Appendix C - Accelerated ETOPS Operational Approval
This appendix is a means to identify factors which Transport Canada may consider to allow a reduction or substitution of the air operator in-service experience requirements prior to granting Accelerated ETOPS Operational Approval.
An excellent propulsion related service safety record for two-engine aeroplanes has been maintained since the introduction of ETOPS. Current data indicates that the ETOPS process benefits are achievable without extensive in-service experience. Therefore, reduction or elimination of in-service experience requirements may be possible when the air operator demonstrates that adequate and validated ETOPS processes are in place.
The Accelerated ETOPS Operational Approval Program with reduced in-service experience does not imply that a reduction of existing levels of safety will be tolerated but rather acknowledges that an air operator may satisfy the objectives of this document by an equivalent means when considering demonstrated operational capability.
This appendix permits an air operator to start ETOPS when they have established that those processes necessary for successful ETOPS operations are in place and are considered to be reliable. It should be emphasized that failure to meet the established criteria, milestones or reliability levels may result in the losing of the Accelerated ETOPS Operational Approval.
C.2.1 ETOPS Process
The airframe-engine combination for which the air operator is seeking Accelerated ETOPS Operational Approval must be ETOPS Type Design approved. The air operator must demonstrate that they have a program in place to address the process elements identified in this section. The following are the ETOPS process elements:
Airframe/engine compliance to Type Design Build Standard (CMP)
Compliance with the Maintenance Requirements (Chapter4 of this document), requiring the following proven ETOPS programs to be in place:
- Fully developed Maintenance Program, including tracking and control;
- Oil consumption monitoring;
- Engine condition monitoring;
- Propulsion system monitoring; air operator to establish a program that results in a high degree of confidence that the propulsion system reliability appropriate to the ETOPS diversion time will be maintained;
- Training and qualification for maintenance personnel;
- ETOPS parts control;
Aircraft discrepancy resolution.
- Compliance with the Flight Operations Program for ETOPS (Chapter3 of this document) which must address:
- Flight planning and dispatch programs;
- Availability of meteorological information;
- Minimum Equipment List considering ETOPS;
- Initial and recurrent training and checking program for flight operations personnel;
Flight crew and dispatch personnel familiarity with routes, and requirements for, and selection of, en route alternates.
- Documentation of the following elements:
- Technology new to the air operator and significant differences in primary and secondary power/systems (engines, electrical, hydraulic and pneumatic) between the aeroplanes currently operated and the aeroplanes for which the air operator is seeking Accelerated ETOPS Operational Approval.
- The plan to train flight and maintenance personnel to the differences identified in paragraphd.1. above.
- The plan to use proven or manufacturer validated Training, Maintenance & Operations Manual procedures relevant to ETOPS for the aeroplane.
- Changes to any previously proven or manufacturer validated Training, Maintenance or Operations Manual procedures described above. Depending on the nature of the changes, the air operator may be required to provide a plan for validating such changes.
- Details of any ETOPS program support from the airframe manufacturer, engine manufacturer, other air operators or any other outside agency.
- The control procedures when maintenance or flight dispatch support is provided by an outside party as described above.
Air operators shall submit an "Accelerated ETOPS Operational Approval Plan" to Transport Canada 6months before the proposed start of operations. This period will give an opportunity for the air operator to incorporate any refinements that may be required to achieve an Accelerated ETOPS Operational Approval.
The air operator's application for Accelerated ETOPS Operational Approval should:
- define proposed routes and necessary diversion times;
- define processes and resources allocated to initiate and sustain ETOPS;
- identify plan for establishing and maintaining ETOPS build standard compliance;
- document plan for compliance with items outlined in ParagraphC.2.1;
- define Review Gates (a Review Gate is a milestone tracking plan to allow to define the tasks and timing for the necessary tasks to be accomplished); items for which TCCA visibility or approval is sought should be included in the Review Gates.
C.2.3 Operational Approvals
Air operators will be considered on individual merit and capability (case-by-case basis). Accelerated ETOPS Operational Approval is not guaranteed and air operators should await approval prior to planning revenue extended range operations.
Accelerated ETOPS Operational Approvals which are granted with reduced in-service experience should be limited to those areas agreed by TCCA contained within the Accelerated ETOPS Operational Approval Plan. Concurrence from TCCA is required should the air operator wish to add or expand the request.
Air operators may be eligible for Accelerated ETOPS Operational Approval up to the Type Design Approval limit.
C.2.4 Process Validation
The air operator should demonstrate that the process, discussed in paragraphC.2.1, is in place and functions as intended. This may be accomplished by thorough documentation and analysis, or by demonstration on an aircraft (simulation).
If an air operator is currently operating ETOPS on different equipment only minimal documentation may be necessary.
The following elements are beneficial in justifying a reduction in the validation requirements of the ETOPS process:
- Experience with other similar airframes and or engines.
- Previous ETOPS experience.
- Long range, over-water operational experience.
- Flight crew, maintenance and flight dispatch personnel experience with ETOPS.
A process may be validated initially by demonstration on a different aeroplane type. It is then necessary to demonstrate that means are in place to assure equivalent results occur on the aeroplane being proposed for Accelerated ETOPS Operational Approval.
Any validation program should address the following:
- Assurance that the validation program will not be allowed to adversely impact actual safety of operations especially during periods of abnormal, emergency, or high cockpit workload operations. It should emphasize that during these abnormal situations that the validation exercise may be terminated.
- A means to monitor and report performance with respect to accomplishment of tasks associated with ETOPS process elements. Any changes to ETOPS maintenance and operational process elements should be defined.
C.2.5 Accelerated ETOPS Surveillance
Air operators must be aware that any deficiencies associated with engineering and maintenance programs, flight dispatch or flight crew performance may result in the rejection of, amendment to, the claimed credit for reduced in-service experience.
Therefore, an accelerated program leading to an ETOPS Operational Approval is considered feasible so long as the air operators retain commitment to the standards which are contained in their ETOPS Operational Approval Plan and associated programs. During the first year of operation close monitoring will be exercised.
C.2.6 Minimum Requirements
As detailed in Chapter3 of this document, the basic operational experience requirement for a given aircraft/engine combination is:
- 12months operation for 120minute approval;
- 3months of 120minute ETOPS experience for 138minute approval; and
12months of 120minute or greater ETOPS experience for greater than 138minutes.
The Accelerated ETOPS Operational Approval allows for a reduction of in-service experience, based on the degree of compliance with the existing air operator's ETOPS program, which can be validated with supporting documentation. The typical operational experience requirements for a given aircraft-engine combination is:
- Nil experience for 75minutes (ETOPS and CMP program in place);
- 3months ETOPS experience for 90minute approval; and
6months ETOPS experience for 120minute approval.
- All in-service experience requirements noted above assume acceptable performance. Air operator ETOPS program difficulties may require additional in-service experience... and/or removal of the eligibility for Accelerated ETOPS Operational Approval.
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