Appendix C - Accelerated ETOPS Operational Approval
This Appendix is a means to identify factors, which TCCA may consider to allow a reduction or substitution of in-service experience requirements on a case by case basis, prior to granting Accelerated ETOPS Operational Approval for a specific airframe-engine combination up to and including 180 minutes ETOPS.
In addition to the requirements of this Appendix, an air operator wishing to be considered for an accelerated ETOPS approval up to and including 180 minutes for a specific airframe-engine combination, must either conduct actual ETOPS operation at 120 minutes for a minimum period of at least 3 months or comply with the condition of a simulated ETOPS program as defined in Appendix D. On a case-by-case basis, an air operator already operating at 180 minutes with a different airframe-engine combination may obtain 180 minutes approval in less than 3 months provided that all the conditions of this Appendix are met.
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 are tolerated but rather acknowledges that an air operator may satisfy the objectives of this document by an equivalent means when considering demonstrated operational capability.
An air operator may be permitted to start ETOPS operations under the conditions of this Appendix when it has established and demonstrated that those processes necessary for successful ETOPS operations are in place and are considered to be reliable. It must 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. It must be demonstrated that there is a program in place to address the process elements identified in this section.
The following are the required ETOPS process elements:
a) Airframe-engine compliance to Type Design Build Standard (CMP)
b) Compliance with the ETOPS Maintenance and reliability requirements as described in Chapter 4 of this manual, requiring the following proven ETOPS programs to be in place:
1) Fully developed Maintenance Control System, as required by Section 4.2 of this manual;
2) Amended Maintenance Control Manual (MCM) as required by Section 4.3 of this manual;
3) Oil consumption monitoring as required in Section 4.4 of this manual;
4) Engine condition and trend monitoring (ECTM) as required in Section 4.5 of this manual;
5) Verification as required by Section 4.6 of this manual;
6) Reliability Program as required by Section 4.7 of this manual;
7) An established propulsion system monitoring program, that results in a high degree of confidence that the propulsion system reliability appropriate to the ETOPS diversion time is maintained as per Section 4.9 of this manual;
8) Initial, update and additional training as well as authorization for all personnel involved in ETOPS operations;
9) ETOPS parts control as per Section 4.11 of this manual; and
10) Aeroplane defect control system.
c) Compliance with the Flight Operations Program for ETOPS as described in Chapter 3 of this manual, which must address:
1) Flight planning and dispatch programs, including initial and annual recurrent ETOPS training for flight dispatcher;
2) Availability of meteorological information;
3) Minimum Equipment List (MEL) considering ETOPS operation; and
4) ETOPS initial and recurrent training and checking program for each flight crew member.
d) Documentation of the following elements:
1) Technology new to the air operator and significant differences in ETOPS significant systems between the aeroplane currently operated and the aeroplane for which the air operator is seeking Accelerated ETOPS Operational Approval;
2) The plan to train each flight crew member, flight dispatcher and maintenance personnel to the differences identified in Paragraph C.2.1 d) 1. above;
3) The plan to use proven or manufacturer validated Training, Maintenance & Operations Manual procedures relevant to ETOPS for the aeroplane for which the air operator is seeking accelerated ETOPS approval;
4) Changes to any previously proven or manufacturer validated Training, Maintenance or Operations Manual procedures described above. Depending on the nature of the changes, a plan for validating such changes, may be required;
5) Details of any ETOPS program support from the aeroplane type certificate holder, engine type certificate holder, other air operators or any other outside agency; and
6) The control procedures when maintenance or flight dispatch support is provided by an outside party as described above.
An "Accelerated ETOPS Operational Approval Plan" must be submitted to TCCA a minimum of 6 months before the proposed start of operations. This period gives an opportunity to incorporate any refinements that may be required to achieve an Accelerated ETOPS Operational Approval.
The application for Accelerated ETOPS Operational Approval must:
a) Define proposed routes and necessary diversion times required to support the applicable routes;
b) Define processes and resources allocated to initiate and sustain ETOPS;
c) Identify the plan for establishing and maintaining ETOPS build standard compliance;
d) Document plan for compliance with items outlined in Section C.2.1; and
e) 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 must be included in the Review Gates. These milestone tasks must be completed during the approval process although the timing may vary.
C.2.3 OPERATIONAL APPROVALS
Operational approvals are to be considered on individual merit and capability (case-by-case basis). Accelerated ETOPS Operational Approval is not guaranteed and air operators are encouraged to await approval prior to planning revenue ETOPS operations.
