NPA 2024-02 Regular update of the air operations rules — Enhanced implementation of FDM programmes and miscellaneous amendments

Dokumendiregister	Transpordiamet
Viit	1.8-5/24/6704-1
Registreeritud	18.04.2024
Sünkroonitud	22.04.2024
Liik	Sissetulev kiri
Funktsioon	1.8 Rahvusvahelise koostöö korraldamine
Sari	1.8-5 Rahvusvaheline kirjavahetus lennundusohutuse küsimustes: ECAC, ICAO, EASA, Eurocontrol, State Letterid
Toimik	1.8-5/2024
Juurdepääsupiirang	Avalik
Juurdepääsupiirang
Adressaat	Euroopa Lennundusohutusamet
Saabumis/saatmisviis	Euroopa Lennundusohutusamet
Vastutaja	Anastasia Levin (Users, Tugiteenuste teenistus, Õigusosakond)
Originaal	Ava uues aknas

Dokument on kokkuvõtte tegemiseks liiga mahukas (642402 tm).

Failid

npa_2024-02 (1).pdf

European Union Aviation Safety Agency

Notice of Proposed Amendment 2024-02 in accordance with

Article 6 of MB Decision No 01-2022

TE.RPRO.00034-011 © European Union Aviation Safety Agency. All rights reserved. ISO 9001 certified. Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 1 of 253

An agency of the European Union

Regular update of the air operations rules

Enhanced implementation of FDM programmes and miscellaneous

amendments

RMT.0392 (Subtask #1e)

EXECUTIVE SUMMARY This Notice of Proposed Amendment (NPA) proposes amendments to the EU air operations regulatory framework on flight data monitoring (FDM) programmes and other miscellaneous topics. The objective is to enhance the implementation of FDM programmes and to make miscellaneous improvements to the regulatory framework to consider the principles of better regulation and lessons learnt from the implementation of rules by national authorities and industry, and to implement safety recommendations. The proposed regulatory material is expected to maintain, and in some cases enhance, the level of safety and to provide benefits in terms of efficiency, with a low to very low economic impact.

REGULATION(S) TO BE AMENDED/ISSUED Regulation (EU) No 965/2012 (Air OPS)

ED DECISIONS TO BE AMENDED/ISSUED ED Decision 2014/025/R – AMC & GM to Part-ARO

ED Decision 2014/017/R – AMC & GM to Part-ORO

ED Decision 2014/015/R – AMC & GM to Part-CAT

ED Decision 2012/019/R – AMC & GM to Part-SPA

ED Decision 2013/021/R – AMC& GM to Part-NCC

ED Decision 2014/016/R – AMC & GM to Part-NCO

ED Decision 2014/018/R – AMC & GM to Part-SPO

AFFECTED STAKEHOLDERS Member States and national competent authorities (NCAs), all aircraft operators, aircrew, design and production organisations.

WORKING METHODS

Development Impact assessments Consultation

By EASA with external support Detailed for FDM Light for other topics

Public – NPA Focused (Advisory Bodies) – meeting

RELATED DOCUMENTS / INFORMATION ToR RMT.0392, issued on 7 October 2020

PLANNING MILESTONES: Refer to the latest edition of Volume II of the European Plan for Aviation Safety.

European Union Aviation Safety Agency NPA 2024-02

Table of contents

An agency of the European Union

Table of contents

1. About this NPA ...................................................................................................................... 6

1.1. How this NPA was developed ................................................................................................... 6

1.2. How to comment on this NPA .................................................................................................. 6

1.3. The next steps .......................................................................................................................... 7

2. In summary — why and what ................................................................................................ 8

2.1. Why we need to act .................................................................................................................. 8

2.1.1. Description of the issue ............................................................................................................ 8

2.1.2. Who is affected by the issue .................................................................................................. 14

2.1.3. Conclusion on the need for rulemaking ................................................................................. 15

2.2. What we want to achieve — objectives ................................................................................. 15

2.3. How we want to achieve it — overview of the proposed amendments................................ 16

2.4. Stakeholders’ views ................................................................................................................ 20

3. Expected benefits and drawbacks of the proposed regulatory material ................................ 21

4. Proposed regulatory material .............................................................................................. 23

4.1. Draft regulation amending Regulation (EU) No 965/2012 ..................................................... 23

ARO.GEN.125 Information to the Agency ..................................................................................... 23

ARO.GEN.135 Immediate reaction to a safety problem ................................................................ 23

ARO.OPS.300 Introductory flights ................................................................................................. 24

ORO.GEN.160 Occurrence reporting ............................................................................................. 25

ORO.SPO.110 Authorisation of high risk commercial specialised operations ............................... 26

ORO.SPO.115 Changes ................................................................................................................... 26

ORO.SPO.120 Continued validity ................................................................................................... 26

ORO.MLR.100 Operations manual – general ................................................................................. 27

ORO.FTL.120 Fatigue risk management (FRM) .............................................................................. 27

ORO.FTL.125 Flight time specification schemes ............................................................................ 27

NCC.GEN.105 Crew responsibilities ............................................................................................... 29

NCC.GEN.106 Pilot-in-command responsibilities and authority ................................................... 29

NCC.GEN.110 Compliance with laws, regulations and procedures ............................................... 30

NCC.OP.190 Ice and other contaminants – flight procedures ....................................................... 30

NCO.GEN.101 Means of compliance ............................................................................................. 31

NCO.GEN.105 Pilot-in-command responsibilities and authority ................................................... 31

NCO.GEN.110 Compliance with laws, regulations and procedure ................................................ 32

European Union Aviation Safety Agency NPA 2024-02

Table of contents

An agency of the European Union

NCO.OP.170 Ice and other contaminants – flight procedures ...................................................... 32

NCO.SPEC.115 Crew responsibilities ............................................................................................. 32

SPO.GEN.101 Means of compliance .............................................................................................. 34

SPO.GEN.105 Crew responsibilities ............................................................................................... 34

SPO.GEN.107 Pilot-in-command responsibilities and authority ................................................... 34

SPO.OP.176 Ice and other contaminants – flight procedures ....................................................... 35

4.2. Draft acceptable means of compliance and guidance material ............................................. 36

GM1 ARO.GEN.200(a) Management system ................................................................................. 36

AMC1 ORO.GEN.160(c) Occurrence reporting .............................................................................. 37

GM1 ORO.GEN.160(c) Occurrence reporting ................................................................................ 38

AMC1 ORO.GEN.200(a)(1) Management system .......................................................................... 39

AMC1 ORO.GEN.200(a)(3) Management system .......................................................................... 40

GM2 ORO.GEN.200(a)(2) Management system ............................................................................ 42

AMC1 ORO.GEN.200(a)(6) Management system .......................................................................... 42

AMC1 ORO.AOC.130 Flight data monitoring – aeroplanes ........................................................... 43

AMC2 ORO.AOC.130 Flight data monitoring – aeroplanes ........................................................... 52

GM1 ORO.AOC.130 Flight data monitoring – aeroplanes ............................................................. 56

GM2 ORO.AOC.130 Flight data monitoring — aeroplanes ........................................................... 74

GM1 ORO.DEC.100 Declaration ..................................................................................................... 92

GM1 ORO.FC.230 Recurrent training and checking ...................................................................... 93

AMC2 ORO.FC.231(a) Evidence-based training ............................................................................. 94

AMC1 ORO.FC.231(a)(5) Evidence-based training ........................................................................ 94

GM1 ORO.FC.231(a)(5) Evidence-based training .......................................................................... 95

AMC1 ORO.FC.231(c) Evidence-based training ............................................................................. 95

AMC4 ORO.FC.231(d)(1) Evidence-based training ........................................................................ 96

AMC2 ORO.FC.232 EBT programme assessment and training topics ........................................... 98

AMC3 ORO.FC.232 EBT programme assessment and training topics ......................................... 100

AMC1 ORO.FC.A.245 Alternative training and qualification programme ................................... 102

GM2 CAT.OP.MPA.107 Adequate aerodrome ............................................................................. 105

AMC1 CAT.OP.MPA.110 Aerodrome operating minima — general ............................................ 105

GM2 CAT.OP.MPA.181 Fuel/energy scheme — fuel/energy planning and in-flight re-planning

policy — aeroplanes .................................................................................................................... 105

AMC2 CAT.OP.MPA.182 Fuel/energy scheme — aerodrome selection policy — aeroplanes .... 106

European Union Aviation Safety Agency NPA 2024-02

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AMC2 CAT.OP.MPA.185(a) Fuel/energy scheme — aerodrome selection policy — aeroplanes 107

AMC1 SPA.LVO.100(a) Low-visibility operations and operations with operational credits ........ 108

AMC1 SPA.LVO.100(b) Low-visibility operations and operations with operational credits ........ 108

AMC2 SPA.LVO.100(b) Low-visibility operations and operations with operational credits ........ 109

AMC1 SPA.LVO.120(a) Flight crew competence.......................................................................... 110

AMC2 SPA.LVO.120(a) Flight crew competence.......................................................................... 110

AMC3 SPA.LVO.120(a) Flight crew competence.......................................................................... 110

AMC2 SPA.LVO.120(b) Flight crew competence ......................................................................... 111

AMC3 SPA.LVO.120(b) Flight crew competence ......................................................................... 111

AMC4 SPA.LVO.120(b) Flight crew competence ......................................................................... 111

AMC6 SPA.LVO.120(b) Flight crew competence ......................................................................... 112

GM1 SPA.LVO.120(b) Flight crew competence ........................................................................... 112

AMC1 SPA.DG.105(a) Approval to transport dangerous goods .................................................. 113

AMC1 SPA.HOFO.145 Flight data monitoring (FDM) programme ............................................... 114

AMC2 SPA.HOFO.145 Flight data monitoring (FDM) programme ............................................... 116

GM1 SPA.HOFO.145 Flight data monitoring (FDM) programme................................................. 120

GM2 SPA.HOFO.145 Flight data monitoring (FDM) programme................................................. 130

GM1 NCC.GEN.105(e)(2) Crew responsibilities ........................................................................... 141

GM1 NCC.GEN.106 Pilot-in-command responsibilities and authority ........................................ 141

AMC3 NCC.OP.110 Aerodrome operating minima — general .................................................... 141

AMC1 NCO.GEN.105(a)(3) Pilot-in-command responsibilities and authority ........................... 143

GM1 NCO.GEN.105(a)(3) Pilot-in-command responsibilities and authority ............................. 144

GM1 SPO.GEN.005 Scope ............................................................................................................ 145

GM1 SPO.GEN.105(e)(2) Crew member responsibilities ............................................................. 145

AMC3 SPO.OP.110 Aerodrome operating minima — general .................................................... 145

5. Impact assessment A — conditions and guidance for effective flight data monitoring ......... 147

5.1. What is the issue?................................................................................................................. 147

5.2. What we want to achieve — objectives ................................................................................... 154

5.3. How we want to achieve it — options ..................................................................................... 154

5.4. Methodology and data used for conducting the impact assessments .................................... 160

5.5. What are the impacts ............................................................................................................... 160

5.6. Conclusion ................................................................................................................................ 176

European Union Aviation Safety Agency NPA 2024-02

Table of contents

An agency of the European Union

6. Impact assessment B — better integration of the flight data monitoring programme in the

operator’s management system ............................................................................................... 179

6.1. What is the issue ...................................................................................................................... 179

6.2. What we want to achieve — objectives ................................................................................... 181

6.3. How we want to achieve it — options ..................................................................................... 182

6.4. Methodology and data ............................................................................................................. 185

6.5. What are the impacts ............................................................................................................... 185

6.6. Conclusion ................................................................................................................................ 198

7. Monitoring and evaluation ................................................................................................ 201

8. Proposed actions to support implementation .................................................................... 202

9. References ........................................................................................................................ 203

9.1. Related EU regulations ......................................................................................................... 203

9.2. Related EASA decisions ............................................................................................................ 203

9.3. Other references ...................................................................................................................... 203

10. Appendices ....................................................................................................................... 206

Appendix A — Methodology and data used for conducting IAs A and B ........................................ 206

Appendix B — Detailed review of the cost impact of Option 1 of IA A ........................................... 222

Appendix C — Detailed review of cost impact of Option 1 of IA B ................................................. 244

11. Quality of the NPA ............................................................................................................ 252

11.1. The regulatory proposal is of technically good/high quality .................................................. 252

11.2. The text is clear, readable and understandable ..................................................................... 252

11.3. The regulatory proposal is well substantiated ....................................................................... 252

11.4. The regulatory proposal is fit for purpose (capable of achieving the objectives set) ............ 252

11.5. The impact assessment (IA), as well as its qualitative and quantitative data, is of high quality 252

11.6. The regulatory proposal applies the ‘better regulation’ principles () .................................... 252

11.7. Any other comments on the quality of this NPA (please specify) .......................................... 253

European Union Aviation Safety Agency NPA 2024-02

1. About this NPA

An agency of the European Union

1. About this NPA

1.1. How this NPA was developed

The European Union Aviation Safety Agency (EASA) identified several issues (as described in Chapter 2)

and, after having assessed the impacts of the possible intervention actions, identified rulemaking as

the necessary intervention action.

This rulemaking activity is included in Volume II of the 2024 edition of the European Plan for Aviation

Safety (EPAS)1 under Rulemaking Task (RMT).0392, Subtask #1e.

EASA developed the regulatory material in question in line with Regulation (EU) 2018/11392 (the Basic

Regulation) and the Rulemaking Procedure3, and in accordance with the objectives and working

methods described in the Terms of Reference (ToR) for this RMT4.

When developing the regulatory material on FDM, EASA received the support of a group of experts

from the industry (including aeroplane operators, aircraft manufacturers, a pilot association and three

industry associations). For the regulatory material related to lessons learnt from the Boeing 737 MAX

human factors issues, EASA also received support from external experts, and the material was

discussed with the Advisory Bodies, namely the certification committee (C.COM), the Air OPS

Technical Body and the Flight Standards Technical Committee (FS.TeC). For the development of the

material related to evidence-based training, fuel/energy management and low-visibility operations,

EASA received the support of experts nominated by the EASA Advisory Bodies to support the

development of safety promotion tasks in these areas5. The remaining material was internally

developed by EASA.

1.2. How to comment on this NPA

Please submit your comments using the automated Comment-Response Tool (CRT) available at

http://hub.easa.europa.eu/crt/6.

The deadline for the submission of comments is 24 June 2024.

1 https://www.easa.europa.eu/en/domains/safety-management/european-plan-aviation-safety 2 Regulation (EU) 2018/1139 of the European Parliament and of the Council of 4 July 2018 on common rules in the field of

civil aviation and establishing a European Union Aviation Safety Agency, and amending Regulations (EC) No 2111/2005, (EC) No 1008/2008, (EU) No 996/2010, (EU) No 376/2014 and Directives 2014/30/EU and 2014/53/EU of the European Parliament and of the Council, and repealing Regulations (EC) No 552/2004 and (EC) No 216/2008 of the European Parliament and of the Council and Council Regulation (EEC) No 3922/91 (OJ L 212, 22.8.2018, p. 1) (https://eur- lex.europa.eu/legal-content/EN/TXT/?qid=1535612134845&uri=CELEX:32018R1139).

3 EASA is bound to follow a structured rulemaking process as required by Article 115(1) of Regulation (EU) 2018/1139. Such a process has been adopted by the EASA Management Board and is referred to as the ‘rulemaking procedure’. See Management Board Decision No 01-2022 of 2 May 2022 on the procedure to be applied by EASA for the issuing of opinions, certification specifications and other detailed specifications, acceptable means of compliance and guidance material (‘rulemaking procedure’), and repealing Management Board Decision No 18-2015 (https://www.easa.europa.eu/the-agency/management-board/decisions/easa-mb-decision-01-2022-rulemaking- procedure-repealing-mb).

4 ToR RMT.0392, Regular Update of Air Operations Rules, Issue 1 (https://www.easa.europa.eu/en/document- library/terms-of-reference-and-rulemaking-group-compositions/tor-rmt0392).

5 SPT.0012, SPT.0097 and SPT.0101, all included in the 2023–2025 edition of the EPAS. 6 In case of technical problems, please send an email to [email protected] with a short description.

European Union Aviation Safety Agency NPA 2024-02

1. About this NPA

An agency of the European Union

1.3. The next steps

Following the consultation on the draft regulatory material, EASA will review all the comments

received and will duly consider them in the subsequent phases of this rulemaking activity. For this

purpose, EASA may involve external experts, depending on the topic.

Considering the above, EASA may issue an Opinion proposing amendments to Regulation (EU)

No 965/2012. The Opinion will be submitted to the European Commission, which shall consider its

content and decide whether to issue amendments to that Regulation.

Following the amendment of the Regulation, EASA may issue a Decision issuing the acceptable means

of compliance (AMC) and guidance material (GM). When issuing the Opinion and Decision, EASA will

also provide feedback to commentators and to the public on who provided comments during the

consultation on the draft regulatory material, which comments were received, how such engagement

and/or consultation was used in rulemaking and how the comments were considered.

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

2. In summary — why and what

2.1. Why we need to act

RMT.0392 is a standing rulemaking task. Its purpose is to address issues and topics of a miscellaneous

nature identified in Regulation (EU) No 965/20127 (the Air OPS Regulation) and the related AMC and

GM, which are not addressed by a dedicated rulemaking task.

The amendments proposed in this NPA stem from various sources ranging from candidate issues

proposed by stakeholders, lessons learnt from the implementation of recent amendments to the Air

OPS Regulation, safety issues resulting from EASA’s safety risk portfolio and proposals coming from

the EASA Advisory Bodies.

2.1.1. Description of the issue

This NPA intends to address several issues.

Flight data monitoring

FDM means the proactive and non-punitive use of digital flight data from routine operations to

improve aviation safety.

Implementing an FDM programme usually consists of:

— continuously recording flight parameter values throughout the flight;

— routinely collecting this data from aircraft;

— processing the recordings with the help of specific software to extract safety-relevant

information, such as deviations from the operating procedures or abnormal parameter values;

— using this information to help identify safety hazards, assess safety risks and monitor that

measures to address safety risks are effective.

The implementation of an FDM programme is required by Air OPS Regulation for aeroplanes operated

for commercial air transport (CAT) operations and with a maximum certificated take-off mass

(MCTOM) of more than 27 000 kg (under ORO.AOC.130), and for helicopters operated for CAT

offshore operations, when the helicopter is required to be equipped with a flight data recorder (under

SPA.HOFO.145).

Lessons learnt from standardisation inspections, the report on the evaluation of the relevance and the

effectiveness of the European Operators Flight Data Monitoring forum (EOFDM) best-practices

documents (EVT.0009), which assessed the effectiveness of the documents produced by the forum8,

and several accident investigation reports show that some of the AMC and GM to the Air OPS

Regulation need to be amended to ensure minimum performance of the FDM programme of an

7 Commission Regulation (EU) No 965/2012 of 5 October 2012 laying down technical requirements and administrative

procedures related to air operations pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 296, 25.10.2012, p. 1) (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32012R0965).

8 EASA, Evaluation of the relevance and the effectiveness of the EOFDM best-practices documents, January 2021 (https://www.easa.europa.eu/en/document-library/general-publications/evaluation-relevance-and-effectiveness- eofdm-best-practices).

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

operator and the effectiveness of the FDM programme in supporting the operator’s management

system.

More specifically, the following issues have been identified as needing to be addressed:

— setting minimum performance objectives for the main steps of an FDM programme (flight data

recovery, flight data processing, flight data analysis);

— establishing the minimum set of risks that should be covered by an FDM programme;

— updating references and examples in the AMC and GM so as to reflect modern technologies and

analysis techniques and current industry practice;

— clarifying how the FDM programme should be integrated with other processes of the operator’s

management system; and

— clarifying data protection principles when FDM data is used in conjunction with other types of

safety data, and when FDM data is used for purposes other than safety.

For more details, please refer to Sections 5.1 and 6.1.

At least three safety issues included in EASA’s CAT aeroplanes safety risk portfolio9 are related to FDM:

— Approach path management (SI-0007);

— Entry of aircraft performance data (SI 0015); and

— Gap between certified take-off performance and take-off performance achieved in operations

(SI-0017).

For more details on these three safety issues, please refer to Section 5.1.1.

In addition, the following safety recommendation addressed to EASA from aircraft accident and

serious incident investigation reports published by the designated safety investigation authorities10

has been considered:

— SR FRAN-2019-025, issued by the French Bureau d’Enquêtes et d’Analyses, after the serious

incident involving an Airbus A340, registered F-GLZU, on 11 March 2017 at El Dorado

International Airport (Colombia)11:

The BEA recommends that EASA in coordination with the national oversight authorities ensure

that European operators introduce in their flight analysis programme, the indicators required to

monitor take-off performance and at the very least, long take-offs.

9 EASA safety risk portfolios are presented in Volume III of the EPAS (https://www.easa.europa.eu/en/document-

library/general-publications/european-plan-aviation-safety-epas-2023-2025). 10 Regulation (EU) No 996/2010 of the European Parliament and of the Council of 20 October 2010 on the investigation and

prevention of accidents and incidents in civil aviation and repealing Directive 94/56/EC (OJ L 295, 12.11.2010, p. 35) (http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1479716039678&uri=CELEX:32010R0996).

11 In addition, note should be taken of the following safety recommendation: ‘It is recommended that the UK Civil Aviation Authority encourage all UK Air Operator Certificate holders to implement into their flight data monitoring programme algorithms to detect the precursors relevant to the monitoring of takeoff performance detailed in the European Operators Flight Data Monitoring Document, Guidance for the implementation of flight data monitoring precursors.’ (SR UNKG-2022-019, issued by the UK Air Accidents Investigation Branch after the serious incident involving a Boeing 737-800 registered G-JZHL, on 1 December 2021 at Kuusamo Airport, Finland).

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

The changes proposed in this NPA on the topic of FDM do not affect the harmonisation of EU

requirements with International Civil Aviation Organization (ICAO) Standards and Recommended

Practices (SARPs), since the AMC and GM have no equivalent in ICAO SARPs12.

Similarly, it is assumed that these changes to the AMC and GM will not affect the aviation regulation

of non-EU countries, except for those non-EU countries that align their national rules for air operations

with EU rules.

Lessons learnt from the Boeing 737 MAX human factors issues

During the design phase of the human–machine interface in the flight deck, the type certificate

applicant must demonstrate compliance with human factors requirements, anticipating potential in-

service events related to human performance and implementing design-related mitigations. The type

certificate applicant must therefore ensure that the design of the flight deck considers a

comprehensive set of design principles well described in the literature under the concept of usability.

The ultimate intent of designing a usable flight deck is to prevent, as far as is practicable, any kind of

human performance issues in both normal and abnormal situations (including failure conditions), and

to enable the management thereof should they occur.

Experience has shown that, despite the best efforts made during the initial airworthiness process of

the type design, actual flight crew behaviour or performance in service may deviate from what was

initially expected by the design approval holders and the certification authorities. Such deviations in

both normal and abnormal situations (including failure conditions) may have safety consequences and

result in serious incidents/accidents if they continue to go unnoticed.

Design approval holders and certification authorities normally rely on the continued airworthiness

process of the type design to further capture and manage design weaknesses, assumptions invalid

over time, etc. In such a context, it is therefore paramount that air operators systematically report to

design approval holders occurrences involving human performance aspects detected by the flight

crew during the operator’s flight operations and/or by instructors during the operator’s simulator

training. It is equally paramount that design approval holders investigate these occurrences and can

determine potential unsafe conditions originating from human performance issues.

The existing regulatory framework for occurrence reporting and continued airworthiness of the type

design do not however fully address these key elements when it comes to human performance.

This topic is related to the safety issue ‘Insufficient consideration of flight crew human factors in the

continued airworthiness process of the type design’ (SI-9003), which will be part of the 1st edition of

the airworthiness safety risk portfolio to be included in the next revision of EPAS Volume III.

Part-NCO — Pilot-in-command responsibilities and authority and use of checklists

With NPA 2022-11, EASA proposed several changes to the Air OPS Regulation to update the regulatory

references to the EASA Basic Regulation. However, NCO.GEN.105 was omitted, together with several

other points, which is why such changes are proposed in this NPA.

12 ICAO State Letter AN 11/1.1.35-21/50 proposes to extend the scope of the standard requiring a flight data analysis

programme in Section 3.3, Annex 6, Part I, to aeroplanes with an MCTOM between 15 000 kg and 27 000 kg. To date, this amendment has not been adopted by the ICAO Council and transposing this amendment into EU rules is not in the scope of this NPA.

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

In addition, regarding point (a)(3) of NCO.GEN.105, some additional amendments are proposed,

particularly at the level of AMC and GM, regarding the use of checklists, following feedback received

from approved training organisations, the operations of which are covered by Part-NCO under

Article 6(9) of the Air OPS Regulation, and pilots in the GA (General Aviation) community.

NCO.GEN.105 defines the responsibilities and authority of the pilot-in-command. Point (a)(3)

establishes that the pilot-in-command is responsible for ensuring that all operational procedures and

checklists are complied with.

AMC1 to NCO.GEN.105(a)(3) establishes that pilots should use checklists provided by the

manufacturer. These checklists are standard and should be customised by the pilot-in-command /

operator; however, in the case of Part-NCO, this is not clearly stated. This has led some NCAs to require

that pilots-in-command / operators use Section 3 (abnormal/emergency procedures) of the aircraft

flight manual (AFM) as if it were a checklist, regardless of its suitability as one. The most direct

implication is very low checklist adherence by pilots.

The use of inappropriate checklists in flight is a safety issue; it can lead to misunderstandings by the

pilots during the operations, which can lead to serious occurrences.

Three accidents have occurred since 201913 where lack of checklist adherence was found by the

relevant safety investigation authority as the causal factor. In all three cases, the Comisión de

Investigación de Accidentes e Incidentes de Aviación Civil (CIAIAC) was responsible, as they happened

in Spain.

The CIAIAC has addressed the following safety recommendation to Agencia Estatal de Seguridad Aérea

(AESA):

REC 51/20: Se recomienda a AESA que garantice la inclusión de los procedimientos y listas de

verificación específicos para instrucción en el Manual de operaciones de las escuelas de

formación (ATO) y supervise su idoneidad.’

(Courtesy translation: It is recommended that AESA ensures adding specific procedures and

checklists for training in the Operations Manual of the ATOs and monitor their appropriateness.)

Other aviation authorities have also identified this issue. The Australian Civil Aviation Safety Authority

(CASA) issued Advisory Circular 91-22 to address it:

The requirements for aircraft checklists are derived from regulation 91.095. The regulation

requires the pilot in command (PIC) to operate an aircraft in compliance with the aircraft flight

manual instructions.

[…]

On review, regulation 91.095 was found to incorrectly express the intended policy objectives.

[…]

Most flight manual operating procedures are presented in a checklist form with interspersed

explanatory information. For effective use by aircraft crew, checklists should be devoid of

13 References to the official reports: Informe técnico (technical report) A-064/2019 (gear up landing), Informe técnico

(technical report) A-046/2020 (gear up landing), Informe técnico (technical report) IN-046/2021 (gear up landing).

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

distracting non-essential information, with any remaining content limited to actionable items

and the corresponding required outcomes. While these checklists are sometimes referred to as

‘abbreviated checklists’, the term should be used with caution to avoid implications that the list

of checks is abbreviated or reduced e.g., as with abbreviated circuit training checklists. More

accurate terms are ‘aircraft checklist’ or ‘cockpit checklist’. Full-text operating procedures

including notes, cautions and warnings as published in a flight manual, are referred to as

‘amplified checklists’ or ‘expanded checklists’, and as such are unsuitable for use in aircraft.

Shortly after, CASA published CASA EX81/21 – Part 91 of CASR – Supplementary exemptions and

directions instrument 2021 to include an exemption to the rule based on its previous advisory circular:

Compliance with flight manual — exemption

(1) The pilot in command of an aircraft to which Part 91 applies is exempted from compliance

with the following provisions of CASR:

(a) paragraph 91.095 (2) (a);

(b) subregulation 91.095 (3) (in relation to paragraph 91.095 (2) (a)).

(2) The exemptions in subsection (1) are subject to the condition that the pilot in command complies

with the requirements and limitations set out in the aircraft flight manual instructions for the aircraft.

Introductory flights carried out with balloons and sailplanes

EASA has been made aware by France’s Directorate General for Civil Aviation of a potential gap in

ARO.OPS.300 in relation to operations with sailplanes and balloons.

Regulation (EU) 2018/39514 on the operation of balloons and Regulation (EU) 2018/1976 (15) on the

operation of sailplanes both establish that the competent authorities shall comply with the

requirements of Part-ARO in the Air OPS Regulation16. Both regulations also contain provisions on

introductory flights17. Nevertheless, point ARO.OPS.300 only mentions introductory flights carried out

in accordance with Part-NCO. This has led to a lack of clarity on the possibility for competent

authorities to define additional conditions for introductory flights of sailplanes and balloons, which is

currently creating economic issues for operators and differences of interpretation among EASA

Member States, resulting in there not being a level playing field.

The intent when Regulation (EU) 2018/395 and Regulation (EU) 2018/1976 were adopted was to keep

the possibility for competent authorities to develop additional conditions for introductory flights

carried out with balloons and sailplanes.

14 Commission Regulation (EU) 2018/395 of 13 March 2018 laying down detailed rules for the operation of balloons

pursuant to Regulation (EC) No 216/2008 of the European Parliament and of the Council (OJ L 71, 14.3.2018, p. 10) (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32018R0395).

15 Commission Implementing Regulation (EU) 2018/1976 of 14 December 2018 laying down detailed rules for the operation of sailplanes pursuant to Regulation (EU) 2018/1139 of the European Parliament and of the Council (OJ L 326, 20.12.2018, p. 64) (https://eur-lex.europa.eu/eli/reg_impl/2018/1976/oj).

16 See points BOP.BAS.005 and SAO.GEN.105. 17 See points BOP.BAS.015 and SAO.GEN.115, for example.

European Union Aviation Safety Agency NPA 2024-02

2. In summary — why and what

An agency of the European Union

Recurrent training and checking

Ground training

EASA has received feedback from several stakeholders requesting clarity on the provisions of

AMC1 ORO.FC.230 regarding ground training, specifically on the frequency that should apply to

ground training on aircraft systems and abnormal and emergency procedures.

Evidence-based training

Several stakeholders highlighted difficulties with understanding some aspects of the AMC and GM

related to evidence-based training (EBT) and requested clarification on how to apply them, specifically

on the link between an EBT programme and upset prevention and recovery training, on the one hand,

and training on flight path management during unreliable airspeed indication and other failures at

high altitude, on the other, and how to apply level 0 grading to EBT.

Fuel/energy schemes — aerodrome selection policy — aeroplanes

During the implementation of the recent provisions on fuel/energy schemes introduced with

Regulation (EU) 2021/129618, there were some difficulties with the interpretation of some of the AMC

related to the planning minima of the destination alternate aerodrome. More specifically, questions

were raised regarding some elements of GM2 CAT.OP.MPA.181, AMC2 CAT.OP.MPA.182 and

AMC2 CAT.OP.MPA.185(a).

Low-visibility operations

During the implementation of the recent provisions on all-weather operations introduced with

Regulation (EU) 2021/223719, there were some difficulties with the interpretation of some of the AMC

on low-visibility operations (LVOs).

