Consolidated Summary of Comments / Responses received ... · Consolidated Summary of Comments /...

Notice of Final Rule Making Extended Diversion Time

Operations (EDTO)

Page A1 Document NFRM 0608OS

Annex A

Consolidated Summary of Comments / Responses received, CASA’s Response and Disposition Actions to

NPRM 0608OS


Operations (EDTO)


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Operations (EDTO)


Comments relating to the proposed amendments to Civil Aviation Order (CAO) 82.0 –

Extended Diversion Time Operations (EDTO) (Issued under the Notice of Proposed Rule Making (NPRM)

0608OS)

How comments have been administered Where comments are the same, or substantially similar, they have been amalgamated into a single response. Where comments stand alone in terms of content, they have been incorporated into this document verbatim. Where comments have an obvious action that can be applied to them, the actions have been documented in the response and disposition. Some comments state an opinion which by its nature is difficult to incorporate into meaningful change to the proposed regulation. Where this is the case, CASA has noted the comments. Some comments have been edited for readability and presentation purposes.

The following comments substantially reflect the consultation process. Numbering of the regulatory provisions reflects numbering as presented in the NPRM.

COMMENT 1 – GENERAL

We request that CASA harmonise its regulations with other aviation regulatory authorities as much as possible.

EXPLANATION: Harmonization of regulatory standards not only benefits the aviation industry economically, but also increases efficiency and maintains the necessary high level of safety.

CASA Response

CASA notes the support for harmonisation. The proposed rule suite is harmonised, as much as possible, with latest international practice. It is also consistent with the extended diversion time concept, as presented at the seventh meeting of the International Civil Aviation Organisation (ICAO) Operations Panel held in Montreal, in May 2006.

Disposition No action required.


Operations (EDTO)



The proposed legislation appears to be based on the new global and ICAO concepts on extended range operations but still appears excessively complex. It is still considered some limitations are more complex than they need to be. There will undoubtedly be added costs to the industry to comply with the added requirements to demonstrate compliance. Our review has not examined or compared the CASA proposal with the global scene although CASA and the New Zealand Civil Aviation Authority (NZCAA) have collaborated on the outcomes. Also no comment is made in this response with regard to operations and airfield sections of the NPRM or the Advisory Circular (AC).

We accept limitations of EDTO for twin engined piston aircraft, but for modern turbine powered twin engined CASR 121 aircraft, there probably only needs to be only two EDTO ratings – flights less than or greater than 90 minutes from a suitable airport and other flights of lesser duration (i.e. The limitations in 121.0244 para (4)).

‘GRAND FATHER’ clauses relating to current ETOPS aircraft must have provision for approved extension beyond 10 years. Current approval, use of delegations/instruments must be transitioned. The new legislation must be realistically based like other foreign legislation and not have unnecessary criminal provisions. Inclusion of criminal references are contrary to the safety culture of the industry and may inhibit honest reporting. By moving towards outcome based legislation and plain English the criminal issues should be able to be deleted or at least be realistic.

CASA Response

CASA notes the comments.

Disposition Specific comments are dealt with under the related rule, later in this document.


Change: In principle, the threshold time remains "60 minutes" for twins.

Explanation: We understand that the threshold time increased to 90 minutes (or the a/c EDTO type design capability if lower than 90 minutes) is an operational exemption to the basic 60 minutes threshold value when certain conditions are met both by the manufacturers (EDTO type design approval) and by the operators (application of CMP standards and EDTO provision on maintenance of parallel system). When all these conditions are not met, the threshold time remains at 60 minutes.

The same principle applies to the "old twins" not EDTO approved but grand-fathered to 75 minutes operations under certain conditions


Operations (EDTO)


CASA Response

CASA disagrees. Provided the required conditions are met under the proposed rules, an operator may conduct a non-EDTO flight to the 90 minute threshold without an approval or an exemption. This is consistent with the proposed amendments to ICAO Annex 6, Part 1, allowing the State of an operator to extend the threshold time for turbine aeroplanes with two engines to a maximum of 90 minutes.



The Australia and International Pilots Association (AIPA) is the professional Association representing pilots employed by the Qantas Group in airline operations within Australia and around the world. AIPA represents over 2,300 members and is the largest professional pilot body in Australia.

As a key stakeholder, AIPA would like to thank the Civil Aviation Safety Authority (CASA) for the opportunity to comment on the Extended Diversion Time Operations (EDTO) Proposed Subpart 121.W of the Civil Aviation Safety Regulations 1998 (CASR).

AIPA whilst supporting the continued improvements in the regulatory framework covering commercial airline operations holds concerns over some of the proposed changes to the Extended Twin-Engine Operations (ETOPS) rules and proposed new limits in relation to EDTO.

These concerns include:

• Increasing the extended diversion operations threshold time for twin-engined turbine aeroplanes from 60 minutes to 90 minutes when certain conditions are met;

• Introduction of additional extended diversion time approval steps beyond 180 minutes and beyond 240 minutes;

• Previous extended diversion operations experience requirements amended to harmonise with the new approval steps;

• Introduction of 180 minute threshold time for all turbine aeroplanes with more than two engines, except where they operated prior to the commencement of the new EDTO rule set (see draft CASR 121.0244);

The other key proposed changes are acceptable to AIPA in principle, and will be subject to review once the final proposals are issued.

AIPA is concerned with any reduction of required ETOPS experience, particularly in conjunction with extending threshold and diversion operating times for EDTO aircraft and new entrant airlines. Additionally the current B767-300, A330-200 and A330-300 series aircraft whilst ETOPS approved to 180 minutes, do not qualify under the manufacturers specification to extend to 240 minutes.


Operations (EDTO)


There are a number of Minimum Equipment List (MEL) restrictions in the B767-300 and A330-200/300 fleet Master Minimum Equipment List (MMEL) which permit the aircraft to fly Extended Range (ER) however, the concern from AIPA's perspective is that it could raise the levels of risk to the flight in the event that associated systems fail or become degraded. A normal risk assessment can only be done with the regulatory authority and the manufacturer for ETOPS/EDTO in producing the MMEL.

Other related issues such as accelerated ETOPS/EDTO training for flight crew and human factors in relation to operating crews physical condition and/or possible limitations have a profound effect on conditions that would affect the acceptable levels of risk.

Moreover, passengers are also at risk if in-flight emergencies resulting from passenger illness or even worse an act of terrorism should occur. It would also place an unacceptable burden on the operating crew if conditions exist where there are technical limitations on the aircraft such as an engine out, auto-pilot inoperative and bleed air restrictions due to valve lockout; this would increase that level of risk further.

Under adverse conditions, the risk effects can have a significant role to play on the levels of stress on operating crew members. Furthermore, exposure to these conditions coupled with a low level of EDTO/ETOPS experience and accelerated training would place an unacceptable level of risk on the crew and passengers.

In reviewing the International Civil Aviation Organisation (ICAO) Report No. OPSP/7- WP/20, the document states, "the ANC determined that the proposals were not sufficiently mature and directed the OPSP Working Group, to continue work on this item." This work had progressed from and through the Extended Range Sub-Group of the Operational Working Group, culminating in recommendations made during the OPSP Working Group (OPSP WG-WHU6) in October 2005.

A summary of some of these key conclusions which address the concerns held by AIPA include:

• Ref: "1.1.2: On long range operations of aeroplanes with more than two engines, there is a risk of insufficient fuel to return to the point of origin or continue onto a destination if there is a decompression in cruise flight, requiring the aircraft to operate at a lower altitude." (Probability of a decompression is in the order of one in a million.)

Under certain conditions where an MEL item has been applied, system limitations could have an adverse effect on the flight due to the degraded mode of operation.

• Ref: "1.1.3: This section of the review pertained to flying in cold regions, primarily Polar areas, where 180 minutes diversion times in the summer months are achievable but not in the winter months. Whilst cold weather conditions are unlikely in this area, there are certain areas of where under particular seasonal climatic conditions; 180 minute diversion times might not be suitable."


Operations (EDTO)


• Ref: "1.1.4: There are modifications to the cargo fire suppression capability required for some aeroplanes; these would need to be assessed on an aircraft by aircraft basis. "It was noted that the cost of upgrading a B-747- 400 beyond the current level of 195 minutes of suppression capability was approximately U. S. $77,000.00."

In the ICAO Proposed Amendments of OPSP/7-WP/20, the following items were flagged as concerns:

• 1.2.1.2.2: "While the frequency of long-range operations is increasing, the aviation infrastructure to support these operations in remote areas of the world is decreasing". "This has been primarily due to long-standing diversion airports in various parts of the world are declining due to budgetary constraints."

• 1.2.1.2.5: "A concern was expressed that the clarity of the proposed changes in SARPS, and guidance material was not specific enough, which could lead to confusion and possible misapplication of the requirements". This comment was made in specific regard to the introduction of ETOPS criteria for maintenance during Extended Diversion Time Operations."

These items are also of concern for AIPA as they are issues that have very little probability of being addressed in future operations.

In addition to the above, and as previously stated, the application of certain MEL restrictions and the possibility of subsequent systems degradation would tend to exacerbate the otherwise acceptable levels of risk. Some of these MEL restrictions include the following:

Boeing B767-300 MEL/Dispatch Deviation Guide

• Ref: 22-10-1 Autopilot Systems (3 installed); with conditions one may be inoperative.

• Ref: 22-11-13 Mode Control Panel Selector; items 1 through to 3a may be inoperative.

• Ref: 22-11-4 Mode Control Panel Switches; items 1 through 9 may be inoperative with restrictions.

• Ref: 22-11-5 Mode Control Panel Windows; items 1 through 3 may be inoperative with restrictions.

• Ref: 22-21-1 Yaw Dampers (2 installed); one may be inoperative.

• Ref: 22-41-1 Maintenance Control Display Panel System; may be inoperative.

• Ref: 36-11-8a Engine Pressure Regulating Valves (PRV); m Except for ER operations beyond 120 minutes, one may be inoperative secured CLOSE provided: provide items a through i (1, 2) are complied with.

• Ref: 36-12-1 Precoolers; except for ER Operations beyond 120 minutes, the aircraft may be dispatched with damage to one precooler and associated ducting between the PRV and Pressure Regulating Shutoff Valve provided, items a through j (1,2) are complied with.


Operations (EDTO)


• Ref: 36-12-2 Fan Air (Precooler); Except for ER operations beyond 120 minutes, one or both may be inoperative provided, items a and b are complied with.

Airbus A330-200 and A330-300

• Ref: 02-22-10-01 Autopilot (2 installed); one may be inoperative for ER operations.

• Ref: 02-22-10-02 Flight Director (2 installed); one may be inoperative.

• Ref: 02-22-72-03 navaids Selection and Tuning (2 installed); one may be inoperative.

• Ref: 02-22-73-01 Performance Information and Vertical Navigation; on or both may be inoperative.

• Ref: 02-22-81-01 Auto Flight Control Panel; ltems A, B, C, E, F, G, H may be inoperative.

• Ref: 02-22-82-10 Multipurpose Control and Display Unit items A, B, C may have varying states of inoperative condition.

• Ref: Flight Management Guidance and Envelope Computer (2 installed); one may be inoperative with restrictions.

• Ref: 02-22-83-02 FMA Indications on PFD; ltems A, B, C, D may be inoperative with restrictions.

• Ref: Bleed Air Supply System (2 installed); one may be inoperative for ER operations (with restriction).

These are representative of only two types of aircraft, and the items selected are but a few of a large number of MMEL items. However, these items do have the potential to increase the level of risk in the cockpit workload.

An essential criterion for ER operations is a higher than usual level of reliability performance and AlPA are of the view that with some of the allowable MMEL items, this level of reliability can be compromised. ICAO has addressed these concerns in its report as follows:

• Ref: "ICAO OPSP/7-WP/20 Appendix A to the report on Agenda Item 7. No: 5, Airworthiness modifications and maintenance programme requirements...item (0; a procedure is established to ensure that the airborne equipment will continue to be maintained at the level of performance and reliability required for extended diversion time operations."