Accelerated ETOPS Operational approvals which are granted with reduced in-service experience are to be limited to those areas agreed by TCCA contained within the Accelerated ETOPS Operational Approval Plan. Concurrence from TCCA is required if the air operator wishes 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
All the process elements identified in Section C.2.1 must be proven prior to an Accelerated ETOPS Operational Approval. In order for a process to be considered proven, it first must be defined. Thus, the various elements of the process must be clearly demonstrated. Role and responsibilities of the personnel who are managing this process must be defined including the training requirements.
It must be demonstrated that the established process is in place and functions as intended. This may be accomplished by thorough documentation and analysis, or by demonstration on an aeroplane (simulation) to confirm that the process works and consistently provides the intended results. There must also be a system in place to ensure that there is proper feedback in the event there is a need to revise the process.
Any simulation flights must not be initiated prior to:
a) The completion of the applicable training of flight crews, maintenance personnel, dispatch personnel;
b) The approval of the ETOPS maintenance control systems;
c) The reliability program being in place and operating; and
d) The aeroplane being configured for ETOPS.
Simulation is a coordinated operation between flight operation and maintenance of all the elements of an air operator’s ETOPS process in a non-ETOPS environment.
An air operator who is currently operating ETOPS on different airframe and/or engine combination may be able to demonstrate that it has a proven process in place and may only require minimal validation. However, it may be necessary to demonstrate that there are means in place to assure an equivalent results on the aeroplane for which an accelerated ETOPS approval is requested.
Given that air operator’s accelerated ETOPS approval is considered for its individual merit and capability on a case-by-case basis at the time of the application, it is important to note that the following elements, although beneficial in justifying a reduction in the validation requirements of the ETOPS process, do not automatically justify that the process identified in Section C.2.1 is a proven one:
a) The air operator’s experience with other similar airframes and/or engines;
b) The air operator’s previous ETOPS experience;
c) The air operator’s long range, over-water operational experience; and
d) The air operator’s flight crew, maintenance and flight dispatch personnel experience with ETOPS.
A process may be validated initially by demonstration on a different aeroplane type or airframe-engine combination than the airframe-engine combination intended to be used in the Accelerated ETOPS operation. 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 must address the following:
a) Assurance that the validation program does not adversely impact actual safety of operations especially during periods of abnormal, emergency, or high cockpit workload operations. It must be emphasized that during these abnormal situations the validation exercise may be terminated;
b) 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 must be defined;
c) Assurance that the validation program provides sufficient frequency and operational exposure to validate maintenance and operational support systems;
d) Prior to the start of the process validation program, the following information is submitted to the Principal Operating Inspector (POI):
i) Validation period, including start dates and proposed completion dates;
ii) Definition of the aeroplane, manufacturer and serial number and model of the airframe and engine;
iii) Description of the area of operation proposed for the validation and actual ETOPS operation; and
iv) Definition for the designated ETOPS routes that should be of a duration necessary to ensure process validation; and
e) Compilations of the result of the ETOPS process validation that :
i) Documents how each element of the ETOPS process was utilized during the validation;
ii) Documents any short comings with the process elements and measures in place to correct short comings;
iii) Documents any changes to the ETOPS processes that were required after an in-flight shutdown (IFSD), unscheduled engine removals, or any other significant operational events; and
iv) Provides periodic process validation reports to their POI. This may be addressed during the review gates.
C.2.5 ACCELERATED ETOPS SURVEILLANCE
Deficiencies associated with engineering and maintenance control systems, flight dispatch or flight crew performance may result in the rejection of or 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 must be exercised.
C.2.6 MINIMUM REQUIREMENTS
1) 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 airframe-engine combination is:
a) Minimal or no in service experience for 90 minutes approval;
b) Minimal or no in service experience for 120 minutes approval; and
c) 3 months 120 minutes ETOPS experience for 180 minutes approval.
On a case-by-case basis, the in-service experience requirements for an accelerated ETOPS approval specified in this paragraph may be further reduced provided that the air operator can successfully demonstrate to the satisfaction of the Principal Operation Inspector (POI) and Principal Maintenance Inspector (PMI) that all of the elements of their ETOPS process for the applicable airframe-engine combination are proven and function as intended.
This may either be accomplished via:
a) The air operator conducting a simulated ETOPS program as per the requirements of Appendix D of this document; or
b) Supporting documentation and demonstration that the elements of a ETOPS process that has been validated for another airframe-engine combination and could be applicable to the new airframe-engine combination would function to an equivalent level of safety on the new airframe-engine combination; and
c) Those elements of the ETOPS process that are unable to be proven until the new airframe-engine combination enters service, must be validated prior to the approval of the requested authority.
2) 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.