need for rulemaking harmonization – supporting the future global air transport system easa/faa...
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Need for Rulemaking Harmonization – Supporting the Future
Global Air Transport System
EASA/FAA Annual Conference, St Petersburg, Florida, 4th June 2008
Vincent De VroeyGeneral Manager Technical & OperationsAssociation of European Airlines (AEA)
European Airlines’ View and a European Airlines’ View and a Perspective from IATAPerspective from IATA
Peter Sørensen Assistant Director
Safety, Operations & InfrastructureInternational Air Transport Association (IATA)
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Overview
AEA Harmonization Priorities
ATM
Maintenance
Operations
Flight crew training
IATA Perspective
Personnel licensing
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33 member airlines
11,115 flights a day
375,600 employees
605 destinations in 161 countries
346 million passengers
6 million tonnes of cargo
Total turnover of €75 billion
The Association of European Airlines
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AEA carriers are NETWORK carriers: global reach
Thanks to the networks and alliances which those carriers have set up, people can fly from anywhere, to anywhere
from Bucharest to Cleveland… from Reykjavik to Delhi…
from Ankara to Innsbruck…
from Berne to Riga…
from Edinburgh to Addis Ababa…
from Bordeaux to Kuala Lumpur…
185 intercontinental destinations in 116 countries 211 European destinations in 43 countries 800 destinations together with partner airlines!
Source: Continental Airlines
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AEA’s top priority: Europe's inefficient Air Traffic Management (ATM)
Europe does not have one single ATM system:It is patched together from old national systems… with segmentation into small, inefficient blocks
Between Member States – and between civil/military
… using a variety of different Air Traffic Control technologies
Fragmented airspace…
Circuitous routings and altitudes
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Background (1): European ATM is inefficient
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Background (2): US ATM system faces safety issues
TCAS RA’s AEA members flying to the USA have analyzed TCAS RA’s on
approach comparing major US airports with European major airports
The rate at some US airports (Newark, LAX, Denver, Philadelphia, SFO) is 100 times the rate at major European airports (LHR, CDG, SPL, FRA etc)
Compliance with ICAO Various serious safety incidents linked to the US ATM
environment with loss of separation or near collision. In light of the Ueberlingen accident, all TCAS RA’s have to be complied with (ICAO), a modus operandi which is not fully understood in the USA
US ATM safety issues need to be tackled with urgency
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ATM: implications for rulemaking
Root of ATM problems in Europe, USA and other areas of the world might not be the same
However, where it implies rulemaking to mandate for capacity or safety reasons, new systems on the aircraft (avionics) or operational procedures, the AEA members expect: Identical technical solutions for similar ATM problems Harmonized approach on ATM operational procedures Globally valid operational & airworthiness approval for
airlines/aircraft (ia datalink, ADS-B, RVSM etc) with approvals issued by the local Authority based on globally harmonized requirements
Global interoperability in ATM solutions and approvals is essential for globally operating airlines (= cost issue!)
Harmonized operational procedures are essential for safety
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Maintenance: mutual recognition rather than full harmonization of rules
Globally recognized Part-145 approvals Airline MROs expect globally recognized Part-145 approvals
which recognize equivalent safety oversight and reduce the number of unnecessary audits or certificates
Harmonization / Recognition Full harmonization of the relevant rules is not realistic because
of the cost implications or different legal environment (f.e. drug and alcohol testing is illegal in Europe, required in the USA)
Mutual recognition of each other system (based on equivalent safety) might be more realistic (i.e. through BASA) than full harmonization
This should not prevent new rules to be harmonized where possible and beneficial to the industry
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Operations: harmonizing existing rules would be extremely costly
Mutual Recognition of AOCs Global Airlines expect mutual recognition of AOCs rather than the
current proliferation of Part 129 requirements which create unnecessary bureaucracy for no added safety value
Harmonization / Recognition Full harmonization of existing operational rules for AOC holders
(EU-OPS, Part 121) is not needed from the airlines point of view since it would be extremely costly due to the legacy and different legal systems and cultural environment
Operational equipment related requirements for newly build aircraft should be harmonized wherever possible (e.g. FDR/CVR, TCAS etc).