• Ref: "ICAO OPSP/7-WP/20 Appendix A to the report on Agenda ltem I. No: 6, Flight dispatch requirements...item (a) pre-flight system serviceability including the status of items in minimum equipment list."


Operations (EDTO)


Whilst AIPA concurs that EDTO may provide a commercial benefit to airlines, it also notes that ICAO has placed restrictions on threshold time. Item 1.2 Threshold Time, designated area, and applicability, Para. 1.2.1; "...Taking into account the level of safety intended by Chapter 4, 4.7.2, it is suggested that the threshold time be 60 minutes for aeroplanes with two engines, and 180 minutes for aeroplanes with more than two engines. However, based on compensating factors such as number of airports in the region, weather conditions normally prevalent in the area, availability of communication, safe and reliable operations with the airframe and engine combination, the suggested threshold time for aeroplanes with two engines may be extended by the State of Operator to 90 minutes."

An additional concern that has been flagged by our members involves a Qantas Flight Operations Flight Standing Order No. 80106, dated 27 July 2006:

All Aircraft ... Refuelling Discrepancies - Revision

Under the "Established fuel on board and cross check": Qantas have increased the allowable fuel quantity discrepancies, as follows:

• B744 ± 2000kg

• B743 ± 3000kg

• B767 ± 1000kg

• B737 ± 600kg

• A330 ± 1000kg

This in effect, when the percentage variation is concerned, can have a significant effect on the actual fuel remaining prior to arrival. In an extreme-case, the aircraft would not only be below landing minima, but could well run its tanks dry, obviously not a desirable situation for an EDTO flight.

This is of major concern to AlPA members, as a Fuel Quantity Indication System with an unknown discrepancy could well result in a flight, especially an EDTO flight, where there is insufficient fuel boarded.

CASA Response

CASA notes the support from the AIPA relating to the continued development and improvement of aviation legislation, and the concerns raised by the AIPA over the proposed EDTO rule suite. In support of those concerns the AIPA has quoted from a report on EDTO (OPSP/7-WP/20) as presented at the ICAO Operations Panel (OPSP), seventh meeting (OPSP 7), Montreal in May 2006. As CASA understands it, the issues raised in that report provide a background explaining that the Air Navigation Council (ANC) had concerns in relation to the OPSP’s earlier work (OPSP 6) on EDTO, which was first considered in 2003. Subsequently, the ANC determined that it was not sufficiently mature and directed that the OPSP continue work. However, CASA also understands that after further development, the Air Navigation Commission's (ANCs) concerns with the recommendations of OPSP 6 were addressed in the new proposal presented in OPSP 7.


Operations (EDTO)


That proposal was considered mature and, consequently, the recommended amendments to Annex 6, Part 1 and consequential amendments were forwarded to the ANC for consideration. CASA’s proposed rule suite is not inconsistent with the recommended amendments to Annex 6, Part 1.

Disposition Specific comments are dealt with under the related rule, later in this document.


I find the rules changes not consistent. They appear to be saying that twin engine operations are safer than four engines.

I do not agree with the so called accountable areas, everything outside of these areas are not counted. I think that the manufacturers are trying to justify the ever increasing use of twin-engine aircraft on great stretches of water.

Shutting down important aerodromes, which could be used to avoid a ditching, will be cold comfort for those who end up in a cold sea.

CASA Response

CASA notes the author’s concerns, but the comment is not clear; the threshold time for twins is 90 minutes whereas that for three or four engine aeroplanes is 180 minutes. It is not correct to say “…everything outside of these areas are not counted...” since EDTO criteria will still apply to relevant routes in all areas.

Disposition No further action.

COMMENT 6 – DEFINITIONS

Adequate Airport (2) If the adequate airport is CAVOK and the only instrument approach becomes unserviceable can the airport still be used for a visual approach? Very limiting as it stands.

CASA Response

CASA disagrees, the requirement is no more limiting than the current ETOPS requirement at CAO 82.0 Appendix 2, paragraph 1.9, and accords with latest international EDTO proposals.



Operations (EDTO)



ADQ airports requirements - more strongly mandates that an instrument approach be available. What if the VOR is US and the weather is CAVOK, can we not use it?

CASA Response

CASA disagrees, see response to Comment 6.


COMMENT 8 - DEFINITIONS

Extended diversion time operation (EDTO). This should read "...from a point on the route to an adequate aerodrome, is no greater than the threshold time”.

CASA Response

CASA disagrees, the suggested change would in effect render the definition for EDTO meaningless.

Disposition No further action required.

COMMENT 9 - DEFINITIONS

Extended diversion time entry point. This should read "...where the relevant threshold time is not exceeded”.

CASA Response

CASA disagrees, the suggested change would in effect render the definition for extended diversion time entry point meaningless.


COMMENT 10 – ROUTE DISTANCE LIMITATIONS

Change: "(a) the aeroplane is configured, maintained and operated in accordance with the relevant Configuration Maintenance and Procedures Standards (CMP) document for the applicable diversion time;"

Explanation: Wording change proposal to be consistent with the CMP content. All the CMP requirements may not be applicable as some may only be mandatory for a higher diversion time.

CASA Response

CASA agrees.


Operations (EDTO)


Disposition The draft rule will be changed to give effect to the intent of the comment.

COMMENT 11 - ROUTE DISTANCE LIMITATIONS

Change: 121.0244(6)(c)?) "any other conditions specified by CASA are complied with (see subregulation 121.6130 (3))."

Explanation: In addition to the 121.6130 (3) demonstration (human factor), does it imply review of all other time limited systems and functions, as well as SSA, MMEL, maintenance program?

CASA Response

The rule is intended to encompass any condition that CASA may consider necessary to be included in the interests of safety. See also Comment 46.



Change: An operator must not operate an aeroplane with more than two turbine engines on a route containing a point more than 180 minutes from an adequate aerodrome at the one-engine inoperative cruise speed (in still air and ISA conditions) unless the aeroplane is operated in accordance with an EDTO approval under CASR 121.0245.

CASA Response

CASA agrees, a sunset clause would better support fair competition and add to safety by not encouraging retention of older aeroplanes, as well as giving operators time to adapt to the new EDTO requirements.

Disposition The draft rules will be changed to give effect to the intent of the comment.


Change: Replace the grand father clause as currently worded by a series of grace periods graduated with the cost and complexity of each step of compliances.

Explanation: We consider that as written, this grand father rule for the operations of tris and quads:

• create unfair commercial distortion between existing operators and new operators having not yet traffic rights on given routes. This type of situation has existed at the introduction of ETOPS and was successfully challenged by the new entrance operators. This is all the more true if the new operations is opened with a state of the art modern four engined aircraft having an enhanced operational safety level by design.


Operations (EDTO)


• encourage continuation of the operations with older technology products that do not incorporate the safety features contemplated by the EDTO type design chapter of the certification rule. The safety improvement intended by the EDTO type design provisions will therefore be discouraged: operators of state of the art products validated by the EDTO type design provisions will have to apply the additional operational and maintenance provisions of the new rules and will therefore bear undue penalties vs. operators of older equipments that do not incorporate the safety features of the EDTO type design rules.

We respectfully suggest CASA:

• take into consideration the operational safety research launched by some major aviation authorities before applying new requirements on the operations of three and four engine aircraft.

• rework the grand father clause as currently worded by a series of grace periods graduated with the cost and complexity of each step of compliances (e.g. Certification exercise, Modification retrofit, Documentary change, Training, Modification of Maintenance & Dispatch procedures and tools)

• apply equally these principles on all three and four engined aircraft manufacturers and operators for the sake of a fair commercial approach.

This would be consistent with the principles adopted by JAA/EASA in its draft LROPS A-NPA OPS 40B or by FAA.

CASA Response

CASA agrees, a sunset clause would better support fair competition and add to safety by not encouraging retention of older aeroplanes, as well as giving operators time to adapt to the new EDTO requirements.



Para 5 of 121.244 should be changed to read "...design requirement to operate no more than 90 minutes from an adequate aerodrome...". Also "... a route containing a point not more than 90 minutes from an adequate aerodrome...".

CASA Response

CASA disagrees, see previous responses to Comments 8 and 9.



Operations (EDTO)



Extended Diversion Time Operation Qualified Personnel means maintenance personnel that have completed the operator’s EDTO maintenance training.

Require detail as to the definition of Qualified Personnel.

CASA Response

CASA disagrees, a member of the flight-crew may also be an EDTO qualified maintenance person.



Comment: Change “EDTO Significant System” to “EDTO Maintenance Significant System” throughout the regulation and the AC material.

EDTO Significant System means the aeroplane propulsion system and any other aeroplane system whose failure could adversely affect the safety of an EDTO flight, or whose functioning is important to continued safe flight and landing during a diversion.

EDTO Maintenance Significant System:

(1) A system for which the redundancy characteristics are directly linked to the number of engines; or

(2) A system that may affect the proper functioning of the engines to the extent that it could result in an in-flight shutdown or uncommanded loss of thrust; or

(3) A system that contributes significantly to the safety of a diversion.

Explanation: The current definition in 121.6105 for “EDTO Significant System” is comprehensive and is used in the original Type Design Approval of the airframe engine. This definition is consistent with FAA’s Aviation Rulemaking Advisory Committee (ARAC) recommendation and the FAA NPRM re: Part 1.1.

However, for the airlines, a subset of this ETOPS /EDTO significant system that directly affects the engines, and systems that directly affect safety of diversion, is used. To differentiate the significant systems used for Type Design versus airline maintenance, ARAC and the FAA in its NPRM relative to 121.7 established the “ETOPS Maintenance Significant System.”


Operations (EDTO)


CASA Response

CASA disagrees. The proposed definition of “EDTO Maintenance Significant System” basically refers to systems linked to the number or functioning of the engines. Whereas, other systems also contribute significantly to the safety of a diversion. Moreover, the proposed “(3) A system that contributes significantly to the safety of a diversion” is a catch all phrase anyway. We believe, introduction of term “EDTO Maintenance Significant System” will cause unnecessary confusion.



In-Flight Shutdown (IFSD) means when an engine ceases to function normally in-flight for any reason or and is shutdown, whether self induced, crew initiated or caused by some other external influence which includes but is not limited to flameout, internal failure, foreign object ingestion, icing, or the inability to obtain and or control thrust.

Explanation: There are many reasons and ways engines cease to function normally, but are not shut down. Increased vibration or temperature or oil consumption or lack of automatic control – if all these were to be counted as IFSDs, the rate would be significantly higher than today’s rates and would require a different criterion to determine EDTO suitability. The industry standard limits IFSD to cases where the flame is out and/or the engine stops turning.

CASA Response

CASA disagrees. The purpose of words “normally” and “or” in the definition of IFSD is to capture all reasons and causes including increased vibration, temperature or oil consumption etcetera.



Time limited system means any system, the failure of which will adversely affect the duration of the available flight time whose capacity has some limit and therefore should be considered in determining the duration of an EDTO diversion, e.g. cargo fire suppression.

Explanation: The proposed definition ties the time limit to a failure of the system itself. The intent of defining time-limited systems is to identify the airplane’s maximum time capability in various EDTO diversion scenarios. The system capability (e.g., cargo fire suppression) may have nothing to do with the failure conditions that need to be considered (e.g., a cargo fire is not a failure of the cargo fire suppression system). This proposed definition is consistent with 121.6125.

CASA Response

CASA agrees.


Operations (EDTO)


Disposition The draft definition will be changed to give effect to the intent of the comment.


Comment: We suggest the following change to this definition: Extended Diversion Time Operation Qualified Maintenance Personnel means maintenance personnel that have completed the operator’s EDTO maintenance training.

Explanation: Since the definition clearly refers to maintenance personnel, we request the change in terminology. Further, this is consistent with the FAA approach in its NPRM.

CASA Response

CASA agrees.

Disposition The draft definition will be changed to give effect to the comment.