Mainly, stakeholders reported inconsistencies between some provisions in the AMC to SPA.LVO.120

related to the flight crew competence for LVOs. The current text of the AMC is not fully aligned for

cases where the operator wishes to add a new ‘LVO capacity’ and train its pilots accordingly. This

creates misalignments in the implementation of the provisions among EASA Member States, resulting

in there not being a level playing field and creating issues with standardisation.

Aerodrome operating minima — general (Part-NCC and Part-SPO)

Table 1 of AMC3 NCC.OP.110 and Table 1 of AMC3 SPO.OP.110 are currently not consistent with

Table 1 of AMC1 CAT.OP.MPA.110. This inconsistency was due to a mistake made during the final

stage of development of the Decision that adopted those AMC, when changes introduced in Table 1

of AMC1 CAT.OP.MPA.110 were not reproduced in the other AMC.

18 Commission Implementing Regulation (EU) 2021/1296 of 4 August 2021 amending and correcting Regulation

(EU) No 965/2012 as regards the requirements for fuel/energy planning and management, and as regards requirements on support programmes and psychological assessment of flight crew, as well as testing of psychoactive substances (OJ L 282, 5.8.2021, p. 5) (https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=CELEX%3A32021R1296&qid=1708337941277).

19 Commission Implementing Regulation (EU) 2021/2237 of 15 December 2021 amending Regulation (EU) No 965/2012 as regards the requirements for all-weather operations and for flight crew training and checking (OJ L 450, 16.12.2021, p. 21) (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32021R2237).

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2. In summary — why and what

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Training on dangerous goods

With SL AN 11/1.1.34-20/75, ICAO adopted competence-based training for dangerous goods, which

was to be implemented by all States in 2023, at the latest. The standards for this training can be found

in ICAO Doc 9284 Technical Instructions for the Safe Transport of Dangerous Goods by Air. Further

information is provided in ICAO Doc 10147, Guidance on a Competency-based Approach to Dangerous

Goods Training and Assessment.

Within the new system, personnel are required to be trained to be competent with respect to their

functions and assessed accordingly. The assessment is continuous, to allow training to be adapted to

the needs. The current AMC1 SPA.DG.105(a) provides for a written examination as the only means to

obtain the qualification, which does not reflect the new approach from ICAO.

Adequate aerodrome and rescue and firefighting services

ICAO Annex 6, Part I, Attachment I ‘Rescue and firefighting services (RFFS) levels’ (supplementary to

Annex 6, Part I, Chapter 4, point 4.1.4), provides guidance for assessing the level of RFFS deemed

acceptable by aeroplane operators using aerodromes. This is useful guidance for the industry, and

currently is not reflected in the Air OPS Regulation.

Editorial amendments

EASA has identified several references to Regulation (EC) No 216/2008 in the Air OPS Regulation that

need to be amended to refer to Regulation (EU) 2018/1139.

2.1.2. Who is affected by the issue

The following stakeholders are affected by the different issues addressed in the NPA.

Flight data monitoring

This issue affects aircraft operators, national competent authorities, aircraft manufacturers and flight

crew.

Lessons learnt from the Boeing 737 MAX human factors issues

This issue affects aircraft operators, national competent authorities, aircraft manufacturers and flight

crew.

Use of checklists in Part-NCO

This issue affects aircraft operators under Part-NCO, including aircrew training organisations, national

competent authorities and flight crew.

Introductory flights carried out with balloons and sailplanes

This issue affects sailplane and balloon operators and pilots and national competent authorities.

Recurrent training and checking

This issue affects aircraft operators, national competent authorities and flight crew.

Fuel/energy schemes — aerodrome selection policy — aeroplanes

This issue affects aircraft operators, national competent authorities and flight crew.

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Low-visibility operations

This issue affects aircraft operators, national competent authorities and flight crew.

Aerodrome operating minima — general (Part-NCC and Part-SPO)

This issue affects aircraft operators, national competent authorities and flight crew.

Training on dangerous goods

This issue affects aircraft operators, national competent authorities and flight crew.

Adequate aerodrome and rescue and firefighting services

This issue affects aircraft operators, national competent authorities and flight crew.

Editorial amendments

The editorial amendments affect aircraft operators and national competent authorities.

2.1.3. Conclusion on the need for rulemaking

EASA concluded, as explained further in Chapter 3 below, that an intervention was necessary and that

non-regulatory actions cannot effectively address the issue identified. Therefore, amendments to the

Air OPS Regulation, and its AMC and GM are required.

2.2. What we want to achieve — objectives

The overall objectives of the EASA system are defined in Article 1 of the Basic Regulation. This NPA

will contribute to achieving the overall objectives by addressing the issues described in Section 2.1.

More specifically, with the regulatory material presented here, EASA intends to achieve the following

objectives.

Flight data monitoring

Regarding FDM, the specific objective of this NPA is to enhance the safety of operations with large

aeroplanes used for CAT, and of operations with large helicopters used for offshore CAT, by:

— making FDM programmes more effective; and

— better integrating the FDM programme in the operator’s management system.

For more details on these objectives, please refer to Sections 5.2 and 6.2 of this NPA.

Lessons learnt from the Boeing 737 MAX human factors issues

The specific objective regarding this topic is to ensure that, during in-service flight operations or

operator training and checking events, CAT operators better detect, collect, investigate and report to

the design approval holder potential flight crew human intervention issues linked to flight deck design,

operating procedures or training, or a combination thereof, that may lead to an unsafe condition.

Use of checklists in Part-NCO

The specific objective regarding this topic is to ensure that pilots engaged in NCO operations comply

with applicable operational procedures and to clarify which checklists should be used to ensure that

compliance.

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Introductory flights carried out with balloons and sailplanes

Regarding this topic, the specific objective is to clarify that competent authorities may establish

additional conditions for introductory flights carried out with balloons and sailplanes.

Recurrent training and checking

Regarding this topic, the specific objective of this NPA is to increase the clarity of several provisions at

AMC level to facilitate understanding and uniform implementation of them.

Fuel/energy schemes — aerodrome selection policy — aeroplanes

The specific objective regarding this topic is to increase the clarity of the provisions on aerodrome

selection policy at AMC level.

Low-visibility operations

The specific objective regarding this topic is to improve the understanding of the provisions at AMC

and GM level related to flight crew competence for LVOs and operations with operational credits.

Aerodrome operating minima — general (Part-NCC, Part-SPO and Part-SPA)

The specific objective on this topic is to ensure consistency and harmonise the take-off minima in

different AMC in Part-NCO, Part-SPO and Part-CAT. An additional objective is to align, when possible,

the values and equipment for take-off and landing minima for CAT II in Part-SPA.

Training on dangerous goods

The specific objective regarding this topic is to ensure full consistency between the EU’s and ICAO’s

approaches to training for dangerous goods.

Adequate aerodrome and rescue and firefighting services

Regarding this topic, the purpose is to include a reference to the relevant ICAO guidance in the GM to

Part-CAT.

Editorial amendments

Regarding the editorial amendments, the purpose of this NPA is to ensure that the Air OPS Regulation

includes the correct regulatory references to the EASA Basic Regulation.

2.3. How we want to achieve it — overview of the proposed amendments

This NPA proposes the following amendments to the Air OPS Regulation and its AMC and GM.

Flight data monitoring

To achieve the objectives indicated in Section 2.2, this NPA proposes changes to the AMC and GM to

the following points of Part-ORO and Part-SPA, containing the requirements related to the

management system, to FDM programmes of aeroplane operators, to FDM programmes of helicopter

offshore operators and to the implementation of an alternative training and qualification programme

(ATQP): ORO.GEN.200, ORO.AOC.130, ORO.FC.A.245 and SPA.HOFO.145.

To make FDM programmes more effective, this NPA proposes to do the following.

— Introduce, in the AMC to ORO.AOC.130 and SPA.HOFO.245, conditions that specify minimum

performance objectives for the main steps of an FDM programme, which are as follows.

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2. In summary — why and what

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(a) Flight data recovery. The conditions address the functioning of the airborne system, the

set of flight parameters to be collected, the flight collection rate and the time to identify

a failure to collect data from an individual aircraft.

(b) Flight data processing. The conditions address the time for routine processing of the data

by the FDM software, and the capabilities of the FDM software.

FDM events and documentation of the source of flight parameters and the algorithms

used to produce FDM events and measurements.

— Introduce, in the AMC to ORO.AOC.130 and SPA.HOFO.245, a minimum set of risks that should

be monitored by an FDM programme. This set includes:

(a) risk areas that are relevant for all aeroplane operators, such as those pointed out by the

EASA Annual Safety Review;

(b) risk areas that are relevant for all offshore operators, such as those pointed out by the

EASA Annual Safety Review or HeliOffshore safety performance reports;

to Regulation (EU) 2015/101820; and

(d) indications that the airworthiness of the aircraft may be affected.

— Introduce changes in GM1 ORO.AOC.130, GM2 ORO.AOC.130, AMC1 ORO.FC.A.245,

GM1 SPA.HOFO.245 and GM2 SPA.HOFO.245 to reflect technological evolutions and current

industry best practices. Examples include the use of modern IT solutions (e.g. software-as-a-

service), new capabilities of modern FDM software or the advent of large data exchange

programmes.

For more details on these proposed amendments, please refer to Chapter 4 and to the description of

Option 1 in Section 5.3. In addition, Section 5.5 contains a detailed assessment of the safety,

environmental, social and economic impacts of these proposed amendments, and their impact on

General Aviation and proportionality.

To better integrate the FDM programme in the operator’s management system, this NPA proposes

the following actions.

— Add the FDM programme to the safety information sources that should be used to support the

safety risk management (SRM) steps, in AMC1 ORO.GEN.200(a)(3).

— Introduce conditions in AMC1 ORO.GEN.200(a)(1) specifying that the FDM programme is part

of the responsibilities of the safety manager and of the safety review board.

— Reinforce internal controls on the implementation of the FDM procedure to protect flight crew

identity, by referring to FDM procedures in AMC1 ORO.GEN.200(a)(6). This AMC specifies the

scope of the operator’s compliance monitoring function.

20 Commission Implementing Regulation (EU) 2015/1018 of 29 June 2015 laying down a list classifying occurrences in civil

aviation to be mandatorily reported according to Regulation (EU) No 376/2014 of the European Parliament and of the Council (OJ L 163, 30.6.2015, p. 1) (https://eur-lex.europa.eu/eli/reg_impl/2015/1018).

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— Clarify in AMC1 ORO.AOC.130, GM1 ORO.AOC.130, AMC1 SPA.HOFO.145 and

GM1 SPA.HOFO.145 how the FDM programme should support the SRM process.

— Reconcile, in AMC1 ORO.AOC.130 and AMC1 SPA.HOFO.145, the conditions regarding the

protection of flight crew identity, with the principles regarding the protection of reporters as

set out in Regulation (EU) No 376/201421.

— Introduce a recommendation in GM1 ORO.GEN.200 that, if a data source that is needed to

support SRM is required to be protected, then the safety policy of the operator provides

consistent protection of this data source when it is used for all other purposes; and recommend,

in GM1 ORO.AOC.130 and GM1 SPA.HOFO.145, that access to FDM data for purposes other

than FDM is consistently framed by procedures to protect flight crew identity.

— Clarify, in AMC1 ORO.FC.A.245, what information may be provided by the FDM programme to

the ATQP responsible person and how this information should be handled.

For more details on these proposed amendments, please refer to Chapter 4 and to the description of

Option 1 in Section 6.3. In addition, Section 6.5 contains a detailed assessment of the safety,

environmental, social and economic impacts of these proposed amendments, and their impact on

non-commercial aviation and on smaller organisations (proportionality).

Lessons learnt from the Boeing 737 MAX human factors issues

Under the scope of the Basic Regulation, and more specifically with regard to Regulation (EU)

No 376/2014 and point ORO.GEN.160(a) in the Air OPS Regulation, operators shall mandatorily report

to their competent authority occurrences of which they become aware. Without prejudice to this

mandatory reporting, CAT operators are further required by point ORO.GEN.160(b) to report

occurrences to the design approval holder.

The in-depth analysis of in-service occurrences involving human interventions requires full knowledge

of the assumptions about the expected flight crew behaviour made by the design approval holder

when demonstrating compliance with the certification basis, to be able to identify any deviations from

these assumptions in the context of flight operations. Since it is not expected that operators have this

knowledge, the responsibility of such analysis is therefore assumed to be assigned to the design

approval holder. However, the efficiency of the continuing airworthiness system requires that design

approval holders are made aware by operators of events or trends that may reveal shortcomings

related to flight deck design, operating procedures or training, or a combination thereof, in a

systematic and comprehensive way.

To ensure that, during in-service flight operations or operator training and checking events, CAT

operators better detect, collect, investigate and report to the design approval holder potential flight

crew human intervention issues linked to flight deck design, operating procedures or training, or a

combination thereof, that may lead to an unsafe condition, this NPA proposes to amend

21 Regulation (EU) No 376/2014 of the European Parliament and of the Council of 3 April 2014 on the reporting, analysis

and follow-up of occurrences in civil aviation, amending Regulation (EU) No 996/2010 of the European Parliament and of the Council and repealing Directive 2003/42/EC of the European Parliament and of the Council and Commission Regulations (EC) No 1321/2007 and (EC) No 1330/2007 (OJ L 122, 24.4.2014, p. 18) (https://eur-lex.europa.eu/legal- content/EN/TXT/?uri=celex%3A32014R0376).

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2. In summary — why and what

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ORO.GEN.16022 and add an AMC and GM (AMC1 ORO.GEN.160(c) and GM1 ORO.GEN.160(c)) to

strengthen the systematic reporting of occurrences or occurrence trends involving human

interventions by CAT operators to the design approval holder. Note that EASA already issued a safety

information bulletin23 recommending that CAT operators consider systematic reporting of

occurrences involving human interventions.

Use of checklists in Part-NCO

This NPA proposes to add a reference to checklists developed by the operator to

AMC1 NCO.GEN.105(a)(3). The new GM1 NCO.GEN.105(a)(3) is also proposed to be added to provide

further guidance on checklists.

Introductory flights carried out with balloons and sailplanes

This NPA proposes to amend ARO.OPS.300 to clarify that competent authorities may establish

additional conditions for introductory flights carried out with balloons and sailplanes.

Recurrent training and checking

Ground training

EASA is proposing to increase the clarity of the provisions of AMC1 ORO.FC.230 regarding ground

training, specifically regarding the frequency that should apply to ground training on aircraft systems

and abnormal and emergency procedures, by adding new text to GM1 ORO.FC.230, which already

contains guidance on several aspects related to recurrent training and checking.

Evidence-based training

To increase the clarity of provisions on EBT at AMC level, specifically on the link between an EBT

training programme and upset prevention and recovery training, on the one hand, and training on

flight path management during unreliable airspeed indication and other failures at high altitude, on

the other, and on how to apply level 0 grading to EBT, EASA is proposing to amend AMC2 ORO.FC.231,

AMC1 ORO.FC.231(a)(5), GM1 ORO.FC.231(a)(5), AMC1 ORO.FC.231(c), AMC4 ORO.FC.231(d)(1),

AMC2 ORO.FC.232 and AMC3 ORO.FC.232.

Fuel/energy schemes — aerodrome selection policy — aeroplanes

To increase the clarity of the provisions on aerodrome selection policy, by addressing the questions

raised by stakeholders, EASA is proposing proposes some amendments to GM2 CAT.OP.MPA.181,

AMC2 CAT.OP.MPA.182 and AMC2 CAT.OP.MPA.185(a).

Low-visibility operations

To improve understanding of the provisions related to flight crew competence for LVOs and

operations with operational credits, and to ensure consistency on how this topic is covered by

different AMC, EASA is proposing some amendments to the current text of AMC1 SPA.LVO.100(a),

AMC1 SPA.LVO.100(b), AMC2 SPA.LVO.100(b), AMC1 SPA.LVO.120(a), AMC2 SPA.LVO.120(a),

22 Proposals to amend point ORO.GEN.160 were included in NPA 2022-11 and previously in NPA 2016-19 (RMT.0681

‘Occurrence reporting’); the related CRD 2016-19 was published on 24 May 2019. The proposals in this NPA consider those changes.

23 EASA SIB 2023-08: Reporting of occurrences involving human interventions linked to flight deck design, operating procedures, training, or a combination thereof (https://ad.easa.europa.eu/ad/2023-08).

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AMC3 SPA.LVO.120(a), AMC2 SPA.LVO.120(b), AMC3 SPA.LVO.120(b), AMC4 SPA.LVO.120(b),

AMC6 SPA.LVO.120(b) and GM1 SPA.LVO.120(b).

Aerodrome operating minima — general (Part-NCC, Part-SPO and Part-SPA)

To ensure consistency and harmonise take-off minima across the AMC to Part-NCO, Part-SPO and Part-

CAT, EASA is proposing changes to Table 1 of AMC3 NCC.OP.110, Table 1 of AMC3 SPO.OP.110 and

Table 1 of AMC1 CAT.OP.MPA.110. In addition, EASA is proposing to align the values for take-off and

landing minima for CAT II in Part-SPA.

Training on dangerous goods

EASA is proposing to remove from AMC1 SPA.DG.105(a) the provision for a written examination as

the only means to obtain the qualification. The amendment proposed does not prevent written

examinations; rather, it provides more flexibility and allows for a proper evaluation, in line with the

ICAO standards and recommended practices.

Adequate aerodrome and rescue and firefighting services

EASA is proposing to add the new GM2 CAT.OP.MPA.107, referring to the relevant ICAO guidance.

Editorial amendments

To ensure that the Air OPS Regulation includes the correct regulatory references to the EASA Basic

Regulation, changes are proposed to ARO.GEN.125, ARO.GEN.135, ORO.SPO.115, ORO.SPO.120,

ORO.MLR.100, ORO.FTL.120, ORO.FTL.125, NCC.GEN.105, NCC.GEN.106, NCC.GEN.110, NCC.OP.190,

NCO.GEN.101, NCO.GEN.105, NCO.GEN.110, NCO.OP.170, NCO.SPEC.115, SPO.GEN.101,

SPO.GEN.105, SPO.GEN.107, SPO.GEN.176, GM1 ARO.GEN.200(a), GM1 ORO.DEC.100,

GM1 NCC.GEN.105(e)(2), GM1 NCC.GEN.106 and GM1 SPO.GEN.105(e)(2).

2.4 What are the stakeholders’ views

The views of the stakeholders involved were positive regarding the amendments proposed on issues

that EASA received external support with: FDM, lessons learned from the Boeing 737 MAX human

factors issues, evidence-based training, fuel/energy management and LVOs. The remaining issues

were developed internally by EASA, so no feedback from stakeholders was received. Nevertheless, the

amendments proposed try to address issues that were raised by stakeholders, so it is assumed that

they will be received positively.

European Union Aviation Safety Agency NPA 2024-02

3. Expected benefits and drawbacks of the proposed regulatory material

An agency of the European Union

3. Expected benefits and drawbacks of the proposed regulatory material

EASA assessed that an intervention was required and that amendments to the Air OPS Regulation and

its AMC and GM are necessary to effectively address the issues described in Section 2.1, because the

objectives described in Section 2.2 cannot be achieved effectively by non-regulatory action.

EASA also assessed the impacts of the proposed regulatory material to ensure that the regulatory

material delivers its full benefits with minimal drawbacks.

The expected benefits and drawbacks of the regulatory material proposed for the topic of FDM were

assessed with the support of a group of experts from the industry (including aeroplane operators,

aircraft manufacturers, a pilot association and three industry associations). They are summarised

below. For the full impact assessments, please refer to Chapters 5 and 6.

Regarding safety benefits, the proposals increase the effectiveness of the SRM process and of the

occurrence reporting process for many operators, they create conditions for more effective FDM

programme oversight, they support EASA’s safety risk portfolios and they make the FDM programme

more useful in supporting an ATQP.

Regarding social benefits, the proposals make the assessment of operations fairer for flight crew

members and they make the FDM programmes better at supporting flight crews’ professional needs.

The proposals bring moderate economic benefits for operators and aircraft manufacturers, by:

— reducing the risk of an occurrence with a significant cost impact on the operator and/or on the

aircraft manufacturer;

— supporting a more cost-efficient SRM process for the operator; and

— creating the conditions for enhanced support to continuing airworthiness and in-line

assessment of new systems.

The identified drawbacks of the proposals are related to the slight increase in some costs. These costs

are limited, as the proposals include a notice period of 2 years, and any AMC amendment that may

impact the design of airborne systems or airborne equipment is proposed to be restricted to aircraft

that will be manufactured 3 years or more following the date of adoption.

The identified drawbacks can be summarised as follows:

— very limited expenses for operators to get the FDM software updated for meeting some new

conditions, such as expenses related to the time to process significant FDM events;

— very limited expenses for operators to adapt their internal procedures for meeting some new

conditions, such as expenses related to documenting the source of flight parameters and the

definitions of FDM algorithms, to preventing disclosure of flight crew identity and to linking

FDM event algorithms with occurrences subject to mandatory occurrence reporting;

— a very limited increase in cost for aircraft manufacturers, associated with a slight increase in

support to their operators;

— a cost impact on small CAT operators that is, in proportion, slightly higher than on larger CAT

operators (no cost impact on non-commercial operations);

— a possible slight and temporary increase in the workload for FDM staff; and

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— a very limited increase in cost for national competent authorities to take into account the

modified AMC in their oversight activities.

For the remaining elements of this NPA, the expected benefits and drawbacks of the proposals are

discussed in the rationale for the amendments proposed in Chapter 4 below.

The proposed regulatory material has been developed in view of the better regulation principles, and

particularly the regulatory fitness principles. In particular, the proposed regulatory material will:

— alleviate existing regulatory burden by increasing clarity on what is needed to achieve an

effective and safe implementation of the rules;

— limit the regulatory burden created by amended requirements to the minimum, since in each

case EASA chose the least burdensome option to address the objectives identified in Chapter 2,

namely by always choosing to amend only AMC and GM whenever possible.

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4. Proposed regulatory material

An agency of the European Union

4. Proposed regulatory material

The amendment is arranged to show deleted, new or amended, and unchanged text as follows:

— deleted text is struck through;

— new or amended text is highlighted in blue;

— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.

Where necessary, the rationale is provided in blue italics.

4.1. Draft regulation amending Regulation (EU) No 965/2012

4.1.1. Annex II (Part-ARO)

SUBPART OPS: AIR OPERATIONS

SECTION I – GENERAL

ARO.GEN.125 Information to the Agency

(a) The competent authority shall without undue delay notify the Agency in case of any significant

problems with the implementation of Regulation (EU) 2018/1139 and its delegated and

implementing acts(EC) No 216/2008 and its Implementing Rules.

[…]

Rationale

Editorial amendment. No impacts expected.

ARO.GEN.135 Immediate reaction to a safety problem

[…]

(b) The Agency shall implement a system to appropriately analyse any relevant safety information

received and without undue delay provide to Member States and the Commission any

information, including recommendations or corrective actions to be taken, necessary for them

to react in a timely manner to a safety problem involving products, parts, appliances, persons

or organisations subject to Regulation (EU) 2018/1139 and its delegated and implementing acts

(EC) No 216/2008 and its Implementing Rules.

[…]

(d) Measures taken under (c) shall immediately be notified to all persons or organisations which

need to comply with them under Regulation (EU) 2018/1139 and its delegated and

implementing acts (EC) No 216/2008 and its Implementing Rules. The competent authority shall

also notify those measures to the Agency and, when combined action is required, the other

Member States concerned.

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4. Proposed regulatory material

An agency of the European Union

Rationale

Editorial amendment. No impacts expected.

SECTION III – OVERSIGHT OF OPERATIONS

ARO.OPS.300 Introductory flights

The competent authority may establish additional conditions for introductory flights carried out in

accordance with Part-NCO, Part-BOP of Regulation (EU) 2018/395 or Part-SAO of Regulation (EU)

2018/1976, in the territory of the Member State. Such conditions shall ensure safe operations and be

proportionate.

Rationale

When ARO.OPS.300 was initially adopted, it was applicable to aeroplanes, helicopters, balloons and

sailplanes, as Part-NCO was also applicable to balloons and sailplanes. Further to Regulation (EU)

2018/395 and Regulation (EU) 2018/1976, Part-NCO is no longer applicable to balloons and sailplanes

(replaced by Part-BOP for balloons and Part-SAO for sailplanes). Nevertheless, the authority

requirements applicable to operations with balloons and sailplanes are still those in Part-ARO of the

Air OPS Regulation. Therefore, ARO.OPS.300 should be modified to reference these new balloon and

sailplane regulations. This will clarify that competent authorities may establish additional conditions

for introductory flights with balloons and sailplanes.

The current proposal will have no safety impact but will increase clarity and possibly efficiency at

competent authority level.

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4.1.2. Annex III (Part-ORO)

SUBPART GEN: GENERAL REQUIREMENTS

SECTION 1 – GENERAL

ORO.GEN.160 Occurrence reporting

[…]

(b) Without prejudice to point (a), the operator shall report to the competent authority and the

organisation responsible for the design of the aircraft:

(1) any incident, malfunction, technical defect, exceeding of technical limitations or

occurrence that would highlight inaccurate, incomplete or ambiguous information

contained in the operational suitability data established in accordance with Regulation

(EU) No 748/2012 or other irregular circumstance that has or may have endangered the

safe operation of the aircraft and that has not resulted in an accident or serious incident;.

(2) any occurrence, or occurrence trends, involving human intervention, that would highlight

shortcomings related to design, procedures or training, or a combination thereof,

detected during operator simulator training and checking sessions, that could have

potentially endangered the safe operation of the aircraft in actual flight operations.

[…]

Rationale

Please note that NPA 2022-11 also proposed amendments to the text in ORO.GEN.160, which

considered the amendments proposed by RMT.0681 ‘Occurrence reporting’. Please refer to NPA 2022-

1124 for more details. The proposals in this NPA consider those changes.

The proposed amendments seek to strengthen the systematic reporting by commercial air transport

(CAT) operators to the DAH of occurrences involving human interventions. That intent is to ensure that,

during in-service flight operations or operator simulator training and checking, CAT operators better

detect, collect, investigate and report occurrences/events/trends to the DAH on potential flight crew

human intervention issues linked to type design, procedures or training, or a combination thereof, that

may lead to an unsafe condition.

The expected benefits of these proposals are an increase in safety as a result of enhancing the detection

of, and strengthening the systematic reporting to the DAH of, human intervention

occurrences/events/trends by CAT operators.

Possible drawbacks are an increased workload for CAT operators (to detect, collect and analyse such

occurrences/events/trends), for DAHs (to analyse a greater number of reports received from CAT

operators) and potentially for EASA (to validate the DAH conclusions and mitigating actions in the

event of an unsafe condition being confirmed).

24 https://www.easa.europa.eu/en/document-library/notices-of-proposed-amendment/npa-2022-11

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SUBPART SPO: COMMERCIAL SPECIALISED OPERATIONS

ORO.SPO.110 Authorisation of high risk commercial specialised

operations

[…]

established by the competent authority, taking into account the applicable requirements of

Regulation (EU) 2018/1139 and its delegated and implementing acts (EC) No 216/2008 and its

Implementing Rules.

Rationale

Editorial amendment. No impacts expected.

ORO.SPO.115 Changes

[…]

(b) The application for approval of a change shall be submitted before any such change takes place,

in order to enable the competent authority to determine continued compliance with Regulation

(EU) 2018/1139 and its delegated and implementing acts (EC) No 216/2008 and its

Implementing Rules and to amend, if necessary, the authorisation. The operator shall provide

the competent authority with any relevant documentation.

[…]

Rationale

Editorial amendment. No impacts expected.

ORO.SPO.120 Continued validity

[…]

(b) The operator’s authorisation shall remain valid subject to:

(1) the operator remaining in compliance with the relevant requirements of Regulation (EU)

2018/1139 and its delegated and implementing acts (EC) No 216/2008 and its

Implementing Rules, taking into account the provisions related to the handling of findings

as specified under ORO.GEN.150;

(2) the competent authority being granted access to the operator as defined in ORO.GEN.140

to determine continued compliance with the relevant requirements of Regulation (EU)

2018/1139 and its delegated and implementing acts (EC) No 216/2008 and its

Implementing Rules; and

[…]

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Rationale

Editorial amendment. No impacts expected.

SUBPART MLR: MANUALS, LOGS AND RECORDS

ORO.MLR.100 Operations manual – general

(a) The operator shall establish an operations manual (OM) as specified under 8.b2 of Annex IV to

Regulation (EU) 2018/1139 (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected.

SUBPART FTL: FLIGHT AND DUTY TIME LIMITATIONS AND REST REQUIREMENTS

SECTION 1 – GENERAL

ORO.FTL.120 Fatigue risk management (FRM)

(a) When FRM is required by this Subpart or an applicable certification specification, the operator

shall establish, implement and maintain a FRM as an integral part of its management system.

The FRM shall ensure compliance with the essential requirements in points 7.f5, 7.g6 and 8.f7

of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008. The FRM shall be described in the

operations manual.

[…]

Rationale

Editorial amendment. No impacts expected.

ORO.FTL.125 Flight time specification schemes

(a) Operators shall establish, implement and maintain flight time specification schemes that are

appropriate for the type(s) of operation performed and that comply with Regulation (EU)

2018/1139 (EC) No 216/2008, this Subpart and other applicable legislation, including Directive

2000/79/EC.

[…]

Subpart, the operator shall apply the applicable certification specifications adopted by the

Agency. Alternatively, if the operator wants to deviate from those certification specifications in

accordance with Article 76(7) 22(2) of Regulation (EU) 2018/1139 (EC) No 216/2008, it shall

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provide the competent authority with a full description of the intended deviation prior to

implementing it. The description shall include any revisions to manuals or procedures that may

be relevant, as well as an assessment demonstrating that the requirements of Regulation (EU)

2018/1139 (EC) No 216/2008 and of this Subpart are met.

[…]

Rationale

Editorial amendment. No impacts expected.

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4.1.3. Annex VII (Part-NCC)

SUBPART A: GENERAL REQUIREMENTS

NCC.GEN.105 Crew responsibilities

[…]

(e) The crew member shall not undertake duties on an aircraft:

(1) if he/she he or she knows or suspects that he/she he or she is suffering from fatigue as

referred to in 7.f5 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008 or feels

otherwise unfit, to the extent that the flight may be endangered; or

(2) when under the influence of psychoactive substances or for other reasons as referred to

in 7.g6 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected.

NCC.GEN.106 Pilot-in-command responsibilities and authority

(a) The pilot-in-command shall be responsible for:

(1) the safety of the aircraft and of all crew members, passengers and cargo on board during

aircraft operations as referred to in 1.c3 of Annex IV to Regulation (EU) 2018/1139 (EC)

No 216/2008;

(2) […];

(3) ensuring that all instructions, operational procedures and checklists are complied with in

accordance with the operations manual and as referred to in 1.b2 of Annex IV to

Regulation (EU) 2018/1139 (EC) No 216/2008;

(4) only commencing a flight if he/she he or she is satisfied that all operational limitations

referred to in 2.a.3 (c) of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008 are

complied with, as follows:

[…]

(e) The pilot-in-command shall, in an emergency situation that requires immediate decision and

action, take any action he/she he or she considers necessary under the circumstances in

accordance with 7.d3 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008. In such cases

he/she he or she may deviate from rules, operational procedures and methods in the interest

of safety.

[…]

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Rationale

Editorial amendment. No impacts expected.

NCC.GEN.110 Compliance with laws, regulations and procedures

[…]

(b) The pilot-in-command shall be familiar with the laws, regulations and procedures, pertinent to

the performance of his/her his or her duties, prescribed for the areas to be traversed, the

aerodromes or operating sites to be used and the related air navigation facilities as referred to

in 1.a1 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008.

