Appendix D - Simulated ETOPS Program


This Appendix provides the guidance for an air operator to substitute the actual in-service experience at 120 minutes ETOPS operation required to obtain 180 minutes ETOPS approval. It establishes the conditions under which TCCA may authorize an air operator to gain in-service experience through a simulation/demonstration program as a pre-requisite for applying for 180 minutes ETOPS authority. The intent is to permit an air operator who does not have the capability to demonstrate ETOPS operation due to route structure to develop and validate an ETOPS program leading to 180-minutes approval.

The objective of the ETOPS simulation/demonstration is to provide the air operator with an acceptable level of experience to demonstrate its capability to safely operate with a maximum diversion time of 180 minutes.


An air operator who wishes to obtain 180 minutes authority through a simulation/demonstration program is to have at least 12 consecutive months of operational in-service experience with the specified airframe-engine combination before the start of a simulated ETOPS flight.


A request to TCCA must be submitted for approval to conduct a simulated and demonstrated ETOPS program, at least 60 days prior to the intended start of the simulated ETOPS flights. The request must address the criteria contained in this manual for 180 minutes ETOPS programs. The application must also contain information on the proposed simulated operation, the proposed demonstration flights and the proposed actual operation. There may be certain items related to 180 minutes and actual operations, which the air operator will not be prepared to address initially. If applicable, these items must be identified to the POI and PMI and addressed during the final application for 180 minutes authority. The application to conduct simulated or demonstrated ETOPS must include:

a) The proposed simulation and demonstration periods (start and end dates);

b) A list of aeroplanes to be used in the simulation and demonstration, including aeroplane registration, manufacturer and serial number and model of the airframes and engines;

c) A description of the areas of operation proposed for simulated, demonstrated and actual operations;

d) A list of designated ETOPS simulation routes, of sufficient duration to provide adequate simulation and usually the air operator’s longest routes, and demonstration routes required to be the proposed routes;

e) A description of the air operator’s relevant ETOPS in-service experience with other airframe-engine combinations and/or relevant non ETOPS in-service experience with the airframe-engine combination to be used in the simulation, including records of in-flight shutdowns, unscheduled engine removals, and any events that could be considered as ETOPS significant events;

f) A description of aeroplane configuration with respect to the applicable CMP document at the start of simulation, including a schedule of compliance for items not yet incorporated or a statement of the date that full compliance is expected;
Note: items requiring incorporation are discussed in Subsection D.7. c)

g) A minimum number of ETOPS simulation and demonstration segments performed;

h) A supplemental ETOPS maintenance and reliability requirements of Chapter 4 of this manual;

i) A plan to ensure that maintenance personnel, at proposed departure and destination airports in the actual area of operation, are qualified in accordance with Chapter 4 and the CARs;

j) Policy guidance to personnel involved in the program in regards to flight safety as stated in Section D.5 of this appendix;

k) Operations requirements that meet the criteria of this manual and the appendices;

l) A Gate and Milestone tracking plan to allow for the orderly tracking and documentation of specific requirements of the ETOPS; and

m) Any other items relevant to the applicant’s ETOPS program requested by the POI and/or PMI;


Authority to conduct 180 minutes ETOPS though a simulated program is granted via an Operation Specification and is initially limited to the areas of operation in which the air operator has already demonstrated capability. New areas of operation are authorized once the air operator’s 180 minutes ETOPS and overall in-service experience record is proven.


While operating in a simulated ETOPS program, it must be clearly demonstrated that the impact of such a program, on flight safety in actual operation, has been considered. When applying to conduct a simulated ETOPS program, it must be clearly stated that the ETOPS simulation must be terminated immediately during any abnormal or emergency situation.


The following is a list of basic elements which must be considered for a simulation/demonstration program. These elements must be addressed both in the initial request and during operations conducted under the program. The elements are:

a) A fully developed and approved Maintenance Control System;

b) An approved airframe, system and engine reliability monitoring and reporting systems;

c) An approved flight planning and dispatch program;

d) An approved initial and recurrent training and checking program for flight crew and flight dispatchers;

e) An approved initial training, qualifications and authorization program for ETOPS maintenance personnel;

f) A simulation scenario of sufficient frequency and operational exposure to demonstrate the application and response of maintenance and operational support systems;

g) A means to monitor and report ongoing ETOPS performance results during the period of the simulation to provide validation or, as necessary, recommended changes to ETOPS maintenance and operational support systems; and

h) resource allocation and decision making process which demonstrates commitment by management and all personnel involved in ETOPS maintenance and operational systems support.


