be sure that the number of movements used to raise an aerodrome RFFS level. effectively. financial or organisational reasons.

EUOPS/JAR-OPS rules shall not be used to justify any misuse of the Annex 14 rules by aerodrome management.220 does not at present prescribe any RFFS category. 5. If large aeroplanes seldom use an aerodrome. In a similar manner to that in which Annex 14 is not to regulate operations. This situation has resulted in many questions from operators.. The third case under consideration is where an aerodrome RFFS category is temporarily downgraded. The aeroplane operator can only make decisions based on company operations and the risks and probabilities therein. The intention of this proposal is to remove the present ambiguity. OBJECTIVE OF PROPOSAL (How does the proposal intend to address the problem? Include recommendations from Working Groups. 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). it may be unable to justify the higher RFFS category economically. 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. 3 . it is clear from ICAO that operations should not be constrained by such a rule. aerodrome operators do not provide the RFFS category if their aerodrome is only nominated as an alternate. research studies. The first concern is that not all aerodromes in all areas of the world follow the RFFS standard as defined in Annex 14.Proposal No (for EASA use only):…………. In addition. The risk assessment looks at this in more detail. by providing an operational rule with a clear definition for operators and flight crews of what constitutes an acceptable level of RFFS. Secondly. Therefore. There are three situations considered in this proposal. normally used for departure and destination. to justify a lower standard for an aerodrome. the intended effect is to provide a clear rule for aeroplane operators on the minimum RFFS category acceptable in certain circumstances. which exists in EU-OPS/JAR-OPS 1. etc. nor used. Since this is not the case. (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. 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. 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. EU-OPS/JAR-OPS 1. Standards vary around the globe and in addition there are situations where an aerodrome’s normal RFFS level is reduced on a temporary basis. The problem is to assess the risk to operations in these circumstances particularly associated with those aerodromes that are infrequently used. 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. 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.

organizations. PROPOSED TEXT (If developed) EU-OPS/JAR-OPS 1. social. 4 . SCALE OF THE ISSUE (Aviation sectors affected (number of aircraft.220)] An operator shall only authorise use of aerodromes that are adequate for the type(s) of aeroplane and operation(s) concerned. persons) Global.220)] [(See ACJ to Appendix 1 to EU-OPS/JAR-OPS 1. harmonization. 7 7. Affects all Commercial Air Transport. 7..220)] [(See EU-OPS/JAR-OPS1. because it removes the possibility of misinterpretation.3 OTHER IMPACTS (Environmental. issues of equity & fairness) Harmonisation The proposal is more restrictive than Annex 6.192)] [(See Appendix 1 to EU-OPS/JAR-OPS 1. 7. 8.2 ECONOMIC IMPACT The OPSG estimates that there will be no adverse economic impact since this proposal confirms established best practice. 6. A risk assessment has been carried out as detailed in the ‘Justification’ paragraph. 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.1 IMPACT SAFETY IMPACT Safety will be improved by the introduction of a mandatory minimum standard of RFFS applicable to all operators and authorities. The proposal is consistent with FAA regulations.220 Authorisation of Aerodromes by the Operator [(See IEM OPS 1. aviation requirements outside EASA scope.Proposal No (for EASA use only):………….

Emergency Services] [(See ACJ to Appendix 1 to EU-OPS/JAR-OPS 1. if the Aeroplane RFFS Category is not available at one or more of the aerodromes required to be specified in the operational flight plan.Proposal No (for EASA use only):…………. c. The Operations Manual shall contain the Aeroplane RFFS Categories for the types of aeroplane to be operated.220 Authorisation of Aerodromes . At the planning stage. b.220)] [a. [Appendix 1 to EU-OPS/JAR-OPS 1.] 5 . 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. 3) Aerodrome RFFS Category: The published RFFS Category for a given aerodrome. 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..