Rationale

Editorial amendment. No impacts expected.

SUBPART B: OPERATIONAL PROCEDURES

NCC.OP.190 Ice and other contaminants – flight procedures

[…]

(b) The pilot-in-command shall only commence a flight or intentionally fly into expected or actual

icing conditions if the aircraft is certified and equipped to cope with such conditions as referred

to in 2.a.5 of Annex IV to Regulation (EC) No 216/2008.

Rationale

Editorial amendment. No equivalent reference exists in Regulation (EU) 2018/1139. Nevertheless, all

the elements of the text of Regulation (EC) No 216/2008 are already contained in point (b) of

NCC.OP.190. Therefore, there is no need for further references. No impacts expected.

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4.1.4. Annex VII (Part-NCO)

SUBPART A: GENERAL REQUIREMENTS

NCO.GEN.101 Means of compliance

Alternative means of compliance to those adopted by the Agency may be used by an operator to

establish compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts. (EC)

No 216/2008 and its Implementing Rules.

Rationale

Editorial amendment. No impacts expected.

NCO.GEN.105 Pilot-in-command responsibilities and authority

(a) The pilot-in-command shall be responsible for:

(1) the safety of the aircraft and of all crew members, passengers and cargo on board during

aircraft operations as referred to in 1.c3 of Annex IV to Regulation (EC) No 216/2008 (EU)

2018/1139;

[…]

(3) ensuring that all operational procedures and checklists for the preparation and execution

of the flight are complied with as referred to in 1.b2 of Annex IV to Regulation (EC) No

216/2008 (EU) 2018/1139;

(4) only commencing a flight if he/she he or she is satisfied that all operational limitations

referred to in 2.a.3(c) of Annex IV to Regulation (EC) No 216/2008 (EU) 2018/1139 are

complied with, as follows:

[…]

(e) The pilot-in-command shall, in an emergency situation that requires immediate decision and

action, take any action he/she he or she considers necessary under the circumstances in

accordance with 7.d3 of Annex IV to Regulation (EC) No 216/2008 (EU) 2018/1139. In such cases

he/she he or she may deviate from rules, operational procedures and methods in the interest

of safety.

[…]

Rationale

The amendments proposed are intended to update the regulatory references to the EASA Basic

Regulation.

Regarding point (a)(3), some additional text has been inserted considering that the current text of

point 1.2 of Annex V to the Basic Regulation (‘A flight must be performed in such a way that the

operating procedures specified in the Flight Manual or, where required the Operations Manual, for the

preparation and execution of the flight are followed’) is not completely identical to point 1.b of

Annex IV to Regulation (EC) No 216/2008. The latter regulation contained a second sentence (‘To

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facilitate this, a checklist system must be available for use, as applicable, by crew members in all phases

of operation of the aircraft under normal, abnormal and emergency conditions and situations.

Procedures must be established for any reasonably foreseeable emergency situation’), which has

become point 8.11 of Annex V to the Basic Regulation, making it applicable only to commercial air

transport and other operations subject to a certification or declaration requirement (i.e. operations

covered by Parts-CAT, -NCC, -SPA and -SPO).

See the rationale for the proposed changes to AMC1 NCO.GEN.105(a)(3).

These changes are merely editorial, and no impact is expected.

NCO.GEN.110 Compliance with laws, regulations and procedure

[…]

(b) The pilot-in-command shall be familiar with the laws, regulations and procedures, pertinent to

the performance of his/her duties, prescribed for the areas to be traversed, the aerodromes or

operating sites to be used and the related air navigation facilities as referred to in 1.a1 of Annex

IV to Regulation (EU) 2018/1139 (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected.

SUBPART B: OPERATIONAL PROCEDURES

NCO.OP.170 Ice and other contaminants – flight procedures

[…]

(a) The pilot-in-command shall only commence a flight or intentionally fly into expected or actual

icing conditions if the aircraft is certified and equipped to cope with such conditions as referred

to in 2.a.5 of Annex IV to Regulation (EC) No 216/2008.

Rationale

Editorial amendment. No impacts expected. See the rationale for proposed amendments to

NCC.OP.190.

SUBPART E: SPECIFIC REQUIREMENTS

NCO.SPEC.115 Crew responsibilities

[…]

(e) The crew member shall not undertake duties on an aircraft:

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(1) if he/she knows he or she or suspects that he/she he or she is suffering from fatigue as

referred to in 7.f.5 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008or feels

otherwise unfit to perform his/her his or her duties; or

(2) when under the influence of psychoactive substances or for other reasons as referred to

in 7.g 6 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected.

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4.1.5. Annex VIII (PART-SPO)

SUBPART A: GENERAL REQUIREMENTS

SPO.GEN.101 Means of compliance

Alternative means of compliance to those adopted by the Agency may be used by an operator to

establish compliance with Regulation (EU) 2018/1139 and its delegated and implementing acts (EC)

No 216/2008 and its Implementing Rules.

Rationale

Editorial amendment. No impacts expected.

SPO.GEN.105 Crew responsibilities

[…]

(e) The crew member shall not undertake duties on an aircraft:

(1) if he/she he or she knows or suspects that he/she he or she is suffering from fatigue as

referred to in 7.f.5 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008or feels

otherwise unfit to perform his/her his or her duties; or

(2) when under the influence of psychoactive substances or for other reasons as referred to

in 7.g 6 of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected.

SPO.GEN.107 Pilot-in-command responsibilities and authority

(a) […]

(4) only commencing a flight if he/she he or she is satisfied that all operational limitations

referred to in 2a.3 (c) of Annex IV to Regulation (EU) 2018/1139 (EC) No 216/2008 are

complied with, as follows:

[…]

Rationale

Editorial amendment. No impacts expected.

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SUBPART B: OPERATIONAL PROCEDURES

SPO.OP.176 Ice and other contaminants – flight procedures

(a) The pilot-in-command shall only commence a flight or intentionally fly into expected or actual

icing conditions if the aircraft is certified and equipped to cope with such conditions as referred

to in 2.a.5 of Annex IV to Regulation (EC) No 216/2008.

[…]

Rationale

Editorial amendment. No impacts expected. See the rationale for proposed amendments to

NCC.OP.190.

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4.2. Draft acceptable means of compliance and guidance material

4.2.1. Annex II (Part-ARO)

SUBPART GEN: GENERAL REQUIREMENTS

SECTION 2 – MANAGEMENT

GM1 ARO.GEN.200(a) Management system

GENERAL

(a) The competent authority designated by each Member State should be organised in such a way

that:

[…]

(2) the functions and processes described in the applicable requirements of Regulation (EU)

2018/1130 (EC) No 216/2008 and its Implementing Rules and its delegated and

implementing acts, AMCs, Certification Specifications (CSs) and Guidance Material (GM)

may be properly implemented;

(3) the competent authority’s organisation and operating procedures for the

implementation of the applicable requirements of Regulation (EU) 2018/1139 and its

delegated and implementing acts (EC) No 216/2008 and its Implementing Rules are

properly documented and applied;

[…]

(b) A general policy in respect of activities related to the applicable requirements of Regulation (EU)

2018/1139 and its delegated and implementing acts (EC) No 216/2008 and its Implementing

Rules should be developed, promoted and implemented by the manager at the highest

appropriate level; […]

[…]

(d) The general policy, whilst also satisfying additional national regulatory responsibilities, should

in particular take into account:

(1) the provisions of Regulation (EU) 2018/1139 (EC) No 216/2008;

[…]

Rationale

Editorial amendment. No impacts expected.

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4.2.2. Annex III (Part-ORO)

SUBPART GEN: GENERAL REQUIREMENTS

SECTION 2 – MANAGEMENT

AMC1 ORO.GEN.160(c) Occurrence reporting

OCCURRENCES OR EVENTS INVOLVING HUMAN INTERVENTION

(a) According to ORO.GEN.160(c), the operator needs to process reported human intervention-

related occurrences, events or adverse trends that may reveal shortcomings related to design,

procedures or training, or a combination of those, detected during flight operations and/or

operator simulator training and checking sessions.

(b) Where the operator cannot determine with certainty that the human intervention-related

occurrence, event or adverse trend is linked to design or where it cannot be excluded that there

is a link to design, the operator should report said occurrence/event to the organisation

responsible for the design of the aircraft.

of the aircraft have been thoroughly analysed, under their management system process, and

contain sufficiently detailed information to allow the organisation responsible for the design of

the aircraft to conduct its own analysis in an efficient manner.

(d) The operator should report at least the following supporting analysis and information to the

organisation responsible for the design of the aircraft, if available.

(1) A description of:

(i) the operational context at the time of the occurrence, such as air traffic control

clearance and meteorological and environmental conditions;

(ii) any relevant information concerning flight crew (e.g. experience on type, time on

duty preceding event, fatigue);

(iii) the aircraft status, including details of any minimum equipment list items;

(iv) any relevant issue on crew resource management; and

(v) relevant pilot training details.

(2) Information on:

(i) how the occurrence was detected (whom, when and how); and

(ii) how the crew recovered from the occurrence (whom, when and how).

(3) Other relevant data, such as:

(i) pilot report data;

(ii) technical logbook data;

(iii) if permitted by flight data monitoring programme requirements and by the

operator’s procedures regarding the protection of flight crew identity, data from

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the flight data monitoring programme that is relevant for the analysis of the

occurrence;

(i) aircraft communication addressing and reporting system (ACARS) data; and

(ii) data on the existence of similar previous events, and whether they resulted (on

those occasions) in unsafe conditions.

(4) If the event or trend concerns operator simulator training and/or checking, the

information provided to the organisation responsible for the design of the aircraft should

include information regarding the training scenario, configuration of the simulator, type

representativeness of the simulator used, any simulator limitations and any other

relevant information pertaining to the training and simulator used.

(e) The operator should actively cooperate with the organisation responsible for the design of the

aircraft and support any investigation commenced by the organisation after reporting an

occurrence/event pursuant to point (b), including timely responses to any additional requests

made.

Rationale

Please refer to the rationale for ORO.GEN.160.

GM1 ORO.GEN.160(c) Occurrence reporting

OCCURRENCES OR EVENTS INVOLVING HUMAN INTERVENTIONS

The following table provides a non-exhaustive list of possible human interventions that could lead or

contribute to a reduction in safety margins and could lead to reportable occurrences or adverse trends

of occurrences.

Table 1 — Non-exhaustive list of events and/or conditions that could lead or contribute to a

reduction in safety margins

Category Outcome Definition

Perception No/wrong/late

visual detection

The operator’s flight crew does not detect (or detects

too late or inaccurately) a visual signal necessary to

formulate a proper action plan or make a correct

decision.

No/wrong/late

aural detection

The operator’s flight crew does not detect (or detects

too late or inaccurately) an aural signal necessary to

formulate a proper action plan or make a correct

decision.

No/wrong/late

kinaesthetic

detection

The operator’s flight crew does not detect (or detects

too late or inaccurately) a kinaesthetic signal (e.g. stick

shaker or pusher) necessary to formulate a proper

action plan or make a correct decision.

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Planning and

decision-making

Incorrect/late/

absence of

decision or plan

The operator’s flight crew is not able to develop an

adequate action plan or decision to manage the

situation.

Response

execution

Timing error The operator’s flight crew takes action that is

appropriate for the perceived situation but executes it

either too early or too late.

Sequence error The operator’s flight crew carries out a series of actions

in the wrong sequence.

Correct action on

the wrong object

The operator’s flight crew takes action that is

appropriate for the perceived situation but executes it

wrongly by selecting an object (e.g. lever, knob, button,

any other HMI element) different from the intended

one.

Wrong action on

the right object

The operator’s flight crew selects the correct object

(e.g. lever, knob, button, any other HMI element) but

performs an action that is not the correct one.

Lack of physical

coordination

The operator’s flight crew takes action that is

appropriate for the perceived situation but executes it

in a wrong manner.

No action

executed

The operator’s flight crew intends to take action that is

appropriate for the perceived situation but does not

execute it.

Communication Incorrect/unclear

transmission of

information

The operator’s flight crew transmits information to

other actors, but this information is incorrect or unclear

(e.g. use of incorrect entry).

No transmission of

information

The operator’s flight crew does not transmit

information that is necessary for other actors to

operate safely/effectively.

Rationale

Please refer to the rationale for ORO.GEN.160.

AMC1 ORO.GEN.200(a)(1) Management system

COMPLEX OPERATORS — ORGANISATION AND ACCOUNTABILITIES

[…]

(a) Safety manager

[…]

(2) The functions of the safety manager should be to:

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[…]

(vi) provide advice on safety matters; and

(vii) ensure initiation and follow-up of internal occurrence/accident investigations.;

(viii) ensure, if a flight data monitoring programme is required, its effective use for

safety risk management.

[…]

(b) Safety review board

[…]

(3) The safety review board should monitor:

[…]

(iii) the effectiveness of the operator’s safety management processes, including those

related to the flight data monitoring programme, if such a programme is required.

[…]

Rationale

AMC1 ORO.AOC.130 specifies that the safety manager should be responsible for the FDM programme.

In addition, the operator’s safety review board should monitor the effectiveness of the FDM

programme as part of its monitoring of the management system’s effectiveness.

Therefore, AMC1 ORO.GEN.200(a)(1) (organisation and accountabilities at a complex operator) is

proposed to be modified to include mentions of the FDM programme in the descriptions of the tasks

of the safety manager and of the safety review board.

AMC1 ORO.GEN.200(a)(3) Management system

COMPLEX OPERATORS — SAFETY RISK MANAGEMENT

(a) Hazard identification processes

(1) Reactive and proactive schemes for hazard identification should be the formal means of

collecting, recording, analysing, acting on and generating feedback about hazards and the

associated risks that affect the safety of the operational activities of the operator. Such

schemes should include the flight data monitoring programme when such a programme

is required.

[…]

(d) Safety performance monitoring and measurement

[…]

(2) This process should include:

(i) safety reporting, addressing also the status of compliance with the applicable

requirements;

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(ii) the flight data monitoring programme, for those aircraft required to be included in

such a programme;

(iii)(ii) safety studies, that is, rather large analyses encompassing broad safety concerns;

(iv)(iii) safety reviews including trends reviews, which would be conducted during

introduction and deployment of new technologies, change or implementation of

procedures, or in situations of structural change in operations;

(v)(iv) safety audits focussing on the integrity of the operator’s management system, and

periodically assessing the status of safety risk controls; and

(vi)(v) safety surveys, examining particular elements or procedures of a specific

operation, such as problem areas or bottlenecks in daily operations, perceptions

and opinions of operational personnel and areas of dissent or confusion.

Rationale

AMC1 ORO.GEN.200(a)(3) (implementation of safety risk management by complex operators)

mentions several sources of safety data for hazard identification, and safety performance monitoring

and measurement (‘reporting systems’, ‘safety studies’, ‘safety audits’, ‘safety surveys’, etc), but not

the FDM programme, although ORO.AOC.130 and SPA.HOFO.145 state that the FDM programme shall

be part of the operator's management system and point (b) of AMC1 ORO.AOC.130 covers the main

steps of SRM.

It is expected that an explicit mention of the FDM programme in this AMC will drive operators to fully

integrate their FDM programme in their management system and competent authorities to verify the

use of the FDM programme to support SRM.

In order to provide operators with sufficient period to implement these changes to their SRM processes,

EASA intends to specify a deferred applicability of 2 years for these changes in the EASA ED Decision

that will adopt them.

Note: In Chapter 3 of EASA NPA 2022-11, it is proposed to introduce a new AMC2 ORO.GEN.200(b) with

the following condition: ‘if the operator holds a HEMS, HOFO or HHO specific approval, it should

implement all the elements and processes of a management system applicable to complex operators.’

If that proposal is adopted, AMC1 ORO.GEN.200(a)(1) and AMC1 ORO.GEN.200(a)(3) will then become

applicable to all helicopter offshore operators in the scope of this NPA, whereas today they are only

applicable to offshore operators with a workforce of more than 20 full-time-equivalent staff, in

accordance with AMC1 ORO.GEN.200(b). However, since most offshore operators have a workforce

that is significantly larger than 20 full-time-equivalent staff, it is considered that the adoption of

AMC2 ORO.GEN.200(b) will not change the impact of the proposed amendments to

AMC1 ORO.GEN.200(a)(1) and AMC1 ORO.GEN.200(a)(3). The public consultation on EASA NPA 2022-

11 ended on 20 March 2023.

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GM2 ORO.GEN.200(a)(2) Management system

SAFETY POLICY REGARDING THE USE OF DATA FOR PURPOSES OTHER THAN SAFETY RISK

MANAGEMENT

If a data source that is needed to support safety risk management is required to be protected, then it

is recommended that the safety policy required by ORO.GEN.200 provides for consistent protection

of this data source when it is used for other purposes. An example is using flight data for a flight data

monitoring programme (protection of the data source is required by ORO.AOC.130 and

SPA.HOFO.145) and for other programmes, such as a fuel efficiency programme or a preventive

maintenance programme. In this example, the safety policy consistently addresses the protection of

flight crew identity across all the programmes in which flight data is used.

Rationale

This new proposed GM recommends that when a source of data that is needed to support the SRM

process is required to be protected, and this data is also used for purposes other than safety, the

operator’s safety policy required by point (a)(2) of ORO.GEN.200 should address data source protection

for all possible uses of the data. This is necessary to avoid that uses of SRM data for purposes other

than safety are detrimental to SRM implementation (through inappropriate handling or disclosing of

this data and thereby degrading the operator’s safety culture or the quality of the data provided by

this source, or otherwise adversely affecting the use of this data for SRM) and ultimately the operator’s

management system.

FDM data is an example of such data (the operator is required to protect the source of data in

accordance with ORO.AOC.130).

AMC1 ORO.GEN.200(a)(6) Management system

COMPLIANCE MONITORING — GENERAL

[…]

(b) […]

(4) management system procedures and manuals, including procedures applicable to the

flight data monitoring programme, when such a programme is required;

[…]

Rationale

The protection of the data source required by points ORO.AOC.130 and SPA.HOFO.145 is not always

effective, especially because the FDM procedure specified in points (j) and (k) of AMC1 ORO.AOC.130

is not complied with. This in turn affects the trust of pilots and the safety culture at the operator, and

ultimately it makes the management system less effective. As the FDM programme shall be integrated

in the management system as per ORO.AOC.130 and SPA.HOFO.145, FDM programme procedures

should be considered part of the management system procedures, and therefore be in the scope of the

compliance monitoring function of every operator. This is clarified by the proposal to explicitly mention

the FDM programme procedures in point (b)(4) of AMC1 ORO.GEN.200(a)(6).

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SUBPART AOC: AIR OPERATOR CERTIFICATION

AMC1 ORO.AOC.130 Flight data monitoring – aeroplanes

ORGANISATION OF THE FLIGHT DATA MONITORING (FDM) PROGRAMME

(a) Safety manager responsibility: The the safety manager, as defined under

AMC1- ORO.GEN.200(a)(1), should be responsible for the identification and assessment of

issues and their transmission to the manager(s) responsible for the process(es) concerned. The

latter should be responsible for taking appropriate and practicable safety action within a

reasonable period of time that reflects the severity of the issue.

(b) Contribution to the management system: An an FDM programme should support the

identification of safety hazards, their evaluation and the management of associated risks,

required by ORO.GEN.200, by allowing the an operator to:

[…]

(3) estimate use the FDM information on the frequency and severity of such occurrences,

combined with an estimation of the level of severity, to assess the safety risks and to

determine which risks are unacceptable or may become unacceptable if the discovered

trend continues;

[…]

(1) Exceedance detection (‘FDM event’): searching for deviations from aircraft flight manual

limits and standard operating procedures. A set of core events should be selected to

cover the main areas of interest to the operator and as much as possible, the most

significant risks identified by the operator. The event definitions should be continuously

reviewed to reflect the operator’s current operating procedures.

(2) All flights measurement (‘FDM measurement’): a system defining what is normal practice.

This may be accomplished by retaining various snapshots of information from each flight.

[…]

(d) FDM analysis, assessment and process control tools: the effective assessment of information

obtained from digital flight data should be dependent on the provision of appropriate

information technology tool sets. These should include specialised software (‘FDM software’)

for processing the flight data. In addition, in order to easily link flight data with occurrence

reports and other data such as traffic data and weather data, these toolsets should have the

following capabilities:

(1) software capable of automatically and uniquely identifying individual flights in the data

files collected for FDM; and

(2) providing to the extent the necessary data is collected, for each FDM event detection,

the aircraft geographical position and altitude, the coordinated universal time (UTC) date

and time, the flight identification and the aircraft registration.

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(e) Education and publication Safety information and promotion: should be a fundamental

principle of aviation safety in helping to reduce accident rates. The operator should pass on the

lessons learnt to all relevant personnel and, where appropriate, industry. the output of the FDM

programme should be used, in compliance with the procedure specified in (k), to support the

sharing of safety information with flight crew members and all other relevant personnel.

(f) Accident and incident data requirements: Accident accident and incident data requirements

specified in CAT.GEN.MPA.195 take precedence over the requirements of an FDM programme.

In these cases the FDR data should be retained as part of the investigation data and may fall

outside the de-identification agreements.

(g) Event reporting: Every every flight crew member should be responsible for reporting events.

Significant risk-bearing incidents detected by FDM should therefore normally be the subject of

mandatory occurrence reporting by the crew. If this is not the case, then they should submit a

retrospective report that should be included under the normal process for reporting and

analysing hazards, incidents and accidents.

(h) Data recovery and analysis: The the data recovery and analysis strategy should ensure a

sufficiently representative capture of flight information to maintain an overview of operations.

Data analysis In addition, FDM event validation should be performed sufficiently frequently to

enable action to be taken on significant safety issues. This includes all of the following:

(1) At least 80 % of the recordings of the flights performed in the past 12 months of any

individual aeroplane that is in the scope of ORO.AOC.130 should be available for analysis

with the FDM software and have valid data, unless the operator demonstrates to its

competent authority that meeting this objective would cause a disproportionate cost

impact; in that case, the proportion of flight recordings of any individual aeroplane that

are available for analysis with the FDM software and have valid data should not be less

than 60 % when averaged over the past 12 months.

(2) The operator should have means to identify, within 15 calendar days, a failure of the

means to collect data from any individual aeroplane in the scope of ORO.AOC.130, unless

the operator demonstrates to its competent authority that meeting this objective would

cause a disproportionate cost impact; in that case, the time to identify such a failure

should not exceed 22 calendar days.

(3) The time between completion of a flight and routine processing of the data of that flight

by the FDM software (including event detection) should not exceed 15 calendar days for

at least 80 % of flights for which data was collected within the FDM programme in the

past 12 months, unless the operator demonstrates to its competent authority that

meeting this objective would cause a disproportionate cost impact; in that case, at least

80 % of the flights for which data was collected within the FDM programme in the past

12 months should be processed by the FDM software within 22 days of completion of the

flight.

(4) For each aeroplane that is in the scope of ORO.AOC.130 and that is first issued with an

individual certificate of airworthiness (CofA) on or after [date of publication + 3 years]:

(i) the operator should ensure that, within 90 calendar days after it starts operating

the aeroplane, the data collected for analysis by the FDM software includes all the

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flight parameters required to be recorded by a flight data recorder in accordance

with AMC1.2 CAT.IDE.A.190; and

(ii) the operator should ensure that, within 90 calendar days after it starts operating

the aeroplane, the recorded flight parameters specified in (i) meet the

performance specifications (range, sampling intervals, accuracy limits and

resolution in read-out) as defined in EUROCAE Document 112A or any later

equivalent standard produced by EUROCAE.

(5) The operator should document the principles it uses for validating significant FDM events

i.e. FDM events that require dedicated and timely review of the related flight data.

Validation of a significant FDM event should be performed as a matter of priority, and in

any case within 15 calendar days after it has been detected by the FDM software, for at

least 80 % of the significant FDM events.

(i) Data retention strategy: The the data retention strategy should aim at providing the greatest

safety benefits practicable from the available data:

(1) A full dataset all raw or decoded flight data recording files should be retained at least

until the action and review processes are complete. 80 % or more of raw or decoded flight

data recording files of the aircraft required to be part of the FDM programme should be

retained and readily retrievable for analysis for at least 2 years;

(2) thereafter, a reduced dataset relating to closed issues should be maintained for longer-

term trend analysis. Programme managers may wish to retain samples of de-identified

full-flight data for various safety purposes (detailed analysis, training, benchmarking,

etc.).

(j) Data access and security policy: The the data access and security policy should restrict

information access to authorised persons. When data access is required for airworthiness and

maintenance purposes, a procedure should be in place to prevent disclosure of crew identity.

(k) Procedure to prevent disclosure of crew identity: The the procedure to prevent disclosure of

crew identity should be written in a document, which should be signed by all parties (airline

management, flight crew member representatives nominated either by the union or the flight

crew themselves). This procedure should, as a minimum, define:

[…]

(6) the conditions under which the confidentiality may be withdrawn for reasons of gross

negligence or significant continuing safety concern the conditions under which the

protection of the information source may be withdrawn. These conditions should be

consistent with the provisions laid down in Regulation (EU) No 376/2014 and the

operator’s safety risk management procedures;

[…]

(l) Maintaining knowledge about data and algorithms: the operator should maintain knowledge of

the source of data and the algorithms used to produce FDM events and measurements. For

each individual aircraft required to be part of the FDM programme and first issued with an

individual CofA on or after [date of publication + 3 years], the operator should produce, within

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90 calendar days after it starts operating this aircraft, the following documentation, and

thereafter keep it up to date:

(1) Documentation on the data source and the performance (at least recording resolution

and recording rate) of all the flight parameters that are collected from that aircraft for

the purpose of the FDM programme.

(2) Documentation on the algorithms used to produce FDM events or FDM measurements

from the data collected from that aircraft. This should include the following:

(i) A description of the logic of each algorithm. This description should be sufficiently

detailed to verify consistency with the applicable flight manual limitations or

standard operating procedures (SOPs), as applicable. In the case of an FDM event

algorithm, the event trigger thresholds should be specified.

(ii) For each algorithm, the flight parameters needed by the algorithm and their

minimum performance for the algorithm to deliver reliable results (at least

minimum accuracy and minimum recording rate).

(l)(m) Airborne systems and equipment: for all aircraft required to be part of the FDM programme

and that are first issued with an individual CofA on or after [date of publication + 3 years],

Airborne airborne systems and equipment used to obtain FDM flight data should range from a

quick access recorder (QAR) in an aircraft with digital systems, to a crash-protected flight

recorder in an older or less sophisticated aircraft continuously collect the data throughout the

flight, including when the aircraft is moving on the ground under its own power. The analysis

potential of the reduced data set available in the latter case may reduce the safety benefits

obtainable. The operator should ensure that FDM use The use of such airborne systems and

equipment, including retrieval of data from the aircraft, does should not adversely affect the

availability or the serviceability of flight recorders equipment required for accident

investigation.

Rationale

The subtitle of AMC1 ORO.AOC.130 is proposed to be changed to clarify that this AMC addresses the

organisation of the FDM programme and not what risk areas should be monitored by the FDM

programme (the latter is addressed in AMC2 ORO.AOC.130, and examples of FDM methods are

provided in GM2 ORO.AOC.130).

Most of the proposed amendments to AMC1 ORO.AOC.130 introduce minimum performance

objectives for the collection of flight data, their processing by software, their analysis and their

retention. This is because the feedback from standardisation inspections (in non-public EASA

Standardisation Annual Reports for 2019 and 2020) and the evaluation of European Operators Flight

Data Monitoring forum (EOFDM) best-practices documents show a great disparity in the effectiveness

of the FDM programmes and that many operators invest too little in technology and human resources,

resulting in them not achieving the goal of an FDM programme.

AMC1 ORO.AOC.130 on flight data monitoring does not include performance objectives to ensure

minimum effectiveness of the FDM programmes. In several visited operators, FDM was not adequately

used by the operator, which hampered its identification of operational hazards and therefore its safety

risk management process.

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Excerpt from the 2019 EASA Standardisation Annual Report.

Other proposed amendments are intended to better show the contribution of the FDM programme to

the operator’s management system, especially to the safety risk management (SRM) process, and to

achieve more consistent protection of the information source between the occurrence reporting system

and the FDM programme.

In order to provide operators with sufficient notice period to implement the amendments, EASA intends

to specify a deferred applicability of 2 years for the changes to AMC1 ORO.AOC.130 in the EASA ED

Decision that will adopt them. In addition, it is proposed to restrict the applicability of points (h)(4), (l)

and (m) of AMC1 ORO.AOC.130 to aeroplanes that are first issued with an individual CofA at least

3 years after the date of publication of the ED Decision, as otherwise they may cause a change to

airborne systems or airborne equipment on already operated aeroplanes.

Detailed rationale

— Regarding point (b): standardisation findings reveal that some operators do not make any use

of the output of their FDM programme for the SRM process required by point (a)(3) of

ORO.GEN.200. Point (b) of AMC1 ORO.AOC.130 contains a description of the purpose of an FDM

programme that matches the main steps of the SRM process, but the link with ORO.GEN.200 is

missing. Therefore, reference to ORO.GEN.200 is proposed to be added.

— Regarding point (b)(3): the proposed amendments remove the ambiguity about the contribution

of the FDM programme regarding SRM: the FDM programme should provide data that supports

safety risk assessment and the monitoring of whether corrective actions are effective, but the

FDM programme is not the sole source of data for assessing safety risks.

— Regarding point (c)(1): it is proposed to move the deleted text to a new AMC2 ORO.AOC.130 that

is dedicated to what should be monitored by the FDM programme.

— Regarding point (d):

• If occurrence reports and relevant contextual data (weather data, traffic data, NOTAMs,

fatigue data, etc.) can easily be linked to FDM events and FDM measurements, this can

greatly enhance the analysis of events and trends. For this, it is necessary to accurately

know where (global navigation satellite system position) and when (UTC date and time)

an FDM event was detected and on which flight it happened (this is also applicable to the

data points required to make an FDM measurement). This means that the FDM software

should be capable of automatically and uniquely identifying individual flights in the flight

data files, enabling it to reliably and quickly relate the flight data of a given flight to other

data sources. Not every piece of FDM software currently has this capability and this will

be taken into account by deferring the applicability date of the amendments to

AMC1 ORO.AOC.130 by 2 years after the date of publication of the ED Decision.

• This also implies that the definition of each FDM event algorithm includes the extraction

of position, date and time information, so that this information can be easily linked with

contextual data afterwards. In addition, the flight identification (call sign) is important to

uniquely relate an event to a flight crew report. The aircraft registration may be useful to

check that the FDM event algorithm was applied to an aircraft type it was designed for.

However, since some of these flight parameters are not expected to be recorded on the

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flight data recorder (FDR) for all aeroplanes, it is not certain that they will always be

available for recording on a quick access recorder. Therefore, the condition ‘to the extent

the necessary data is collected’ is proposed to be added.

• The requirement in ORO.AOC.130 to have ‘adequate safeguards to protect the source of

the data’ still needs to be complied with. The scope of this proposed objective is only the

technical capability of the FDM software, not the use or protection of this data.

