EASA OPS NPA response

[bookworm]

Has AOPA published its response to the EASA OPS NPA of last year? Any burning issues there?

[Mike Cross]

October 09 Issue of GA Magazine

Consultation on EASA’s OPS-NPA closed on
the last day of July, and IAOPA has made
almost 50 critical observations on the
proposals. The response document has been
collated by Jacob Pedersen of AOPA-Denmark,
who sat on the 001 Working Group which
supposedly wrote the document. Jacob has
often pointed out that despite this, new
proposals kept creeping in of which 001 had
no knowledge.
Among the most important responses is the
fact that the document is so badly written
that it is almost impossible to follow. To find
the answer on a single regulation, the pilot of
a non-commercial complex aircraft must look
up nine different places in the document. The
document is written to satisfy lawyers, not to
explain the rules, and EASA’s online tool is no
substitute for clear regulation. In addition,
regulations should always be proportional,
and those which require one-man operators
of small aircraft to hire consultants to audit
their operations should be abandoned.
Regulations which would require noncommercial
operators to carry greater fuel
reserves than commercial flights should also
be revisited. Other fundamental problems
IAOPA has highlighted include the
requirement to carry oxygen above 10,000
feet, which would force pilots in the
EASA Ops – the holes in the plot mountains to fly dangerously low in areas
where they have operated safely for years; the
proposals that VFR aircraft should carry
certain equipment and conform to restricted
minima when there is no demonstrated safety
gain; the new regulations’ repudiation of the
concept of ‘VFR on top’ would be a
dangerous retrograde step; accelerate-stop
distances as set out in the proposals are
meaningless for single-engine aircraft for
which the concept of a ‘V1’ speed is
meaningless; PLBs should be an acceptable
alternative to ELTs; and the proposal that
helicopters should be forbidden from flying
beyond autorotational distance from land
without having floats fitted is nonsense in the
absence of any safety case for it.
The full list of IAOPA observations on the
OPS NPA can be read on the IAOPA-Europe
website at www.iaopa.eu

AOPA's response to the NPA click here.

[bookworm]

Thanks Mike

You might have meant to point to the link above the one you did:
http://www.iaopa.eu/mediaServlet/OPS_Comments-02b.pdf

02c is the response to the OR section, which is of course still relevant to OPS, but doesn't affect most of us in the way 02b does.

[Mike Cross]

Apologies, thanks for the correction.

[Flyingfemme]

I see the lunatics are still running the asylum.

It will, however, make things much, much safer. We will all be so busy recording rest/duty periods and auditing operations that we won't have time to do any actual flying!