available at 30 minutes notice. Three Categories operations. An En-Route Alternate Aerodrome required to be adequate and specified in the operational flight plan (e. 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. a published RFFS Category equivalent to Category 4.Minimum Aerodrome RFFS Category AERODROMES (Required to be specified in the operational flight plan)(7) Departure and Destination Aerodrome Take-Off Alternate. If an individual aerodrome serves more than one purpose.. See ACJ to Appendix 1 to EUOPS/JAR-OPS 1. the highest required category corresponding to that purpose at the time of expected use must be available. 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. For an ETOPS en-route alternate aerodrome. but not lower than category 1.Proposal No (for EASA use only):…………. Two categories(2) below the Aeroplane RFFS Category. RFFS Category 4(3) No downgrade (1) Two Categories for all-cargo operations. is acceptable. (4) (5) (6) (7) 6 .220. for all-cargo (2) (3) Or Two Categories below the Aeroplane RFFS Category. [Table 1 .g. the 3% ERA). if this is less than RFFS Category 4 but not lower than Category 1. but not lower than category 1. but not lower than category 1.

the JAA OPSG decided to find a sensible level of RFFS to maintain safety while providing sufficient operational flexibility for operations. This has led to a variety of standards. whereas. the commander may decide to land at an aerodrome where the Aerodrome RFFS Category is lower than specified above. it was agreed this approach would be unnecessarily restrictive. EU-OPS/JAR-OPS 1.Authorisation of Aerodromes Emergency Services Temporary Downgrade – A downgrade of aerodrome RFFS category notified by Notam. Therefore. Annex 14 states that it is not intended to set standards for operations. ACJ to Appendix 1 to EU-OPS/JAR-OPS 1. an aeroplane operator views his exposure to risk somewhat differently. d. In flight.. 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. temporary should be limited to 72 hours without further reference to the Authority. The JAA OPSG made an assessment of how to apply standards intended for aerodromes to operations. e. However.Proposal No (for EASA use only):………….] 9. especially if it involves fire. 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. The group examined the following criteria in assessing the level of RFFS to propose. only for aerodromes. It would close some routes. 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. especially in the case of an alternate aerodrome which is rarely used. The group concluded that the mission of RFFS is to save lives in the event of an accident. 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. An aerodrome must set a standard of RFFS adequate for all the types of movements. which it normally receives. 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. as the interpretation can be different from operator to operator and from NAA to NAA. JUSTIFICATION (Why should your proposal be adopted?. if in his judgement and after due consideration of all the prevailing circumstances. In the scope of this ACJ. The risk is that such an accident occurs. to do so would be safer than to divert.220 . 7 .220 allows interpretation as to the adequacy or otherwise of an aerodrome’s RFFS category.

In the case of an alternate aerodrome where the operator of the aeroplane has very few. Therefore. 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. Aerodromes are graded A. based on the operational procedures. The opinion of fire fighting experts The JAA OPSG consulted with aerodrome fire fighting experts from Paris ADP RFFS Management. movements the probability of an accident is low. . The difficulties to operate on aerodromes category B and C have no link with the aerodrome RFFS category. Wheel.g. 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. 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.. 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. This philosophy was based on the assumption that the probability of an accident occurring increases with the number of movements. The OPSG believe that this is sufficient mitigation to cover the additional difficulties. Aerodrome hazards The JAA OPSG considered if there were particular aerodromes with a higher risk of an accident. When questioned about the JAA OPSG proposal. B and C. specifically 2 RFFS categories below the Annex 14 standard for the operator. • • • • • 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. if any. but the low frequency of movements means that the exposure is low. 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 . engine. Historically.Proposal No (for EASA use only):…………. this method was used in ICAO Annex 14 to apply a remission factor based on a number of movements.

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. 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. For example. The airlines considered all have excellent safety records. Lufthansa and British Airways) were considered. The French law (Décret 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).g.. This is common practice in many major airlines and has not produced any data to contradict the assessment that this practice is safe. The proposed NPA does not raise any other comment. the temporary absence of one fireman (e.Proposal No (for EASA use only):…………. 9 . 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. facility or system. allowing an exceptional use of 2 RFFS categories below Annex 14 standard would not be dangerous. time. a former fire professional who had attended the relevant ICAO panel meetings as an IATA observer. Existing RFFS policy of major European operators The existing RFFS policies of 3 major European airlines (Air France. (in compliance with Annex 14). Therefore this NPA accordingly allows a 1 (temporarily 2) categories below the Annex 14 RFFS category for operations at departure and destination aerodromes. The former JAA OPSG Chairman came to the same conclusions after a previous study when he questioned British Airway's Fire Protection Manager. quality and safety management systems and are universally regarded as safe and responsible operators. • It is in the common interest of the aeroplane operator and the RFFS management to keep some flexibility by allowing such exceptional alleviations. 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. • • Other fire fighting experts were also consulted. The JAA OPSG believes that this gives enough operational flexibility without compromising operational safety. and some independent researchers at Cranfield and Greenwich Universities were also consulted. property or the environment) of the proposed activity. Therefore we can use this to assess the adverse consequences (physical harm to people. This standard describes a structured process that identifies both the likelihood and the extent of adverse consequences arising from a given activity. This in line with the general principle of using statistics when determining aircraft safety levels. the Authority regulating the aerodrome will impose and publish official access limitations.