The simulation is intended to provide for accumulation of in-service experience, which is equivalent to the actual conduct of ETOPS operation. The following must be addressed:

a) Identification of simulated areas of operation and alternates that are proposed to be used to meet the dispatch limitations for an ETOPS alternate airport;

b) A plan to conduct simulated ETOPS with the specified airframe engine for at least 12 consecutive months. The sample size should consist of approximately 1000 separate flights. These operations should be conducted on flights, which contain approximately 3 hours of cruise flight. The number of operations and months of in-service experience may be increased or decreased following a review by the POI on a case-by-case basis considering:

1) Experience with similar technology airframe-engine combinations in conducting ETOPS; (i.e., 757/767, A 310 or A330);

2) Experience with the specified airframe engine combination;

3) Experience with non-ETOPS aeroplane in international over water operations;

4) The record of the airframe engine combination in ETOPS with other air operators; and

5) Other scenarios.

c) Airframe Engine Combination Build Standards.

1) Engine/APU Items. This statement applies equally to Engine manufacturer items, Engine Build Up Systems and Auxiliary Power Units on aeroplanes proposed to be used to conduct simulated ETOPS flights. Normally, the configuration, maintenance, and operating items identified in the current approved Configuration, Maintenance, and Procedures (CMP) document are implemented prior to the start of simulated ETOPS flights. However, items identified in the CMP document by an asterisk may be accomplished per the manufacturer’s recommended schedule.

2) Airframe Items. It is recommended that aeroplane proposed to be used in the simulated ETOPS program be configured to the CMP Build Standard for airframe items at the start of simulated ETOPS flights. Further, if certain equipment significantly impacts maintenance and/or operational procedures then TCCA may require that it may be installed early in the simulation period. Airframe items which the applicant intends to incorporate at a later date are to be identified in the application along with a schedule for compliance. During the final three months of the simulation period, all aeroplanes used to conduct simulated ETOPS flights are to fully comply with the CMP document.

3) Equipment Required by the CARs for extended overwater flight. Any equipment required by the CARs for extended overwater flight, which is not installed at the start of simulated ETOPS operations, must be identified. They should present the PMI with a schedule for the installation of such equipment. If certain equipment significantly impacts maintenance and/or operational procedures then the POI and/or PMI, may require that equipment be installed early in the simulation period.

d) Maintenance Control Systems. The simulation program must be designed to aid air operators in the development of decision-making processes through implementation of supplemental ETOPS maintenance and reliability requirements as specified in Chapter 4 of this manual. It is not within the scope of this Appendix to restate each required program element, but to outline the extent of their application in simulated programs. These are:

1) Dispatch Considerations. All dispatch actions real or simulated including documentation of discrepancies must be completed prior to actual dispatch of the aeroplane. Air operators conducting ETOPS simulations have the same dispatch options as would be exercised in actual ETOPS operations. These considerations are:

i) Minimum Equipment List (MEL). In instances in which the aeroplane does not meet the operator’s ETOPS MEL requirements (but does meet non ETOPS requirements), dispatch options are to include:

A) Taking appropriate action to clear MEL and operate as an ETOPS segment;

B) Substitute an ETOPS capable aeroplane and operate as an ETOPS segment; or

C) Operate the flight as a non-ETOPS segment; and

ii) Domestic Verification Flights. Instances in which the air operator’s program prescribes a domestic verification flight prior to ETOPS, dispatch options
could include:

A) Substitute an ETOPS capable aeroplane and operate as an ETOPS segment.

B) Operate the flight as a non-ETOPS segment; or.

C) Perform the verification flight in accordance with the approved TC procedure and operate as an ETOPS segment.

2) ETOPS Destination Reliability Requirements. The excessive use of the option to operate as a non ETOPS segment is not desirable in that it indicates a lack of commitment to the ETOPS program. Therefore, during the period of simulation, it is recommended that ETOPS destination reliability remain at 98% or higher. The following details the ground rules for destination reliability requirements.

i) An ETOPS flight is considered reliable if it arrives at its planned destination within 6 hours of its planned arrival time;

ii) If an ETOPS flight does not arrive at its intended destination within 6 hours of planned due to factors unrelated to the air operators maintenance or operations programs, then the flight may be counted as reliable. Passenger medical emergencies, air traffic flow control and flights rescheduled for passenger load considerations are examples of flights that would not be counted against the ETOPS destination reliability requirements;

iii) Flights which are conducted under the non ETOPS MEL are not considered as reliable for the destination reliability calculation;

iv) Any ETOPS designated flight which is unreliable under the criteria specified above must be reported to the principal maintenance inspector (PMI) within 72 hours of the event. The report must include:

A) If maintenance related, a description of the discrepancy or malfunction that caused the flight to be unreliable including operating under a non ETOPS MEL;

B) If operations-related, a description of the operational problem which caused the flight to be unreliable;

C) Chronology of the problem beginning with the first notification to maintenance or operations personnel up to the time of flight termination or cancellation;

D) The actions which followed initial notification of the problem;

E) Logistical aspects surrounding the availability of repair parts and/or required maintenance equipment at the station where the problem occurred; and

F) Any other information that may be deemed pertinent to the factors, which caused the flight to be unreliable; and

v) Destination reliability data must be compiled and reported to the PMI each month starting from commencement of ETOPS simulation. This report must include:

A) The number of flights scheduled during the period and total number scheduled since start of ETOPS simulation;

B) The number of flights considered reliable and unreliable during the period and since start of ETOPS simulation;

C) The percentage of flights considered reliable during the period and since the start of ETOPS simulation; and

D) Inservice experience data to include inflight shutdown (IFSD) rates, (3 month, 6 month, 12 month rolling average, as agreed with the PMI), unscheduled engine removals and rates, delays and cancellations, airframe-engine hours and cycles, record of APU start and run reliability, and any other significant operator events required to be reported under the maintenance reliability program identified in Chapter 4. Data such as IFSD rates and events for portions of the applicant’s airplane engine combination fleet which are not intended to be utilized in the ETOPS simulation also be reported.

e) Operations Programs.