EDTO Multiple Identical System Maintenance means:

(1) For turbine engine powered aeroplanes with two or more engines – a maintenance action performed on the same element of identical but separate EDTO significant systems during the same routine or non-routine maintenance actions.

(2) For turbine engine powered aeroplanes with more than two engines – a maintenance action performed on the same element of identical but separate EDTO significant systems on two engines of a three-engined aeroplane, or more than one engine per side of a four-engined aeroplane during the same routine or non-routine maintenance actions.

Comment: Modify (1) and Delete (2) above to simplify.

The principles of identical system maintenance are not just associated with EDTO (or previously ETOPS) but should be standard practice for all critical system maintenance. Processes must be put in place to cover persons covering identical systems.

CASA Response

The Federal Aviation Administration (FAA) in reviewing comment received on its ETOPs NPRM, has decided not to apply ETOPs - specific maintenance requirements to three or four engine aeroplanes and CASA has decided, in concert with the NZCAA, to follow suit. The comment is therefore no longer relevant.

Disposition The definition will be reworded to reflect the CASA response.


Operations (EDTO)



Change: "Configuration Maintenance and Procedures Standards (CMP) document — in relation to EDTO means an approved document specifying the minimum requirements for the aeroplane configuration including any special inspection, hardware life limits, flight crew procedures, Master Minimum Equipment List constraints and maintenance practices found necessary by the certification authority to establish the suitability of an airframe/engine combination for EDTO."

Explanation: The CMP also includes EDTO specific flight crew procedure also found in the ETOPS supplement of the Flight Manual.

CASA Response CASA agrees.

Disposition The draft definition will be changed to give effect to the comment.


Change: "Performance Deterioration Allowance (PDA) means the difference between the aeroplane manufacturer’s published fuel consumption model and the actual fuel consumption applicable to a specific aeroplane.

Explanation: The performance factor is the difference between the airplane in-flight performance model produced and delivered by the manufacturer and the actual fuel consumption figures of a given aircraft based on a series of aircraft (weight, speeds, power settings, Bleeds, Fuel quality…) and flight (altitude, temperature...) conditions.




Change: Time limited system means any system that ceases to function or the failure of which will adversely affect the duration of the available flight time.

Explanation: Time limited includes systems:

(1) that ceases to function after a certain time because of the exhaustion of their main component (e.g. Oxygen, cargo fire suppression agent…)

(2) that may fail after a certain time.

CASA Response CASA agrees, refer to Comment 18.



Operations (EDTO)



Comment: We suggest the following changes in this section:

121.6110 General

(1) The operator must ensure that EDTO do not commence unless:

(a) The operations specification of the air operator certificate permits EDTO; and

(b) Procedures for EDTO meeting the requirements of this subpart are specified in the certificate holder’s operations manual; and

(c) The applicable meteorological planning requirements of this subpart are met at the time of aeroplane dispatch; and

(d) The aeroplane meets the requirements of the CMP document for an EDTO flight.

(2) A pilot in command performing an EDTO must ensure that, before the aeroplane reaches the extended diversion time entry point, each required aerodrome nominated as an EDTO alternate aerodrome is forecast to be at or above the approved aerodrome landing minima for the expected approach during the possible period of use; and

(3) Prior to proceeding beyond the EDTO entry point, any in-flight operational requirements defined in the CMP document must be completed.

Explanation: Add CMP in a new sub-paragraph 1(d) for further clarification, and clarify paragraph (3).

The airframe engine combination must comply with the CMP standard prior to dispatch.

As indicated in the suggested revision, paragraph (3) would address any unique ETOPS in-flight operational requirements, such as starting the APU before entering the EDTO phase of flight.

CASA Response

CASA agrees that this would clarify the intent of paragraph (3).



Operations (EDTO)



Change: Remove "(3) Prior to proceeding beyond the extended range entry point, the aeroplane meets the requirements of the CMP document for an EDTO flight.

Explanation: We do not concur with this approach. The CMP is not a document to be used in flight. As for the MEL, once dispatched, the flight crew should refer only to the applicable approved procedures as given by the A/C monitoring and warning systems (ECAM/FWC) and/or listed in the relevant documents (QRH, AFM, FCOM, CMP). Unless the timeframe of applicability of the procedure is specifically described, these procedures are applicable throughout the EDTO mission i.e. before, within and after the EDTO sectors. If such check on EDTO sensitive systems is requested by the certification authorities for the EDTO approval of an aircraft or for its continued airworthiness, then it would be added in the CMP procedure standards.

CASA Response

CASA disagrees, but concurs with Comment 24, which will be amended accordingly as previously stated.

Disposition No additional action required.

COMMENT 26 – APPLICATION FOR EDTO APPROVAL

Comment: We suggest that subparagraph (2)(a) be revised as follows:

(a) The particular airframe/engine combination, including the latest revision number of the approved CMP document required for extended diversion time operations as normally identified in the Flight Manual the type certificate data sheet or supplemental type certificate; and

Explanation: Standard practice for the last 20+ years has been to identify the CMP document in the AFM and Type Data Sheet. The intent of the AFM has been to direct the user to the CMP to ascertain the latest revision status. This approach has worked effectively around the world.

CASA Response

CASA disagrees, it is consistent with the aeroplane eligibility requirements.



Operations (EDTO)


COMMENT 27 - APPLICATION FOR EDTO APPROVAL

Add para (g) “Experience of the AOC holder with EDTO operations”.

CASA Response CASA disagrees. CASA sees no purpose in the suggested additional requirement, the rule as drafted accords with the proposed ICAO standards published in document OPSP/7-WP/20, dated 18 May 2006.


COMMENT 28 – AEROPLANE ELIGIBILITY FOR EDTO

This needs to be amended to reference EASA/JAA. Type Design is accepted so it is unreasonable to impose FAA rules on an EASA aircraft.

CASA Response

CASA disagrees, the draft rule allows for an equivalent standard.


COMMENT 29 – AEROPLANE ELIGIBILITY

Change: (1) To be eligible for EDTO approval, an aeroplane must have an EDTO type design approval as contained in:

(a) The approved Aeroplane Flight Manual or supplement; and

(b) The Type Certificate Data Sheet or Supplemental Type Certificate.

Explanation: Replace "or" by "and". This is consistent with AC 121 5.2

CASA Response

CASA disagrees. Aeroplanes can gain, in some cases, EDTO type design approval subsequent to being manufactured in which case the approval may not be in the TCDS.



Comment: (2) Aeroplanes operating under this subpart must conform to the fire detection and suppression for cargo baggage compartment requirements of FAA Federal Aviation Regulation Part 25 (Fire Protection), or an equivalent standard acceptable to CASA.


Operations (EDTO)


Explanation: What is the purpose of this paragraph, as it does not refer to minimum protection time? The EDTO type design provisions contains a specific requirement for the cargo fire protection system, yet it is the operational rule (CASR 121.6125) that makes the link between the demonstrated cargo fire protection time and the EDTO diversion time contemplated by the operator.

Is it to state that Class D cargo holds are not allowed for EDTO?

CASA Response

CASA agrees.



Change: Note: Notwithstanding the above, CASR 121.0244(8) provides for continuance of previous approvals for certain aeroplanes.

Explanation: In parallel to the comments made on the grand father rule for tris and quads, we feel certain sources of misinterpretation of this grand-father clause as presently written:

• 121.0244 grants the continuation of an existing operations of tris and quads i.e. a new operator electing to operate with the same product as an existing operator must obtain an EDTO approval.

• Yet, this note or AC 121 5.2.2 seems not to request a type design approval for tris and quads already operated in Australia but would require the new operators to apply for an EDTO approval. 121.6115 request an "approved" CMP. How can an approved CMP be available for a new operator of an aircraft already operated by another one in Australia without a formal EDTO approval? This is also not consistent with 121.6125 which clearly requests a formal EDTO type design approval.

We respectfully highlight to CASA the possible misinterpretations of certain provisions of this EDTO NPRM concerning the continuation of the operations of tris and quads and recalls that as written, this rule produces unfair competition between the operators and the manufacturers as explained in the comments made on 121.0244 (8).

CASA Response

CASA agrees, as previously stated, a sunset clause would better support fair competition and add to safety by not encouraging retention of older aeroplanes, as well as giving operators time to adapt to the new EDTO requirements.



Operations (EDTO)


COMMENT 32 – EDTO APPROVAL REQUIREMENTS – 180 MINUTES

Comment: We suggest the following change to subparagraph (1)(c)

(1) An operator requesting approval to conduct EDTO must provide CASA with details that show that: …

(c) the certificate holder has an approved operations training programme that specifically addresses operational factors significant to the EDTO time requested; and …

Explanation: Requirements should cover all operational elements, including training.

CASA Response

CASA disagrees, the other operational elements required for an EDTO approval, including the requirement for training, are comprehensive – see rules regarding the training and evaluation of flight crew. Therefore, CASA deems the proposed rule satisfactory without the suggested change.


COMMENT 33 - EDTO APPROVAL REQUIREMENTS – 180 MINUTES

Change: (f) the aeroplane time-limited system capability will not be less than the EDTO time requested, based on a diversion time (in still air and ISA conditions) at the one-engine inoperative cruise speed plus a 15 minute allowance for holding, approach and landing.

Explanation: This operational limitation concerning the time-limited systems is consistent with current and new draft worldwide EDTO rules for EDTO operations below 180 min.

Yet, for EDTO operations above 180 min, the JAA and FAA WG have acknowledge that certain time limited system (e.g. cargo fire suppression system) can be checked in all engines operating conditions. They have also requested to take into consideration the forecasted weather (wind and temperature effect) during the diversion.

Airbus would welcome consistency between the various EDTO operational rules with regards to these time-limited systems as it significantly impacts the design of its new aircraft or the development of new modifications. We therefore respectfully request CASA to take into consideration the proposed principles issued by JAA and FAA with this regards. (same comment for 121.6126)

CASA Response

CASA agrees.

Disposition The rule will be redrafted to give effect to the comment.


Operations (EDTO)


COMMENT 34 – ADDITIONAL REQUIREMENTS FOR APPROVAL – EDTO GREATER THAN 180 MINUTES – TWIN ENGINE

ADDITIONAL REQUIREMENTS FOR APPROVAL para (1) (b)

does the word 'operational' mean 'serviceable'? Serviceable is used elsewhere and is the accepted term.

CASA Response

CASA agrees.

Disposition The draft rule will be redrafted to give effect to the comment.


We suggest that subparagraph (2) be deleted from both paragraphs:

(2) In determining suitability for EDTO greater than 180 minutes, CASA will take into account the availability of manufacturers’ reliability monitoring programmes.

Explanation: It is unclear what the authority means by the phrase “CASA will take into account the availability of manufacturers’ reliability monitoring programmes.” Presumably, the authority is referring to manufacturer’s reliability data for the world fleet of the airplane of interest. In section 5.2.3 of the advisory material, CASA indicates it will accept the type design approval from the state of manufacture. Based on this, it is assumed the regulatory authority for the state of manufacture would maintain the responsibility for continued airworthiness and issue airworthiness directives, as necessary, to maintain a given EDTO approval. Based on this, it would be expected that CASA would consult with the regulatory authority of the state of manufacture to determine the type design suitability of the airplane for EDTO operations beyond 180-minute EDTO.

CASA Response

CASA agrees.

Disposition The draft rule is not required and will be deleted.


Operations (EDTO)



There is a large degree of duplication in 6126 thru 6128 between what CASA requires “In addition to the MEL limitations for EDTO” with respect to the systems that must be operational for dispatch. It would appear better from a progressive viewpoint to state what additional systems are required for each distance, rather than simply duplicating the previous criteria.

OPERATIONAL – In 6126 thru 6128; does this mean serviceable, or actually operating. Assume it means serviceable.

QE Comment: It is the Operators responsibility to have a reliability programme. In many cases manufacturers programmes would support the operators’ programmes. Such programmes are based on experience, customised maintenance programmes etc. QE

Also suggest adjust the CASR reg numbering to blocks of 5 per standard processes.