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. but it assumes that a large aeroplane equals a large fire and this link will not always be true. b. Furthermore. but likewise the size of the fire could be the issue.. Annex 14 uses size of the aeroplane as a logical criterion. There is therefore no correlation between the size of the aeroplane and the length of time an evacuation will take. 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.Proposal No (for EASA use only):…………. In evaluating the consequence of not being able to fight the fire for long 10 . 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. but not exceeding 3 minutes from initial call. As a rapid intervention force the response time is to be 2 minutes. Hence. It is not intended to save the hull. only to save lives. or in the vicinity of an aerodrome. but supplemented this by consulting fire experts. this may take several minutes. During aeroplane certification all large passenger aeroplanes must demonstrate the ability to evacuate completely in 90 seconds. 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. based on the width and length of the largest aeroplane ‘normally’ (departure and destination) using the aerodrome. 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 not necessarily a linear relationship between the size of the aeroplane and the size of any fire. This will always be an unknown. The assumption is that more passengers and fuel on larger aeroplanes will require more manpower. to producing foam at a minimum of 50% of the discharge rate. However. The JAA OPSG as a group has in its membership much of the knowledge to complete this analysis. 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. There is therefore a gap in the operational regulation which operators have frequently asked to be filled. Hazard identification and initial consequence evaluation The RFFS category of an aerodrome prescribes manpower. Risk Analysis Personnel In accordance with the guidelines the risk analysis process will follow a defined sequence of steps. The size of the aeroplane could be a factor. c. 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. equipment and fire fighting media. 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.

which reduces the likelihood of a diversion. However. f. Further reduction is allowed for ETOPS flights because of the increased standard of system reliability required for ETOPS aeroplanes. g. which further reduces the likelihood of a diversion. The principle applied in this proposal is to limit the frequency of exposure to the risk associated with a lower category of RFFS. 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..Proposal No (for EASA use only):…………. of a wheel fire possibly caused by a brake over heat on landing. 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. ETOPS has additional system reliability. Allowing the most reduction to aerodromes. Risk calculation The risk is that using the proposed RFFS categories causes a fatality. During the takeoff roll. this document proposes lower RFFS in case of temporary depletion. A larger fire could be suppressed. 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. Uncertainties The uncertainty is that there is a possibility of an uncontrolled fire on every size of aeroplane. engine fire etc. d. This scenario could occur with maximum RFFS facilities. There does not appear to be any historical evidence of this. 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). An example is the accident involving a British Airtours B737-200 at Manchester in 1985. There is no historical data to make us believe that this risk is significant. However. 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. the JAA OPSG estimates that since the proposal is more restrictive than existing operational rules and established practice the risk is extremely remote. Although the takeoff was successfully aborted. which are used as alternates and / or infrequently used. but it is an extremely remote possibility. the aircraft suffered an uncontained failure of the left engine. There is no data available. However. 55 passengers and crew could not escape the aircraft before being 11 . 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. since it is possible for a small aeroplane to have a big fire. 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. but for a shorter period of time. but in this case by defining ‘temporary’. h. which tore a fuel line and ignited a massive fire. achieves this. as a result of events. e. upon which to base a calculation of risk. the company responsible for the management of the Paris aerodromes. limits exposure to 72 hours. Finally. enough to evacuate the aeroplane the conclusion could be a loss of life.