— Regarding point (e): this point is about informing flight crew members and promoting safety;

therefore, it is proposed that the heading ‘Education and publication’ is replaced by ‘Safety

information and promotion’. In addition, the content of this point is proposed to be reworded to

make it specific (‘and, where appropriate, industry’ is a rather vague condition). Point (a)(4) of

ORO.GEN.200 requires that the management system includes ‘maintaining personnel trained

and competent to perform their tasks’. Further, point (b) of AMC1 ORO.GEN.200(a)(4) specifies

that the operator should establish communication about safety matters with their staff. Hence,

the communication of safety information based on FDM to flight crew members supports the

objective set in ORO.GEN.200 to maintain the competence of the staff.

— Regarding points (h)(1) and (h)(2): the purpose of the proposed amendments is to limit the

probability that events go undetected because the event flight is not recorded or not processed

by the FDM software. A flight collection rate of 80 % for any individual aircraft should be an

achievable target for many operators (flight collection rate = number of valid flight recordings

with data collected / number of flown flights, computed over 1 year). Today, many operators

that have installed wireless quick access recorders collect data on 95 % or more of their flights.

Therefore, a target of 80 % is proposed for point (h)(1). For point (h)(2), the objective is to

identify a failure of the means to collect data from an individual aircraft within 15 calendar days.

In addition, because these objectives might cause a disproportionate cost impact for some

operators, points (h)(1) and (h)(2) offer the possibility to agree on less demanding objectives

with the competent authority, if justified (flight collection rate of 60 % and time to identify a

failure of the means to collect data from an individual aircraft not exceeding 22 calendar days).

— Regarding point (h)(3):

• For the FDM programme to effectively contribute to the SRM, it should detect significant

events and new adverse trends in a timely manner. For example, it may help detect

unreported events that require an immediate inspection to ensure that an aircraft is still

airworthy. This starts with timely collection of data after the flight and timely processing

of this data by the FDM software.

• Furthermore, when a retrospective report from a flight crew is needed or required in

accordance with Regulation (EU) 2015/1018, it is preferable to request it within a few

days of the concerned flight, when the crew members’ memory of the flight is still fresh.

As a general principle, the shorter the time taken to recover and analyse the flight data,

the better.

• However, for a small proportion of aeroplane operators, especially those performing on-

demand long-range flights, it may be more challenging to recover the flight data within

1 week or less. Therefore, the objective is proposed to be set to a maximum of 15 calendar

days for 80 % of the flights. In addition, because this objective might still cause a

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disproportionate cost impact for some operators, the proposed point (h)(3) offers the

possibility to agree on a less demanding objective with their competent authority, if

justified (22 calendar days for at least 80 % of the flights).

— Regarding point (h)(4):

• Without the necessary flight parameters, FDM event and measurement definitions cannot

be programmed or they are more difficult to programme as they may require

reconstructing some flight parameters in the first place, which can be challenging. An

example is terrain avoidance and warning system (TAWS) / ground proximity warning

system (GPWS) warnings: just recording that the TAWS displayed a warning to the flight

crew without indication of the active TAWS mode is often not sufficient for an event

analysis, but reliably reconstructing the active TAWS mode is far from straightforward.

• In addition, the performance of recorded flight parameters can be decisive for

implementing an FDM algorithm. For example, if the main gear compression parameter

is only recorded every 4 seconds, accurately locating the point of touchdown at landing is

challenging. With a typical approach speed of 150 kts, an aeroplane covers a distance of

about 310 m within 4 seconds.

• All aeroplanes with a MCTOM of over 5 700 kg that are first issued with an individual CofA

on or after 1 January 2023 and that are operated for commercial air transport should

record on an FDR the flight parameters specified in ED-112A Tables II-A.1 and II-A.2, and

comply with the performance requirements specified in those tables (refer to

AMC1.2 CAT.IDE.A.190). If these flight parameters are collected for recording by the FDR,

they can also be collected for FDM. Therefore, the data collected for FDM should include

these flight parameters. This set can be extended in terms of recorded parameters or their

performance, according to the needs of the operator or the peculiarities of the aircraft

model.

• Currently, many operators have no in-house abilities to modify data frame layouts on the

aircraft they operate. Therefore, it is proposed that point (h)(4) is only applicable to

aeroplanes manufactured on or after [date of publication + 3 years], to avoid a

disproportionate impact on currently operated aircraft.

• For newly operated aircraft, it is proposed that the operator is granted 90 calendar days

to check that the flight parameters specified in point (h)(4) are collected for that aircraft,

and that these flight parameters meet the performance specifications specified in ED-

112A. This time is considered sufficient to verify the content of the flight data collected

from the newly operated aircraft and to obtain the necessary documentation from the

installer of the airborne system that is used on that aircraft to collect flight data.

— Regarding point (h)(5):

• A time objective for the validation of significant FDM events is proposed, to ensure that

such events are addressed within a reasonable time. Significant FDM events are those

requiring a timely and dedicated analysis of the related flight data. Examples of significant

FDM events were introduced in point (a)(1) of GM1 ORO.AOC.130.

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• The validation of significant FDM events should be a priority task of the FDM programme.

A maximum time for validation of significant FDM events is proposed to be set to

15 calendar days from the time of their detection by the FDM software. This is a maximum

time and not the recommended time.

• This time objective needs to be met for at least 80 % of significant FDM events, and not

100 %, to give operators sufficient flexibility to cope with unplanned situations, especially

those operators with small FDM teams (typically just one or two staff members).

• To achieve this objective, a function should allow the FDM analyst to document the time

when a significant FDM event is validated, for showing compliance later. It is considered

that introducing such a function into current FDM software would not be challenging for

FDM software providers. In addition, the applicability date of the amendments to

AMC1 ORO.AOC.130 is intended to be deferred by 2 years after the date of publication of

the ED Decision, which should provide for sufficient notice period to update FDM software.

— Regarding point (i):

• Retaining more than a year of flight data is necessary to monitor long-term trends and to

factor in seasonal variations. Point (c)(2) of GM1 ORO.AOC.130 explains that ‘All events

are usually archived … Over time, this archived data can provide a picture of emerging

trends and hazards that would otherwise go unnoticed.’

• In addition, the recording duration should be sufficient to test and validate new FDM

event and measurement definitions. Testing and fine-tuning FDM event and

measurement definitions usually requires large numbers of flights.

• Retaining raw flight data for longer periods is also advantageous when an operator needs

to change FDM software, or when it needs evidence for a dispute (e.g. a passenger injury

claim).

• It is considered that 2 years of data retention is sufficient. A longer duration is not

proposed because of the volume of data to be stored and because the operated aircraft

and the nature of operations change over time, and older flights cannot always be related

to more recent flights.

As an example, the memory capacity required to store an hour of raw flight data,

assuming that 2 048 12-bit-long words are recorded per second, is 10.5 MB. Assuming

that utilisation of the aircraft is 18 hours per day on average, the memory capacity

required to store the raw flight data corresponding to 2 years of operation of the aircraft

is slightly more than 160 GB. Given that the current data storage cost is a few tens of euro

per terabyte of data, the total cost impact for an operator to store the raw flight data

corresponding to 2 years of operation of its fleet is considered very limited.

• The new objective might necessitate revisiting the agreement with flight crew

representatives regarding flight data protection. It is proposed to take this into account

by deferring the applicability date of the amendments to AMC1 ORO.AOC.130 by 2 years

after the date of publication of the ED Decision.

• The sentence ‘Programme managers may wish to retain samples of de-identified full-

flight data for various safety purposes (detailed analysis, training, benchmarking, etc.).’

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is proposed to be moved to point (c)(2)(iii) of GM1 ORO.AOC.130, as it does not specify

means of compliance and is rather guidance. In addition, it is slightly reworded

(‘programme managers’ is replaced by ‘the FDM team’).

— Regarding point (k)(6): the conditions for protection of information sources should be aligned

across different regulations so that operators can use the same processes or procedures

regardless of the source and to foster a positive safety culture. The framework for withdrawing

the protection of the information source is defined in Regulation (EU) No 376/2014.

— Regarding point (l): this is a new point proposed to ensure that operators maintain knowledge

of the collected flight data and of FDM algorithms implemented in their software, which is

sufficient to understand and correctly interpret the output of their FDM programme. The

operator is responsible for the FDM programme, and this includes responsibility for correct and

timely analysis of the output of FDM algorithms to support the SRM process. This responsibility

cannot be delegated or transferred and implies that the operator has sufficient knowledge of

the collected flight data and of how it was processed.

• To maintain this knowledge over time, the operator should document the following.

o Information on the data source (which aircraft sensor or system) and the

performance of flight parameters (recording resolution and recording rate). This

information should be documented as it is essential for ensuring that flight

parameters used by the FDM algorithms (FDM event algorithms and FDM

measurement algorithms) that are programmed in the FDM software are

adequate. This documentation should be controlled. In addition, it should include

the history of modifications, to retain knowledge of changes made despite the

evolution of the fleet and FDM staff changes.

o Information on the FDM algorithms that is sufficient to ensure that these

algorithms are adequate for the aircraft model, type of operation, SOPs, etc., or, if

necessary, to perform (or request) an adaptation of these FDM algorithms. Today,

many operators still use predefined algorithms that are provided with the FDM

software, and they unfortunately perform no or limited adaptation of these

algorithms.

• For newly operated aircraft, it is proposed that the operator is granted 90 calendar days

to produce this documentation. This time objective is aligned with point (h)(4), which also

grants 90 days to check the flight parameters collected from that aircraft and the

performance specifications of these flight parameters.

— Regarding point (m):

• Using the FDR for FDM should now be reserved for exceptional cases, as it brings

significant drawbacks for the FDM programme (the recording duration is limited, the

number of parameters is limited and collecting data is more resource intensive) and may

have an impact on the serviceability of the FDR. The FDR is required equipment for ICAO

Annex 13 purposes. Use of the FDR was probably more commonplace in the 1990s and

early 2000s, when there were no readily available alternatives, but today most operated

aircraft are fitted with dedicated FDM recorders (quick access recorders, wireless quick

access recorders, etc.). FDM has been required by JAR-OPS and then EU-OPS since 2005,

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and large commercial air transport aeroplanes manufactured in the last two decades all

have specific airborne equipment for FDM purposes, so they do not use the FDR.

• However, to not be overprescriptive and hinder the development of new technologies, the

use of the FDR is not proposed to be forbidden. Rather, the retrieval of flight data from

the aircraft for the purpose of the FDM programme should not affect the availability or

the serviceability of required flight recorders (FDRs, cockpit voice recorders, data link

recording systems, etc.).

• Rather than forbidding the use of the FDR, it is more relevant for this AMC to specify the

minimum performance of the airborne system, such as the capability to continuously

collect flight data throughout the flight, including in the ground phases.

AMC2 ORO.AOC.130 Flight data monitoring – aeroplanes

SCOPE OF THE FLIGHT DATA MONITORING (FDM) PROGRAMME

(a) A set of core FDM events or FDM measurements should be selected to cover the main areas of

interest to the operator and, as much as possible, the most significant risks identified by the

operator. The event definitions and measurement definitions should be continuously reviewed

to reflect the operator’s current operating procedures.

(b) For all aeroplanes in the scope of ORO.AOC.130 and that are first issued with an individual CofA

on or after 1 January 2016, the FDM programme should monitor, to the extent possible with

the available flight data and without requiring overly complex algorithms, at least the following

key risk areas:

(1) risk of runway excursion during take-off or landing;

(2) risk of airborne collision

(3) risk of aircraft upset; and

(4) risk of collision with terrain.

data, the FDM programme should monitor:

(1) exceedances indicating that the airworthiness of the aircraft may be affected and that

are related to:

(i) speed and configuration;

(ii) altitude;

(iii) accelerations;

(iv) attitude angles;

(v) engine limitations (such as related to thrust parameters, exhaust gas temperature,

vibration levels and reverse thrust versus aircraft speed);

(vi) aircraft weight;

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(2) caution and warning alerts to the flight crew indicating that the airworthiness of the

aircraft may be affected.

(d) The operator should establish and maintain a document identifying which types of occurrences

are monitored with the FDM programme. This document should cover at least the occurrences

subject to mandatory reporting and listed in Regulation (EU) 2015/1018, Annex I, Section 1

(excluding paragraph 1.5, point (3)) and Section 5. This document should provide a short

description of the applicable FDM event(s) or FDM measurement(s) for each type of occurrence

that is monitored with the FDM programme.

Rationale

There is no specification in AMC1 ORO.AOC.130 regarding the risk areas that should be monitored by

the FDM programme. As a result, compliance with AMC1 ORO.AOC.130 does not guarantee that the

operator uses its FDM programme to monitor the risk areas that are relevant for all large aeroplane

operators, such as those pointed out by the EASA Annual Safety Review or by the European Plan for

Aviation Safety, or those corresponding to occurrences subject to mandatory occurrence reporting in

accordance with Annex I to Regulation (EU) 2015/1018. Several accident investigations have shown

that this may lead to adverse trends not being detected at all by the operator because occurrences are

not reported by flight crews and not monitored through FDM25. See also No 2016-02R1 (erroneous

take-off parameters) and No 2017-20 (slow rotation at take-off) of the EASA safety information

bulletins.

In order to provide operators with sufficient notice period to implement the new proposed

AMC2 ORO.AOC.130, it is proposed that the applicability of this new proposed AMC is deferred by

2 years.

Detailed rationale

— Regarding the proposed point (a): it is proposed to move part of point (c)(1) of

AMC1 ORO.AOC.130 to point (a) of this new AMC, as this part addresses what is to be monitored

with the FDM programme. Point (a) contains the general conditions regarding the choice of the

risk areas to be monitored with the FDM programme and adapts the definitions of FDM events

and measurements to the SOPs.

— Regarding the proposed point (b):

25 See, for instance, the following investigation reports:

— Serious incident to the Airbus A340-313E registered F-GLZU on 11 March 2017 at Bogotà (Colombia), Bureau d’Enquêtes et d’Analyses (BEA France). Link to the BEA website: https://bea.aero/;

— Serious incident to the Boeing 737-800 registered PH-BXG, at Amsterdam Schiphol Airport on 10 June 2018, Dutch Safety Board (DSB Netherlands). Link to the DSB website: https://onderzoeksraad.nl/en/ ;

— Serious incident to a Boeing 737-800 registered G-JZHL at Kuusamo Airport, on 1 December 2021, Air Accidents Investigation Branch (AAIB United Kingdom). Link to the AAIB website: https://www.gov.uk/government/organisations/air-accidents-investigation-branch.

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• When considering commercial air transport operations with large aeroplanes, the most

relevant risk areas for monitoring are aircraft upset, airborne collision and runway

excursion according to EASA’s 202026 and 202127 annual safety reviews.

• In addition, these three key risk areas appear in Volume II of the 2024 EPAS28

(Section 3.1.1), along with the risk of terrain collision (29).

• These four key risk areas (airborne collision, runway excursion at take-off and landing,

aircraft upset and terrain collision) can be monitored with the help of the flight

parameters that are usually recorded for FDM programmes. The European Operators

Flight Data Monitoring forum has published detailed industry good practices on how to

monitor precursors related to these four key risk areas in its document titled Guidance for

the implementation of flight data monitoring precursors.

• It is important to monitor the risk of runway excursion at take-off and not only at landing,

as highlighted by No 2016-02 (erroneous take-off parameters) and No 2017-20 (slow

rotation at take-off) of the EASA safety information bulletins.

• The proposed point (b) is applicable to aeroplanes manufactured since 1 January 2016, as

these aeroplanes should record on the crash-protected FDR the parameters specified in

AMC1.1 CAT.IDE.A.190. These parameters are considered sufficient to monitor the four

key risk areas specified in point (b) using FDM algorithms. It is assumed that the airborne

systems and equipment used to obtain flight data for the FDM programme collect, as a

minimum, the parameters specified in AMC1.1 CAT.IDE.A.190. Usually, on aeroplanes

manufactured since 1 January 2016, such airborne systems and equipment collect many

more parameters.

— Regarding the proposed point (c):

• Any exceedance of a flight parameter value that indicates a potential effect on the

airworthiness of the aircraft should be monitored by the FDM. This includes, for example,

exceeding hard landing limits, load factor exceedance in flight, flap / slat / landing gear

overspeed, excessive engine temperature and tail strike. Point (c) also includes the

monitoring of caution and warning alerts to the flight crew, when they indicate that the

airworthiness of the aircraft may be affected.

• Airborne systems that are used to collect flight data (such as quick access recorders /

wireless quick access recorders) and installed on aeroplanes first issued with an individual

CofA on or after 1 January 2016 are assumed to record the necessary flight parameters

on the FDR to comply with AMC1.1 CAT.IDE.A.190. However, flight controls input, the

aircraft weight or engine settings might not be recorded for older aeroplanes. Therefore,

26 EASA, Annual Safety Review 2020, 2020 (https://www.easa.europa.eu/en/document-library/general-

publications/annual-safety-review-2020). 27 EASA, Annual Safety Review 2021, 2021 (https://www.easa.europa.eu/en/document-library/general-

publications/annual-safety-review-2021#group-easa-downloads). 28 EASA, European Plan for Aviation Safety (EPAS) 2024, 2024 (https://www.easa.europa.eu/en/document-library/general-

publications/european-plan-aviation-safety-epas-2024). 29 This explanation is based on the definition of ‘terrain collision’ in the Annex to Regulation (EU) 2020/2034.

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point (c) specifies ‘If the necessary flight parameters are collected by the airborne system

used to obtain flight data’.

• Using FDM for predictive maintenance or for on-condition monitoring is not in the scope

of point (c) because the purpose of an FDM programme is safety, not maintenance

efficiency. In addition, predictive maintenance and on-condition monitoring often require

data and analysis techniques that are different to those used for FDM.

— Regarding the proposed point (d):

• FDM algorithms should be used to help detect unreported occurrences that are in the

scope of Annex I to Regulation (EU) 2015/1018, as it is important to track these

occurrences. FDM algorithms can also help detect events that are precursors to

occurrences subject to mandatory reporting, so that corrective actions are taken to

prevent such occurrences.

• In addition, the FDM programme and occurrence reporting are both parts of the

operator’s management system and both under the control of the operator’s safety

manager. Some FDM events should already trigger a request for retrospective reporting

in accordance with point (g) of AMC1 ORO.AOC.130. FDM can be used to support

occurrence reporting and the management system while maintaining protection of the

data sources and without requiring the operator’s reorganisation.

• Annex I to Regulation (EU) 2015/1018 lists the occurrences related to the operation of the

aircraft that must be reported to the operator’s competent authority (in accordance with

Regulation (EU) No 376/2014). The most relevant for FDM are contained in Sections 1 and

5 of that Annex. However, the scope of paragraph 1.5, point (3), is very unspecific and

may raise questions about the protection of data sources, because this point is asking for

individual flight crew performance to be monitored: ‘Any occurrence where the human

performance has directly contributed to or could have contributed to an accident or a

serious incident.’ Therefore, it is proposed that this point is excluded.

• Some types of occurrences cannot be reliably monitored with just flight parameters (e.g.

incorrect fuel type or contaminated fuel, interference with the aircraft caused by laser

illumination). For others, monitoring based on FDM may require very complex algorithms.

For others, some flight parameters are missing for programming the FDM algorithms, or

the performance of these flight parameters may be insufficient. Therefore, point (d) only

specifies that the operator documents, for each occurrence in Section 1 (except

paragraph 1.5, point (3)) and Section 5 of Annex I, whether this occurrence is covered by

the FDM programme and, if so, with which FDM algorithm(s). The operator does not have

to implement new FDM algorithms to comply with point (d).

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GM1 ORO.AOC.130 Flight data monitoring – aeroplanes

IMPLEMENTATION OF AN FDM PROGRAMME

[…]

(a) FDM analysis techniques

(1) Exceedance / FDM event detection

(i) FDM programmes are used for detecting exceedances, such as deviations from

flight manual limits, standard operating procedures (SOPs), or good airmanship.

Typically, a set of core events establishes the main areas of interest that are based

on a prior assessment of the most significant risks by the operator. It is advisable

to monitor significant deviations from the SOPs in all phases of the flight, including

when the aircraft is on the ground. In addition, it is advisable to consider the

following risks: risk of runway excursion or abnormal runway contact at take-off or

landing, risk of loss of control in flight, risk of airborne collision, and risk of collision

with terrain.

Examples of FDM events for aeroplanes: low or high lift-off rotation rate, stall

warning, ground proximity warning system (GPWS) warning, flap limit speed

exceedance, fast approach, high or low on glideslope, heavy landing.

Examples of significant FDM events for aeroplanes: stall warning, terrain

awareness warning system (TAWS) warning.

(ii) Trigger logic expressions may be simple exceedances such as redline values. The

majority, however, are composites that define a certain flight mode, aircraft

configuration or payload-related condition. Analysis software can also assign

different sets of rules dependent on airport or geography. For example, noise

sensitive airports may use higher than normal glideslopes on approach paths over

populated areas. In addition, it might be valuable to define several levels of

exceedance severity (such as low, medium and high). While such levels of

exceedance severity can help identify the most relevant events and trends, they

should not be considered safety risk levels: assessing the safety risk level

associated with an exceedance or a trend usually requires a more thorough

assessment and considering all relevant data available to the operator.

Example for aeroplanes: FDM software assigning different sets of rules dependent

on airport or geography. For example, noise-sensitive airports may use higher-

than-normal glideslopes on approach paths over populated areas.

(iii) Exceedance detection provides useful information, which can complement that

provided in crew reports.

Examples for aeroplanes: reduced flap landing, emergency descent, engine failure,

rejected take-off, go-around, airborne collision avoidance system (ACAS) or GPWS

warning, and system malfunctions.

(iv) The operator may also modify the standard set of core events to account for

unique situations they regularly experience, or the SOPs they use.

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Example for aeroplanes: to avoid nuisance exceedance reports from a non-

standard instrument departure.

(v) The operator may also define new events to address specific problem areas.

Example for aeroplanes: restrictions on the use of certain flap settings to increase

component life.

(vi) Being able to easily adjust the variables of FDM event algorithms can be

advantageous, by allowing for an FDM event definition to be adapted to new

operational conditions.

(2) All-flights measurements / FDM measurements

[…]

Examples of parameters monitored for aeroplanes: take-off weight, flap setting,

temperature, rotation and lift-off speeds versus scheduled speeds, maximum pitch rate

and attitude during rotation, and gear retraction speeds, heights and times.

Examples of comparative analyses for aeroplanes: pitch rates from high versus low take-

off weights, good versus bad weather approaches, and touchdowns on short versus long

runways.

[…]

(4) Investigation of incidents flight data by the operator

[…]

Examples of incidents where recorded data could be useful, for aeroplanes:

— high cockpit workload conditions as corroborated by such indicators as late

descent, late localizer and/or glideslope interception, late landing configuration;

— unstabilised and rushed approaches, glide path excursions, etc.;

— exceedances of prescribed operating limitations (such as flap limit speeds, engine

overtemperatures); and

— wake vortex encounters, turbulence encounters or other events causing significant

vertical accelerations.

[…]

(5) […]

Examples of continuing airworthiness uses, for aeroplanes: engine thrust level and

airframe drag measurements, avionics and other system performance monitoring, flying

control performance, and brake and landing gear usage.

(b) FDM equipment and software

(1) General

FDM programmes generally involve systems that capture flight data, transform the data

into an appropriate format for analysis, and generate reports and visualisation to assist

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in assessing the data. Typically, the following equipment capabilities are is needed for

effective FDM programmes:

(i) […]

(ii) a means to transfer the data recorded on board the aircraft to the ground a ground-

based processing station; and

(iii) a ground-based computer system software or a service to process and analyse the

data, identify deviations from expected performance, generate reports to assist in

interpreting the read-outs, etc.; and

(iv) optional software for a flight animation capability to integrate all data, presenting

them as a simulation of in-flight conditions, thereby facilitating visualisation of

actual events.

(2) Airborne equipment

(i) The flight parameters and recording capacity required for flight data recorders

(FDR) to support accident investigations may be insufficient to support an effective

FDM programme. Other Several technical solutions are available, including the

following:

(A) Quick access recorders (QARs). QARs Some systems are installed in the

aircraft and record flight data onto a low-cost removable medium.

(B) Some systems automatically download transmit the recorded data

information via secure wireless systems after completion of the flight when

the aircraft is in the vicinity of the gate.

be analysed on board while the aircraft is airborne. Whatever the flight data

processing performed by such systems, a complete set of raw flight data still

needs to be recovered after the flight, as this is needed for in-depth analysis

of flight data by the FDM team.

(ii) Fleet composition, route structure and cost considerations will determine the most

cost-effective method of removing the data from the aircraft.

(3) Ground replay and analysis equipment FDM software or service

(i) Data are is downloaded from the aircraft recording device into a ground-based

processing station, where the data are and held securely to protect this sensitive

information.

(ii) FDM programmes generate large amounts of The processing and analysis of flight

data requiring requires specialised analysis FDM software or an FDM service.

(iii) The analysis FDM software or service typically converts the raw flight data into

flight parameters expressed in engineering units and textual interpretation (‘flight

parameter decoding’) and applies FDM algorithms on the flight parameters (refer

to points (a)(1) and (a)(2)) checks the downloaded flight data for abnormalities.

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(iv) The analysis FDM software or service may include: typically includes the following:

capability to produce parameter plots and parameter tables, capability to drill

down and visualise flight parameter values over the portion of the flight during

which an event was detected annotated data trace displays, engineering unit

listings, visualisation for the most significant incidents, access to interpretative

material, links to other safety information and statistical presentations.

(v) For the FDM software or service, the following additional capabilities are

advantageous.

(A) Capability to interface with advanced processing tools or to access advanced

functions libraries.

(B) Capability to link flight data with other data sources (such as occurrence

reports or weather data) in order to facilitate the analysis of events and

trends. This capability should be used in accordance with data protection

policies and procedures and its output restricted to authorised users (refer

to AMC1 ORO.AOC.130).

in a standard electronic format that is compatible with business intelligence

tools.

(D) Capability to export FDM outputs in formats compatible with geographical

information systems.

(E) Capability to replay flight data of a given flight in a flight animation, thereby

facilitating visualisation of actual events.

(F) Capability to design and provide individual FDM summary reports or

dashboards that can be confidentially consulted by flight crew members.

(G) Capability to export the information related to flight parameter decoding

into a file format:

(a) that is compliant with an electronic documentation standard that has

a general public licence policy; and

(b) that includes means to retain the history of changes to the decoding

information.

(1) FDM process

[…](i) […].

Examples for aeroplanes: rate of unstable approaches or hard landings.

(ii) Highlight unusual or potentially unsafe circumstances: the user determines when

non-standard, unusual or basically potentially unsafe circumstances occur; by

comparing them to the baseline margins of safety, the changes can be quantified.

Example for aeroplanes: increases in unstable approaches (or other unsafe events)

at particular locations.

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(iii) Identify potentially unsafe trends: based on the frequency and severity of FDM

events occurrence, trends are identified. Combined with an estimation of the level

of severity, the risks are assessed to determine which may become unacceptable

if the trend continues. If a trend seems to point at an increase of risk to an

unacceptable level, a safety risk assessment is necessary, as part of the operator

safety risk management.

Example for aeroplanes: a new procedure has resulted in high rates of descent that

are nearly triggering GPWS warnings.

(iv) Mitigate risks: once an unacceptable risk has been identified, appropriate risk

mitigation actions are decided on and implemented.

Example: having found high rates of descent, the SOPs are changed to improve

aircraft control for optimum/maximum rates of descent.

(iv) Monitor effectiveness of corrective actions, if the FDM programme is relevant for

that purpose: once a remedial action has been put in place in the framework of the

operator’s safety risk management, its effectiveness is monitored, confirming that

it has reduced the identified risk and that the risk has not been transferred

elsewhere. At this stage, the operator typically evaluates whether the FDM

programme can contribute to this monitoring.

Example for aeroplanes: confirm that other safety measures at the aerodrome with

high rates of descent do not change for the worse after changes in approach

procedures.

(2) Analysis and follow-up

(i) FDM data is are typically processed compiled every month or at shorter intervals.

The data is are then reviewed to identify specific exceedances and emerging

undesirable trends and to disseminate the information to flight crews.

(ii) If deficiencies in pilot handling technique deviations from the standard operating

procedures are evident detected and require attention, the information is usually

de-identified in order to protect the identity of the flight crew. The information on

specific these deviations is passed (in accordance with point (k) of

AMC1 ORO.AOC.130) to the person responsible exceedances is passed to a person

(safety manager, agreed flight crew representative, honest broker) assigned by the

operator for flight crew contact confidential discussion with the pilot. The decision

to initiate flight crew contact (e.g. notification, request for additional information

or confidential discussion) should be made after an initial assessment that takes

into account contextual information. If it is decided to have a confidential

discussion with the flight crew, the responsible person assigned by the operator

provides the necessary contact with the pilot in order to clarify the circumstances,

obtain feedback and give advice and recommendations for appropriate action.

Such appropriate action is determined after a thorough safety risk assessment that

is performed in the framework of the operator safety risk management and that

takes into account all available data. Appropriate action could include re-training

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for the pilot (carried out in a constructive and non-punitive way), revisions to

manuals, or requesting changes to ATC and or airport operating procedures.

(iii) Follow-up monitoring enables the effectiveness of any corrective actions to be

assessed. Flight crew feedback is essential for the identification and resolution of

safety problems and could be collected through interviews, for example by asking

the following:

(A) Are the desired results being achieved soon enough?

(B) Have the problems really been corrected, or just relocated to another part

of the system?

(iiiiv) All events are usually archived in a way that means they can be sorted, validated

and presented database. The database is used to sort, validate and display the data

in easy-to-understand management reports. Over time, this archived data can

provide a picture of emerging trends and hazards that would otherwise go

unnoticed. In addition, the FDM team may wish to retain samples of de-identified

full-flight data for various safety purposes (detailed analysis, training,

benchmarking, etc.).

(iv) Sharing of safety information is part of the necessary processes to maintain

personnel competent to perform their tasks and to support an effective

management system (refer to ORO.GEN.200). Therefore, lessons Lessons learnt

from the FDM programme may warrant inclusion in the operator’s safety

promotion programmes. Safety promotion media may include newsletters, flight

safety magazines, emails, video messages, the provision of information on the

company’s intranet, highlighting examples in training and simulator exercises,

periodic reports to industry and the competent authority. Care is required,

however, to ensure that any information acquired through FDM is de-identified

before using it in any training or promotional initiative.

(vi) […]

(d) Preconditions for an effective FDM programme

(1) Protection of FDM data and of related flight crew reports

The integrity of FDM programmes rests upon protection of the FDM data. Any disclosure

for purposes other than safety management can compromise the voluntary provision of

safety data, thereby compromising flight safety. It is also advised to take into account

Regulation (EU) 2016/679 (general data protection regulation), where applicable. In

addition, the inherent protection of reporters under Regulation (EU) No 376/2014 applies

to flight crew members, whether their reports are voluntarily provided or retrospectively

requested by the operator.

[…]

(3) Requisite safety culture

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Indicators of an effective a positive safety culture within an FDM programme typically

include:

(i) top management’s demonstrated commitment to promoting a proactive positive

safety culture;

[…]

(iv) involvement of persons with appropriate expertise when assessing FDM events,

FDM measurements and trends when identifying and assessing the risks (for

example, pilots experienced on the aircraft type being analysed);

[…]

(vii) an efficient communication system for disseminating hazard information (and

subsequent risk assessments) internally and to other organisations to permit

timely safety action. inclusion of the general trends provided by and lessons learnt

from the FDM programme in the communications on safety matters specified in

AMC1 ORO.GEN.200(a)(4).