CASA Response

CASA agrees with all comments, however final rules will be published as an Order and not a Regulation.

Disposition The rules will be redrafted to give effect to the comment.


Change: (ii) APU (including electrical and pneumatic supply to its designated capability) if required by the manufacturer's system safety analysis; and

Explanation: The APU is a Group 1 ETOPS Significant System under the EDTO type design draft rules. If the aircraft electrical or pneumatic architecture complies with the certification requirements and all the EDTO type design provisions without considering the APU, then the APU should not be explicitly prescribed as a NO GO item by the operational rule. EDTO Dispatch allowance for the APU should rather be managed jointly through the MMEL FOEB and the EDTO RTB as any other EDTO MEL dispatch conditions.

Airbus acknowledges that certain Group 2 ETOPS Significant Systems (Communication, FQI...) are explicitly required at dispatch by the EDTO operational rules. (same comment 121.6127 1.b.ii)

CASA Response

CASA agrees.

Disposition The draft rule will be changed to give effect to the comment.


Operations (EDTO)



Change: In determining suitability for EDTO greater than 180 minutes, CASA will take into account the availability of manufacturers’ reliability monitoring programmes.

Explanation: Airbus would welcome further guidance on this requirement in order to support our Australian customers to comply with it.

As part as its EDTO type design approval, Airbus sets-up such reliability monitoring and quick reporting programs for review by its prime certification authorities (EASA). This might be coordinated with the NAA of its customers on case by case basis (events occuring in the country).

What kind of programmes supported by the manufacturers is expected from the operators to comply with this requirement? (same comment 121.6127 (2))

CASA Response

CASA agrees.



We suggest that subparagraph (2) be deleted from both paragraphs:

(2) In determining suitability for EDTO greater than 180 minutes, CASA will take into account the availability of manufacturers’ reliability monitoring programmes.

Explanation: It is unclear what the authority means by the phrase “CASA will take into account the availability of manufacturers’ reliability monitoring programmes.” Presumably, the authority is referring to manufacturer’s reliability data for the world fleet of the airplane of interest. In section 5.2.3 of the advisory material, CASA indicates it will accept the type design approval from the state of manufacture. Based on this, it is assumed the regulatory authority for the state of manufacture would maintain the responsibility for continued airworthiness and issue airworthiness directives, as necessary, to maintain a given EDTO approval. Based on this, it would be expected that CASA would consult with the regulatory authority of the state of manufacture to determine the type design suitability of the airplane for EDTO operations beyond 180-minute EDTO.

CASA Response

CASA agrees.



Operations (EDTO)



Agree with the ability of CASA to consider unique case by case situations that may occur (eg Australian remoteness and large distances). The unknown factor is that this could add significant costs.

CASA Response

CASA agrees.

Disposition The rule will be amended to mandate standardised minimum experience requirements before CASA may grant Certificate holders approval to operate beyond 240 minutes from an adequate airport. This will harmonise with current international practice.

COMMENT 41 – EDTO APPROVAL REQUIREMENTS – AEROPLANES WITH MORE THAN TWO ENGINES

Comment: We suggest the following changes to paragraph (1):

(1) CASA may approve operators to routinely operate aeroplanes with more than two engines beyond the threshold time of 180 minutes provided:

(a) the requirements of CASR 121.6125 are complied with; and

(b) the following systems are operational for dispatch:

(i) Fuel Quantity Indicating System (FQIS); and

(ii) APU (including electrical and pneumatic supply to its designated capability); and

(iii) Auto Throttle System; and

(iv) a communication system, in addition to that required by CASR 121.0865, capable of providing direct communications of landline quality between the flight crew and air traffic services and the flight crew and the operator.

Explanation: For 3- and 4-engine airplanes (tris and quads), typically the APU is a non-essential system, not required for flight operations. APU and auto throttle systems are not required for tris/quads in the FAA’s NPRM.

CASA Response

CASA agrees that the suggested change would accord with the requirement published in the draft FAA NPRM.

Disposition The draft rules will be changed to give effect to the comment.


Operations (EDTO)



The requirement for an aircraft with more than two engines to have an operational APU prior to dispatch on a more than a 180 minute EDTO flight is not reasonable. The main reason for this is that most APUs on such aircraft CANNOT operate in flight. This requirement should only apply – on a route by route basis – when APU power would be required on the ground following a diversion e.g. in polar region.

CASA Response

CASA agrees.



Change: Remove "(ii) APU (including electrical and pneumatic supply to its designated capability);

Explanation: Four engine airplanes are usually fitted with at least 1 main electrical generator on each engine, which means a total of 4 independent generators not taking into account the APU. What is the rationale to require more operative generators on a quad compared to a twin for same type of operations?

Therefore, this limitation is not justified by the redundancy offered by quads. It is not consistent with current FAA NPRM and JAA NPA. It is neither consistent with the AC 121 9.4.2.b (similar wording to the FAA NPRM).

CASA Response

CASA agrees that the suggested change would accord with the requirement published in the draft FAA NPRM.



Para 1 (b): Should include an item (v) and (vi):

(v) Both auto-pilots must be serviceable.

(vi) Aircraft to be equipped with a serviceable SATCOM.


Operations (EDTO)


CASA Response

CASA disagrees. The suggested change does not accord with the FAA NPRM. CASA is also of the view that the rule is adequate without the suggested change.


COMMENT 45 – ADDITIONAL REQUIREMENTS – ALL EDTO OPERATIONS

This is an open cheque that allows prescriptive legislation to creep in.

CASA Response

The comment is inconsistent with the spirit in which all stakeholders, in particular CASA and NZCAA, have participated in developing the EDTO rule suite.


COMMENT 46 – EDTO PROVING FLIGHT

Change: (3) Any condition considered as being critical in terms of airworthiness, crew workload or performance risk must be demonstrated during the proving flight unless CASA has witnessed a successful demonstration prior to the proving flight.

Explanation: This requirement is redundant with what is reviewed in the frame of EDTO Type Certification (dedicated flight tests are performed to assess crew work load in different failure conditions). The ability of the crew to cope with those EDTO related failures should be reviewed during EDTO flight crew training (simulator session). Our recommendation is that the content of the proving flight should be focussed on the EDTO processes and (normal) procedures (flight preparation, EDTO service check, communication between maintenance and flight operations, flight watch….).

This requirement is not fully consistent with the guidance of AC 121-02, paragraph 9.11.10.

CASA Response

CASA disagrees, the flight is not for the purpose of demonstrating the suitability of the aeroplane, but that the operator has the competence and capability to safely conduct the intended operation – see subregulation (1).



Operations (EDTO)


COMMENT 47 – EDTO PROVING FLIGHT

Para 1 of 121.6130: Pilots should have at least two years of ETOPS experience.

Para 3 of 121.6130: where it states "...crew workload or performance risk must be demonstrated during the proving flight..." there should be a serious analysis workload of the particularly when you consider the terms covered off in ICAO Annex 6.

CASA Response CASA does not agree, the suggested requirement does not accord with international practice. Further, the proposed EDTO rule suite is consistent with ICAO’s proposed amendments to Annex 6, Part I for extended diversion time operations.


COMMENT 48 – EDTO MAINTENANCE ELEMENTS

Not acceptable but would be acceptable with suggested changes. Require detail as to the definition of Qualified Personnel.

CASA Response CASA disagrees, a System of Maintenance does not have a list of qualified personnel authorised to perform tasks. Lists of qualified personnel authorised to carryout maintenance tasks are maintained by maintenance organisations as part of their quality management system. This list is also made available in an EDTO manual.



We suggest the following change to subparagraph (1)(b)(iv):

(iv) A list of Identification of EDTO specific procedures or tasks that must be accomplished or verified by EDTO qualified maintenance personnel;

Explanation: Identification of tasks with words such as “EDTO Significant Task” on Maintenance Task Cards is preferable to requiring an operator to produce a separate list of EDTO tasks. “EDTO qualified maintenance personnel” is consistent with the previous definition


Disposition The draft rule will be changed to give effect to the comment.


Operations (EDTO)



We suggest that subparagraph (1)(b)(v) be deleted:

(b)(i) A pre-departure service check that must be completed immediately prior to an EDTO flight and certified complete by an EDTO qualified maintenance person;

…

(v) A procedure to verify the status of the aeroplane and that EDTO significant systems and equipment are serviceable for an intended flight;

Explanation: Paragraph (v) is merely a restatement of the EDTO Pre-departure Service Check required in paragraph (1)(b)(i).

CASA Response

CASA disagrees. While 121.6140(b)(i) and 121.6140(b)(v) have some degree of overlap they are not exactly the same tasks. For the sake of clarity CASA intends to retain both items.



Add the following new paragraph after 121.6140(1)(c)(ii)(B):

(C) notification of Maintenance Control and Flight Operations if an EDTO qualified part is not available causing the aircraft’s EDTO dispatch capability to be downgraded.

Explanation: Installation of a non-EDTO part may render the aircraft unsuitable for an EDTO flight, or may restrict the maximum diversion time for an EDTO dispatch.

CASA Response

CASA disagrees. An operator’s parts control programme would include a requirement for this.



Operations (EDTO)



Agree that personnel associated with EDTO operations must be trained and qualified and that they must understand that additional requirements and competencies are required. Pre-departure service checks may be done by flight crew when specific circumstances (eg remote locations, diversions etc) occur and this does not always require a maintenance person. As written it’s too prescriptive. It may be appropriate to include this in Advisory/guidance material.

Agree with (5) above for an engine condition monitoring programme. The detail provided on what is in a programme should simply be in Advisory documentation.

CASA Response

A member of the flight-crew may also perform these checks, if appropriately trained and authorised. Regarding the engine condition monitoring programme, CASA agrees.

Disposition Draft advisory material to be changed to give effect to the intent of the comment regarding the engine condition monitoring programme.


Change: (7) An operator must establish an engine oil consumption monitoring programme that ensures:

(a) that sufficient oil is carried for each engine and APU (if required for EDTO) to allow completion of a scheduled EDTO flight; and

(b) the oil consumption of an engine or APU (if required for EDTO) does not exceed the manufacturer’s recommendation; and

(c) monitoring of all oil added to an approved EDTO engine or APU (if required for EDTO) of an approved EDTO airframe/engine combination whether or not a flight is an EDTO flight.

Explanation: An APU oil consumption programme is required only if the APU is required for EDTO as recalled in AC 121 Appendix B D1.

CASA Response

CASA agrees.

Disposition Regulation will be amended to give effect to the comment.


Operations (EDTO)


COMMENT 54 – QUARTERLY EDTO REPORTS

We agree with the requirement to submit reports but many of the following points are what should be covered in Advisory/ Guidance Material.

CASA Response

CASA notes the comment, however, the rule is consistent with international practice.


COMMENT 55 – QUARTERLY EDTO REPORTS

(d) Unscheduled change of aeroplane en route due to technical reasons or malfunctions.

Comment: Amend above as shown as no reason to report other business decisions to change aircraft. Intent covered by following point (e).

CASA Response

CASA agrees, the requirement is unnecessary.

Disposition Sub-regulation (d) of the rule to be deleted.

COMMENT 56 – EDTO QUARTERLY REPORT

Dispatch Requirements to be performed by EDTO Qualified Personnel.

CASA Response

The EDTO Quarterly Report requirements are additional to the EDTO Maintenance Element requirements, which adequately covers the pre-departure maintenance requirements.



For Extended Diversion Time Operations EDTO beyond 180 minutes from an adequate aerodrome an additional communication facility will be available to provide direct landline quality communications at all stages of flight between the flight crew and air traffic services and the flight crew and the operator.

CASA Response

CASA agrees.


Operations (EDTO)


Disposition Suggested editorial change to be undertaken.


(a) EDTO alternate aerodromes must be identified and listed in the EDTO dispatch release and;

Comment: Acceptable if EDTO dispatch release can be part of the operators’ processes and not represent a new document.