Hence. frequency and mitigations 1. overcome by smoke and fumes. i. Verification The JAA OPSG believes that the experts consulted inside and outside the group adequately addressed the problem. 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. consequences. Where other aerodromes are less likely to be used because they are en-route alternates or because of the increased reliability of ETOPS flights. hence. volume I. the proposed RFFS category is higher.. Annex 14 only addresses the departure and destination aerodromes. 3. The frequency analysis has been based on the experience of the group. 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. Summary of the risk. The proposed NPA would never allow such an operation. Therefore this proposal seeks to bring some safe and operational clarification.Proposal No (for EASA use only):…………. This methodology is consistent with U. 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. a diversion to an aerodrome is not ‘normal use’ of that aerodrome. The JAA OPSG in consultation with fire experts has carried out hazard identification and risk estimation. 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. By definition. Departure and Destination Aerodrome The JAA OPSG has confirmed with ICAO that the RFFS requirements in Annex 14.S. as has the consequence estimation. The RFFS category proposed in this NPA is still considered capable of containing this risk with an acceptable probability. 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. 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. For the same reason the temporary downgrade of an aerodrome’s normal RFFS level is limited to 72 hours in order to limit the number of flights exposed to the risk. 2. 12 . 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. at these aerodromes. 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.

but not lower than category 1) also limited to 72 hours. 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. the JAA OPSG felt that the benefits of having clear 13 . It also gives operators a framework within which to work by recognising that. there may be occasions when operations may be prohibited by this rule. If EUOPS/JAR-OPS 1 adopted the Annex 14 standard this would not oblige aerodrome operators to upgrade their RFFS facilities. These aerodromes are so infrequently used that the owners are unwilling to upgrade their facilities for the small possibility of receiving a diversion. For a destination aerodrome. 2 categories below the Annex 14 standard may be used. the proposals contained in this proposal permit safe but realistic global operations. 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. ETOPS En-Route Alternates For ETOPS en-route alternates category 4 is allowed. 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. It would also restrict the operating crews’ options in the event that diversion became necessary. However. In this case. The amount of the reduction and the length of time it is allowed have been specified in the proposal. Temporarily downgraded RFFS If an aerodrome RFFS category is temporarily reduced for a short time period this should not cause a diversion. Alternate aerodrome Alternate aerodromes tend to have lower RFFS standards than would normally be required. The OPSG believe it is better and safer to have more aerodromes. but the effect would be negative for the aeroplane operator. there will be occasions when the RFFS standard will be lower than expected and it sets minimum standards for such circumstances. OTHER COMMENTS Adopting this proposal sets a standard for operators to follow. which do not comply with the Annex 14 standards for the type of aeroplane operated. 10.220 can exist. 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. by being prescriptive.. requiring the operator to ensure that the aerodrome RFFS category is not more than 1 (temporarily 2) level(s) below the Annex 14 table. An analysis of destinations by operators who are represented on the OPSG revealed that there are very few destinations. but in mitigation this is limited to 72 hours. The disadvantage of this is that. available for a diversion even if some of them are slightly below the Annex 14 standard. which are closer to track. 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. in practice. and aerodromes. reducing the exposure to the lower RFFS category. It removes the undesirable situation where different interpretations of EU-OPS/JAR-OPS 1.Proposal No (for EASA use only):…………. justified by the increased reliability of ETOPS flights reducing the likelihood of a diversion.

rules outweighed this disincentive. The options proposed in this proposal set a standard. so this ……………………………………………………………………………………………………………. To summarise the JAA OPSG position is that to facilitate global operations where the application of Annex 14 standards is not universal. Therefore. (For EASA use only ) Date Received:       Acknowledgement Receipt Sent:       Initial Assessment: Date Responded to Proposer:             14 . is a big step in the right direction for getting this area of operations regulated..Proposal No (for EASA use only):…………. which reflects existing custom and practice. Send your proposal to: RWPD@easa. 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.. The present operational regulations leave operators without guidance. The JAA OPSG would like to recommend mandating of Annex 14 standards for the future. RFFS categories of 1 category below Annex 14 for normal operations can be permitted at departure and destination aerodromes with no adverse safety implications. removes any doubt or confusion and the possibility for different interpretations. it is the option. whilst not going all the way up to Annex 14 which the OPSG recommends. but the fact is that aerodromes have not universally adopted the standard.

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