(4) Integration with the operator’s management system

Point ORO.AOC.130 requires the integration of the FDM programme with the operator’s

management system. Because of that, FDM programme outputs are expected to be used

together with other relevant data sources and for supporting safety risk management

(SRM). The SRM process is not an internal process of the FDM programme, but a process

of the operator’s management system. AMC1 ORO.AOC.130 specifies that the safety

manager should be responsible for the identification and the assessment of issues, which

are the first steps of the SRM process. The European Operators Flight Data Monitoring

forum document Breaking the Silos (June 2019) details industry good practice regarding

integration of the FDM programme in the management system.

(5) Up-to-date flight parameter decoding documentation

(i) The flight parameter decoding documentation is the documentation containing

information sufficient for extracting flight parameter values from the recording

data files and decoding them into values expressed in engineering units or textual

interpretation This information is essential for programming flight parameter

decoding by the FDM software.

(ii) It is important that flight parameter decoding documentation is obtained at the

time of aircraft delivery and that it is kept up to date. To facilitate the management

of this documentation over time, it is recommended that this documentation is

compliant with an electronic documentation standard that has a general public

licence policy. In addition, it is advisable to have a versioning system that allows

for quick identification of the applicable decoding information for any individual

aircraft and any time period.

(iii) When the airborne equipment used for FDM purposes records a copy of the FDR

data stream, the FDR decoding documentation that must be retained in

accordance with CAT.GEN.MPA.195 could be used.

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(e) Implementing an FDM programme

[…]

(2) Aims and objectives of an FDM programme

(i) As with any project there is a need to define the direction and objectives of the

work. A phased approach is recommended so that the foundations are in place for

possible subsequent expansion into other areas. Using a building block approach

will allow expansion, diversification and evolution through experience.

Example: with a modular system, begin by looking at basic safety-related issues

only. Add engine health monitoring, etc. in the second phase. Ensure compatibility

with other systems.

(ii) A staged set of objectives starting from the first week’s replay and moving through

early production reports into regular routine analysis will contribute to a sense of

achievement as milestones are met.

Examples of short-term, medium-term and long-term goals:

(A) Short-term goals:

— establish data download procedures, test replay FDM software, and

identify aircraft defects;

— verify, for all aircraft in the FDM programme, that the flight

parameters used for FDM events and measurements are valid and

correctly decoded;

— verify that the flight parameter decoding documentation (see

point (d)) is complete and correct;

— design and/or adapt FDM algorithms and test them, validate and

investigate exceedance detections data; and

— establish a user-acceptable routine report format to highlight

individual exceedances and facilitate the acquisition of relevant

statistics.

(B) Medium-term goals:

— produce reports and dashboards an annual report — that include key

performance indicators;

— add other modules to the analysis (e.g. continuing airworthiness); and

— plan for the next fleet to be added to the FDM programme.

— network FDM information across all of the operator’s safety

information systems; and

— ensure FDM provision for any proposed alternative training and

qualification programme (ATQP).; and

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— use utilisation and condition monitoring to reduce spares holdings.

(iii) Initially, focusing on a few known areas of interest will help prove the system’s

effectiveness. In contrast to an undisciplined ‘scatter-gun’ approach, a focused

approach is more likely to gain early success.

Examples for aeroplanes: rushed approaches, or rough runways at particular

aerodromes. Analysis of such known problem areas may generate useful

information for the analysis of other areas.

(3) The FDM team

(i) Experience has shown that the ‘team’ necessary to run an FDM programme could

vary in size from one person for a small fleet, to a dedicated section for large fleets.

The descriptions below identify various functions to be fulfilled, not all of which

need a dedicated position. As the safety manager should be responsible for the

FDM programme, and FDM outputs should, to the extent possible, be analysed in

relation to other safety data sources, it is expected that the FDM team is part of

the safety manager’s team.

(A) Team leader: it is essential that the team leader earns the trust and full

support of both management and flight crew. The team leader acts

independently of others in line management to make recommendations that

will be seen by all to have a high level of integrity and impartiality. The

individual requires good analytical, presentation and management skills.

(B) Flight operations interpreter: this person is usually a current qualified pilot

(or perhaps a recently retired senior captain or instructor), who knows the

operator’s route network and aircraft. This team member’s in-depth

knowledge of SOPs, aircraft handling characteristics, aerodromes and routes

is used to place the FDM data in a credible context.

[…]

(E) Engineering technical support: this person is usually an avionics specialist,

involved in the supervision of mandatory serviceability requirements for FDR

systems. This team member is knowledgeable about FDM and the associated

systems needed to run the programme.

(F) FDM analyst: this person is responsible for the design and validation of FDM

algorithms and the analysis of FDM outputs. This usually requires at least

basic knowledge of statistics and/or programming skills, and in-depth

knowledge of the FDM software or service. If the processing of data or the

validation of FDM events is subcontracted to a service provider, the FDM

analyst should have the necessary skills to effectively control and direct the

work performed by that service provider. Replay operative and

administrator: this person is responsible for the day-to-day running of the

system, producing reports and analysis.

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(ii) All FDM team members need appropriate training or experience for their

respective area of data analysis. Each team member is allocated a realistic amount

of time to regularly spend on FDM tasks.

(f) Other uses of flight data

Whenever access to data from the FDM programme is requested to meet operational needs,

such as fuel efficiency, aircraft performance and preventive maintenance, it is recommended to

have a written procedure in place to prevent disclosure of crew identity. Furthermore, it is

advisable that such a procedure contains, as a minimum, the following:

(1) the aim of the programme in which flight data is to be used;

(2) a data access and security policy, restricting access to information to specifically

authorised persons identified by their position;

(3) a data retention policy; and

(4) the method to obtain de-identified flight crew feedback on those occasions that require

specific flight follow-up for contextual information.

(g) The FDM programme and large data exchange programmes

Some States and organisations have set up so-called large data exchange programmes, under

which they gather very large amounts of data (including FDM data) provided by many operators

and by other industry stakeholders, which are then centrally processed and analysed.

Participation in a large data exchange programme may bring various benefits for an operator,

such as being able to compare its safety performance with that of comparable operators or

getting access to other types of data (weather, traffic, etc.) or to advanced data integration

capabilities. In addition, in the case of an operator with a small fleet producing small amounts

of flight data that do not allow for reliable identification of trends, joining a large data exchange

programme might help to overcome this limitation. However, taking part in a large data

exchange programme does not in itself satisfy ORO.AOC.130 and every operator remains

responsible for the implementation of its FDM programme. The operator’s FDM programme

needs to be well integrated into the management system for it to take advantage of a large data

exchange programme.

Rationale

GM1 ORO.AOC.130 is proposed to be updated, to reflect technological evolutions and current industry

best practice. In addition, corrections were needed to clarify the following:

— the FDM programme is expected to support SRM, but the SRM steps should not be implemented

by the FDM programme in isolation;

— the use of flight data for purposes other than the FDM programme should be framed by

procedures to ensure appropriate handling of this data;

— the expected benefits from taking part in a large data exchange programme, and differences

between a large data exchange programme and the FDM programme of an operator.

Detailed rationale

— Regarding the changes proposed to point (a)(1):

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• The second sentence of point (a)(1)(i) has been deleted, as its intent is covered by point (a)

of AMC2 ORO.AOC.130. Similarly, the last sentence of point (a)(1)(i) has been deleted, as

its intent is covered by point (b) of AMC2 ORO.AOC.130.

• A sentence has been inserted into point (a)(1)(i) to recommend monitoring significant

deviations from the SOPs in all phases of flight. It is important that the FDM algorithms

cover all phases of flight (including taxi) as safety issues have been identified for each

flight phase. Refer to the CAT aeroplanes safety risk portfolio, as presented, for instance,

in Volume III of the 2021–2025 EPAS30. The investigation of a serious incident regarding

an Airbus A34031 found that several operators did not have any FDM algorithm in place

to monitor take-off performance, which shows the need to include all flight phases. The

investigation reports of two serious incidents with a Boeing 737-80032 illustrate the value

of FDM for detecting take-offs with insufficient performance when they are not reported

by the flight crew.

• The examples of FDM events are split into ‘examples of FDM events for aeroplanes’ and

‘examples of significant FDM events for aeroplanes’. This is to illustrate the notion of

‘significant FDM events’ that is proposed to be introduced in point (h)(5) of

AMC1 ORO.AOC.130.

• A sentence has been inserted in point (a)(1(ii) to remind operators that the FDM event

severity level is not equal to the level of safety risk. As some operators tend to confuse

these two notions, clarification was felt necessary.

• A point (a)(1)(vi) has been added, as being able to adjust the FDM event algorithms in the

event of a change to the SOPs, new destinations, etc., can make a significant difference

with regard to the relevance of results. For this purpose, it is not always necessary to

define a new FDM event: adjusting some variables in the FDM event algorithm can be

sufficient. Today, many operators use predefined algorithms that are provided in their

FDM software or by their FDM service provider and they unfortunately perform no or

limited adaptation of these algorithms.

— Regarding the changes proposed to point (a)(4):

The example of an incident related to high cockpit workload was removed, as there is no

scientific evidence that flight crew workload could be reliably assessed using only flight data.

— Regarding the changes proposed to point (b)(1):

• The capabilities needed to support the processing of flight data are not equipment related

only and should take into account modern IT solutions such as software-as-a-service. The

30 EASA, The European Plan for Aviation Safety (EPAS 2021–2025), Volume III ‘Safety risk portfolios’, 2021

(https://www.easa.europa.eu/sites/default/files/dfu/epas_2021_2025_vol_three_final.pdf). 31 Serious incident to the Airbus A340-313E registered F-GLZU on 11 March 2017 at Bogotà (Colombia), Bureau d’Enquêtes

et d’Analyses (France). 32 Serious incident to the Boeing 737-800 registered PH-BXG, at Amsterdam Schiphol Airport on 10 June 2018, Dutch Safety

Board (Netherlands); and Serious incident to a Boeing 737-800 registered G-JZHL at Kuusamo Airport, on 1 December 2021, Air Accidents Investigation Branch (United Kingdom).

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recommended capabilities of the FDM software or service are addressed in point (b)(3)

(see below).

• The content of point (b)(1)(iv) has been moved to a new point (b)(3)(v), which lists

recommended optional capabilities of FDM software or an FDM service.

— Regarding the changes proposed to point (b)(2):

• The first sentence of point (b)(2)(i) has been removed because using the FDR for FDM

should be reserved for older aircraft that have no other solutions or as a temporary

solution. Using the FDR for FDM was probably more commonplace in the 1990s and early

2000s, but today most operated aircraft are fitted with dedicated airborne equipment.

• As technology evolves and there are many solutions, reference to quick access recorder

technology in point (b)(2)(i)(A) was replaced by more generic wording.

• Point (b)(2)(i)(B) has been split into two points and the new point (b)(2)(i)(C) is focused on

airborne systems that preprocess flight data during the flight.

• A sentence has been added into point (b)(2)(i)(C) reflecting that some of these systems

only retain or transmit a fraction of the flight data collected. This may be acceptable for

aircraft condition monitoring, but it is not appropriate for an FDM programme: the FDM

staff should have access to all raw flight data collected by the airborne system, so that, if

necessary, they can drill down into the data of a given flight (for instance, to analyse a

severe FDM event) and apply a new FDM algorithm definition to historical flight data.

• Point (b)(2)(ii) does not seem safety related; therefore, it has been removed.

— Regarding the changes proposed to point (b)(3):

• This point has been renamed ‘FDM software or service’, as the capabilities needed to

support the processing of flight data are not equipment related only and should take into

account modern IT solutions. For the same reason, the mention of a ‘ground-based

processing station’ has been removed from point (b)(3)(i).

• Today, the volume of flight data is not really a limiting factor for ground systems;

therefore, the term ‘large amounts of data’ has been removed from point (b)(3)(ii).

However, the processing of flight data still requires the use of specialised software and/or

contracting a specialised service provider, due to the peculiarities of flight data.

• The high-level description of what FDM software performs in point (b)(3)(iii) has been

amended, as it was too restrictive (it did not include the conversion into flight parameters)

and a link to the explanations about exceedance detection and measurements in point (a)

was missing.

• In point (b)(3)(iv), the old-fashioned terms ‘data trace’ and ‘listings’ have been replaced

by ‘plots’ and ‘tables’.

• The new point (b)(3)(v) recommends additional capabilities of the FDM software or

service that were identified as helpful for the analysis of data or internal communication,

as follows.

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o Capability to interface with advanced analysis packages (point (b)(3)(v)(A)), as this

allows the FDM analyst to faster implement algorithms, and not be limited by the

functions available in the FDM software for designing FDM algorithms.

o Capability to link flight data with other data sources such as occurrence reports,

weather data, etc. (point (b)(3)(v)(B)). Such capability should be used in accordance

with data protection policies and procedures. Point (j) of AMC1 ORO.AOC.130

specifies that there should be a data access and security policy restricting

information access to authorised persons.

o Capability to export FDM outputs (data of FDM events and FDM measurements) in

a standard electronic format that is compatible with business intelligence tools, so

that advantage can be taken of such tools (point (b)(3)(v)(C)).

o Capability to export FDM output in a data format that is compatible with a

geographical information system (point (b)(3)(v)(D)). This may be useful for

presenting and interpreting data related to aircraft trajectory or spatial distribution

of FDM events or for the analysis of those FDM events related to proximity to other

traffic, proximity to terrain or obstacles, airspace design or navigation procedures.

o Capability to produce flight animations. The content of the former point (b)(1)(iv)

was moved to point (b)(3)(v)(E). The words ‘simulation of in-flight conditions’ were

removed, as flight animation is only about visually reconstructing some of the

information displayed to the pilot, the aircraft trajectory or the field of view from

the cockpit, but not an accurate aircraft simulation like that provided by flight

simulation training devices.

o Capability to provide individual FDM summary reports or dashboards that can be

confidentially consulted by flight crews, for example through their personal

electronic devices (point (b)(3)(v)(F)).

o Capability to export the flight parameter decoding information into a format that

complies with an electronic documentation standard, which has a general public

licence policy and which allows for configuration control (point (b)(3)(v)(G)). This

makes it easier for an operator to import this information into its FDM software

and to maintain it, also considering that an aircraft typically has several operators

throughout its economic life cycle. For example, ARINC 647A FRED (flight recorder

electronic documentation) is a standard that has been developed for the decoding

documentation of the flight data recorder, and this standard meets the conditions

in point (b)(3)(v)(G).

— Regarding the changes proposed to point (c)(1):

• The introduction of ‘potentially’ in points (c)(1)(ii) and (c)(1)(iii) brings an important

nuance: the FDM programme is used to detect circumstances and trends that may be

unsafe, but the safety risk assessment does not stop there. In many cases, FDM data taken

alone is not sufficient to confirm that given circumstances were unsafe or that a trend is

unsafe.

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• Point (c)(1)(iv) has been removed, as it described a step of the operator’s SRM, not a

specific FDM process. The risk mitigation actions mentioned in the former point (iv) should

be decided after a thorough assessment of safety risks that considers all relevant data

available to the operator.

• Additional corrections to points (c)(1)(iii) and (c)(1)(v) have been performed to clarify the

following.

o Safety risks should be assessed and remedial actions be put in place in the

framework of the operator SRM, not by the FDM programme in isolation.

o FDM is not always appropriate for the monitoring of a safety issue. It is up to the

operator to determine the most appropriate data source to monitor the evolution

of a given safety issue.

— Regarding the changes proposed to point (c)(2):

• In point (c)(2)(i), ‘every month’ has been removed, as taking up to 1 month for compiling

FDM data is not consistent with the EU time frame to analyse an FDM event that

corresponds to a reportable occurrence (72 hours in accordance with Regulation (EU)

No 376/2014) and with how human memory works: it cannot be reasonably expected that

flight crew members will still provide an accurate retrospective report of an incident more

than 1 month after it occurred. In addition, modern equipment and software solutions

enable data to be processed on a daily basis, or even continuous processing as data comes

in. However, as the time objective regarding data processing has been set in point (h)(3)

of AMC1 ORO.AOC.130, there is no need to be specific in this point.

• Point (c)(2)(ii) is proposed to be amended to clarify the following.

o The focus should be on deviations from the SOPs that require attention rather than

‘deficiencies in pilot handling techniques’, as this is more consistent with the end of

that point, which includes ‘revisions to manual’ and ‘changes to ATC and airport

procedures’.

o The decision to initiate the flight crew contact should be made after an initial

assessment, and not systematically.

o The person responsible for flight crew contact (typically the gatekeeper) may use

means to exchange information with the flight crew other than a confidential

discussion. A confidential notification to the flight crew or a request that the flight

crew provide additional information may be sufficient, depending on the case.

o Safety risks should be assessed, and remedial actions decided in the framework of

the operator SRM, not by the FDM programme in isolation.

o Further to that, the part of the text regarding de-identification has been removed.

Instead, reference to point (k) of AMC1 ORO.AOC.130 is made, as this point

addresses the procedure to protect flight crew identity.

• Point (c)(2)(iii) has been removed as it described a data source (flight crew surveys and

interviews) that may be important for the operator SRM but is not part of FDM.

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• In the new point (c)(2)(iii), the term ‘database’ has been removed, as it is old-fashioned.

Modern IT solutions often store data in ‘data lakes’, ‘data clouds’, etc. In addition, a

sentence previously in point (i) of AMC1 ORO.AOC.130 (about retaining samples of de-

identified full flight data) has been moved to this point, as the content of this sentence is

guidance, and so better placed in GM than in AMC.

• Regarding the new point (c)(2)(iv): this point has been reworded to better link the sharing

of safety information based on FDM with point (a)(4) of ORO.GEN.200, which requires

that the management system includes ‘maintaining personnel trained and competent to

perform their tasks’. Point (b) of AMC1 ORO.GEN.200(a)(4) specifies that the operator

should establish communication about safety matters that:

‘(i) ensures that all personnel are aware of the safety management activities as

appropriate for their safety responsibilities;

(ii) conveys safety critical information, especially relating to assessed risks and

analysed hazards;

(iii) explains why particular actions are taken; and

(iv) explains why safety procedures are introduced or changed.’

Hence, the communication of safety information based on FDM to all personnel of the

operator supports the implementation of ORO.GEN.200.

Reference to more modern ways of disseminating information (such as emailing) have

been inserted. ‘Periodic reports to industry and the competent authority’ is not considered

safety promotion; therefore, it has been removed.

— Regarding the changes proposed to point (d)(1):

As flight data might be considered personal data under Regulation (EU) 2016/679 (refer

to European Operators Flight Data Monitoring forum document Breaking the Silos33),

advice to take into account this regulation has been inserted. In addition, a reminder has

been added that the inherent protection of reporters under Regulation (EU) No 376/2014

applies to flight crew members, whether their reports are spontaneously provided or

retrospectively requested by the operator. Using the example of an exceedance that was

not reported by the flight crew but is detected through an FDM event, the flight crew

should be requested to provide a retrospective report and they should benefit the

reporter’s protection in accordance with Regulation (EU) No 376/2014. The reporting

timeline (within 72 hours in accordance with Regulation (EU) No 376/2014) should start

when the flight crew is made aware of the event.

— Regarding the changes proposed to point (d)(3):

• ‘Effective safety culture’ and ‘proactive safety culture’ have both been replaced by

‘positive safety culture’, as this is a more commonly used term, and it is the term used in

ICAO Annex 19.

33 EOFDM Working Group C, Breaking the Silos – Fully integrating flight data monitoring into the safety management

system, initial issue, June 2019.

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• Point (d)(3)(iv) has been amended because risk assessment is not an internal FDM process.

Point (d)(3) should only contain examples of indicators that are specifically applicable to

an FDM programme.

• The content of point (d)(3)(vii) has been changed because a communication system for

‘disseminating hazard information’ should be part of the operator’s management system,

as specified in AMC1 ORO.GEN.200(a)(4).

— Regarding the new proposed point (d)(4):

This point has been created to:

• clarify that integration of the FDM programme in the operator management is one of the

preconditions for an effective FDM programme;

• remind the reader that SRM is wider than just the FDM programme;

• remind the reader that identification and assessment of safety issues is under the

responsibility of the safety manager;

• make reference to a European Operators Flight Data Monitoring forum document that

details best practice on integrating the FDM programme in the operator’s management

system.

— Regarding the proposed new point (d)(5):

• The flight parameter decoding documentation is essential for an operator to be able to

use the recorded flight parameters for FDM. This documentation is needed for each

individual aircraft. Therefore, it is proposed to add it to the list of preconditions for an

effective FDM programme.

• To ensure that there is no misunderstanding about what ‘flight parameter decoding

documentation’ means, an explanation of this term is introduced.

• To maintain knowledge over time and ensure that the right decoding is applied to current

or historical flight data, there should be a versioning system that enables quick

identification of the applicable decoding information for any individual aircraft and any

time period. This will help the operator retain knowledge of changes regarding flight

parameter decoding despite evolutions of the fleet and FDM staff changes, which will in

turn help to maintain the performance of the FDM programme in the long term.

• It is expected that the first version of the flight parameter decoding documentation will

be provided by the installer of the airborne system (type certificate / supplemental type

certificate holder), as this organisation should have the full knowledge of what

parameters are recorded and where in the data frames, and what conversion equations

should be applied to retrieve parameter values expressed in engineering units. However,

this documentation should be kept up to date by the operator.

• If the documentation format complies with an electronic documentation standard that

has a general public licence policy, it will be easier for an operator to maintain this

documentation, or to import it into its FDM software, taking into account that an aircraft

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typically has several operators throughout its life cycle. For example, ARINC 647A format

could be used for FDM flight parameter decoding documentation.

• Aircraft in the scope of ORO.AOC.130 (and SPA.HOFO.145) must also retain the flight

parameter decoding documentation of the flight data recorder, as required by point (d)

of CAT.GEN.MPA.195 (Handling of flight recorder recordings: preservation, production,

protection and use). Hence, where flight data collected for FDM is the same as the flight

data recorded by the FDR, the decoding documentation of the latter can be used.

— Regarding the changes proposed to point (e)(2):

• The last sentence of the example in point (e)(2)(i) has been deleted, as engine condition

monitoring is not in the scope of FDM.

• In point (e)(2)(ii)(A), ‘Identify aircraft defects’ has been removed as it does not seem to be

a relevant short-term goal for an FDM programme. Instead, two points have been

inserted: the first one is about verifying that flight parameters used by the FDM software

are valid and correctly decoded and the second one is about verifying that the flight

parameter decoding documentation that is addressed in point (d)is complete and correct.

• In point (e)(2)(ii)(B), the goal to produce an annual report has been replaced by ‘produce

reports and dashboards’. This is because new information technologies make it possible

to design web-based reports and dashboards that can be updated much more frequently

than once per year.

• The last point of point (e)(2)(ii)(C) has been deleted, as aircraft condition monitoring and

predictive maintenance are not in the scope of FDM.

— Regarding the changes proposed to point (e)(3):

• A sentence has been inserted in point (e)(3)(i) to recommend that the ‘FDM team’ is part

of the team under the authority of the safety manager. This is consistent with

AMC1 ORO.AOC.130, which specifies that the safety manger should be responsible for the

FDM programme.

• In point (e)(3)(i)(A), the statement that ‘the team leader [of the FDM programme] acts

independently of others in line management to make recommendations’ does not seem

in line with the integration of the FDM programme in the operator’s management system

(as required by ORO.AOC.130) and with the safety manager being responsible for the FDM

programme (in accordance with AMC1 ORO.AOC.130). It is rather expected that the FDM

team leader reports to the safety manager and that the safety manager makes

recommendations based on the analyses of all available data, including FDM data.

Therefore, the second sentence of point (e)(3)(i)(A) has been deleted.

• In point (e)(3)(i)(B), ‘current pilot’ has been replaced by ‘qualified pilot’, as it is considered

more relevant that the flight operations interpreter has the appropriate qualification

rather than having recently been flying.

• In point (e)(3)(i)(E), the part of the first sentence regarding serviceability requirements for

FDR systems has been deleted, as the FDR should no longer be used for an FDM

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programme, and today most operators do not use the FDR to collect data for the FDM

programme.

• In point (e)(3)(i)(F):

o The description of the ‘replay operative and administrator’ function has been

deleted. This description seems to relate to a technician who monitors the

operation of software and hardware and produces ready-made reports. However,

today, with wireless flight data transmission and software-as-a-service solutions,

there may be little need to monitor FDM software and hardware.

o Instead, the function of FDM analyst, which seemed to be missing in (e)(3)(i), has

been inserted. The FDM analyst is responsible for the design and validation of FDM

algorithms and the analysis of FDM outputs. Therefore, they should have sufficient

knowledge of how FDM event and measurement algorithms are designed and of

their intrinsic limitations, so that they can support correct interpretation of FDM

software outputs and present these outputs in a meaningful way. This in turn

means that the FDM analyst should have a scientific education, especially

knowledge of statistics and some programming skills.

o If data processing and FDM event validation are subcontracted to a service

provider, the FDM analyst should be capable of controlling and directing the work

of that service provider, as effective implementation of the FDM programme

remains the responsibility of the operator. Therefore, point (e)(3)(i)(F) also

recommends that the FDM analyst has the necessary skills to effectively control and

direct the work performed by the FDM service provider.

— Regarding the new proposed point (f):

• The use of flight data for purposes other than the FDM programme is allowed and

common practice among operators. Flight data is used, for example, to support fuel

efficiency programmes or monitor aircraft performance.

• Nevertheless, the flight data used for the FDM programme should not be used in an

uncontrolled manner in other programmes, otherwise this would defeat the purpose of

requiring ‘safeguards to protect the source of data’ (refer to ORO.AOC.130).

• Therefore, point (f) recommends addressing all uses of flight data through a written

procedure that provides a framework for using the flight data, including the aim, data

access principles, data retention principles and how to obtain flight crew feedback.

• The content of point (f) is consistent with the new proposed GM2 ORO.GEN.200(a)(2).

— Regarding the new proposed point (g):

• It provides a general overview of the possible benefits of joining a large data exchange

programme, in particular for operators that have small fleets. Examples of large data

exchange programmes are the FAA Aviation Safety Information Analysis and Sharing

programme, the International Air Transport Association Flight Data Exchange programme

and the EASA Data4Safety programme.

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• The operator remains responsible for its FDM programme in all cases. Therefore, point (g)

also clarifies that joining a large data exchange programme is not an alternative means

of compliance to AMC1 ORO.AOC.130. It also emphasises that, for participation in a large

data exchange programme to bring safety benefits, the FDM programme should be

completely integrated in the management system of the operator.

GM2 ORO.AOC.130 Flight data monitoring — aeroplanes

EXAMPLES OF FDM METHODS EVENTS

Table 1 provides examples of precursors of incidents that could be monitored through an FDM

programme, by means of FDM events or FDM measurements. Methods to monitor these precursors

may be further developed using operator- and aeroplane-specific limits. The table is considered

illustrative and not exhaustive.

Note 1: Key risk areas as described in the Annex to Regulation (EU) 2020/2034 correspond to the

aviation occurrence categories defined by the CAST/ICAO Common Taxonomy Team as follows:

— ‘excursion’ corresponds to ‘Runway excursion’ (RE);

— ‘aircraft upset’ corresponds to ‘Loss of control - inflight’ (LOC-I);

— ‘terrain collision’ corresponds to ‘Controlled flight into or toward terrain’ (CFIT);

— ‘airborne collision’ corresponds to ‘Airprox/TCAS alert/Loss of separation/Near midair

collision/Midair collision’ (MAC).

Note 2: Please refer to European Operators Flight Data Monitoring forum (EOFDM) Working Group B,

Guidance for the implementation of flight data monitoring precursors, for further details on methods

to monitor the example precursors of incidents provided in Table 1.

Note 3: The far-right column of Table 1 only indicates the occurrence types directly related to the

precursors among those listed in Regulation (EU) 2015/1018, Annex I ‘Occurrences related to the

operation of the aircraft’. The precursors of incidents listed in Table 1 may also be used to detect

occurrence types other than those indicated in the far-right column.

Note 4: In addition to the precursors of incidents in Table 1, operators may need to monitor caution

and warning alerts displayed to the flight crew and other indications that the airworthiness of the

aircraft may be affected (as specified in AMC2 ORO.AOC.130). FDM events or measurements that

monitor significant deviations from the SOPs in all phases of flight, including when the aircraft is on

the ground, are also advisable. For brevity, Table 1 does not include such events.

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Table 1

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

1 RE01 – Engine power

changes during take-off

Develop means to detect engine power changes during

take-off that may lead to a runway excursion.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

2 RE02 – Inappropriate

aircraft configuration

Develop means to detect inappropriate aircraft

configuration (lifting devices, pitch trim) which could

cause take-off and landing performance problems; not all

aircraft are equipped with take-off configuration warning

systems and some of these systems cannot detect all

types of configuration errors.

Excursion (at take-off and at

landing)

1.3(6) Actual or attempted take-off,

approach or landing with incorrect

configuration setting.

3 RE03 – Monitoring the

centre-of-gravity (CG)

position

Develop means to detect CG out of limits on take-off or

not consistent with the pitch trim settings.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

4 RE04 – Reduced elevator

authority

Develop means to detect abnormal rotation in response

to elevator inputs, reduced elevator movement or

excessive force required to move the elevator surfaces.

Excursion (at take-off and at

landing)

2.1(7) Abnormal functioning of flight

controls such as asymmetric or

stuck/jammed flight controls (e.g. lift

(flaps/slats), drag (spoilers), attitude

control (ailerons, elevators, rudder)

devices).

5 RE05 – Slow acceleration Develop means to measure the acceleration during the

take-off roll and to detect abnormal values, taking into

account the various factors that affect the take-off

performance.

Excursion (at take-off and at

landing)

1.3(5) Inability to achieve required or

expected performance during take-off,

go-around or landing.

6 RE06 – Aircraft

malfunction

Develop means to detect aircraft malfunctions which are

likely to cause rejected take-offs (RTOs) (e.g. ‘master

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

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No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

warning’ and ‘master caution’ alerts and airspeed

indication disagreements).

7 RE07 – Late rotation Develop means to detect rotations conducted after VR or

beyond the expected distance (or time) after the start of

the take-off roll.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

8 RE08 – Slow rotation Develop means to detect slow rotation. Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

9 RE09 – No lift-off Develop means to detect late lift-off (in time and/or

distance) after rotation or start of the take-off roll.

Excursion (at take-off and at

landing)

1.3(5) Inability to achieve required or

expected performance during take-off,

go-around or landing.

10 RE10 – Rejected take-off

(RTO)

Develop means to identify rejected take-off (RTO). Excursion (at take-off and at

landing)

1.3(4) Any rejected take-off.

11 RE11 – Runway remaining

after rejected take-off

Develop means to estimate the runway remaining ahead

of the aircraft after the start of the rejected take-off (RTO)

and to estimate the ground distance spent during the

RTO.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

12 RE12 – Inadequate use of

stopping devices

Develop means to identify late or inadequate activation of

thrust reverser, brakes, airbrakes or other stopping

devices during rejected take-offs (RTOs) and landings.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

13 RE13 – Insufficient

deceleration

Develop means to detect slow deceleration after landing

or rejected take-off (RTO), taking into consideration the

various factors that affect the landing and the RTO

performance.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

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No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

14 RE14 – Incorrect input

performance data

Develop means to detect erroneous data entry or

calculation errors which could lead to incorrect thrust

settings, incorrect V speeds or incorrect target approach

speeds.