CASA Response

The rule does not require a stand-alone document.


COMMENT 59 – EN-ROUTE

ENROUTE para 1(a) and 2

This paragraph is far too general. The pilot in command has responsibility for the aircraft and 121.6110 para (2) clearly states that the PIC must ensure that forecasts are above that required.

Maybe the wording in 121.6205 should be '.... informed of significant non-weather related changes to conditions at designated EDTO alternate aerodromes'. That is what occurs today is also reflects the responsibility of the Australian PIC.

CASA Response

CASA disagrees, the rule is consistent with international practice.



Comment: We suggest revising subparagraph (1)(b) as follows:

(b) for the time period established in CASR 121.6200 (3)(b)(i), the forecast weather, the landing distances, aerodrome services and facilities at designated EDTO alternates must be evaluated. If any conditions are identified (such as weather forecast below the landing minima) which would preclude safe approach and landing, then the pilot must be notified and an acceptable alternate selected where safe approach and landing can be made.

If no acceptable EDTO Alternate can be found, the flight must be re-routed to stay within the Operator’s EDTO Threshold Times (90 or 180 minutes), possibly necessitating turnback or diversion.


Operations (EDTO)


Explanation: We consider that this restriction is probably the intent of the authority, but it needs to be clearly stated.


Disposition The comment reflects the intent of the draft rule, however, it will be redrafted for clarification.


Comment: We suggest revising subparagraph (2)(b) as follows:

(b) The pilot in command may continue the flight if the meteorological forecast for an EDTO alternate is subsequently revised below the EDTO alternate aerodrome’s landing minima or if the aerodrome becomes unavailable for any reason. for a required EDTO alternate aerodrome.

Explanation: The point of this provision is to preclude a diversion from being initiated to an aerodrome that has become unusable for any reason, and to advise the pilot that, until he reaches the next ETP, he may not have a viable alternate available, although most likely there will be enough fuel to reach the next ETP airport.

CASA Response

CASA agrees.

Disposition Rule to be redrafted to give effect to the comment.


Para 2: Should include an item (c):

(c) Pilot is trained and qualified to operate as an ETOPS/EDTO pilot.

CASA Response

CASA disagrees, the requirement is adequately covered by the flight crew training and evaluation rules.



Operations (EDTO)


COMMENT 63 – EDTO FUEL REQUIREMENTS

EDTO FUEL REQUIREMENTS para 3 (b)

This wording is confusing. What we believe it really means is that upon reaching the alternate the aircraft must have sufficient fuel to hold at 1,500 ft for 15 minutes plus fuel to conduct an instrument approach and land.

The way it is currently worded implies that there is a requirement for double the 15 minutes holding requirement. This is not correct.

CASA Response

CASA agrees, the draft rule is confusing and it could be interpreted to mean that in addition to the minimum reserve fuel the aircraft must carry an additional 15 minutes holding fuel. This was not the intent of the rule.

Disposition The draft rule will be redrafted to clarify the intent of the rule.


Comment: We suggest the following change to paragraph (3):

(3) An operator must not allow an aeroplane to commence a flight, planned as an EDTO flight unless, considering the known and forecast weather conditions, or using a wind forecast model acceptable to CASA, it carries sufficient fuel to satisfy the requirements of this section.

Explanation: This change is for clarification purposes. [Further information added in Annex B, AC121-02(0), paragraph 7.1.1(c).]

CASA Response

CASA disagrees, the proposed change is unnecessary.



(b) An EDTO flight upon reaching the alternate must have sufficient fuel in addition to the minimum reserve fuel to hold for 15 minutes at 1,500 feet above the aerodrome elevation and then to conduct an instrument approach and land.

Comment: specifies 15 minutes holding "in addition to the minimum fuel reserves" – We hope this is not asking for a FFR on top of the 15 minutes holding?

CASA Response

CASA agrees, refer to Comment 63.

Disposition The draft rule will be redrafted to clarify the intent of the rule.


Operations (EDTO)



Change: Add "(h) Additional fuel consumptions due to any MEL or CDL items should be accounted for during the appropriate phase of flight when applicable".

Explanation: Proposed clarification.

CASA Response

CASA agrees.

Disposition Proposed change to be incorporated to clarify the rule.

COMMENT 67 – STANDARD EDTO EN-ROUTE ALTERNATE AERODROME PLANNING MINIMA

Comment: We suggest paragraph (1) be revised as follows:

(1) To meet the requirements of an EDTO alternate aerodrome one of the following aerodrome planning minimas must be satisfied when flight planning and for aeroplane dispatch purposes. When applying the criteria for two or more runways, these must be two non-intersecting runways. For airports with at least two operational navigational facilities, each providing a straight in approach procedure to different suitable runways

Explanation: The suggested change is to make this information consistent with the Advisory Circular proposed by FAA-ARAC

We request that CASA consider incorporating rule language, consistent with that proposed by the Canadian authority in TP6327 which permits use of RNAV/GPS approaches for EDTO Alternates.

CASA Response

CASA agrees.

Disposition The draft rules to be amended to give effect to the comment. It should be noted, however, that the request to be consistent with the Canadian authority’s rule language is unnecessary because the current proposed definition does not preclude RNAV/GNSS approaches.


Operations (EDTO)


COMMENT 68 – ADVISORY CIRCULAR – TYPE DESIGN APPROVAL

Comment: We suggest the following changes to this paragraph:

5.1 The process, which will normally lead to the type design EDTO approval, can be divided into two steps as follows:

• Eligibility for EDTO

The applicant manufacturer must show that the design features of the particular airframe/engine combination are suitable for the intended operations. The considerations for type design approval are currently detailed in JAA GAI-20, and FAA AC 120-42A.FAA Part 25/33, EASA CS25 and associated advisory material.

Explanation: The suggested changes are intended to ensure that there is no confusion between operators’ operational approval requirements and the manufacturer’s type design approval responsibilities.

CASA Response

CASA partially agrees.

Disposition Draft Advisory material to be amended by deletion of out-dated references.


Capability for EDTO

The applicant manufacturer must show that the particular airframe/engine combination, having been recognised eligible for EDTO, demonstrates a level of reliability suitable for the intended operation. exhibits a high level of service reliability suitable for the intended operation. Manufacturer’s reliability monitoring programmes may be taken into account for this purpose.

Explanation: The suggested changes are intended to ensure that there is no confusion between operators’ operational approval requirements and the manufacturer’s type design approval responsibilities.

CASA Response

CASA disagrees, refer to Comment 70.



Operations (EDTO)



Operator experience and reliability programs with EDTO/ETOPS should also be a consideration. Manufacturers do not necessarily control Reliability programs. It’s the Operator’s responsibility with the JAA transition to EASA is reference to JAA GAI-20 still relevant? Will need to be updated if and when EASA document is issued.

CASA Response

CASA agrees.

Disposition The draft advisory material will be amended to allow for operator experience.


Comment:

(e) Description or reference to a document containing the approved aeroplane configuration, maintenance, procedures and dispatch CMP standards.

Explanation: Clarification.

CASA Response

CASA disagrees. The definition of CMP refers to flight crew procedures.



Delete as this is excessive and is basically duplicated in 5.2.3. This is also covered by the Type Certification basis of the aircraft.

CASA Response

CASA disagrees, this paragraph is required for clarification.



Operations (EDTO)



Comment

Change this paragraph as follows:

5.3 Modifications of type design

5.3.1 Modifications or maintenance actions to achieve or maintain the reliability objective of EDTOs for the airframe/engine combination are incorporated into the design CMP standard document.

(a) Additional modifications or maintenance actions generated by an operator or manufacturer to enhance or maintain the continued airworthiness of the aeroplane must be made through the normal approval process.

(b) The operator or manufacturer (as appropriate) must thoroughly evaluate such changes to ensure that they do not adversely affect reliability or conflict with requirements for extended range EDTO approval.

(c) The Airworthiness Directive (AD) process may be utilised as necessary to implement a CMP standard change.

(d) The EDTO operational approval of each EDTO operator will require it to keep its EDTO fleets in conformity with the current CMP standard, taking into account implementation delays.

Explanation: The suggested changes provide clarification and ensure there is no confusion between type design approval and the operational approval. As such, (d) should been deleted and this provision should be reflected in the operational section of the AC.

CASA Response

CASA agrees.

Disposition The advisory material will be amended by deletion of text as suggested by the commenter.


Re Continuing Airworthiness, CASA may also require changes in the interests of safety but the key global responsibility is largely on the NAA. The last sentence of 5.4.1 should be made 5.4.2 as it’s a different issue.

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to give effect to the comment.


Operations (EDTO)



Comment: We request that the entire paragraph 5.5 be moved under Section 6 and re-titled “Airworthiness.”

Explanation: The content of paragraph 5.5 is a requirement for operators, and it would be less confusing to the operators if this is moved under Section 6.

CASA Response

CASA disagrees and believes the paragraph is appropriately placed.


COMMENT 76 – ADVISORY CIRCULAR – OPERATIONAL APPROVAL CONSIDERATIONS

Comment: We suggest the following changes be made to paragraph 6.4.1:

6.4.1 Following the accumulation of adequate operating experience by the world fleet of the specified airframe/engine combination, and the establishment of an IFSD rate objective for use in ensuring the propulsion system reliability necessary for EDTOs, an In authorizing the operation of an aeroplane with two engines on EDTO , CASA will ensure that the operator’s past experience and compliance record is satisfactory or the operator establishes the processes necessary for successful and reliable extended diversion time operations and shows that such processes can be successfully applied throughout such operations. An assessment will be made of the applicant's ability to achieve and maintain this level of propulsion system reliability.

Explanation: The suggest change would provide consistency with the ICAO Operational panel approved position under paper OPSP/7-WP/20 (Attachment E to Annex 6 Part I, section 8).

CASA Response

CASA agrees.

Disposition The draft advisory material will be amended as proposed by the commenter.


Accumulation of adequate operating experience by the world fleet of the specified airframe-engine combination’ may be difficult for new aircraft with more than two engines. Qantas requests clarification of this statement in relation to new types e.g. the Boeing 787. Other countries plan to issue an EDTO approval on Certification of the aircraft. How does CASA plan to manage new types?


Operations (EDTO)


CASA Response


Disposition The draft advisory material will be amended as shown at Comment 76.


Comment: Following the accumulation of adequate operating experience by the world fleet of the specified airframe/engine combination through in-service experience or equivalent demonstration (early EDTO approval), and the establishment of an IFSD rate objective for use in ensuring the propulsion system reliability necessary for EDTOs, an assessment will be made of the applicant's ability to achieve and maintain this level of propulsion system reliability.

Explanation: Launch customers of a newly EDTO approved aircraft may not have at EIS world fleet in-service data as reference but would rely on the results of the early EDTO demonstration for the engines (3000 cycles test).

CASA Response


Disposition The draft advisory material will be amended as shown at Comment 76.

COMMENT 79 – ADVISORY CIRCULAR – OPERATIONAL APPROVAL CONSIDERATION

Engineering Modifications and Maintenance Program Considerations Insert G. Qualified Personnel - The Maintenance Program must ensure adequate numbers of qualified personnel are trained and authorised to adequately perform the Maintenance Program.

CASA Response

CASA agrees.

Disposition The draft advisory material will be amended to incorporate the text as proposed by the commenter.


Operations (EDTO)


COMMENT 80 – OPERATIONAL APPROVAL CONSIDERATION

Comment: We suggest the following changes:

(e) Control Process – Procedures and a centralised control process must be established which would preclude an aeroplane being released for EDTO after propulsion system shutdown or primary airframe EDTO Maintenance Significant system failure on a previous flight, or significant adverse trends in system performance, without appropriate corrective action having been taken. Confirmation of such action as being appropriate, in some cases, may require the successful completion of one or more non-revenue or non-EDTO revenue flights (as appropriate) prior to being released on an EDTO. As an alternative the first 60 minutes of an EDTO flight can be used as a verification flight.