AWO requirements to be harmonized as well New rules to be harmonized where possible and where there is a
value for the airlines
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Flight Crew Training
Separate business The Flight Crew Training business is increasingly becoming a
separate business competing in the global market
International trade Some current rules (FAA) or rulemaking proposals (EASA) are a
barrier to international trade For safety and efficiency reasons, European airlines need access to
flight crew training resources around the world i.a in Europe, USA and elsewhere
Harmonization / Recognition Different authorities to recognize each other systems’ without
imposing additional restrictions or duplicate requirements for personnel licensing or approvals (flight simulators)
The planned BASAs are an opportunity to solve this problem
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Conclusion
ATM rules: new systems on the aircraft (avionics) or operational procedures should be harmonized with globally valid approvals (= cost and safety issue),
Maintenance rules: need mutual recognition of the relevant approvals allowing international trade without barriers and reducing unnecessary audits,
Operational rules for AOC holders: no need for full harmonization which would be costly and might not be feasible (different cultures etc). Need for mutual recognition of AOCs rather than proliferation of Part 129,
Flight Crew Training rules: BASA’s should remove current restrictions to international trade
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The challenge of licensedThe challenge of licensedpersonnel shortagespersonnel shortages
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Why Harmonization is Critical for Personnel Licensing
The aviation industry has realized that there will be a global shortage of engineers, licensed mechanics as well as pilots e.g. an estimated shortage of 3.600 pilots annually
The aviation industry estimate a fleet growth of 17650 aircraft by 2018
In times of high training demand, training quality is at stake and consequently negative impact on flight safety
Variations in training standards worldwide add to the problem Quality level of key personnel must be maintained Risks for delayed aircraft introductions and missed opportunities
for growth and ROE
.
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Industry’s Initiative – IATA Training and Qualification Initiative (ITQI)
IATA’s initiative to
1) review the airline industry training needs for licensed personnel (pilots, mechanics / engineers) and
2) develop recommendations for meeting these needs with no compromise to safety and quality.
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ITQI Deliverables
F lig h t O p era tion d e live ra b les E n g in e erin g a nd M a in ten a nce d e live rab les
C o m m o n de live ra b les
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KEY DELIVERABLE:
Problem / ImpactAnalysis
Consultant
Staff Selection &Assessment
Criteria
KEY DELIVERABLES:
ConsultantKEY DELIVERABLES:
ICAO
QualificationRequirements
KEY DELIVERABLES:
Boeing
TrainingDevices & Syllabi
Cert. Standard for TrainingProviders
Deliverables20
08
200
920
10
Achieve ICAO ANC approval
Complete guidance material & working paper for ICAO
Develop audit scheme
Complete gap analysis of existing requirements / regulations
KEY DELIVERABLES:
Complete gap analysis of certification standards
Complete development of certification standards
Complete gap analysis of selection criteria
Complete development of selection criteria / best practices guide
Implement regionally
Complete gap analysis of training devices
Complete first draft of best practices and guidance material
Complete development of guidance material & implem. concept
Conduct market survey
Element B1 Element B4 Element B2 Element B3
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Member airline survey to verify actual challenges
Draft working paper for simulator standards
Implementation plan for Multi-Crew Pilot Licensing (MPL)
Action plan for harmonization of Flight Crew Licenses
Achievements
Safety impact analysis
Government awareness program
Gap Analysis of current global and national regulations
Draft industry standard for Flight Training Devices
Best practice and guidance material for training concepts
Next Steps
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Implementation support & audit scheme
Update relevant requirements
Regulatory acceptance
Final ITQI outcome and spin-offs
IATA Training and Qualification best industry practice manual
Project phases
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Summary
Regulators will be key to implementation of ITQI A global and collaborative initiative to mitigate the threats inherent to the
global shortage of licensed personnel. Secured resources and buy-in from all segments of the aviation industry,
to ensure SAFETY to create awareness among the industry, governments and
regulators to develop global standards and harmonization needs to work on solutions to develop the New Generation Aviation Professionals
Open for all industry stakeholders
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Industry Stakeholders
ICAO, FSF, IFALPA, EASA, Transport Canada, CASA, NCAA, ATA,
JAL, CAL, EVA, SIA, MES, SAS, LH, ANA, Delta, IB, Fedex, AF, SAA, KLM, Qantas,
Airbus, Boeing, ATR, Embraer, Bombardier
LFT, LTT, CAE, Alteon, FSEMC MSI, Thales