Excursion (at take-off and at

landing)

1.1(1) Use of incorrect data or

erroneous entries into equipment used

for navigation or performance

calculations that has or could have

endangered the aircraft, its occupants

or any other person.

15 RE15 – Runway remaining

at lift-off

Develop means to estimate the runway remaining ahead

of the aircraft at the moment of lift-off and to detect

abnormal values.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

16 RE16 – Aircraft handling Develop means to monitor the use of aircraft controls

(rudder and nose-wheel steering) and brakes during take-

off, rejected take-off (RTO), and landing, and to detect

non-standard cases. In addition, monitor simultaneous

control inputs of both flight crew and analyse their

potential negative influence on safety.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

17 RE17 – Crosswind Develop means to estimate the crosswind during take-off,

approach and landing, and to detect abnormal values.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

18 RE18 – Forward thrust

asymmetry

Develop means to identify forward thrust asymmetry

during the take-off roll.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

19 RE19 – Steering system

malfunction

Develop means to identify problems with the steering

system which could affect lateral controllability.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

20 RE20 – Lateral deviation Develop means to identify excessive lateral deviations or

oscillations during take-off, rejected take-off (RTO) and

landing, taking into consideration the runway width.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

21 RE21 – Reverse thrust

asymmetry

Develop means to identify reverse thrust asymmetry

during a rejected take-off (RTO) or landing.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

22 RE22 – Braking

asymmetry

Develop means to identify braking asymmetry during a

rejected take-off (RTO) or landing (possibly in

combination with RE12 ‘Inadequate use of stopping

devices’).

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

23 (Reserved)

24 RE24 – Tailwind Develop means to estimate the tailwind during take-off,

approach and landing.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

25 RE25 – Excessive engine

power

Develop means to monitor the engine power reduction

before touchdown and to identify abnormal engine

utilisation in this phase of the flight.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

26 RE26 – Unstable approach Develop means to identify and quantify unstable

approaches, regardless of whether they result in go-

around manoeuvres.

Excursion (at take-off and at

landing)

1.3(8) Approach continued against air

operator stabilised approach criteria.

27 RE27 – High energy over

the threshold

Develop means to estimate the height, airspeed and

ground speed while crossing the runway threshold.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

28 RE28 – Long flare Develop means to detect the start of the flare and to

estimate the ground distance the aircraft has covered

from the start of the flare until touchdown.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

29 RE29 – Deep landing Develop means to estimate the distance from the runway

threshold until the touchdown point, and also the runway

length available after touchdown.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

30 RE30 – Abnormal runway

contact (ARC)

Develop means to identify and quantify bounced (main or

nose wheels), off-centre, nose-first or asymmetrical

landings, as well as tail and wingtip strikes.

Excursion (at take-off and at

landing)

1.3(7) Tail, blade/wingtip or nacelle

strike during take-off or landing.

1.3(12) Hard landing.

31 RE31 – Go-around Develop means to identify go-arounds and balked

landings.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

32 RE32 – Excessive energy

at touchdown

Develop means to correctly identify the touchdown

instant, to measure airspeed and ground speed, and to

identify cases of excessive energy.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence).

33 RE33 – Wrong runway or

wrong runway entry point

used

The difference between actual and planned runway or

runway entry point used should be monitored.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

34 RE34 – Erroneous

guidance

Develop means to detect cases of erroneous guidance

during approach and landing.

Excursion (at take-off and at

landing)

No direct link to a specific type of

occurrence.

35 LOC01 – Fire, smoke and

fumes

Develop means to detect the presence of fire, smoke or

fumes in the cabin, cargo compartment, engines, and

landing gear bay.

Aircraft upset 4(2) Any burning, melting, smoke,

fumes, arcing, overheating, fire or

explosion.

36 LOC02 – Pressurization

system malfunction

Develop means to identify malfunctions of the

pressurisation system which could cause crew

incapacitation or discomfort. System malfunctions could

cause abnormal or unexpected rates of cabin pressure,

inability to cope with transients in engine regime,

abnormal cabin altitude (not necessarily high enough to

trigger alerts for the crew) or reversion from automatic

control to manual. There might be scope for integration

Aircraft upset 4(7) Uncontrollable cabin pressure.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

with the aircraft health monitoring systems and support

for continued airworthiness.

37 LOC03 – Pressurization

system misuse

Develop means to identify the situations where the

pressurisation system is not used correctly. For example,

failure to turn on the bleed pressure after take-off, failure

to set the landing pressure altitude, or inadequate use of

the manual control mode.

Aircraft upset No direct link to a specific type of

occurrence.

38 (Reserved)

39 LOC05 – High cabin

altitude

Develop means to identify situations of abnormal cabin

altitude, including but not limited to values that would

trigger cabin altitude alerts (possibly in combination with

LOC02 ‘Pressurisation system malfunction’).

Aircraft upset No direct link to a specific type of

occurrence.

40 LOC06 – Oxygen (O2)

masks not deployed and

not used by the crew

Develop means to identify situations where the crew

failed to deploy and use the oxygen (O2) masks in

response to real or nuisance situations.

Aircraft upset 4(9) Any use of crew oxygen system by

the crew.

41 LOC07 – Supplementary

oxygen (O2) system failure

Develop means to identify the failure of or leaks in the

flight crew supplementary oxygen (O2) system.

Aircraft upset 4(9) Any use of crew oxygen system by

the crew.

42 LOC08 – Centre of gravity

(CG) out of limits

Develop means to estimate the CG position and to detect

situations where it is beyond the limits or not consistent

with the pitch trim settings, as a result of load shifts,

incorrect loadings or fuel imbalance.

Aircraft upset No direct link to a specific type of

occurrence.

43 LOC09 – Abnormal

operations

Develop means to identify operations at or beyond the

edges of the operating envelope or not in compliance

with the standard operating procedures (SOPs). This

should cover all airframe and engine limitations (as

Aircraft upset 1.4(6) Exceedance of aircraft flight

manual limitation.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

specified in the aircraft flight manual (AFM), including but

not limited to indicated airspeed/Mach versus altitude,

vertical speed, G limits, flap speed limits, speed brake

limits, tire speed limits, landing gear limits, temperature

limits, manoeuvrability speeds, engine parameters,

tailwind, crosswind, excessive rudder inputs).

2.2(4) Engine operating limitation

exceedance, including overspeed or

inability to control the speed of any

high-speed rotating component (e.g.

APU, air starter, air cycle machine, air

turbine motor, propeller or rotor).

44 LOC10 – Incorrect

performance calculation

Develop means to detect erroneous data entry or

calculation errors which could lead to incorrect thrust

settings, incorrect V speeds or incorrect target approach

speeds (to be reconciled with recommendation RE01 for

runway excursions).

Aircraft upset 1.1(1) Use of incorrect data or

erroneous entries into equipment used

for navigation or performance

calculations that has or could have

endangered the aircraft, its occupants

or any other person.

45 LOC11 – Overweight take-

off

Develop means to identify overweight take-off situations

that could have an adverse effect on the climb

performance and obstacle clearance for performance-

limited departures (possibly in combination with LOC10

‘Incorrect performance calculation’).

Aircraft upset No direct link to a specific type of

occurrence.

46 LOC12 – Envelope

protection systems

Develop means to detect in-flight activation of the

envelope protection systems of the aircraft.

Aircraft upset 1.4(4) Activation of any flight envelope

protection, including stall warning, stick

shaker, stick pusher and automatic

protections.

47 LOC13 – Inadequate

aircraft energy

Develop means to identify situations of inadequate

aircraft energy (speed and/or altitude and/or thrust) for

each phase of the flight.

Aircraft upset No direct link to a specific type of

occurrence.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

48 LOC14 – Inadequate

aircraft attitude

Develop means to identify cases of excessive angles of

pitch and roll. The identification should take into

consideration the range of values acceptable for each

phase of flight.

Aircraft upset No direct link to a specific type of

occurrence.

49 LOC15 – Loss of lift Develop means to identify situations of actual loss of lift

and cases of operation close to the edges of the lift

envelope.

Aircraft upset 1.4(4) Activation of any flight envelope

protection, including stall warning, stick

shaker, stick pusher and automatic

protections.

50 (Reserved)

51 LOC17 – Electromagnetic

interference (EMI)

Develop means to identify cues that could suggest

situations of electromagnetic interference (EMI) (possibly

in combination with LOC24 ‘Instrument malfunction’).

Aircraft upset No direct link to a specific type of

occurrence.

52 LOC18 – Adverse weather Develop means to identify the presence of adverse

weather in the vicinity of the aircraft.

Aircraft upset 5(9) to 5(13).

53 LOC19 – Wind shear Develop means to identify situations of wind shear

(reactive and predictive).

Aircraft upset 5(12) A significant wind shear or

thunderstorm encounter that has or

could have endangered the aircraft, its

occupants or any other person.

54 LOC20 – Severe

turbulence

Develop means to identify situations of severe turbulence

caused by different sources (clear-air turbulence, wake

vortex, mountain waves, etc.).

Aircraft upset 5(7) Wake-turbulence encounters.

5(11) Severe turbulence encounter or

any encounter resulting in injury to

occupants or deemed to require a

‘turbulence check’ of the aircraft.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

55 LOC21 – Icing conditions Develop means to identify situations of extremely cold

conditions or icing of the engines, nacelles, propellers,

wings and airframe. Operation in cold or icing conditions

is frequent for most aircraft operations; therefore, they

should not be considered abnormal. The objective is to

develop a set of measurements to enable a better

understanding of such environmental conditions in order

to assess the response of the aircraft ice detection

systems and to support recommendation LOC22 ‘De-icing

system failure’.

Aircraft upset 5(13) Icing encounter resulting in

handling difficulties, damage to the

aircraft or loss or malfunction of any

aircraft system.

56 LOC22 – De-icing system

failure

Develop means to identify failure, ineffectiveness or

incorrect utilisation (e.g. late activation) of de-icing and

anti-icing systems.

Aircraft upset No direct link to a specific type of

occurrence.

57 LOC23 – Engine failure Develop means to identify situations of latent or active

engine failure, including foreign object damage (FOD) and

hardware degradation and failure. There might be scope

for integration with the engine health monitoring (EHM)

and continued airworthiness.

Aircraft upset 2.2(5) Failure or malfunction of any part

of an engine, power plant, APU or

transmission resulting in any one or

more of the following:

(a) thrust-reversing system failing to

operate as commanded;

(b) inability to control power, thrust or

rpm (revolutions per minute);

components/debris.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

58 LOC24 – Instrument

malfunction

Develop means to identify situations of instrument

malfunction (possibly in combination with LOC17

‘Electromagnetic interference (EMI)’).

Aircraft upset 2.1(6) Malfunction or defect of any

indication system when this results in

misleading indications to the crew.

59 (Reserved)

60 LOC26 – Loss of thrust Develop means to identify situations of unintended loss of

thrust, or reduced engine performance, taking into

consideration (but not only) the range of values

acceptable for each phase of flight and fuel flow.

Aircraft upset 2.2(1) Failure or significant malfunction

of any part or controlling of a propeller,

rotor or power plant.

2.2(3) Flameout, in-flight shutdown of

any engine or APU when required (e.g.

ETOPS (extended range twin engine

aircraft operations), MEL (minimum

equipment list)).

61 LOC27 – Hardware failure Develop means to identify cues that could suggest the

existence of latent failures in safety-critical components

(including but not limited to landing gears, doors, brakes,

wheels and hydraulic systems). There might be scope for

integration with the aircraft health monitoring (AHM)

systems and continued airworthiness.

Aircraft upset No direct link to a specific type of

occurrence.

62 LOC28 – Flight control

failure

Develop means to identify cues that could suggest failure

or ineffectiveness of the flight controls.

Aircraft upset 2.1(7) Abnormal functioning of flight

controls such as asymmetric or

stuck/jammed flight controls (e.g. lift

(flaps/slats), drag (spoilers), attitude

control (ailerons, elevators, rudder)

devices).

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

63 LOC29 – Mismanagement

of automation

Develop means to identify situations of inadequate or

unexpected use of automation or unexpected

disconnection of automation.

Aircraft upset 1.4(9) Misinterpretation of automation

mode or of any flight deck information

provided to the flight crew that has or

could have endangered the aircraft, its

occupants or any other person.

64 LOC30 – Abnormal flight

control inputs

Develop means to identify situations of abnormal inputs

into thrust controls, control surfaces and lifting devices,

taking into consideration the range of values acceptable

for each phase of flight.

Aircraft upset No direct link to a specific type of

occurrence.

65 LOC31 – Fuel exhaustion Develop means to identify situations of low fuel

quantity – by comparison to the planned fuel quantity –

as the flight proceeds to its destination.

Aircraft upset 4(8) Critically low fuel quantity or fuel

quantity at destination below required

final reserve fuel.

66 LOC32 – Incorrect aircraft

configuration

Develop means to identify situations of incorrect or

unusual aircraft configuration for each phase of the flight.

Aircraft upset 1.3(6) Actual or attempted take-off,

approach or landing with incorrect

configuration setting.

67 CFIT01 – Poor visibility

conditions

Develop means to identify present visibility conditions

(e.g. instrument meteorological conditions (IMC) or visual

meteorological conditions (VMC)).

Collision with terrain No direct link to a specific type of

occurrence.

68 CFIT02 – Wrong altimeter

settings

Develop means to identify wrong altimeter settings. Collision with terrain 1.4(7) Operation with incorrect

altimeter setting.

69 CFIT03 – Flight below

minimum sector altitude

(MSA)

Develop means to identify situations of aircraft that fly

below the minimum sector altitude (MSA).

Collision with terrain 1.3(9) Continuation of an instrument

approach below published minimums

with inadequate visual references.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

70 CFIT04 – Deviation below

the glideslope

Develop means to identify (severe) deviations below the

glideslope that increase the CFIT risk.

Collision with terrain 1.3(8) Approach continued against air

operator stabilised approach criteria.

71 CFIT05 – Flight

management system

(FMS) incorrectly set

Develop means to identify errors in the flight

management system (FMS) settings, especially those

associated to close-to-terrain operations (e.g. approach in

a mountainous area).

Collision with terrain No direct link to a specific type of

occurrence.

72 CFIT06 – Inadequate

vertical mode selections

of the aircraft flight

control system (AFCS)

Develop means to identify inadequate vertical mode

selections of the aircraft flight control systems (AFCS),

especially those associated to close-to-terrain operations

(e.g. approach in a mountainous area).

Collision with terrain 1.4(9) Misinterpretation of automation

mode or of any flight deck information

provided to the flight crew that has or

could have endangered the aircraft, its

occupants or any other person.

73 CFIT07 – Incorrect

descent point

Develop means to identify incorrect descent points. Collision with terrain No direct link to a specific type of

occurrence.

74 CFIT08 – Inadequate

terrain awareness and

warning system (TAWS)

escape manoeuvre

Develop means to identify escape manoeuvres, after a

triggered TAWS alert, which are non-compliant with the

correct manoeuvre or airline standard operating

procedures (SOPs). Apart from that, approaches with

repeated TAWS soft warnings (or just one TAWS warning)

should be monitored. Repeated TAWS soft warnings

during an approach can evidence that either the aircraft

was not safe with regard to the terrain potentially due to

the approach procedure design, or that the TAWS needs

to be adjusted for that particular approach.

Collision with terrain 5(3) Activation of genuine ground

collision system such as ground

proximity warning system (GPWS) /

terrain awareness and warning system

(TAWS) ‘warning’.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

75 CFIT09 – Inadequate

missed approach and go-

around flight path

Develop means to identify missed approach and go-

around flight paths that are non-compliant with published

information or airline standard operating procedures

(SOPs).

Collision with terrain No direct link to a specific type of

occurrence.

76 CFIT10 – Loss of

communication

Develop means to identify loss of communication. Collision with terrain 3(2) Prolonged loss of communication

with ATS (air traffic service) or ATM

unit.

77 CFIT11 – Low-energy state

during approach /

unstable approach

Develop means to identify low-energy states during

approach and unstable approach.

Collision with terrain No direct link to a specific type of

occurrence.

78 CFIT12 – Inadequate

response to wind shear

warnings

Develop means to detect inadequate response to wind

shear warnings, especially in situations close to terrain

(e.g. approach in a mountainous area).

Collision with terrain 5(12) A significant wind shear or

thunderstorm encounter that has or

could have endangered the aircraft, its

occupants or any other person.

79 CFIT13 – Reduced

horizontal distance to

terrain

Develop means to identify scenarios of reduced horizontal

distance to terrain.

Collision with terrain No direct link to a specific type of

occurrence.

80 CFIT14 – Reduced time to

terrain impact

Develop means to identify scenarios of reduced time to

terrain impact assuming the aircraft maintains current

track and speed.

Collision with terrain No direct link to a specific type of

occurrence.

81 MAC01 – Incorrect

altimeter setting or

incorrect transition timing

Develop means to detect incorrect altimeter settings or

incorrect transition timing, which could lead to situations

of increased mid-air collision (MAC) risk.

Airborne collision 1.4(7) Operation with incorrect

altimeter setting.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

82 MAC02 – Lateral deviation Develop means to detect situations where the actual

flight trajectory deviates from the published, cleared or

intended trajectory.

Airborne collision 1.4(5) Unintentional deviation from

intended or assigned track of the lowest

of twice the required navigation

performance or 10 nautical miles.

83 MAC03 – Flight-level bust Develop means to identify flight-level busts, i.e. situations

where the cleared and intended altitude or flight level is

overshot during climb or undershot during descent.

Airborne collision 1.4(3) Level bust.

84 MAC04 – High rate of

climb/descent

Develop means to identify climbs and descents with high

rates. Due to the trigger logic of ACAS alerts, high rates

can lead to the generation of nuisance alerts (see MAC08

‘Airborne collision avoidance system (ACAS) alerts’).

Airborne collision No direct link to a specific type of

occurrence.

85 MAC05 – Inadequate use

of automation

Develop means to identify situations of inadequate use of

automation related to the aircraft trajectory.

Airborne collision 1.4(9) Misinterpretation of automation

mode or of any flight deck information

provided to the flight crew that has or

could have endangered the aircraft, its

occupants or any other person.

86 MAC06 – Automatic

altitude control system

OFF in reduced vertical

separation minima

(RVSM) conditions

Develop means to identify situations of inappropriate

settings of the automatic altitude control system in

reduced vertical separation minima (RVSM) conditions.

Airborne collision No direct link to a specific type of

occurrence.

87 (Reserved)

88 MAC08 – Airborne

collision avoidance

system (ACAS) alerts

Monitor every safety-relevant information with respect to

the airborne collision avoidance system (ACAS) that is

available within the FDM. In particular, resolution

Airborne collision 5(2) ACAS RA (Airborne Collision

Avoidance System, Resolution

Advisory).

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

No Number and title of the

precursor as per EOFDM

documentation

Description of the precursor as per EOFDM

documentation

Relevant key risk area as described

in the Annex to Regulation (EU)

2020/2034

Occurrence types as defined in Annex I

to Regulation (EU) 2015/1018 that are

directly related to the precursor

advisories (RAs) shall be identified and further

investigated in detail.

89 MAC09 – Inappropriate

airborne collision

avoidance system (ACAS)

settings

Develop means to monitor the settings of the airborne

collision avoidance system (ACAS) and to verify their

suitability.

Airborne collision No direct link to a specific type of

occurrence.

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

The following table provides examples of FDM events that may be further developed using operator

and aeroplane specific limits. The table is considered illustrative and not exhaustive. Other examples

may be found in the documents published by the European Operators Flight Data Monitoring

(EOFDM) forum.

Event Group Description

Rejected take-off High speed rejected take-off

Take-off pitch Pitch rate low or high on take-off

Pitch attitude high during take-off

Unstick speeds Unstick speed high

Unstick speed low

Height loss in climb-out Initial climb height loss 20 ft above ground level (AGL) to 400 ft above

aerodrome level (AAL)

Initial climb height loss 400 ft to 1 500 ft AAL

Slow climb-out Excessive time to 1 000 ft AAL after take-off

Climb-out speeds Climb-out speed high below 400 ft AAL

Climb-out speed high 400 ft AAL to 1 000 ft AAL

Climb-out speed low 35 ft AGL to 400 ft AAL

Climb-out speed low 400 ft AAL to 1 500 ft AAL

High rate of descent High rate of descent below 2 000 ft AGL

Missed approach Missed approach below 1 000 ft AAL

Missed approach above 1 000 ft AAL

Low approach Low on approach

Glideslope Deviation under glideslope

Deviation above glideslope (below 600 ft AGL)

Approach power Low power on approach

Approach speeds Approach speed high within 90 seconds of touchdown

Approach speed high below 500 ft AAL

Approach speed high below 50 ft AGL

Approach speed low within 2 minutes of touchdown

Landing flap Late land flap (not in position below 500 ft AAL)

Reduced flap landing

Flap load relief system operation

European Union Aviation Safety Agency NPA 2024-02

4. Proposed regulatory material

An agency of the European Union

Event Group Description

Landing pitch Pitch attitude high on landing

Pitch attitude low on landing

Bank angles Excessive bank below 100 ft AGL

Excessive bank 100 ft AGL to 500 ft AAL

Excessive bank above 500 ft AGL

Excessive bank near ground (below 20 ft AGL)

Normal acceleration High normal acceleration on ground

High normal acceleration in flight flaps up (+/- increment)

High normal acceleration in flight flaps down(+/- increment)

High normal acceleration at landing

Abnormal configuration Take-off configuration warning

Early configuration change after take-off (flap)

Speed brake with flap

Speed brake on approach below 800 ft AAL

Speed brake not armed below 800 ft AAL

Ground proximity warning Ground proximity warning system (GPWS) operation - hard warning

GPWS operation — soft warning

GPWS operation — windshear warning

GPWS operation — false warning

Airborne collision avoidance

system (ACAS II) warning

ACAS operation — Resolution Advisory

Margin to stall/buffet Stick shake

False stick shake

Reduced lift margin except near ground

Reduced lift margin at take-off

Low buffet margin (above 20 000 ft)

Aircraft flight manual limitations Maximum operating speed limit (VMO) exceedance

Maximum operating speed limit (MMO) exceedance

Flap placard speed exceedance

Gear down speed exceedance

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Event Group Description

Gear selection up/down speed exceedance

Flap/slat altitude exceedance

Maximum operating altitude exceedance

Rationale

GM2 ORO.AOC.130 is proposed to be amended to provide industry best practices on monitoring

precursors of incidents related to the key risk areas that are specified in AMC2 ORO.AOC.130 with FDM

(refer to the EOFDM Working Group B document Guidance for the implementation of flight data

monitoring precursors). The new Table 1 of GM2 ORO.AOC.130 contains examples of such precursors

that could be monitored by means of FDM events or FDM measurements.

In addition, the new Table 1 of GM2 ORO.AOC.130:

— identifies, for each precursor of an incident, the relevant key risk area; these key risk areas are

defined in Regulation (EU) 2020/2034 for implementing the European risk classification scheme

that supplements Regulation (EU) No 376/2014;

— links the precursors of incidents to occurrence types subject to mandatory reporting as per

Regulation (EU) No 376/2014, as listed in Regulation (EU) 2015/1018, Annex I.

Linking the example precursors of incidents to the framework applicable to occurrence reporting

contributes to better integrating the FDM programme and occurrence reporting. The FDM programme

and occurrence reporting are both parts of the operator’s management system, are both used to

support SRM and are both under the control of the operator’s safety manager. Their integration is

beneficial for both processes and ultimately for the management system.

SUBPART DEC: DECLARATION

GM1 ORO.DEC.100 Declaration

[…]

MANAGED OPERATIONS

When the non-commercial operation of a complex motor-powered aircraft is managed by a third party

on behalf of the owner, that party may be the operator in the sense of Article 3(h)(13) of Regulation

(EU) 2018/1139 (EC) No 216/2008, and therefore has to declare its capability and means to discharge

the responsibilities associated with the operation of the aircraft to the competent authority.

In such a case, it should also be assessed whether the third-party operator undertakes a commercial

operation, defined as the operation of an aircraft, in return for remuneration or other valuable

consideration, which is available to the public or, when not made available to the public, which is

performed under a contract between an operator and a customer, where the latter has no control

over the operator in the sense of Article 3(i) of Regulation (EC) No 216/2008.

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Rationale

Editorial amendment. The definition of commercial operation used is the same as in Article 3(i) of

Regulation (EC) No 216/2008. No impacts expected.

SUBPART FC: FLIGHT CREW

SECTION 2 – ADDITIONAL REQUIREMENTS FOR COMMERCIAL AIR TRANSPORT OPERATIONS

GM1 ORO.FC.230 Recurrent training and checking

LINE CHECK AND PROFICIENCY TRAINING AND CHECKING

[…]

GROUND TRAINING PROGRAMME

(e) Training on aircraft systems. It is recommended that training on aircraft systems referred to in

point (a)(1)(i)(A) of AMC1 ORO.FC.230 is carried out at least every 12 calendar months, so that

all the systems are covered over a period not exceeding 3 years.

(f) Training on abnormal and emergency procedures. It is recommended that the training on

abnormal and emergency procedures referred to in point (a)(1)(i)(C) of AMC1 ORO.FC.230 is

carried out at least every 12 calendar months, so that all such procedures are covered over a

period not exceeding 3 years. Since operators cover major failures of aircraft systems in the

FSTD/aircraft training programme, the ground training may focus on those other abnormal and

emergency procedures that are not classified as major failures but have an impact on the safety

of the flight. The ground training programme may not cover all the abnormal and emergency

procedures; therefore, trivial and minor abnormal procedures may not be included.

COMPUTER-BASED TRAINING

(g) Computer-based training (CBT) may be used for ground training. CBT is any interactive means

of structured training using a computer to deliver the content. CBT provides a valuable source

of theoretical instruction, enabling the students to progress at their own pace within specified

time limits. Such systems may allow self-study or distance learning, if they incorporate adequate

knowledge testing procedures. It is good practice for the operator to make available a suitably

qualified ground instructor at an agreed time and day (e.g. at the next briefing of a simulator

session) to assist with areas of difficulty for the student.

Rationale

The proposed new points (e) and (f) provide guidance on the frequency that should apply to ground

training on aircraft systems and abnormal and emergency procedures. The wording of points (e) and

(f) assumes that at least two elements of the training (aircraft systems in point (e), abnormal and

emergency procedures in point (f)) are covered every 12 months.

The new point (g) clarifies that CBT is possible in the context of ground training and includes some

guidance on CBT. The definition of CBT comes from the EASA publication Guidance for allowing virtual

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classroom instruction and distance learning, and the remaining elements mirror AMC2 ORA.ATO.125,

with the necessary adaptations to suit the needs in Subpart ORO.FC.

These proposals are intended to add clarity to the current provisions. A low positive impact on safety

is expected.

AMC2 ORO.FC.231(a) Evidence-based training

UPSET PREVENTION AND RECOVERY TRAINING (UPRT) FOR COMPLEX MOTOR-POWERED AEROPLANES WITH

A MAXIMUM OPERATIONAL PASSENGER SEATING CONFIGURATION (MOPSC) OF MORE THAN 19 AND FLIGHT

PATH MANAGEMENT DURING UNRELIABLE AIRSPEED INDICATION AND OTHER FAILURES AT HIGH ALTITUDE

IN AEROPLANES WITH A MAXIMUM CRUISING ALTITUDE ABOVE FL300

Operators approved for EBT should follow the provisions for upset prevention and recovery training

(UPRT) contained in AMC1 ORO.FC.220&230 ‘Operator conversion training and checking & recurrent

training and checking’ and for training on flight path management during unreliable airspeed

indication and other failures at high altitude in aeroplanes with a maximum cruising altitude above

FL300 contained in AMC1 ORO.FC.120&130. These provisions should be are included in the tables of

assessment and training topics detailed in ORO.FC.232. Further guidance can be found in the EASA

EBT manual.

Rationale

The amendments proposed aim to clarify that operators approved for EBT need to include in their

training programmes elements related to training on flight path management during unreliable

airspeed indication and other failures at high altitude, as detailed in AMC1 ORO.FC.120&130.

Compliance with AMC1 ORO.FC.120&130 is already required by EBT operators (and non-EBT

operators); therefore, the amendments to AMC2 ORO.FC.231(a) simply clarify:

— that the provisions in AMC1 ORO.FC.120&130 can be integrated in the EBT programme;

— how to integrate them, which is provided in the amendments proposed in AMC2 ORO.FC.232

(see below).

The proposed amendments add clarity to the text, and a low positive impact on safety is expected.

AMC1 ORO.FC.231(a)(5) Evidence-based training

CONTINGENCY PROCEDURES FOR UNFORESEEN CIRCUMSTANCES THAT MAY AFFECT THE DELIVERY OF THE

MODULE

[…]

(FCL.060):

[…]

(5) when the pilot misses two or more modules and the pilot’s rating is expired by less than

1 year:

[…]

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(ii) training topics B and C of the other module(s) missing should be rescheduled

before the pilot can resume line operations.

[…]

Rationale

The purpose of the proposed amendments is to clarify that the provisions of point (c)(5) of the AMC

also apply to cases in which the pilot has missed two modules or more.

The proposed amendments add clarity to the text, and no impact is expected.

GM1 ORO.FC.231(a)(5) Evidence-based training

CONTINGENCY PROCEDURES — RATINGS RENEWAL

(a) […]

[…]

(2) […]

[…]

(ii) Two or more modules are missing: the pilot must complete one module (two

simulator sessions) and training topics B and C of the other missing module (an

extra simulator session) with a total of three simulator sessions. Training data is

gathered in a short time period; therefore, an EBT instructor with examiner

privilege is involved to ensure the proficiency of the pilot.

[…]

Rationale

Please refer to the rationale for the amendments to AMC1 ORO.FC.231(a)(5).

AMC1 ORO.FC.231(c) Evidence-based training

TRAINING SYSTEM PERFORMANCE — FEEDBACK PROCESS

[…]

(1) level 0 grading metrics (competent/binary metrics): data metrics providing the

information whether the pilot(s) is (are) competent or not (for training: whether the pilot

‘completed’ the training or not);

[…]

Rationale

Level 0 grading is a binary grading. The purpose of the first proposed amendment is to clarify that

level 0 can be used to grade training sessions (e.g. scenario-based training). The wording

‘competent/not competent’ was perceived as confusing as it is usually used in the context of evaluation

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or checking. A few existing paragraphs of GM to ORO.FC.231 clearly cover the possibility of using level 0

grading in scenario-based training while taking level 1 de-identified, and proposed amendments are

consistent with that.

The wording used (‘whether the pilot ‘completed’ the training or not’) follows the philosophy described

in point (a)(3)(i) of ORO.FC.231.

The proposed amendments add clarity to the text, and no impact is expected.

AMC4 ORO.FC.231(d)(1) Evidence-based training

RECOMMENDED GRADING SYSTEM METHODOLOGY — VENN MODEL

(a) […]

Abbreviated word picture VENN model

TEM Observable behaviours

Grading OUTCOME (1) HOW WELL (2) = HOW MANY (i)+ HOW OFTEN (ii)

1 unsafe situation ineffectively few, hardly any rarely

2 not an unsafe situation minimally acceptable some occasionally

3 safe situation adequately many regularly

4 safe situation effectively most regularly

5 enhanced safety, effectiveness and

efficiency

in an exemplary

manner all, almost all always

(b) Grades should be determined during each EBT module as follows:

Abbreviated word picture VENN model

Observable behaviours & TEM outcome Grading

HOW MANY (2)(i) + HOW OFTEN (2)(ii) = HOW WELL (2) OUTCOME (1) GRADE

few, hardly any rarely ineffectively unsafe situation 1

some occasionally minimally acceptable not an unsafe situation 2

many regularly adequately safe situation 3

most regularly effectively safe situation 4

all, almost all always in an exemplary

manner

enhanced safety,

effectiveness and efficiency

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(1) EVAL — overall performance of the phase at level 1 grading metrics.