Explanation: It is current common practice for an airline to verify certain maintenance actions during the early non-EDTO portion of a revenue flight. This is especially helpful when there is a long non-EDTO portion. Consider adding a paragraph allowing these revenue verification flights or proving flights when appropriate.

Using the first 60 minutes of an ETOPS flight as the verification flight is an accepted FAA practice, see FAA Orders 8300.10 and 8400.10/Appendix: 3; and Joint Handbook Bulletins for Airworthiness (HBAW) 94-03, and Air Transportation (HBAT) 94-09.

CASA Response

CASA agrees.

Disposition The draft advisory material will be amended by incorporation of the proposed changes, except that the word 'maintenance' will not be inserted.


(a) Does this include all Service Bulletins etc. If so, it would appear to be excessive as the operator must comply with the CMP. If the operator incorporates self design changes that affect the EDTO operation, then this is reasonable to advise CASA.

(b) Assume reference to CASA for modifications includes an Authorised Person/delegate or Organisation in a process approved by CASA provided it does not alter the certification basis.

CASA Response

In principle, the CMP does not repeat Airworthiness Directive. An operator thus needs to ensure compliance with both ADs applicable in Australia and the CMP standards when operating EDTO.



Operations (EDTO)



The maintenance program used must ensure that the airframe and propulsion systems will continue to be maintained at the level of performance and reliability necessary for EDTO, including such programs as engine condition monitoring and engine and APU (if required for EDTO) oil consumption monitoring.

Explanation : Include APU in oil consumption monitoring if APU is required for EDTO.


Disposition The advisory material will be changed to give effect to the comment.

COMMENT 83 – ADVISORY CIRCULAR – FLIGHT PREPARATION AND IN-FLIGHT CONSIDERATIONS

MEL – in some respects, this para must be related to the NPRM 121.6127 para (1) as an example. This para (1) requires the fuel quantity system, APU, auto throttle and communication system to be operative for EDTO flights.

CASA Response CASA is not sure of the point behind the comment, the identified rule and paragraph in the advisory material are consistent.


COMMENT 84 – ADVISORY CIRCULAR – FLIGHT CREW TRAINING, EVALUATION, AND OPERATIONS MANUALS

Comment: We suggest the following change to this paragraph:

CASA will review in-service experience of critical and essential aeroplane EDTO Maintenance Significant systems. The review will include system reliability levels and individual event circumstances, including crew actions taken in response to equipment failures or unavailabilities. The purpose of the review will be to verify the adequacy of information provided in training programs and operating manuals. The aviation community should provide information for and participate in these reviews. CASA may use the information resulting from these reviews to require the operator to amend flight crew training programs, operations manuals and checklists, as necessary.

Explanation: This suggested change would provide consistency.

CASA Response CASA disagrees. See Comment 16.



Operations (EDTO)



Comment: Detailed compliance documents for the type design approval are not required if CASA has already given approval to another operator to operate extended range operations with the same airframe/engine combination.

Explanation: See comments made on the interpretation of the grand-father rule for tris and quads in CASR Subpart 121 requirements.

CASA Response

The comment relates to a proposed grandfather provision that has now been superseded by a sunset clause.


COMMENT 86 – ADVISORY CIRCULAR – OPERATIONAL LIMITATIONS

Comment: We suggest revising this paragraph as follows:

Definition of the particular airframe/engine combinations, including the current approved CMP standard required for EDTO as normally identified in the AFM.

Explanation: Standard practice for the last 20+ years has been to identify the CMP document in the AFM, Type Data Sheet. The intent of the AFM has been to direct the user to the CMP to ascertain the latest revision status. This approach has worked effectively around the world.

CASA Response

CASA disagrees, the advisory material harmonises with the rules.



Validation of Operator EDTO Maintenance and Operations Capability The operator must demonstrate that it has the competence and capability to conduct safely and support adequately the intended operation. Before being granted EDTO operational approval, the operator must provide evidence that: (a) the EDTO maintenance checks, servicing, and programs called for in Appendix B of this AC are being properly conducted at representative departure and destination aerodromes; Should read "(a) the EDTO maintenance checks, servicing, and programs called for in Appendix B of this AC are being properly conducted and certified for by Qualified Personnel.


Operations (EDTO)


CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to give effect to the intent of the comment.


Comment: Revised this paragraph as follows:

The MEL should reflect adequate levels of primary EDTO Maintenance significant system redundancy to support 180 minutes (still air) operations. The systems listed in paragraph 7.1.1(a)(i) through (xvi) must be considered.

Explanation: The suggested change is for consistency.

CASA Response


Disposition The draft advisory material will be changed to refer to 'EDTO significant' instead of 'primary system' redundancy.

COMMENT 89 – ADVISORY CIRCULAR – MAINTENANCE REQUIREMENTS

Comment: We suggest deleting the list of systems under Paragraph A3. However, if it is to be retained, we request that it be labelled as “Typical Examples of EDTO Maintenance Significant Systems.”

Additionally, there appear to be some typographical errors in ATA 70-79 sections.

Explanation: The list of systems can vary depending on the aeroplane e.g., HMG, back up generators.

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed by deletion of the test referred to by the commenter.


The wording in the table needs to be universal so as not to impose requirements of one type design (767) on others (A330 or 787).

Reference is made to the HMG – is reference to a Ram Air Turbine (RAT) also needed in ATA 24 or 29. Likewise in ATA 34 is reference needed to Global Positioning Systems (GPS) required.


Operations (EDTO)


CASA Response

CASA agrees, see response to Comment 89.

Disposition The draft advisory material will be changed as shown at Comment 89.


Comment: Depending on the aircraft systems architecture, The EDTO Significant systems list may include but is not limited to: …

Explanation: We support the inclusion of a sample EDTO list of significant systems in the AC 121. Yet, we would recommend to add a caption stating that this is a sample list which may vary depending on the aircraft architecture. Airbus makes available to its customers a list of EDTO significant systems customised by aircraft type.

This list contains systems unique for EDTO operations in the sense that they participate in the "Prevent&Protect the diversion" concept. We consider for instance that Engine and APU fire Detection are not unique for ETOPS as these functions are fundamental for a non EDTO operations as well (covered by basic TC) and therefore we do not include them in our list.

CASA Response

CASA agrees, see response to Comment 89.



(2) Aeroplanes with more than two propulsion engines:

(i) 0.2/1,000 engine hours for 3 engine aeroplanes conducting EDTO.

(ii) 0.1/1,000 engine hours for 4 engine aeroplanes conducting EDTO.

Explanation: These IFSD values are given in the FAA NPRM. The EASA ETOPS/LROPS WG sets different objectives depending whether consequences of the loss of two engines is catastrophic or not: for a four engine aeroplane, an IFSD objective of 0.01/1000 E.H would result in the loss of two engines being extremely improbable. A four engine aircraft operator able to demonstrate such IFSD rate on its aircraft could take benefit of this safety analysis (e.g. flight over high terrain area with few en-route adequate airports [for instance south polar flight]).

CASA Response

EDTO maintenance requirements will not be applied to three and four engine aeroplanes.

Disposition The draft advisory material will be changed to reflect agreement that EDTO maintenance requirements will not apply to aeroplanes with more than two engines.


Operations (EDTO)



(2) Aeroplanes with more than two propulsion engines:

(i) 0.2/1,000 engine hours for 3 engine aeroplanes conducting EDTO.

(ii) 0.1/1,000 engine hours for 4 engine aeroplanes conducting EDTO.

Explanation: These IFSD values are given in the FAA NPRM. The EASA ETOPS/LROPS WG sets different objectives depending whether consequences of the loss of two engines is catastrophic or not: for a four engine aeroplane, an IFSD objective of 0.01/1000 E.H would result in the loss of two engines being extremely improbable. A four engine aircraft operator able to demonstrate such IFSD rate on its aircraft could take benefit of this safety analysis (e.g. flight over high terrain area with few en-route adequate airports [for instance south polar flight]).

CASA Response

See response to Comment 92.



EDTO MAINTENANCE PROGRAM.

(c) An EDTO service check should be developed to verify that the status of the aeroplane and certain critical items are acceptable. This check should be accomplished and signed off by an authorised and qualified person prior to an EDTO flight. Such a person maybe a member of the flight crew.

Remove "Such a person may be a member of the flight crew".

Insert "Qualified Personnel may be a member of the Flight Crew and in addition to the EDTO Maintenance Qualification be provided with EDTO Flight Crew Training".

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to incorporate text giving effect to the comment.


Operations (EDTO)



B2.(h) Add the following note:

NOTE: Servicing of fluids and gases is not considered multiple maintenance action.

Explanation: This statement clarifies that checking the oil does not require two mechanics, similar to the statement in AC developed by FAA ARAC in paragraph 10(b).

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to incorporate the proposed note.


C1. The operator should develop a manual for use by personnel involved in EDTO. All EDTO maintenance requirements and procedures should be identified in this manual as well as the specific duties, responsibilities, processes and procedures assigned to the various Maintenance & Engineering departments. Samples of the forms and reports should be included.

Insert "as well as the specific duties" Insert "number and identity of qualified and Authorised Personnel".

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed by insertion of text as proposed by the commenter.


Comment: We suggest this paragraph be revised as follows:

The operator must develop a verification program or procedures should be established to ensure corrective action following an engine shutdown, primary EDTO Maintenance significant system failure or adverse trends or any prescribed events which require a verification flight or other action and establish means to assure their accomplishment. A clear description of who must initiate verification actions and the section or group responsible for the determination of what action is necessary must be identified in the program. Primary systems or conditions requiring verification actions must be described in the operator's EDTO manual. A maintenance verification flight can be a non-revenue flight, a non-EDTO revenue flight, or the first 60 minutes of an EDTO flight. It is essential that the verification of a maintenance action be done immediately following the action.


Operations (EDTO)


If verification will take longer than 60 minutes, then the airplane must remain within 60 minutes of an alternate airport until verification is accomplished. If the verification is unsatisfactory, the flight must either be re-routed to remain within the operator’s EDTO Threshold Time of an EDTO Alternate Aerodrome or turn back.

Explanation: The first change is for consistency.

The statement added to the end of the paragraph is necessary to establish the ground rules for the conduct and successful compliance with Verification Flight requirements. Using the first 60 minutes of an ETOPS flight as the verification flight is an accepted FAA practice [see FAA Orders: 8300.10 and 8400.10/Appendix: 3; and Joint Handbook Bulletins for Airworthiness (HBAW) 94-03 and Air Transportation (HBAT) 94-09.]

CASA Response

CASA agrees. See also Comment 80.

Disposition The draft advisory material will be changed to incorporate text based on this proposal.


Comment: Revise Paragraph H3 as follows:

If the IFSD rate computed on a 12 month rolling average exceeds the relevant values in subparagraphs (1) or (2) below, the operator, in conjunction with CASA, must investigate common cause effects or systemic errors:

(1) Aeroplanes with two propulsion engines;

(i) 0.05/1,000 engine hours for EDTO up to and including 120 minutes.

(ii) 0.02 0.03/1,000 engine hours for EDTO beyond 120 minutes up to and including 180 minutes.

(iii) 0.01 0.02/1,000 engine hours for EDTO beyond 180 minutes.

Explanation: Even though on the Type Design Approval side the authorities have set 0.02/1,000 engine hours as a target for 180-minute operations, the target set before investigation for common cause is set at the airline’s fleet level, which is slightly different. For example, in the current Advisory Circular 120-42A, Appendix 4, Paragraph 8, the FAA sets this level at 0.03/1,000 engine hours for 180-minutes. Accordingly, the FAA-ARAC report and the FAA NPRM relevant to 121.374(c)(i)(B) and 121.374(c)(i) (C) set these values at 0.03 for up to 180-minutes, and 0.02 for beyond 180-minute operations. CASA should maintain consistency with current levels and philosophy.

CASA Response

CASA agrees.


Operations (EDTO)


Disposition The draft advisory material will be revised as proposal by the commenter.


