Sofema Aviation Services (SAS) www.sassofia.com considers the changes introduced by Amendment (EU) 2021/2237 to Regulation EU 965/2012 “All weather operations and for flight crew training and checking”.
Introduction
The existing rules regulating all-weather operations should be updated to ensure that they reflect recent technological advancements in new airborne systems and the best practices in the domain of air operations.
- It is necessary to address all-weather operations in all relevant aviation domains, including
o Initial airworthiness
o Air operations
o Flight crew licensing and
o Aerodromes
- The new rules should improve harmonization with the United States FAA requirements and include in Union law as much as feasible the latest amendments to the standards adopted by the International Civil Aviation Organization (ICAO),
o ICAO Annex 6,
– Part I (11th edition),
– Part II (10th edition) and
– Part III (9th edition), regarding all-weather operations and the instrument approach terminology.
- The new rules should be performance – and risk-based, in order to be resilient to continuous technological progress. They should not be technology-dependent and may accommodate future changes, thus avoiding dependency on particular technological solutions.
- The new rules should allow efficiency gains based on technological advancements and the operational use of new, advanced technologies such as enhanced flight vision systems (EFVS), as well as the application of some advanced new operational procedures, which support all-weather operations.
- The use of innovative training tools for the purpose of flight crew training and checking should also be sought.
- The new rules on all-weather operations and flight crew training and checking should contribute to allow for a level playing field for all actors in the internal aviation market of the Union and improve the competitiveness of the Union’s aviation industry.
- The aerodrome operating minima should be aligned as much as possible between CAT operations, non-commercial operations with complex motor-powered aircraft (NCC), and specialised operations (SPO).
- The requirements for all-weather operations for non-commercial operations with other-than-complex motor-powered aircraft (NCO) should also be simplified to incentivize the use of instrument flight rules.
- Based on operational experience and considering the nature of operations and the lower risks involved, some alleviations to flight crew training and checking requirements, which were previously available only for CAT, should be extended to SPO and NCC operations.
- Operational developments have shown that the required level of safety can be maintained with less stringent and more flexible requirements. Similarly, some increased flexibility regarding operations with different aircraft types or variants should be provided for small helicopter operators. Small simple single-engine helicopter types that behave in a similar way in normal and emergency conditions should also benefit from some of the simplifications that are currently available within an aeroplane class rating.
Detailed Overview of Changes Introduced by Regulation (EU) 2021/2237
In line with the new focus based on performance and risk, many of the elements of the regulation have been implemented at the level of AMCs and GMs. This fact, in combination with optimisation and reorganisation of the existing material, means that a large number of AMCs and GMs have been modified, although in many cases this does not necessarily imply the introduction of any actual change with respect to the preceding regulation.
- New definitions of instrument approach operations (2D, 3D) with their corresponding categories (A and B) and those for the procedures (PA, LPV, NPA), to align them with the ICAO definitions.
- Clarification of the term “AFM or additional data from the TC/STC holder” based on the landing systems.
- Clarifications about the continuous descent final approach (CDFA) technique are introduced to exclude circling approach operations from its scope.
- New types of operation such as EFVS and EFVS 200 are also introduced (Enhanced Flight Vision System (EFVS) is an electronic means to provide the flight crew with a real-time sensor-derived or enhanced display)
- Mandatory Reporting Requirements – EASA Decision includes a list of events regarding onboard equipment failures and ground infrastructure that may lead to the end of an LVO.
- The method for calculating DH and RVR for operations not subject to SPA, derived from other points of the regulation, is carried over to the AMCs and GMs of that requirement.
- The new concept of EFVS 200 operations (which are not subject to approval) is introduced through the CAT.OP.MPA.312 and its AMCs and GMs.
o This type of operation is based on the concept of operational credit, to enable aircraft equipped with an enhanced flight vision system (EFVS) to apply lower RVR than those that would be applicable pursuant to CAT.OP.MPA.110.
o The minimum RVR applicable to the EFVS 200 operation shall under no circumstances be lower than 550 m, nor shall the DH be less than 200 ft.
Specific approvals (Part-SPA)
There are general changes in the requirements for LVO approvals.
- Given that the definition of low-visibility operations is extended to all those with RVR below 550 m, the concept of LVTO operations is therefore extended to all take-offs with RVR lower than 550 m, even though specific approval shall only be required for those with RVR below 400 m, as has been the case up to now.
- The LTS CAT I, OTS CAT II and EVS approach operations disappear. The operational attributions of these SPAs shall now be envisaged within the framework of operational credits.
- The terms CAT IIIA and CAT IIIB disappear, and these operations shall be referred to as CAT III.
- The concept of “operational credits” is introduced, to permit the application of reduced minima for those aircraft fitted with equipment supplementary to that required as standard, though specific to a given operation.
- In particular, the following operational credits are introduced:
o SA CAT I is an operational credit applied to a CAT I operation that permits the instrument segment of a CAT I approach to be extended to a minimum DH of 150 ft.
o SA CAT II is an operational credit applied to a CAT II operation that permits the use of a runway not meeting the lighting requirements for a CAT II approach. It does not imply lower DHs than for a standard CAT II.
o EFVS operations, which allow the RVR (but not the DH) to be reduced on the visual segment under certain conditions, for aircraft equipped with an enhanced flight vision system (EFVS).
Concerning Runway Suitability
One requirement that disappears from SPA.LVO.105 is the need for operational verification for each runway/aircraft type combination before commencing CAT II or III operations.
- For the specific approval SPA.NVIS, new AMCs to allow the use of NVIS devices using IFR operations are introduced.
Next Steps
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Tags:
Aviation Training, International Civil Aviation Organization, SAS blogs, EASA Part SPA, Regulation (EU) 2021/2237, Regulation EU 965/2012, United States FAA requirements, Approvals for Industry & Regulatory Authorities
