Flight Time Limitations for Business Aviation A Snapshot of EBAA Activity Andrea Němec Manager Safety and Rulemaking BBGA Annual Conference 12 March 2013.

Flight Time Limitations for Business AviationA Snapshot of EBAA Activity

Andrea Němec Manager Safety and Rulemaking

BBGA Annual Conference

12 March 2013

Structure

Past FTL activities Current FTL activities

Main issues under considerationFuture developments

12 March 2013 © EBAA

Past FTL ActivitiesEASA Rulemaking Activity EBAA Working Group

• EASA → began writing new FTL rules• Creation of EBAA Working Group on FTL• Collection of different FTL national regulations

• First draft NPA FTL available• Drafting of EBAA’s position on FTL based on the

available draft NPA and BizAv best practice.

• Publication of NPA 2009-22 on FTL• EBAA Position → CS structure.• EBAA launched FTL Survey in conjunction with Dr

Mark Rosekind (Alertness Solutions).

• Strong reaction from the community against the NPA 2009-22.

• EASA creates the Rulemaking group OPS 0.55 FTL (CAT)

• EBAA Participates in OPS 0.55 FTL WG• OPS 0.55 FTL → ”Air Taxi” rules to be drafted in a

future rulemaking group OPS 0.71 FTL (now split in two rulemaking groups on Air Taxi and on EMS).

• BizAv FTL separate from airline rules.

• Publication of NPA 2010-14 on FTL • EBAA Position → IR + CS structure.© EBAA

Past Achievements

• Common position on FTL for Business Aviation• Scientific study providing solid basis for the future development of sector rules• Collection of operational experience of BusAv operators• EASA acceptance of a future separate regulation on FTL for BusAv Operations

Current FTL Activities

EASA Rulemaking Activity EBAA Working Group

FTL requirements for CAT operations - EMS (Airplane + Helicopter) [RMT.0346 (OPS.071(a))]

• EBAA ensured participation of 1 expert in the EASA WG: Uwe Marks (Aero-Dienst)

FTL requirements for CAT operations - Air taxi and single-pilot operations (Airplane)[RMT.0429 and RMT.0493 (OPS.071(b))]

• EBAA ensured participation of 2 experts in the EASA WG: Marco Pereira (NetJets) and Dannys Famin (Unijet)

12 March 2013 © EBAA

Objectives of the EASA Rulemaking Tasks

Development of FTL requirements for CAT operations of air taxi and single-pilot (aeroplane) and EMS (aeroplane + helicopter) by:

• Reviewing and assessing EU-OPS Subpart Q provisions and outcome of Common Response Document to the

Notice of Proposed Amendment (NPA) 2010-14; Existing applicable FTL national provisions.

• Carrying out a Regulatory Impact Assessment Best option to achieve the objectives while minimising negative impacts.

• Submitting regulatory proposals For Implementing Rules, Certification Specifications, Acceptable Means of Compliance

and Guidance Material

FTL - Air taxi and single-pilot operations with airplane Reference Documents:

EBAA Working Group Inputs

EU-OPS Subpart Q - Flight and duty time limitations and rest requirements;

Opinion 04/2011 on Air Operations – Notice of Proposed Amendment (NPA) 2009-02

Common Response Document (CRD) 2010-14 to NPA 2010-14Provided inputs to the Regulatory Impact Assessment of the NPA 2010-14: 2.2 Fatigue Hazard Identification

• 2.2.2 Hazard/Mitigation table

ICAO Annex 6: Part I – International Commercial Air Transport - Aeroplanes Chapter 4 – Flight operations § 4.10 Fatigue Management Attachment A – Flight time and flight duty period ICAO latest amendments on flight time limitations and rest

requirements nad related GM (Amendment No 33 to Annex 6 Part I)

Fatigue Risk Management System• FRMS Manual for Regulators (ICAO Doc 9966)• FRMS Implementation Guide for Operators

© EBAA

Current activities on FTL: Air taxi and single-pilot

Main Issues Under Consideration (1/3)

• Positioning• Important issue in Business Aviation• Positioning duties before or immediately after a FDP

• Duty Hours• Combination of flight duties with ground duties

Use of Fatigue Risk Management Systems?• Cumulative Duty

• Risk of fatigue deriving from high cumulative workload• In BusAv fatigue less of an issue than for Airliners

• Night, early and late duties• Consecutive Night Duties

Increase minimum rest after consecutive night duties?• Consecutive series of early starts and/or late arrivals

Limit the number of consecutive early starts, additional rest after a series of early starts?

• Calculation of FDP • Clear maximum FDP limit• Table or other means but must remain simple• Must take into account the restorative sleep during WOCL period

• Extension of FDP due to split duty • Split duty with rest should enable longer flight duty periods

• Extension of FDP due to in-flight rest• Common practise but need to be managed

• Pilot-in command discretion• For extension of FDP based on particular circumstances

All affected crew members to agree with extension of FDP• For reduction of FDP and/or increase of rest in case of fatigue risk

Main Issues Under Consideration (2/3)

• Standby • Airport Standby

Definition of facilities for Airport Standby Accommodation• Standby other than airport

Standby at home should not count as duty time for BusAv• Basic Rest - Reduced rest arrangements

• Suitable accommodation• Minimum duration of reduced rest• Requirement for reduced rest to occur in the WOCL

• Compensation for effects of time zone differences (for long haul operations)• Rest after flights with time zone differences should take into account the operational specifics of BusAv

Main Issues Under Consideration (3/3)

EBAA Working Group Inputs Example

Hazard Reference Applicability Fatigue hazard description Possible mitigation

measures

1. Duty Hours

1.1 All operations Combination of flight duties with ground duties (e.g. administrative, managerial, simulator, etc.)

a) Reduced duty/flight duty periodsb) Limitations on combining flight

and ground dutiesc) Limit number of flying sectorsd) Use of FRMSe) Include any ground duties

prior to a flight as FDPf) Allow provisions as for split

duty

2. Cumulative Duty

2.1 All operations High cumulative workload • ………….

RMT.0429 and RMT.0493 Milestone Foreseen date

Notice of Proposed Amendment (NPA) 2014/Q1

Comment Response Document (CRD) + Opinion

2015/Q3

Decision 2016/Q3

© EBAA

Future Developments (1/2)

© EBAA

Future Developments (2/2)

RMT.0346 Milestone Foreseen date

Notice of Proposed Amendment (NPA) 2014/Q3

Comment Response Document (CRD) + Opinion

2014/Q1

Decision 2016/Q1

© EBAA

FTL - Emergency Medical Services (EMS) by Aeroplanes and Helicopters

12 March 2013 © EBAA

FTL - Air Taxi and Single-Pilot Operations with Aeroplane

THANK YOU FOR YOUR ATTENTION