Para H3 (2) is not required – see earlier comments.

CASA Response

CASA agrees.

Disposition The draft advisory material will be revised as shown at Comment 98.


We suggest adding the following guidance:

- Causes of engine in-flight shutdown or other engine/propulsion system problems may be associated with design problems, and/or maintenance and operation procedures applied to the aeroplane. It is important to identify the root cause of events so that the appropriate corrective action is implemented. An operator should not be considered responsible for the occurrence of a design related event in its fleet. However, maintenance or operational problems may be wholly, or partially, the responsibility of the operator. If an operator has an unacceptable engine in-flight shutdown rate attributed to maintenance or operational practices, then action tailored to that operator may be required by the CASA.

- A high rate of engine in-flight shutdowns for a small fleet may be due to the limited number of engine operating hours and may not be indicative of an unacceptable rate. The underlying causes for such a jump in the rate will have to be considered by the CASA.

Explanation: The final report of the ICAO Operations Panel 7 on Extended Diversions Time Operations, [see Appendix C, Chapter 7 (Airworthiness Requirements for Extended Diversion Time Operations), paragraphs 7.4.2 & .3 (Page 1C-15)] provides guidance to the State of the Operators that will add value if incorporated in this CASA guidance document.

CASA Response

CASA disagrees, the note to H4 adequately covers the issue.



Operations (EDTO)



MAINTENANCE TRAINING

I.1 The maintenance training must focus on the special nature of EDTO. This program must be included in the normal maintenance training. The goal of this program is to ensure that all personnel involved in EDTO are provided with the necessary training so that the EDTO maintenance tasks are properly accomplished and to emphasise the special nature of EDTO maintenance requirements. Qualified maintenance personnel are those who have completed the operator's extended range training program and have satisfactorily performed extended range tasks under supervision, within the framework of the operator's approved procedures for personnel authorisation.

After the words "Qualified Maintenance Personnel Are those who" Insert " hold a CASA endorsed Licence for that aircraft type and who have.....".

CASA Response

CASA disagrees, refer to Comment 15.



We suggest the following revisions to this paragraph:

The maintenance training must focus on the special nature of EDTO. This program must be included in in addition to the operator’s normal maintenance training. The goal of this program is to ensure that all personnel involved in EDTO are provided with the necessary training so that the EDTO maintenance tasks are properly accomplished and to emphasise the special nature of EDTO maintenance requirements. Qualified maintenance personnel are those who have completed the operator's extended range EDTO training program and have satisfactorily performed extended range EDTO tasks under supervision, within the framework of the operator's approved procedures for personnel authorisation.

Explanation: Only the personnel that will be involved in EDTO need to be trained and qualified in EDTO.

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to reflect the proposals made by the commenter.


Operations (EDTO)


COMMENT 103 – ADVISORY CIRCULAR – BACKGROUND

Reference to foreign regs/standards should include EASA CS25.

CASA Response CASA disagrees. The suggested change is unnecessary because an equivalent standard is allowed.


COMMENT 104 – ADVISORY CIRCULAR – BACKGROUND

Eligibility for EDTO

The applicant must show that the design features of the particular airframe/engine combination are suitable for the intended operations. The considerations for type design approval are currently detailed in EASA AMC 20-6, and FAA AC 120-42A.

Explanation: Change of European ETOPS guidance reference further to transfer of responsibility between JAA and EASA.

CASA Response

CASA agrees.

Disposition The draft advisory material will be changed to reflect the relevant EASA reference and document.


The organization of Sections 6 through 9 appears to allow some overlap and potential for confusion on how to obtain EDTO operational approval. For example, Section 6.3 refers to “Operational Approval” requirements and Section 9.4 refers to “Requirement for EDTO approval,” while Section 9.6 refers to “EDTO Approval.”

Explanation: We request streamlining and reassessment of the organization of Sections 6 through 9.

CASA Response


Disposition The draft advisory material will be reworded for clarification.


Operations (EDTO)



Revise paragraph 6.1 as follows:

6.1 Criteria Maximum Diversion Time Options

Explanation: The suggestions to re-title the section to “Maximum Diversion Time Options” and to add the approval level allowed on tris/quads are for the sake of clarity.

CASA Response




6.1.1 Three sets of operational approval criteria are to be used options are available for two-engine aeroplanes:

(a) EDTOs with a maximum diversion time above 90 minutes up to 180 minutes to an enroute alternate (at the approved one-engine-inoperative cruise speed under standard conditions in still air);

(b) EDTOs with a maximum diversion time above 180 minutes up to 240 minutes to an enroute alternate (at the approved one-engine-inoperative cruise speed under standard conditions in still air);

(c) EDTOs with a maximum diversion time above 240 minutes (at the approved one-engine-inoperative cruise speed under standard conditions in still air).


CASA Response




Operations (EDTO)



6.1.2 EDTO Operational approvals may be granted to operators of airplanes with more than two engines with a maximum diversion time above 180 minutes to an enroute alternate (at the approved one-engine-inoperative cruise speed under standard conditions in still air);


CASA Response




We suggest the following changes:

Since these EDTO alternates serve a different purpose than the destination alternate aerodrome and would normally be used only in the event of an engine failure or other the loss of primary aeroplane systems, failures, an aerodrome must not be listed as an EDTO alternate unless the requirements of CASR 121.6109 are met…

Explanation: Suggestions provide better clarity.

CASA Response

CASA agrees.



We suggest the following change to the second bullet in this paragraph:

The latest available forecast weather conditions for a period commencing at the earliest time of landing and ending at the latest time of landing at that aerodrome, equals or exceeds the authorised weather planning minima for EDTO alternate aerodromes in CASRs 121.6215 and 121.6216 121.6220. In addition, for the same period, the forecast crosswind component, including gusts, for the landing runway expected to be used must not exceed the maximum permitted manufacturer recommended crosswind for single-engine landing, taking into account the runway condition (dry, wet or contaminated).


Operations (EDTO)


When planning and conducting the flight, adverse weather conditions at EDTO alternates having forecast probabilities of less than 40% may be disregarded; however, any ’INTER’ or ’TEMPO’ must be taken into account when determining the amount of fuel to be carried.

Explanation: We believe that the intent is to refer to “Normal” EDTO Planning Minima and “CAT II or III” EDTO Planning Minima as in 121.6220. If this is not the case, then further clarity is necessary.

To the best of our knowledge, no commercial airplane has a “demonstrated” engine-out crosswind capability or one on anything other than a smooth dry runway. Boeing provides this information in the Flight Crew Training Manuals as recommended limits.

CASA Response

CASA agrees.

Disposition Editorial correction noted. The draft advisory material will be reworded for clarification.


We suggest the following change to the last bullet in this paragraph:

In addition, the operator's program should provide flight crews with information on adequate aerodromes appropriate to the route to be flown which are not forecast to meet CASRs 121.6215 and 121.6216 121.6220 en-route alternate weather minima. Aerodrome facility information and other appropriate planning data concerning these aerodromes should be provided to flight crews for use when executing a diversion.

Explanation: We believe that the intent is to refer to “Normal” EDTO Planning Minima and “CAT II or III” EDTO Planning Minima as in 121.6220. If this is not the case, then further clarity is necessary.

CASA Response

CASA agrees.

Disposition Editorial correction noted.


Operations (EDTO)



Add a new bullet to 7.1.1(d)(ii) as follows:

• A wind aloft forecast distributed worldwide by the World Area Forecast System (WAFS) is an example of a wind forecast model acceptable to the CASA.

Explanation: This addition will provide additional guidance on the wind forecast model. It is also consistent with the Advisory Circular as proposed by the FAA ARAC.

CASA Response

CASA agrees.

Disposition The draft advisory material will be reworded to give effect to the suggested change.

COMMENT 113 – ADVISORY CIRCULAR – FLIGHT CREW TRAINING, EVALUATION, AND OPERATING MANUALS

Revise the title of this paragraph to read:

8.3 EDTO Check Airman Program

Explanation: The revision indicates the correct title of this program.

CASA Response

CASA disagrees. The term is not used in Australian aviation legislation.



Make the following revision:

8.3.1 The objective of the EDTO check airman program should be to ensure standardised flight crew practices and procedures and also to emphasise the special nature of EDTOs. Only those with a demonstrated understanding of the unique requirements of EDTO should be designated as check pilots for EDTO.

Explanation: The revision indicates the correct title of the program.

CASA Response

CASA disagrees. The term is not used in Australian aviation legislation.



Operations (EDTO)



The organization of Sections 6 through 9 appears to allow some overlap and potential for confusion on how to obtain EDTO operational approval. For example, Section 6.3 refers to “Operational Approval” requirements and Section 9.4 refers to “Requirement for EDTO approval,” while Section 9.6 refers to “EDTO Approval.”

Explanation: We request streamlining and reassessment of the organization of Sections 6 through 9.

CASA Response




9.1.2 – could be simplified to one EDTO time limitation.

CASA Response

CASA disagrees, however, paragraph 9.1.2 no longer applies.

Disposition Paragraph 9.1.2 will not be transposed to the final advisory material.


Revise this paragraph as follows:

(b) A practice to be established such that, in the event of a single or multiple primary EDTO Maintenance significant system failure, the pilot will initiate the diversion procedure to fly to and land at the nearest aerodrome in terms of time, determined to be suitable by the flight crew, unless it has been justified that no substantial degradation of safety results from continuation of the planned flight.

Explanation: The revision provides better consistency.

CASA Response

CASA partially agrees. See Comment 88.



Operations (EDTO)



We suggest deleting the proposed paragraphs 9.4.2(b) and (c), and replacing them with the following paragraphs (b), (c), and (d):

(b) Polar area is defined as an area of EDTO applicability.

(c) EDTO requirements are specified in the certificate holder’s approved maintenance and operations programs. EDTO must be authorised in the certificate holder’s operations specifications and conducted in compliance with Subpart 121.W. Approvals may be granted, for operations employing aircraft with more than two engines, to conduct EDTO operations on a routine basis with maximum diversion times up to 240 minutes in any area of operations. For all such operations, the nearest available EDTO alternate within 240 minutes diversion time (in still air at one-engine-inoperative speed) must be specified. If an EDTO alternate is not available within 240 minutes, the nearest alternate EDTO alternate must be specified. In either case, the operator must designate the nearest available EDTO alternate(s) along the planned route of flight. On all such operations, MEL limitations for EDTO apply and in addition, the Fuel Quantity Indicating System (FQIS) and, if so equipped, SATCOM voice and SATCOM or HF Data Link must be operational. For company communications, on such operations, operators shall use the most reliable communications technology available. For such operations, the airframe/engine combination must be EDTO type design approved for the maximum authorised diversion time.

(d) All operators of aeroplanes with more than two engines operating on EDTO routes must comply with all the operational and process.

Explanation: The suggested reformatting is intended to distinguish polar area of operations as EDTO from the basic requirements applicable to all aeroplanes with more than two engines.

CASA Response

Since the NPRM was published, CASA has considered the matter further and is now of the view that integrating Polar requirements within the EDTO regime is impractical. This change is consistant with the FAA’s final rules on polar operations.

Disposition The proposed designated EDTO areas will be abolished and Polar areas will be regulated independently from EDTO.


Operations (EDTO)



Remove "The critical fuel scenario must also consider fuel required for all-engine-operations at 10,000 feet, or above 10,000 feet if the aeroplane is equipped with sufficient supplemental oxygen."

Explanation: This portion of the EDTO fuel planning requirement is already included in 121.6210. We do not understand the rationale to introduce this single requirement at this place.

CASA Response

CASA agrees.

Disposition The wording will be deleted from the draft to give effect to the comment.


Where the AC states - ‘The operator should be prepared to demonstrate the processes required to initiate and carry out its passenger recovery plan.’ The word ‘demonstrate’ could be interpreted to require a practical demonstration. Any recovery plan would be based on the TC manufacturers requirements.

CASA Response

CASA disagrees, the intent that an operator may have to demonstrate the “processes” involved with a passenger recovery is clear.