(2) MT — overall performance of the phase at level 0 grading metrics. When the phase is

graded ‘not competent’ or ‘not completed’, it requires level 2 grading metrics.

[…]

Rationale

The replacement table improves the presentation of the existing table and moves the TEM column to

the end of the table in accordance with the latest amendments from ICAO.

Additionally, it is proposed to introduce new wording to point (b), to reflect the practice used by many

operators, which consider ‘not completed’ more appropriate for this training phase, as ‘not competent’

is wording traditionally used in a checking environment. See the rationale for the proposed

amendments to AMC1 ORO.FC.231(c).

The proposed amendments add clarity to the text, and no impact is expected.

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AMC2 ORO.FC.232 EBT programme assessment and training topics

GENERATION 4 (JET) — TABLE OF ASSESSMENT AND TRAINING TOPICS

[…]

Section 5 — UPRT training topic with frequency (B). Evaluation phase, manoeuvres training phase or scenario-based training phase (EVAL, MT or SBT)

EV A

L, M

T o

r SB

Upset prevention

training B

N/A

Compliance with AMC1 or AMC2 to

ORO.FC.220&230 and AMC1

ORO.FC.120&130

Include ‘upset prevention elements’ in

‘Table 1’ and ‘unreliable airspeed

indication’ and other failures for the

recurrent training programme in at least

every cycle, such that all the elements are

covered over a period not exceeding 3

years. The elements are numbered with

letters from A to I in Table 1 of AMC1

ORO.FC.220&230. Each element is made

up of several numbered components.

[…]

See Table 1 of AMC1 ORO.FC.220&230: Elements and respective components of upset

prevention training.

Intentionally blank

CRZ […] X x x

APP

[…] x x x x

CRZ […] X x x

CRZ […] X x x x

CRZ […] X x x X

CRZ High-altitude ACAS RA (where the RA is required to be flown in manual flight) x x x x

CRZ Basic flight physics principles concerning flights at high altitude, with a particular

emphasis on the relative proximity of the critical Mach number and the stall and pitch

behaviour, and an understanding of the reduced stall angle of attack when compared

with low-altitude flight. Note: By executing at high altitude any of components A.3, A.4,

A.5, A.6 or A.7 of Table 1 (prevention) of AMC1 ORO.FC.220&230 or component A.3 of

Table 2 (recovery), this element may be credited.

Intentionally blank

CRZ Interaction of automation (autopilot, flight director, auto-throttle/autothrust) and the

consequences of failures inducing disconnection of the automation. Note: By executing

at high altitude any of the components F.3, F.6 or H.5 of Table 1 of AMC1

ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ Consequences of an unreliable airspeed indication and other failures at high altitude

and the need for the flight crew to promptly identify the failure and react with

appropriate (minimal) control inputs to keep the aircraft in a safe envelope. Note: By

executing at high altitude any of the components H.1, H.2, H.3, H4, H5, H6 or H7 of

Table 1 of AMC1 ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ Unreliable airspeed indication or other failures at high altitude and the need for the

flight crew to promptly identify the failure and react with appropriate (minimal) control

inputs to keep the aircraft in a safe envelope.

X X X X X X X

CRZ Degradation of fly-by-wire (FBW) flight control laws/modes and its impact on aircraft

stability and flight envelope protections, including stall warnings. Note: By executing at

Intentionally blank

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high altitude component H.6 of Table 1 AMC1 ORO.FC.220&230 this element may be

credited.

CRZ Practical training, using appropriate simulators, on manual handling at high altitude in

normal and non-normal flight control laws/modes, with particular emphasis on pre-stall

buffet, the reduced stall angle of attack when compared with low-altitude flight and the

effect of pitch inputs on the aircraft trajectory and energy state. Note: By executing at

high altitude any of the components A.3, A.4, A.5, A.6, A.7, F.3, G.5, H.7 or I.1 of Table 1

of AMC1 ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ The requirement to promptly and accurately apply the stall recovery procedure, as

provided by the aircraft manufacturer, at the first indication of an impending stall.

Differences between high-altitude and low-altitude stalls must be addressed. Note: By

executing at high altitude component A.2 of Table 1 of AMC1 ORO.FC.220&230, this

element may be credited.

Intentionally blank

CRZ Procedures for taking over and transferring manual control of the aircraft, especially for

FBW aeroplanes with independent side-sticks. Note: By executing at high altitude any

of the components F.1, F.6, H.3 or H.4 of Table 1 of AMC1 ORO.FC.220&230, this

element may be credited.

Intentionally blank

N/A Task sharing and crew coordination in high workload/stress conditions with appropriate

call-out and acknowledgement to confirm changes to the aircraft flight control

law/mode. Note: By executing at high altitude the training topic ‘workload distraction,

pressure, stress’, this element may be credited.

Intentionally blank

[…]

Rationale

The proposed additions to Section 5 of the table, on UPRT training, improve the link with AMC1 ORO.FC.120&130 and AMC1 ORO.FC.220&230. See the

rationale for the amendments to AMC2 ORO.FC.231(a).

The proposed amendments add clarity to the text, and a low positive impact on safety is expected.

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AMC3 ORO.FC.232 EBT programme assessment and training topics

GENERATION 3 (JET) — TABLE OF ASSESSMENT AND TRAINING TOPICS

[…]

Section 5 — UPRT training topic with frequency (B). Evaluation phase, manoeuvres training phase or scenario-based training phase (EVAL, MT or SBT)

EV A

L, M

T o

r SB

Upset prevention

training B

N/A

Compliance with AMC1 or AMC2 to

ORO.FC.220&230 and AMC1

ORO.FC.120&130

Include ‘upset prevention elements’ in

‘Table 1’ and ‘unreliable airspeed

indication’ and other failures for the

recurrent training programme in at least

every cycle, such that all the elements are

covered over a period not exceeding 3

years. The elements are numbered with

letters from A to I in Table 1 of AMC1

ORO.FC.220&230. Each element is made

up of several numbered components.

[…]

[…] Intentionally blank

CRZ […] X x x

APP

[…] x x x x

CRZ […] X x x

CRZ […] X x x x

CRZ […] X x x X

CRZ […] x x x x

CRZ Basic flight physics principles concerning flights at high altitude, with a particular

emphasis on the relative proximity of the critical Mach number and the stall and pitch

behaviour, and an understanding of the reduced stall angle of attack when compared

with low-altitude flight. Note: By executing at high altitude any of the components A.3,

A.4, A.5, A.6 or A.7 of Table 1 (prevention) of AMC1 ORO.FC.220&230 or component A.3

of Table 2 (recovery), this element may be credited.

Intentionally blank

CRZ Interaction of automation (autopilot, flight director, auto-throttle/autothrust) and the

consequences of failures inducing disconnection of the automation. Note: By executing

at high altitude any of the components F.3, F.6 or H.5 of Table 1 of AMC1

ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ Consequences of an unreliable airspeed indication and other failures at high altitude

and the need for the flight crew to promptly identify the failure and react with

appropriate (minimal) control inputs to keep the aircraft in a safe envelope. Note: By

executing at high altitude any of the components H.1, H.2, H.3, H4, H5, H6 or H7 of

Table 1 of AMC1 ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ Unreliable airspeed indication or other failures at high altitude and the need for the

flight crew to promptly identify the failure and react with appropriate (minimal) control

inputs to keep the aircraft in a safe envelope.

x x x x x x x

CRZ Degradation of fly-by-wire (FBW) flight control laws/modes and its impact on aircraft

stability and flight envelope protections, including stall warnings. Note: By executing at

Intentionally blank

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high altitude component H.6 of Table 1 of AMC1 ORO.FC.220&230, this element may be

credited.

CRZ Practical training, using appropriate simulators, on manual handling at high altitude in

normal and non-normal flight control laws/modes, with particular emphasis on pre-stall

buffet, the reduced stall angle of attack when compared with low-altitude flight and the

effect of pitch inputs on the aircraft trajectory and energy state. Note: By executing at

high altitude any of the components A.3, A.4, A.5, A6, A7, F.3, G.5, H.7 or I.1 of Table 1

of AMC1 ORO.FC.220&230, this element may be credited.

Intentionally blank

CRZ The requirement to promptly and accurately apply the stall recovery procedure, as

provided by the aircraft manufacturer, at the first indication of an impending stall.

Differences between high-altitude and low-altitude stalls must be addressed. Note: By

executing at high altitude component A.2 of Table 1 of AMC1 ORO.FC.220&230, this

element may be credited.

Intentionally blank

CRZ Procedures for taking over and transferring manual control of the aircraft, especially for

FBW aeroplanes with independent side-sticks. Note: By executing at high altitude any

of the components F.1, F.6, H.3 or H.4 of Table 1 of AMC1 ORO.FC.220&230, this

element may be credited.

Intentionally blank

N/A Task sharing and crew coordination in high workload/stress conditions with appropriate

call-out and acknowledgement to confirm changes to the aircraft flight control

law/mode. Note: By executing at high altitude the training topic ‘workload distraction,

pressure, stress’, this element may be credited.

Intentionally blank

[…]

Rationale

The proposed additions to Section 5 of the table, on UPRT training, improve the link with AMC1 ORO.FC.120&130 and AMC1 ORO.FC.220&230. See the

rationale for the amendments to AMC2 ORO.FC.231(a).

The proposed amendments add clarity to the text, and a low positive impact on safety is expected.

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AMC1 ORO.FC.A.245 Alternative training and qualification

programme

COMPONENTS AND IMPLEMENTATION

(a) Alternative training and qualification programme (ATQP) components

The ATQP should comprise the following:

[…]

(5) A feedback loop for the purpose of curriculum validation and refinement, and to ascertain

that the programme meets its proficiency objectives.

(i) The feedback should be used as a tool to validate that the curricula are

implemented as specified by the ATQP; this enables substantiation of the

curriculum, and that proficiency and training objectives have been met. The

feedback loop should include data from operations flight data monitoring, the

advanced flight data monitoring (FDM) programme and LOE/LOQE programmes. In

addition, the evaluation process should describe whether the overall

targets/objectives of training are being achieved and should prescribe any

corrective action that needs to be undertaken.

[…]

(7) A flight data monitoring/analysis programme consisting of the following:

(i) A flight data monitoring (FDM) programme, as specified described in AMC1

ORO.AOC.130. Data collection should reach a minimum of 60 % of all relevant flights

conducted by the operator before ATQP approval is granted. This proportion may be

increased as determined by the competent authority.

(ii) An advanced FDM when an extension to the ATQP is requested: an advanced FDM

programme is determined by the level of integration with other safety initiatives

implemented by the operator, such as the operator’s safety management system. The

programme should include both systematic evaluations of data from an FDM programme

and flight crew training events for the relevant crews. Data collection should reach a

minimum of 80 % of all relevant flights and training conducted by the operator. This

proportion may be varied as determined by the competent authority.

The purpose of an FDM or advanced FDM programme for ATQP is to enable the operator

to:

(i) The FDM programme should be used to:

(A) provide data to support the ATQP programme’s implementation and justify

any changes to the ATQP;

[…]

(iii) Data gathering: Transmission of information: the FDM programme should provide

to the ATQP responsible person the information that is needed for ATQP purposes.

Subject to the procedure to prevent disclosure of crew identity (refer to point (k)

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of AMC1 ORO.AOC.130), the level of detail of that information should allow

targeted changes to the training programme to be defined. the data analysis

should be made available to the person responsible for ATQP within the

organisation. The data gathered by the FDM programme for this purpose should:

[…]

(iiiiv) Data handling Handling of transmitted information: the operator should establish

a procedure to ensure the confidentiality of individual flight crew members, as

described by AMC1 ORO.AOC.130. FDM-based information transmitted to the

ATQP responsible person, which should be consistent with the procedure to

prevent disclosure of crew identity specified in AMC1 ORO.AOC.130.

[…]

Rationale

AMC1 ORO.FC.A.245 is proposed to be amended to align its FDM-related conditions with current

industry good practice and the conditions in AMC1 ORO.AOC.130.

In order to provide operators with sufficient notice period to implement the amendments, it is expected

that the implementation of the amendments introduced to AMC1 ORO.FC.A.245 will be deferred by

2 years.

Detailed rationale

— Regarding the changes proposed to point (a)(5), the distinction between ‘FDM programme’ and

‘advanced FDM programme’ has been removed. The term ‘advanced FDM programme’ is not

used elsewhere in the Air OPS Regulation, ICAO Annex 6 or ICAO Document 10 000; nor is it used

in FDM guidance and good-practice documents, such as UK Civil Aviation Authority CAP739 or

European Operators Flight Data Monitoring forum industry good-practice documents. FDM

specialists in the industry and authorities also do not use this term. In addition, the conditions

that determined an ‘advanced FDM programme’ in the former point (a)(7)(i) of

AMC1 ORO.FC.A.245 should now be required to be met by any FDM programme:

• the proposed new point (h)(1) of AMC1 ORO.AOC.130 specifies that at least 80 % of the

flights of any aeroplane in the scope of ORO.AOC.130 should be available for analysis with

the FDM software;

• every FDM programme must be integrated in the operator’s management system, as

required by ORO.AOC.130.

Further to that, data from flight crew training events (e.g. from training sessions with flight

simulation training devices) fall outside the scope of an FDM programme. According to the

definition of FDM in Annex I to the Air OPS Regulation (Part-DEF), it is based on the use of digital

flight data from routine operations, not on other types of data.

— Regarding the changes proposed to point (a)(7):

• The description of advanced FDM programmes has been removed.

• The system based on two-step FDM implementation (‘normal’ FDM programme at the

time of ATQP approval, followed by ‘advanced’ FDM programme when the ATQP approval

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is renewed) has been replaced by a single condition to implement an FDM programme as

specified in AMC1 ORO.AOC.130. However, this change depends on the adoption of the

new point (h)(1) of AMC1 ORO.AOC.130; a condition to achieve a flight collection rate of

80 % for extensions to ATQP approval would need to be maintained in point (a)(7), should

the condition in point (h)(1) of AMC1 ORO.AOC.130 not be retained after the consultation

on this NPA.

• The former point on data gathering (new point (a)(7)(ii)) has been rephrased to better link

it to the confidentiality procedure specified in point (k) of AMC1 ORO.AOC.130 and to

clarify that the FDM programme should provide the ATQP responsible person with the

information needed for their job and not necessarily all analyses. Usually, designated staff

members (e.g. the safety manager, or safety analysts under the safety manager’s

authority) are entitled to have access to the identifiable FDM data or FDM analyses that

relate to individual flight crew members, while other functions in the operator (training,

flight operations, finance, etc.) do not have access to such protected data.

• The former point on data handling (new point (a)(7)(iii)) has been reworded for clarity (the

FDM-based information is confidential, not the flight crew members).

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4.2.3 Annex IV (Part-CAT)

SUBPART B: OPERATING PROCEDURES

SECTION 1 – MOTOR-POWERED AIRCRAFT

GM2 CAT.OP.MPA.107 Adequate aerodrome

RESCUE AND FIREFIGHTING SERVICES (RFFS)

Guidance on the assessment of the level of an aerodrome’s RFFS can be found in ICAO Annex 6, Part I,

attachment I.

Rationale

In its Annex 6, Part I, ICAO introduced guidance related to RFFS, which is guidance for industry to

implement RFFS procedures.

The new proposed GM provides a new source of information for the industry. The alignment with ICAO

SARPs provides consistency, which will have a positive impact in terms of standardisation. The expected

overall impact is low positive.

AMC1 CAT.OP.MPA.110 Aerodrome operating minima — general

TAKE-OFF OPERATIONS

[…]

Table 1

Take-off — aeroplanes (without LVTO approval)

RVR or VIS

[…]*: The reported RVR or VIS value representative of the initial part of the take-off run

can be replaced by pilot assessment.

[…]

Rationale

The deletion of the word ‘reported’ is proposed to ensure consistency with the proposed changes to

AMC3 NCC.OP.110 and AMC3 SPO.OP.110. See the rationales for those changes.

The amendment proposed aims to ensure clarity and consistency, and no impact is expected.

GM2 CAT.OP.MPA.181 Fuel/energy scheme — fuel/energy planning

and in-flight re-planning policy — aeroplanes

BASIC FUEL SCHEME WITH VARIATIONS — STATISTICAL CONTINGENCY FUEL METHOD

As an example of statistical contingency fuel, the following statistical values of the deviation from the

planned to the actual trip fuel provide appropriate statistical coverage:

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(a) 99 % coverage plus 3 % of the trip fuel if the calculated flight time:

(1) is less than 2 hours; or

(2) is more than 2 hours and no fuel ERA aerodrome is available;

(b) 99 % coverage if the calculated flight time is more than 2 hours and a fuel ERA aerodrome is

available; and

(1) the calculated flight time is more than 2 hours;

(2) a fuel ERA aerodrome is available; and

(3) at the destination aerodrome, two separate runways are available and usable, one of

which is suitable for type B instrument approach operations, and the meteorological

conditions are in accordance with point CAT.OP.MPA.182(e).

The statistical contingency fuel (SCF) method is a method to calculate contingency fuel based on the

operator’s experience, typically considering statistically representative data from the past. It is

applicable for specific city pairs and aircraft type combinations. When considering appropriate

percentiles, the following factors, among others, are to be considered: specific route segment issues,

runway availabilities, seasonality, time of day and aircraft type combinations. A common practice is

the use of a coverage value of 90 %, 95 % or 99 %, but other practices may be possible. The values

used need to be monitored and regularly adapted to reflect realistic baselines. It is recommended that

this is done weekly or, as a minimum, monthly. The competent authority needs to be satisfied with

the safety risk assessment and the operator’s capability of implementing and monitoring the SCF

procedure proposed. For further explanations, refer to ICAO Doc 9976 and the EASA fuel

implementation manual.

Rationale

The example used in the current GM2 CAT.OP.MPA.181 led to some confusion among stakeholders. It

is therefore proposed to amend the GM to include a more general text. The EASA fuel implementation

manual to which the proposed GM refers is still under development and will be published in 2024.

The proposed amendment intends to increase clarity and no impact is expected.

AMC2 CAT.OP.MPA.182 Fuel/energy scheme — aerodrome

selection policy — aeroplanes

BASIC FUEL SCHEME – DESTINATION ALTERNATE AERODROME

[…]

(b) For each IFR flight, the operator should select and specify in the operational and ATS flight plans

two destination alternate aerodromes when, for the selected destination aerodrome, the safety

margins for meteorological conditions of point (a) of AMC5 CAT.OP.MPA.182, and the planning

minima of AMC6 CAT.OP.MPA.182 cannot be met, or when no meteorological information is

available.

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[…]

Rationale

The proposed amendments aim to address questions raised by the reference to

AMC6 CAT.OP.MPA.182, which is unnecessary and duplicates other provisions in

AMC5 CAT.OP.MPA.182.

The proposed amendment intends to increase clarity and no impact is expected.

AMC2 CAT.OP.MPA.185(a) Fuel/energy scheme — aerodrome

selection policy — aeroplanes

BASIC FUEL SCHEME WITH VARIATIONS — PROCEDURES FOR IN-FLIGHT FUEL MANAGEMENT

(a) […]

[…]

(3) destination 1 aerodrome alternate fuel if a destination 1 alternate aerodrome is required

according to point (c)(4) of CAT.OP.MPA.181;

(4) additional fuel, if required; and

(5) FRF extra fuel, if required; and

(6) FRF.

[…]

Rationale

The reference to CAT.OP.MPA.181(c)(4) is proposed to be introduced for legal certainty.

It is also proposed to introduce a reference to ‘extra’ and final reserve fuel, which are both required to

be considered for in-flight planning under CAT.OP.MPA.181 (points (5) and (7)) but were mistakenly

not mentioned in this AMC.

The proposed amendment intends to increase clarity and no impact is expected.

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4.2.4 Annex V (Part-SPA)

SUBPART E: LOW-VISIBILITY OPERATIONS (LVOS) AND OPERATIONS WITH OPERATIONAL CREDITS

AMC1 SPA.LVO.100(a) Low-visibility operations and operations

with operational credits

LOW-VISIBILITY TAKE-OFF (LVTO) OPERATIONS — AEROPLANES IN AN RVR OF LESS THAN 400 M

[…]

(b) The reported RVR value representative of the initial part of the take-off run can be replaced by

pilot assessment.

representative of the parts of the runway from the point at which the aircraft commences the

take-off run until the end of the calculated accelerate-stop distance from that point.

[…]

Rationale

It is proposed to remove the word ‘reported’ from point (b) to clarify that the pilot assessment can

replace: :

— RVR that has been reported in the airport; and/or

— touchdown zone RVR, when it is not available (e.g. the tower provides MID and STOP-END RVR

but touchdown RVR is out of service).

The wording of point (c) is proposed to be amended to avoid misunderstanding between take-off run

and take-off distance.

The proposed amendments aim to improve clarity, and no impact is expected.

AMC1 SPA.LVO.100(b) Low-visibility operations and operations with

operational credits

INSTRUMENT APPROACH OPERATIONS IN LOW-VISIBILITY CONDITIONS — CAT II OPERATIONS

[…]

Table 4

CAT II operation minima: RVR (m) versus DH (ft)

Aircraft categories Auto-coupled or HUD to below DH*

A, B, C D

DH (ft) 100–120 300 300*/350*

121–140 400 400

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Aircraft categories Auto-coupled or HUD to below DH*

A, B, C D

141–199 400**/450 400**/450

*: An RVR of 300 m may be used for a Category D aeroplane conducting an autoland or

using HUDLS to touchdown touch down.

**: An RVR of 400 m may be used for an aeroplane conducting an autoland or using

HUDLS to touch down.

Rationale

The proposed amendment aims to align the LVO take-off minima that require specific approval (i.e.

RVR of 400 m) with the CAT II instrument approach operation (which also requires specific approval)

at AMC level. In addition, it is proposed to add a reference to the use of HUDLS, which is currently

missing.

AMC2 SPA.LVO.100(b) Low-visibility operations and operations with

operational credits

INSTRUMENT APPROACH OPERATIONS IN LOW-VISIBILITY CONDITIONS — CAT III OPERATIONS

[…]

Table 5

CAT III operation minima: RVR (m) versus DH (ft)

DH(ft) Ground Rroll-out control/Ground-roll guidance system RVR (m)*

50-99 Not required 175

0-49 or no DH Fail-passive 125

Fail-operational 75

Rationale

The amendment clarifies that the equipment that the AMC refers to is the ground-roll control or

ground-roll guidance and not the ‘approach’ landing system. Some operators have been using fail-

passive automatic landing systems (i.e. CAT III single) with a 125 m RVR, when this should not be the

case. According to point (c) of CS AWO.B.CATIII.113, a fail-operational automatic landing system is

required, or a fail-operational hybrid landing system and a fail-operational or fail-passive automatic

ground-roll control or head-up ground-roll guidance. Thus, a fail-passive automatic landing system (i.e.

CAT III single) can only be certified at 50 feet or above and therefore 175 m RVR is required. The

amendment is proposed to avoid misunderstandings between landing systems and ground systems.

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AMC1 SPA.LVO.120(a) Flight crew competence

COMPETENCE OF THE FLIGHT CREW FOR THE INTENDED OPERATIONS — EXPERIENCE IN TYPE OR CLASS, OR

AS PILOT-IN-COMMAND/COMMANDER

To ensure that the flight crew is competent to conduct the intended operations, the operator should

assess the risks associated with the conduct of low-visibility approach operations by pilots new to the

aircraft type or class, including pilots new to the role of pilot-in-command, and take the necessary

mitigations. Where such mitigations include an increment to the visibility or RVR for LVOs, this should

be stated in the operations manual.

Rationale

The proposed amendment intends to clarify that this AMC is also applicable when a pilot-in-command

has not previously been pilot-in-command on any aircraft type. Although this was indicated in the

subtitle of the AMC, it was not explicitly mentioned in the text of the AMC, and this was creating

confusion among stakeholders.

The purpose of the proposed amendments is to introduce clarity to the provisions, and a low positive

impact on safety is expected. It may also lead to a low economic impact for operators that are not

already applying the AMC to new pilots-in-command.

AMC2 SPA.LVO.120(a) Flight crew competence

COMPETENCE OF THE FLIGHT CREW FOR THE INTENDED OPERATIONS — RECENT EXPERIENCE FOR EFVS

OPERATIONS

[…]

(b) If a flight crew member is authorised to operate as pilot flying and pilot monitoring during EFVS

operations, the flight crew member should complete the required number of approaches at

least one approach in the other each operating capacity.

Rationale

Please refer to the rationale for the proposed changes to AMC3 SPA.LVO.120(a).

AMC3 SPA.LVO.120(a) Flight crew competence

COMPETENCE OF THE FLIGHT CREW FOR THE INTENDED OPERATIONS — RECENT EXPERIENCE FOR SA CAT I,

CAT II, SA CAT II AND CAT III APPROACH OPERATIONS

[…]

(d) If a flight crew member is authorised to operate as pilot flying and pilot monitoring, the flight

crew member should complete the required number of approaches at least one approach in

the other each operating capacity.

Rationale

The proposed changes aim to eliminate inconsistencies between the current points (b) and (d) of

AMC3 SPA.LVO.120(a), which were not fully aligned for cases where the operator wishes to add a new

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‘LVO capacity’ and train its pilots accordingly. Point (b) refers to ‘at least one approach’ to add the

additional capacity, and point (d) required the same number of approaches as the first capacity, which

for some cases could be up to four approaches, which is excessive and not the original intention.

Related changes have been made to AMC2 SPA.LVO.120(a), AMC2 SPA.LVO.120(b),

AMC3 SPA.LVO.120(b), AMC4 SPA.LVO.120(b) and AMC6 SPA.LVO.120(b), to ensure consistency.

The proposed amendments aim to improve clarity, and an overall low positive impact is expected.

AMC2 SPA.LVO.120(b) Flight crew competence

INITIAL TRAINING AND CHECKING FOR SA CAT I, CAT II, SA CAT II AND CAT III APPROACH OPERATIONS

[…]

(d) If a flight crew member is authorised to operate as pilot flying and pilot monitoring, the flight

crew member should complete at least one approach in the other operating capacity.

Rationale

The new point (d) is proposed to ensure consistency across the AMC to SPA.LVO.120. Although

GM1 SPA.LVO.120, describing the general philosophy of LVO training, already mentions the possibility

of adding new capacities, this was not explicitly mentioned in all AMC and this was creating confusion

for operators and authorities.

Please refer also to the rationale for the proposed changes to AMC3 SPA.LVO.120(a).

The proposed amendments aim to improve clarity, and an overall low positive impact is expected.

AMC3 SPA.LVO.120(b) Flight crew competence

INITIAL TRAINING AND CHECKING FOR EFVS OPERATIONS

[…]

(d) If a flight crew member is authorised to operate as pilot flying and pilot monitoring, the flight

crew member should complete at least one approach in the other operating capacity.

Rationale

Please refer to the rationale for the proposed changes to AMC2 SPA.LVO.120(b).

AMC4 SPA.LVO.120(b) Flight crew competence

RECURRENT CHECKING FOR LVTO, SA CAT I, CAT II, SA CAT II AND CAT III APPROACH OPERATIONS

[…]

(d) If a flight crew member is authorised to operate as pilot flying and pilot monitoring, the flight

crew member should complete at least one approach in the other operating capacity.

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Rationale

Please refer to the rationale for the proposed changes to AMC2 SPA.LVO.120(b).

AMC6 SPA.LVO.120(b) Flight crew competence

RECURRENT CHECKING FOR EFVS OPERATIONS

[…]

(b) If a flight crew member is authorised to operate as pilot flying and pilot monitoring during EFVS

operations, then the flight crew member should complete the required number of approaches

at least one approach in the other each operating capacity.

Rationale

Please refer to the rationale for the proposed changes to AMC3 SPA.LVO.120(a).

GM1 SPA.LVO.120(b) Flight crew competence

FLIGHT CREW TRAINING

[…]

Table 1

Summary of initial training requirements for LVOs and operations with operational credits

Approval Airborne

equipment

Previous experience Reference Practical (FSTD)

training4

LIFUS

(if required)4

CAT II

Auto coupled

to below DH

with manual

landing

[…] […] […] […]

Previously qualified with

the same operator, similar

operations3

AMC2 SPA.LVO.120(b)

point (b)(32)(ii) […] […]

[…] […] […] […]

[…]

Rationale

Editorial amendment to correctly reflect the regulatory reference; no impact is expected.

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SUBPART G: TRANSPORT OF DANGEROUS GOODS

AMC1 SPA.DG.105(a) Approval to transport dangerous goods

TRAINING PROGRAMME

(a) The operator should indicate for the approval of the training programme how the training will

be carried out. For formal training courses, the course objectives, the training programme

syllabus/curricula and examples of the assessments to be carried out written examination to

be undertaken should be included.

(b) […]

handouts, leaflets, circulars, slide presentations, videos, computer-based training, etc., and

may take place on-the-job or off-the-job. The person being trained should receive an overall

awareness of the subject. This training programme should also include a written, oral or

computer-based an assessment plan examination covering all areas of the training syllabi

programme, and showing that a required minimum level of knowledge competence has been

acquired.

(d) Training intended to give an in-depth and detailed appreciation of the whole subject or

particular aspects of it should be by formal training courses, which should include a written

examination., the successful passing of which will result in the Personnel should be assessed

to ensure that they are competent to perform any function for which they are responsible.

Successful demonstration of their competence will result in the issue of the proof of

qualification. The course may be by means of tuition, as a self-study programme, or a mixture

of both. The person being trained should gain sufficient knowledge so as to be able to apply

the detailed rules of the Technical Instructions.

[…]

Rationale

The proposed amendments aim to provide for more flexibility regarding the assessment of personnel,

to facilitate the implementation of the new competence-based approach to the training on

dangerous goods adopted by ICAO.

There is not expected to be an impact on safety. An assessment plan needs to be elaborated in

accordance with the competence-based training provisions. Continuous assessment provides the

possibility to improve and adapt training. The fact that all knowledge components are addressed or

appear to be included in a course and that all trainees have passed the required test does not

necessarily mean that they can competently perform their assigned functions. The amendment

provides sufficient flexibility to the operator to tailor both the assessment and the training to the

functions and ensure that the competence needed for the performance of the duties is achieved by

the personnel.

As operators are already implementing competence-based training in accordance with ICAO, the

change can only have a positive impact for those operators who no longer need to have a written

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examination as proof of competency and, thus, can remove the examination from their training

programmes. Thus, the economic impact, if any, would be positive.

SUBPART K: HELICOPTER OFFSHORE OPERATIONS

AMC1 SPA.HOFO.145 Flight data monitoring (FDM) programme

ORGANISATION OF THE FDM PROGRAMME

(a) Safety manager responsibility: Rrefer to point (a) of AMC1 ORO.AOC.130.

(b) Contribution to the management system: refer to point (b) of AMC1 ORO.AOC.130.

(d) FDM analysis, assessment and process control tools: refer to point (d) of AMC1 ORO.AOC.130.

(e) Safety information and promotion: refer to point (e) of AMC1 ORO.AOC.130.

(f) Accident and incident data requirements: refer to point (f) of AMC1 ORO.AOC.130.