Polar flights – question if this requires special inclusion within the EDTO AC or NPRM. CASA currently can control Polar flights within present Regulations and as a special case. The only reason to include / retain is ICAO standardisation.

Some of the Para 9.11 items should be split away from 9.11 as they should be reworded so they are applicable to all EDTO Operations.

CASA Response

Since the NPRM was published, CASA has considered the matter further and is now of the view that integrating Polar requirements within the EDTO regime impractical. This change is consistant with the FAA’s final rule on Polar operations.

Disposition The proposed designated EDTO areas will be abolished and Polar areas will be regulated independently from EDTO.


Operations (EDTO)



For Twin engine aircraft, APU, including electrical and pneumatic supply to its designed capability if required by the manufacturer's system safety analysis;

Explanation: See comments made on CASR 121.

CASA Response

CASA notes the comment.

Disposition The rules will reflect that only those items required for an EDTO flight, as stated by the manufacturer’s Master Minimum Equipment List (MMEL), must be serviceable to undertake an EDTO flight.


Correct the reference in this paragraph as follows:

1.1 The fleet average In Flight Shut Down (IFSD) rate for the specified airframe/engine combination will continue to be monitored in accordance with Appendix B paragraph D H of this AC.

Explanation: The reference to Paragraph D is a typo. Paragraph H has the IFSD rate requirements.

CASA Response

CASA agrees.

Disposition Editorial change noted.


Change the title of Paragraph B to:

“Suitable EDTO Aerodrome Selection”

Explanation: For consistency, this suggested change is warranted.

CASA Response

CASA agrees.

Disposition Editorial change noted.


Operations (EDTO)


COMMENT 127 – KEY PROPOSED CHANGE 1 – LIFTING THE THRESHOLD TIME FOR EXTENDED DIVERSION TIME OPERATIONS FROM 60 MINUTES TO 90 MINUTES, WHEN CERTAIN CONDITIONS ARE MET

Sufficient operator experince in ETOPS has shown this is acceptable.

CASA Response

CASA notes the comment of support.


COMMENT 128 – KEY PROPOSED CHANGE 1 – LIFTING THE THRESHOLD TIME FOR EXTENDED DIVERSION TIME OPERATIONS FROM 60 MINUTES TO 90

As previously outlined the combination of applied MEL items, lack of ETOPS flying experience and reduced training for flight crew in addition to a system of maintenance that might not have the resources to satisfy the regulatory and operational requirements are of concern to AIPA.

We would consider the possible scenarios that could be presented to operating crew would exceed acceptable levels of risk in cockpit workload and operating efficiency.

Acceptable ETOPS experience and acceptable flight crew training along with systems of maintenance that would reduce the need for the application of the MEL on critical items/systems as an essential feature.

CASA Response

The AIPA’s specific concerns are dealt with individually under the relevant rule previously in this document. It should be noted that CASA has mandated minimum standards in relation to crew training and systems of maintenance. CASA has also mandated minimum experience requirements to conduct certain EDTO. The final EDTO suite of rules and standards is consistent with ICAO Annex 6, Part 1 and harmonised with international best practice.



Operations (EDTO)


COMMENT 129 – KEY PROPOSED CHANGE 1 – LIFTING THE THRESHOLD TIME FOR EXTENDED DIVERSION TIME OPERATIONS FROM 60 MINUTES TO 90

Some clarifications in 121.0002 are requested.

CASA Response

Specific comments have been dealt with under the relevant rule previously in this document.


COMMENT 130 – KEY PROPOSED CHANGE 2 – INTRODUCING NEW EXTENDED DIVERSION TIME APPROVAL STEPS (BEYOND 180 MINUTE AND BEYOND 240 MINUTES)

NZALPA believes that total reliance on one propulsion system to provide for a safe landing at a suitable en-route diversion aerodrome beyond 240 minutes is unreasonable and unnecessary. Up to 240 minutes could be acceptable after extensive operator experience through proving flights.

CASA Response

CASA disagrees. The new EDTO rule suite legislates standards that determine the design, operation and maintenance of certain aeroplanes to operate extended range from an adequate airport. The rule suite also legislates current CASA policy, international best practices and recommendations, as well as harmonising with international standards. It is a composite rule suite that has been comprehensively consulted and designed to ensure EDTO flights will continue to operate safely.


COMMENT 131 – KEY PROPOSED CHANGE 2 – INTRODUCING NEW EXTENDED DIVERSION TIME APPROVAL STEPS (BEYOND 180 MINUTE AND BEYOND 240 MINUTES)

Airbus proposes a change on the MEL dispatch limitation wording and wishes to get further clarification and wording improvement if required on the second requirement.

CASA Response

Specific comments have been dealt with under the relevant rule previously in this document.



Operations (EDTO)


COMMENT 132 – KEY PROPOSED CHANGE – INTRODUCING NEW EXTENDED DIVERSION TIME APPROVAL STEPS (BEYOND 180 MINUTE AND BEYOND 240 MINUTES)

Existing fleets currently do not have manufacturer's approval in excess of 180 minutes EDTO. There is a concern that operators are currently reducing the levels of in house maintenance and outsourcing. Given that an aging fleet and the effects of outsourcing on a system of maintenance can reduce the current level of aircraft and aircraft system reliability, AIPA would prefer to see a more conservative line and a process that would not lower the acceptable risk levels. New generation aircraft specifically designed for EDTO of this magnitude would be acceptable, provided that adequate levels of flight crew experience, flight crew training and a system of maintenance are employed.

CASA Response

CASA notes the comments, refer to the response to Comment 129. Also, the AIPA’s specific concerns have been dealt with under the relevant rules previously in this document.


COMMENT 133 – KEY PROPOSED CHANGE 3 – AMENDING PREVIOUS EXTENDED DIVERSION OPERATIONS EXPERIENCE REQUIREMENTS TO HARMONISE WITH THE NEW APPROVAL STEPS

This could also be tied to Grandfathering. See comment below.

CASA Response

CASA is of the view that this is unnecessary, previous EDTO experience will only be required for certain EDTO steps.


COMMENT 134 – KEY PROPOSED CHANGE 3 – AMENDING PREVIOUS EXTENDED DIVERSION OPERATIONS EXPERIENCE REQUIREMENTS TO HARMONISE WITH THE NEW APPROVAL STEPS

The harmonisation process would have to be a consultative process with key stakeholders to ensure that elements of airline operations that have a significant effect on reliability and levels of safety are included in any approval step.

CASA Response

Refer to CASA’s response to Comment 129.



Operations (EDTO)


COMMENT 135 – KEY PROPOSED CHANGE 4 – INTRODUCING 180 MINUTE THRESHOLD TIME FOR ALL TURBINE AEROPLANES WITH MORE THAN TWO ENGINES, EXCEPT WHERE THEY OPERATED PRIOR TO THE COMMENCEMENT OF THE NEW EDTO RULE SET

We fundamentally disagrees with this proposal but understands the international harmonisation issues.

CASA Response

CASA notes the acknowledgement for the need to harmonise with international standards and refers to the response to comment 129.



Grandfathering of previously approved operators should be for a limited time to allow an operator to meet the new standards in a reasonable time without undue cost but should not be entitled to continue forever with such approval.

In addition all EDTO flights should be required to carry suitable survival suits to withstand extreme environmental conditions below freezing on a 1 per 50pax basis. Also the Nav data base must include all suitable airfields that could provide for safe landing with a suitably designed GPS approach to the runway that could be used in an emergency.

CASA Response

AOC holders currently approved to conduct ETOPs will be provided an adequate period of grace to allow them to consider and comply with the new standards. CASA is of the view that it is unreasonable to mandate that all EDTO flights should carry survival suits and, furthermore, CASA has not been presented with any justification to do so. However, AOC holders conducting Polar Area operations will be required to carry at least 2 suits on each aeroplane in certain circumstances; this requirement harmonises with best international practice.



Operations (EDTO)



Airbus acknowledges the worldwide on-going discussions concerning the application of certain of the existing ETOPS provisions on the certification and the operations & maintenance of three and four engine aircraft.

Airbus also acknowledges that further to the comments made by the industry, certain major aviation authorities (EASA/JAA; DOT Canada) have decided that it is presently premature to issue new rules restricting tris and quads and that further operational safety research have to be performed to consolidate the rationale for issuing such new requirements. As a result, they have decided to split the rulemaking: EDTO rules for twins have been put on the fast track while those for trijets and quads have been placed in the slow lane awaiting further operational safety input.

We respectfully suggest CASA to follow the same approach.

Airbus does not argue against the rulemaking initiatives on tris and quads provided they provide a fair and equal treatment between the manufacturers and the operators and a certain level of operational flexibility in their application.

Airbus considers that the grandfather rule as presently written in CASR 121.0244 fails to achieve this objective (Explanations made in the CASR comments form).

CASA Response

CASA partly agrees, specific comments regarding the introduction of EDTO requirements for turbine aeroplanes with more than two engines have been dealt with under the relevant rules previously in this document. However, it is worth noting here that such aeroplanes are exempt from EDTO requirements for a period of eight years after the making of these rules.



Operations (EDTO)



As previously mentioned the need to ensure an ongoing programme to maintain an acceptable level of training, experience and maintenance programmes to reduce the levels of risk would need to be in place and demonstrated by operators.

An industry review of the impacts of medical emergencies, fire and acts of terrorism should also need to factor into any approval process to ensure that procedures set in place will maintain an acceptable level of risk.

CASA Response

Refer to CASA’s response to Comment 129. Medical emergencies and acts of terrorism are outside the scope of the EDTO rule suite, those matters are dealt with elsewhere.


COMMENT 139 – KEY PROPOSED CHANGE 5 – ALL EDTO OPERATORS TO IMPLEMENT A PASSENGER RECOVERY PLAN IN THE ABSENCE OF APPROPRIATE FACILITIES TO ENSURE THE CARE AND SAFETY OF THE FULL COMPLEMENT OF PASSENGERS AND CREW

Any plan or process should be on a consultative basis, and all stakeholders must be encouraged to participate.

CASA Response

CASA has received no other specific comments regarding the proposed requirement for a recovery plan. Consequently, in the absence of any comments, the final rule will be made as drafted.



Operations (EDTO)


COMMENT 140 – KEY PROPOSED CHANGE 6 – SPECIFIED EDTO ALTERNATE AERODROME MUST HAVE OPERABLE RFFS AVAILABLE

We believe that there should be an option to use an airfield in the event of a short term outage of RFFS at international ports. Currently we have approval to use an airfield in the event of a 72 hour outage.

CASA Response

CASA disagrees, the requirement to have RFFS available was consulted with all stakeholders at the working group meeting held in Brisbane, in February 2006. CASA notes following some discussion that it was generally agreed that the proposed rule was acceptable. The requirement also accords with ICAO Annex 6, Part 1, and international best practice.


COMMENT 141 – KEY PROPOSED CHANGE 7 – INTRODUCING AN ADVISORY CIRCULAR TO PROVIDE COMPREHENSIVE GUIDANCE FOR OBTAINING OPERATIONAL APPROVAL TO CONDUCT EDTO

All new aircraft should conduct 20 sectors prior to operating beyond 180 mins to allow for teething problems that are invariably encountered with entry into service aircraft.

CASA Response

For the AOC holder to be eligible for EDTO approval, each relevant aeroplane for EDTO must have an EDTO type design approval. CASA may issue an EDTO approval with or without conditions, including the need for proving flights.



We strongly support the development of this AC. We have certain comments on its content and would also recommend adding further guidance to treat the Accelerated ETOPS concept.

CASA Response

CASA notes the comment of support - specific issues have been dealt with earlier in the document.



Operations (EDTO)



All guidance material should be backed up by a legislative process and promulgated regulations.

CASA Response

The EDTO advisory material will be supporting a comprehensive EDTO suite of rules contained in CAO 82.0, which has a head of power in the Civil Aviation Act, 1988.


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