(g) Event reporting: refer to point (g) of AMC1 ORO.AOC.130.

(h) Data recovery and analysis: the data recovery and analysis strategy should ensure a sufficiently

representative capture of flight information to maintain an overview of operations. In addition,

FDM event validation should be performed sufficiently frequently to enable action to be taken

on significant safety issues. This includes all of the following.

(1) At least 80 % of the flights of any individual helicopter in the scope of SPA.HOFO.145 and

that were performed in the past 12 months should be available for analysis with the FDM

software and have valid data, unless the operator demonstrates to its competent

authority that meeting this objective would cause a disproportionate cost impact; in that

case, the proportion of flights of any individual helicopter, that are available for analysis

with the FDM software and have valid data, should not be less than 60 % when averaged

over the past 12 months.

(2) The operator should have means to identify within 15 calendar days a failure to collect

data from any individual helicopter in the scope of SPA.HOFO.145, unless the operator

demonstrates to its competent authority that meeting this objective would cause a

disproportionate cost impact; in that case, the time to identify such a failure should not

exceed 22 calendar days.

(3) The time between completion of a flight and routine processing of the data of that flight

by the FDM software (including event detection) should not exceed 7 calendar days for

at least 80 % of flights collected with the FDM programme in the past 12 months, unless

the operator demonstrates to its competent authority that meeting this objective would

cause a disproportionate cost impact; in that case, at least 80 % of the flights collected

with the FDM programme in the past 12 months should be processed by the FDM

software within 15 days of completion of the flight.

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(4) For each helicopter that is in the scope of SPA.HOFO.145 and that is first issued with an

individual CofA on or after [date of publication + 3 years]:

(i) the operator should ensure that, within 90 calendar days after it starts operating

the helicopter, the data collected for analysis by the FDM software includes all the

flight parameters required to be recorded by a flight data recorder in accordance

with AMC1.2 CAT.IDE.H.190; and

(ii) the operator should ensure that, within 90 calendar days after it starts operating

the helicopter, the recorded flight parameters specified in (i) meet the

performance specifications (range, sampling intervals, accuracy limits and

resolution in read-out) as defined in EUROCAE Document 112A or any later

equivalent standard produced by EUROCAE.

(5) The operator should document the principles it uses for validating significant FDM events

(i.e. FDM events that require dedicated and timely review of the related flight data).

Validation of a significant FDM event should be performed as a matter of priority, and in

any case within 15 calendar days after it has been detected by the FDM software, for at

least 80 % of the significant FDM events.

(i) Data retention strategy: refer to point (i) of AMC1 ORO.AOC.130.

(j) Data access and security policy: refer to point (j) of AMC1 ORO.AOC.130.

(k) Procedure to prevent disclosure of crew identity: refer to point (k) of AMC1 ORO.AOC.130.

(l) Maintaining knowledge about data and algorithms: refer to point (l) of AMC1 ORO.AOC.130.

(m) Airborne systems and equipment: refer to point (m) of AMC1 ORO.AOC.130.

Rationale

Similar to AMC1 ORO.AOC.130, the subtitle of AMC1 SPA.HOFO.145 is proposed to be changed to

clarify that this AMC addresses the minimum performance of the FDM programme and not what risk

areas should be monitored by the FDM programme (the latter is addressed in the proposed

AMC2 SPA.HOFO.145, and examples of FDM methods are provided in the proposed amendments to

GM2 SPA.HOFO.145).

The reference to AMC1 ORO.AOC.130 is proposed to be replaced by points that refer to the conditions

specified in the points of AMC1 ORO.AOC.130.

However, the proposed point (h) of AMC1 SPA.HOFO.145 does not refer to a point of the proposed

AMC1 ORO.AOC.130, as the conditions in subpoints (h)(3) and (h)(4) are slightly different. More

specifically:

— Point (h)(3) specifies that the time between completion of a flight and routine processing of the

data of that flight with the FDM software should not exceed 7 calendar days for 80 % of the

flights, while point (h)(3) of AMC1 ORO.AOC.130 sets an objective of a maximum of 15 calendar

days for 80 % of the flights. The reason is that helicopter offshore operators are already required

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to download flight data on a daily basis by the International Association of Oil & Gas Producers34.

Nevertheless, similar to what is proposed for point (h)(3) of AMC1 ORO.AOC.130, the proposed

point (h)(3) of AMC1 SPA.HOFO.145 includes the possibility to agree on a less demanding

objective with the competent authority to avoid a disproportionate cost impact.

— Point (h)(4)(i) specifies that the data collected for analysis by the FDM software should include

the flight parameters recorded by an FDR in accordance with AMC1.2 CAT.IDE.H.190, while the

proposed point (h)(4)(i) of AMC1 ORO.AOC.130 specifies that the data collected for analysis by

the FDM software should include the flight parameters recorded by an FDR in accordance with

AMC1.2 CAT.IDE.A.190. The flight parameters to be recorded on an FDR are different for an

aeroplane and a helicopter.

In order to provide operators with sufficient notice period to implement the amendments, it is expected

that the applicability date of these amendments to AMC1 SPA.HOFO.145 will be deferred by 2 years.

In addition, the applicability of points (h)(4), (l) and (m) of AMC1 SPA.HOFO.145 is proposed to be

restricted to helicopters that are first issued eith an individual CofA at least 3 years after the date of

publication of the ED Decision, as otherwise the applicability of these points may cause a change to

airborne systems or airborne equipment on already operated helicopters.

AMC2 SPA.HOFO.145 Flight data monitoring (FDM) programme

SCOPE OF THE FLIGHT DATA MONITORING (FDM) PROGRAMME

(a) A set of core FDM events or FDM measurements should be selected to cover the main areas of

interest to the operator and, as far as possible, the most significant risks identified by the

operator. The event definitions and measurement definitions should be continuously reviewed

to reflect the operator’s current operating procedures.

(b) For all helicopters in the scope of SPA.HOFO.145 and that are first issued with an individual CofA

on or after 1 January 2016, the FDM programme should monitor, to the extent possible with

the available flight data and without requiring overly complex algorithms, at least the following

key risk areas:

(1) risk of aircraft upset;

(2) risk of collision with terrain;

(3) risk of obstacle collision in flight, during take-off or landing;

(4) risk of excursion from the touchdown and lift-off area, during take-off or landing.

data, the FDM programme should monitor:

(1) exceedances indicating that the airworthiness of the aircraft may be affected and that

are related to any of the following parameters:

34 Refer to International Association of Oil & Gas Producers, Offshore Helicopter Recommended Practices, 2020

(https://www.iogp.org/bookstore/product/offshore-helicopter-recommended-practices/) (see the module ‘Aircraft operations’).

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(i) speed;

(ii) altitude;

(iii) accelerations;

(iv) attitude angles;

(v) aircraft weight;

(vi) engine torque;

(2) caution and warning alerts to the flight crew indicating that the airworthiness of the

aircraft may be affected.

(d) The operator should establish and maintain a document identifying which types of occurrences

are monitored with the FDM programme. This document should cover at least occurrences

subject to mandatory reporting and listed in Regulation (EU) 2015/1018, Annex I, Section 1

(excluding paragraph 1.5, point (3)) and Section 5. This document should provide a short

description of the applicable FDM event(s) or FDM measurement(s) for each type of occurrence

that is monitored with the FDM programme.

Rationale

There is no specification in the proposed AMC1 SPA.HOFO.145 regarding the risk areas that should be

monitored by the FDM programme. As a result, compliance with the proposed AMC1 SPA.HOFO.145

would not allow it to be ensured that the operator uses its FDM programme to monitor the risk areas

that are obviously relevant for all offshore operators, such as those corresponding to occurrences

subject to mandatory occurrence reporting in accordance with Annex I to Regulation (EU) 2015/1018.

In order to provide operators with sufficient notice period to implement the proposed

AMC2 SPA.HOFO.145, it is expected that its applicability will be deferred by 2 years.

Detailed rationale

— Regarding point (a): similarly to point (a) of the proposed AMC2 ORO.AOC.130, this point

contains the general conditions regarding the choice of the risk areas to be monitored with the

FDM programme and adapting the definitions of FDM events and measurements to the

standard operating procedures.

— Regarding point (b):

• When considering commercial air transport (CAT) operations with helicopters, the most

relevant risk areas for monitoring according to EASA’s 2022 Annual Safety Review (ASR),

Figure 67, are aircraft upset, terrain collision, airborne collision and obstacle collision in

flight.

• The 2022 EASA ASR contains specific safety statistics for helicopter operators based in

EASA Member States. However, Figure 64 of the 2021 EASA ASR shows that more than

half of accidents and serious incidents occurred during CAT operations performed by such

operators over 2011–2020 actually occurred during helicopter emergency medical

services or air taxi operations. In addition, an internal review of EASA accident data for

CAT helicopter operations shows that almost no airborne collision occurred involving

helicopter operators based in EASA Member States during offshore operations and that,

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for such operators, the key risk area ‘airborne collision’ is instead relevant for other

subtypes of CAT operations (e.g. helicopter emergency medical services, air taxi,

sightseeing).

• In addition, the HeliOffshore Safety Performance Report shows that the main CAST/ICAO

Common Taxonomy Team occurrence categories for all accidents over 2013–2021 (73

accidents in total) are as follows.

o System component failure – non-power plant (SCF-NP) and system component

failure – power plant (SCF-PP), with 21 % and 7 % of accidents, respectively. An SCF-

NP or SCF-PP event with a helicopter is likely to result in aircraft upset and/or terrain

collision, if not recovered by the flight crew.

o Controlled flight into terrain (CFIT), with 13 % of accidents. CFIT is a subset of the

risk area ‘terrain collision’.

o Loss of control – in flight (LOC-I), with 13 % of accidents. LOC-I is a subset of the risk

area ‘aircraft upset’.

o Abnormal runway contact (ARC), with 9 % of accidents. ARC is a subset of the risk

area ‘excursion’.

o Collision with obstacle(s) during take-off and landing (CTOL), with 7 % of accidents.

CTOL is a subset of the risk area ‘obstacle collision in flight’.

o Other, with 29 % of accidents. This category contains ‘15 different causes, each with

a proportion of 5 % or less’.

• While HeliOffshore Safety Performance Report data is specific to offshore operators, a

large proportion of operators that are HeliOffshore members are not based in an EASA

Member State.

• Therefore, based on the data from the 2021 EASA ASR and the HeliOffshore Safety

Performance Report, and taking into account the respective scopes of these documents,

the most important risk areas for helicopter offshore operations performed by operators

based in EASA Member States seem to be:

o aircraft upset;

o terrain collision;

o obstacle collision in flight; and

o excursion.

— With regard to monitoring the risk of terrain collision, examples are provided in the updated

GM2 SPA.HOFO.145 proposed in this section. In addition, a helicopter terrain awareness and

warning system (HTAWS) is required for helicopters in the scope of SPA.HOFO.145 and

manufactured since 1 January 2019, in accordance with SPA.HOFO.160 (‘Equipment

requirements’). Hence, when a HTAWS is installed, the related HTAWS warnings could be

captured by the FDM programme to help monitor the risk of collision with terrain. In addition, a

flight parameter corresponding to the HTAWS should be recorded on the FDR of helicopters first

issued with an individual CofA on or after 1 January 2023, in accordance with

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AMC1.2 CAT.IDE.H.190. It is assumed that, for those helicopters, the same flight parameters can

be collected by the airborne system used to collect flight data for the FDM programme.

— With regard to monitoring the risk of obstacle collision in flight during take-off or landing: flight

parameters that should be recorded on the FDR of helicopters first issued with an individual CofA

on or after 1 August 1999 in accordance with AMC2 CAT.IDE.H.190 (such as pitch and roll

attitude, airspeed, altitude) are sufficient to monitor some of the precursors of this risk area. It

is assumed that, for those helicopters, the same flight parameters are collected by the airborne

system used to collect flight data for the FDM programme (e.g. the quick access recorder or

wireless quick access recorder). Examples of such precursors that could be monitored by the FDM

programme are provided in the updated GM2 SPA.HOFO.145 presented in this section.

— With regard to monitoring the risks of aircraft upset and the risk of excursion from the

touchdown and lift-off area: flight parameters that should be recorded on the FDR of helicopters

first issued with an individual CofA on or after 1 August 1999 in accordance with

AMC2 CAT.IDE.H.190 (such as pitch and roll attitude, airspeed, altitude, normal acceleration)

are sufficient to monitor some precursors of aircraft upset and of excursion. It is assumed that,

for those helicopters, the same flight parameters are collected by the airborne system used to

collect flight data for the FDM programme. Examples of such precursors that could be monitored

by the FDM programme are provided in the updated GM2 SPA.HOFO.145 presented in this

section.

However, it should be noted that, for some of the helicopters operated today, the necessary

flight parameters to monitor some of the risk areas listed in point (b) may be difficult to collect

without expensive changes to the airborne equipment. In addition, the information that these

flight parameters contain may be insufficient (for instance, the flight parameter may only be a

Boolean parameter or its sampling rate may be insufficient), which may significantly limit the

possibilities to programme effective FDM algorithms. The condition ‘to the extent possible with

the available flight data and without requiring overly complex algorithms’ is meant to take into

account this possible limitation.

— Regarding point (c):

• Any exceedance of a flight parameter value that indicates a potential immediate effect

on the airworthiness of the aircraft should be monitored by the FDM programme. This

includes, for example, exceedances related to:

o speed;

o altitude;

o accelerations;

o attitude angles;

o aircraft weight; and

o engine torque.

• Point (c) also includes the monitoring of caution and warning alerts to the flight crew,

when they indicate that the airworthiness of the aircraft may be affected.

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• However, for older helicopters, some of the necessary flight parameters might not be

recorded. Therefore, point (c) specifies ‘If the necessary flight parameters are collected by

the airborne system used to obtain flight data’.

• Using FDM for predictive maintenance or for usage monitoring is not in the scope of

point (c) because the purpose of an FDM programme is safety, not maintenance

efficiency. In addition, predictive maintenance and health and usage monitoring systems

often require dedicated airborne equipment and data and analysis techniques that are

different to those used for FDM.

— Regarding point (d): see the rationale for point (d) of AMC2 ORO.AOC.130.

GM1 SPA.HOFO.145 Flight data monitoring (FDM) programme

IMPLEMENTATION DEFINITION OF AN FDM PROGRAMME

Refer to GM1 ORO.AOC.130, except for the examples that are specific to aeroplane operation.

Flight data monitoring is defined in Annex I to this Regulation. It should be noted that the requirement

to establish an FDM programme is applicable to all individual aircraft in the scope of SPA.HOFO.145,

not to a subset selected by the operator.

(a) FDM analysis techniques

(1) Exceedance / FDM event detection

(i) FDM programmes are used for detecting exceedances, such as deviations from

rotorcraft flight manual limits, standard operating procedures (SOPs) or good

airmanship . It is advisable to monitor significant deviations from the SOPs in all

phases of flight, including when the aircraft is on the ground.

Examples of FDM events for helicopters: low or high pitch rotation rate on take-

off, high pitch attitude on landing, excessive roll attitude, low ground speed on

approach.

Examples of significant FDM events for helicopters: high rate of descent below

500 ft, high torque on take-off, terrain awareness warning system (TAWS) warning,

low airspeed on departure.

(ii) Trigger logic expressions may be simple exceedances such as redline values. The

majority, however, are composites that define a certain flight phase or

configuration. In addition, it might be valuable to define several levels of

exceedance severity (such as low, medium and high). While such levels of

exceedance can help identify the most relevant events and trends, they should not

be considered safety risk levels: assessing the safety risk level associated with an

exceedance or trend requires a more thorough assessment and considering all

relevant data available to the operator.

Example for helicopters: FDM software assigning different sets of rules dependent

on location or time of day. For example, being able to differentiate between day

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and night operations, whether take-off/approach was conducted to an airfield or

an offshore installation.

(iii) Exceedance detection provides useful information, which can complement that

provided in crew reports.

Examples for helicopters: engine failure(s), engine/gearbox overtorque, high/low

rotor speed, airborne collision avoidance system (ACAS), stabilisation

augmentation system (SAS) status and system malfunctions.

(iv) The operator may also modify the standard set of core events to account for

unique situations it regularly experiences, or the SOPs it uses.

Example for helicopters: arrival profiles for helicopter-specific landing areas.

(v) The operator may also define new events to address specific problem areas.

Example for helicopters: to monitor compliance with temporary operating

restrictions mandated by an airworthiness directive.

(vi) Being able to easily adjust the variables of FDM event algorithms can be

advantageous as it allows for an FDM event definition to be adapted to new

operational conditions.

(2) All-flight measurement / FDM measurements

FDM data is retained from all flights, not just the ones producing significant events. A

selection of parameters is retained that is sufficient to characterise each flight and enable

a comparative analysis of a wide range of operational variability. Emerging trends and

tendencies may be identified and monitored before the trigger levels associated with

exceedances are reached.

Examples of parameters monitored for helicopters: maximum torque during take-off,

pitch attitude and rotation rates during take-off, gear retraction and extension heights

and maximum speed with gear extended.

Examples of comparative analyses for helicopters: pitch attitude and rotation rates

achieved during night departures versus day departures.

(3) Statistics

Series of data are collected to support the analysis process: these usually include the

number of flights flown per aircraft and details sufficient to generate rate and trend

information.

(4) Investigation of incident flight data by the operator

Recorded flight data provides valuable information for follow-up to incident reports and

other technical reports. It is useful in adding to the impressions and information recalled

by the flight crew. It also provides an accurate indication of system status and

performance, which may help in determining cause and effect relationships.

Examples of incidents for which recorded data could be useful for helicopters:

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— unstable approaches (excessive ground speed, excessive rate of descent,

downwind approach, etc.),

— loss of control in flight (incorrect autopilot mode engaged, vortex ring state, etc.),

— exceedances of prescribed operating limitations (such as related to engine / main

gearbox torque, engine temperature, main rotor rpm, etc.),

— turbulence encounters or other events causing significant vertical accelerations.

It should be noted that recorded flight data have limitations. For example, not all the

information displayed to the flight crew is recorded, the source of recorded data may be

different from the source used by a flight instrument and the sampling rate or the

recording resolution of a parameter may be insufficient to capture accurate information.

(5) Continuing airworthiness

Data of all-flight measurements and exceedance detections can be utilised to assist the

continuing airworthiness function. For example, engine monitoring programmes look at

measures of engine performance to determine operating efficiency and predict

impending failures.

Examples of continuing airworthiness use for helicopters: avionics and other system

performance monitoring, gearbox overtorque, engine temperature exceedance.

(b) FDM equipment and software

(1) General

FDM programmes generally involve systems that capture flight data, transform the data

into an appropriate format for analysis, and generate reports and visualisation to assist

in assessing the data. Typically, the following is needed for effective FDM programmes:

(i) an on-board device to capture and record data on a wide range of in-flight

parameters;

(ii) a means to transfer the data recorded on board the aircraft to the ground;

(iii) software or a service to process and analyse the data, identify deviations from

expected performance, generate reports to assist in interpreting the read-outs,

etc.

(2) Airborne equipment

(i) Several technical solutions are available, including the following.

(A) Some systems are installed in the aircraft and record flight data onto a low-

cost removable medium.

(B) Some systems automatically transmit the recorded data via secure wireless

systems after completion of the flight.

is airborne. Whatever the flight data processing performed by such systems,

a complete set of raw flight data still needs to be recovered after the flight,

as this is needed for in-depth analysis of flight data by the FDM team.

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(3) FDM software or service

(i) Data is downloaded from the aircraft recording device and held securely to protect

this sensitive information.

(ii) The processing and analysis of flight data require specialised FDM software or a

specialised FDM service.

(iii) The FDM software or service typically converts the raw flight data into flight

parameters expressed in engineering units and textual interpretation (‘flight

parameter decoding’) and applies FDM algorithms on the flight parameters (refer

to points (a)(1) and (a)(2)).

(iv) The FDM software or service typically includes the following: capability to produce

parameter plots and parameter tables, capability to drill down and visualise flight

parameter values over the portion of the flight during which an event was

detected, access to interpretative material, links to other safety information and

statistical presentations.

(v) For the FDM software or service, the following additional capabilities are

advantageous.

(A) Capability to interface with advanced processing tools or to access advanced

functions libraries.

(B) Capability to link flight data with other data sources (such as occurrence

reports or weather data) in order to facilitate the analysis of events and

trends. This capability should be used in accordance with data protection

policies and procedures and its output restricted to authorised users (refer

to AMC1 ORO.AOC.130).

in a standard electronic format that is compatible with business intelligence

tools.

(D) Capability to export FDM outputs in formats compatible with geographical

information systems.

(E) Capability to replay flight data of a given flight in a flight animation, thereby

facilitating visualisation of actual events.

(F) Capability to design and provide individual FDM summary reports or

dashboards that can be confidentially consulted by flight crew members.

(G) Capability to export the information related to flight parameter decoding

into a flight format:

— that is compliant with an electronic documentation standard that has

a general public licence policy; and

— that includes means to retain the history of changes to the decoding

information.

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(1) FDM process

Typically, operators follow a closed-loop process in applying an FDM programme, for

example the following.

(i) Establish a baseline: initially, operators establish a baseline of operational

parameters against which changes can be detected and measured.

Examples for helicopters: rate of unstable approaches, rate of incorrect pitch rate /

pitch attitude at take-off.

(ii) Highlight unusual or potentially unsafe circumstances: the user determines when

non-standard, unusual or potentially unsafe circumstances occur; by comparing

them to the baseline margins of safety, the changes can be quantified.

Example for helicopters: increases in unstable approaches (or other unsafe events)

at particular locations.

(iii) Identify potentially unsafe trends: based on the frequency and severity of FDM

events, trends are identified. If a trend seems to point to an increase of risk to an

unacceptable level, a safety risk assessment is necessary, as part of the operator

safety risk management.

Example for helicopters: increases in unstable approaches at particular locations.

(iv) Monitor effectiveness of corrective actions, if the FDM programme is relevant for

that purpose: once a remedial action has been put in place in the framework of the

operator’s safety risk management, its effectiveness is monitored, confirming that

it has reduced the identified risk and that the risk has not been transferred

elsewhere. At this stage, the operator typically evaluates whether the FDM

programme can contribute to this monitoring.

Example for helicopters: confirm that the change has resulted in a reduction in

events and that no new additional events have been generated.

(2) Analysis and follow-up

(i) FDM data is typically processed at short intervals. The data is then reviewed

to identify specific exceedances and emerging undesirable trends and to

disseminate the information to flight crews.

(ii) If deviations from the standard operating procedures are detected and

require attention, the information on these deviations is passed (in

accordance with point (k) of AMC1 SPA.HOFO.145) to the person responsible

for flight crew contact. The decision to initiate flight crew contact (e.g.

notification, request for additional information or confidential discussion)

should be made after an initial assessment that takes into account contextual

information. If it is decided to have a confidential discussion with the flight

crew, the responsible person provides the necessary contact with the pilot in

order to clarify the circumstances, obtain feedback and give advice and

recommendations for appropriate action. Such action is determined after a

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thorough safety risk assessment that is performed in the framework of the

operator safety risk management and that takes into account all available

data. Appropriate action could include retraining (carried out in a

constructive and non-punitive way), revisions to manuals, or requesting

changes to ATC or airport operating procedures.

(iii) All events are usually archived in a way that means they can be sorted,

validated and presented in easy-to-understand management reports. Over

time, this archived data can provide a picture of emerging trends and hazards

that would otherwise go unnoticed. In addition, the FDM team may wish to

retain samples of de-identified full-flight data for various safety purposes

(detailed analysis, training, benchmarking, etc.).

(iv) Sharing of safety information is part of the necessary processes to maintain

personnel competent to perform their tasks and to support an effective

management system (refer to ORO.GEN.200). Therefore, lessons learnt from

the FDM programme may warrant inclusion in the operator’s safety

promotion programmes. Safety promotion may include newsletters, flight

safety magazines, emails, video messages, the provision of information on

the company’s intranet, highlighting examples in training and simulator

exercises. Care is required, however, to ensure that any information acquired

through FDM is de-identified before using it in any training or promotional

initiative.

(v) All successes and failures are recorded, comparing planned programme

objectives with expected results. This provides a basis for review of the FDM

programme and the foundation for future programme development.

(d) Preconditions for an effective FDM programme

(1) Protection of FDM data and of related flight crew reports

The integrity of FDM programmes rests upon protection of the FDM data. Any disclosure

for purposes other than safety management can compromise the voluntary provision of

safety data, thereby compromising flight safety. It is also advised to take into account

Regulation (EU) 2016/679 (general data protection regulation), where applicable. In

addition, the inherent protection of reporters under Regulation (EU) No 376/2014 applies

to flight crew members, whether their reports are spontaneously provided or

retrospectively requested by the operator.

(2) Essential trust

The trust established between management and flight crew is the foundation for a

successful FDM programme. This trust can be facilitated by:

(i) early participation of the flight crew representatives in the design, implementation

and operation of the FDM programme;

(ii) a formal agreement between management and flight crew, identifying the

procedures for the use and protection of data; and

(iii) data security, optimised by:

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(A) adhering to the agreement;

(B) the operator strictly limiting data access to selected individuals;

(D) ensuring that operational problems are promptly addressed by

management.

(3) Requisite safety culture

Indicators of a positive safety culture within an FDM programme typically include:

(i) top management’s demonstrated commitment to promoting a positive safety

culture;

(ii) a non-punitive operator policy that covers the FDM programme;

(iii) FDM programme management by dedicated staff under the authority of the safety

manager, with a high degree of specialisation and logistical support;

(iv) involvement of persons with appropriate expertise when assessing FDM events,

FDM measurements and trends (for example, pilots experienced on the aircraft

type being analysed);

(v) monitoring fleet trends aggregated from numerous operations, not focusing only

on specific events;

(vi) a well-structured system to protect the confidentiality of the data; and

(vii) inclusion of the general trends provided by and lessons learnt from the FDM

programme in the communications on safety matters specified in

AMC1 ORO.GEN.200(a)(4).

(4) Integration with the operator’s management system

SPA.HOFO.145 requires the integration of the FDM programme with the operator’s

management system. Because of that, FDM programme outputs are expected to be used

together with other relevant data sources and for supporting safety risk management

(SRM). The SRM process is not an internal process of the FDM programme, but a process

of the operator’s management system. AMC1 SPA.HOFO.145 specifies that the safety

manager should be responsible for the identification and the assessment of issues, which

are the first steps of the SRM process. The European Operators Flight Data Monitoring

forum document Breaking the Silos (June 2019) details industry good practice regarding

integration of the FDM programme with in the management system.

(5) Up-to-date flight parameter decoding documentation

(i) The flight parameter decoding documentation is the documentation containing

information sufficient for extracting flight parameter values from the recording

data files and decoding them into values expressed in engineering units or textually

interpreting them. This information is essential for programming flight parameter

decoding by FDM software.

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(ii) It is important that flight parameter decoding documentation is obtained at the

time of aircraft delivery and that it is kept up to date. To facilitate the management

of this documentation over time, it is recommended that this documentation is

compliant with an electronic documentation standard that has a general public

licence policy. In addition, it is advisable to have a versioning system that allows

for quick identification of the applicable decoding information for any individual

aircraft and any time period.

(iii) When the airborne equipment used for FDM purposes records a copy of the FDR

data stream, the FDR decoding documentation that must be retained in

accordance with CAT.GEN.MPA.195 could be used.

(e) Implementing an FDM programme

(1) General considerations

(i) Typically, the following steps are necessary to implement an FDM programme:

(A) implementation of a formal agreement between management and flight

crew;

(B) establishment and verification of operational and security procedures;

(D) selection and training of dedicated and experienced staff to operate the

programme; and

(E) commencement of data analysis and validation.

(ii) An operator with no FDM experience may need a year to achieve an operational

FDM programme. Another year may be necessary before any safety and cost

benefits appear. Improvements in the analysis software, or the use of outside

specialist service providers, may shorten these time frames.

(2) Aims and objectives of an FDM programme

(i) As with any project there is a need to define the direction and objectives of the

work. A phased approach is recommended so that the foundations are in place for

possible subsequent expansion into other areas. Using a building block approach

will allow expansion, diversification and evolution through experience.

Example: with a modular system, begin by looking at basic safety-related issues

only.

(ii) A staged set of objectives starting from the first week’s replay and moving through

early production reports into regular routine analysis will contribute to a sense of

achievement as milestones are met.

Examples of short-term, medium-term and long-term goals:

(A) Short-term goals:

— establish data download procedures, test FDM software;

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— verify, for all aircraft in the FDM programme, that the flight

parameters used for FDM events and measurements are valid and

correctly decoded;

— verify that the flight parameter decoding documentation (see

point (d)) is complete and correct;

— design and/or adapt FDM algorithms and test them, validate and

investigate exceedance detections; and

— establish a user-acceptable routine report format to highlight

individual exceedances and facilitate the acquisition of relevant

statistics.

(B) Medium-term goals:

— produce reports and dashboards that include key performance

indicators;

— add other modules to the analysis (e.g. continuing airworthiness); and

— plan for the next fleet to be added to the FDM programme.

— network FDM information across all of the operator’s safety

information systems; and

— ensure FDM provision for any proposed alternative training and

qualification programme (ATQP).

(ii) Initially, focusing on a few known areas of interest will help prove the system’s

effectiveness. In contrast to an undisciplined ‘scatter-gun’ approach, a focused

approach is more likely to gain early success.

Examples for helicopters: monitoring of onshore and offshore approaches, and

onshore and offshore take-off profiles. Analysis of such known problem areas may

generate useful information for the analysis of other areas.

(3) The FDM team

(i) Experience has shown that the ‘team’ necessary to run an FDM programme could

vary in size from one person for a small fleet, to a dedicated section for large fleets.

The descriptions below identify various functions to be fulfilled, not all of which

need a dedicated position. As the safety manager should be responsible for the

FDM programme, and FDM outputs should, to the extent possible, be analysed in

relation to other safety data sources, it is expected that the FDM team is part of

the safety manager’s team.

(A) Team leader: it is essential that the team leader earns the trust and full

support of both management and flight crew. The individual requires good

analytical, presentation and management skills.

(B) Flight operations interpreter: this person is usually a qualified pilot (or

perhaps a recently retired senior captain or instructor), who knows the

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operator’s route network and aircraft. This team member’s in-depth

knowledge of SOPs, aircraft handling characteristics, aerodromes and routes

is used to place the FDM data in a credible context.

technical aspects of the aircraft operation and is familiar with the power

plant, structures and systems departments’ requirements for information

and any other engineering monitoring programmes in use by the operator.

(D) Gatekeeper: this person provides the link between the fleet or training

managers and flight crew involved in events highlighted by FDM. The

position requires good people skills and a positive attitude towards safety

education. The person is typically a representative of the flight crew

association or an ‘honest broker’ and is the only person permitted to

connect the identifying data with the event. It is essential that this person

earns the trust of both management and flight crew.

(E) Engineering technical support: this person is usually an avionics specialist.

This team member is knowledgeable about FDM and the associated systems

needed to run the programme.

(F) FDM analyst: this person is responsible for the design and validation of FDM

algorithms and the analysis of FDM outputs. This usually requires at least

basic knowledge of statistics and/or programming skills, and in-depth

knowledge of the FDM software or service. If the processing of data or the

validation of FDM events is subcontracted to a service provider, the FDM

analyst should have the necessary skills to effectively control and direct the

work performed by that service provider.