1) Training. Flight crew and dispatchers who participate in the simulation must have received ETOPS training prior to participation in the simulation; and

2) Operations. Flights must be planned, dispatched and flown in accordance with this manual. All dispatch actions real or simulated including documentation of discrepancies must be completed prior to actual dispatch of the aeroplane. The following elements must be evaluated:

i) Critical fuel reserves and critical fuel requirements during ETOPS simulated flights;

ii) ETOPS alternate airports;

iii) Operational flight plans including diversion data such as Equal Time Points, critical fuel requirements, heading information;

iv) Minimum Equipment List (MEL) items;

v) Plotting charts, annotated during flight planning as they would for an actual flight.

vi) Communications capabilities in order to familiarize themselves with operational characteristics of HF communication and SATCOM; and

vii) Technical assistance, where exercise are conducted on selected flights to evaluate the availability and quality of assistance from maintenance technical centers.

f) Number of operations are to be observed by TC maintenance and operations inspectors. Simulated malfunctions and contingencies must be given to determine the capability to respond correctly and expeditiously.


The purpose of the demonstration phase is to gain experience and to validate effectiveness consistent with the highest level of safety over actual 180 minute routes. Flights conducted during the demonstration phase must be conducted utilizing applicable CARs and this manual’s criteria for airframe engine configuration, maintenance, dispatch, and flight crew programs. The following must be addressed:

a) Area of operation: The demonstration flights must be conducted over intended routes. Exact tracks, points of entry, diversion airports, and support facilities at origins and destinations should be established as if 180 minute authority were actually being exercised in regularly scheduled service;

b) Sample size and timing: A minimum of twelve (one way) demonstration flights must be flown in the planned actual area of operations. The number of demonstration flights may be increased or decreased by the POI, on a case-by-case basis based on the factors identified in Paragraphs D.7 (b) (1) through (4). The initial flight must be flown approximately 90 days prior to the date of anticipated 180 minute approval. The purpose of these flights is to demonstrate proof of concept in the exercise of all operational and maintenance factors. Results of these flights are used to modify the ETOPS program elements to assure that subsequent flights fully conform to desired profiles. so that the experience base built, repeatable, operations;

c) ETOPS Maintenance and reliability requirements: The maintenance control system for the ETOPS demonstration flights must be fully developed and conform to the requirements of Chapter 4 of this Manual;

d) Configuration compliance: All aeroplanes flying in the demonstration flights must comply to configuration requirements as established in the CMP Document and applicable CARs. Similarly, all training, dispatch, maintenance, and maintainability/reliability standards criteria must be in full conformance with this manual;

e) Configuration delays. Should a delay occur in the configuration of the aeroplane (for example, due to part availability) the simulation program must be continued until ready to conduct demonstration flights;

f) Flight profiles: Demonstration flight segments must be integrated into the operational schedule and submitted in advance to the POI. All flights must conform to the operations specifications and 180 minute ETOPS criteria;

g) Diversion exercises. During the course of the demonstration flights, ETOPS diversion exercises must be conducted in accordance with the established ground rules, at a frequency and extent to be determined by TC. The demonstration diversions must be consistent with the guidelines established by TC for 180 minute ETOPS validation flights. Diversion exercises should not impact the applicant’s destination reliability record or required number of simulation/demonstration flights; and

h) Validation flight credit. At the discretion of TC, the final flight or flights conducted during the demonstration phase may be planned and conducted as the TC required ETOPS validation flight(s). This flight or flights must be coordinated between TC and the air operator well in advance. This provision does not alter the requirement to conduct simulation/demonstration for 12 consecutive months and approximately 1,000 flights.


To validate the accuracy and repeatability of data sources, flight planning methodology and algorithms, and operational decision processes, a "paper airline" data assimilation and analysis must be conducted in parallel to both the simulation and demonstration phases and must address the following:

a) Area of operation: The "paper airline" must be "flown" over the exact route(s) intended for the regularly scheduled ETOPS flights.

b) Sample size and timing: A minimum of one flight per business day, per intended segment, must be planned. "Business day" is described as the period in which normal duties permit data retrieval and analysis. Where the frequency is less than daily, the "paper" scenario must still maintain a minimum analysis volume of at least 5 flights per week.

c) Maintenance program. Although maintenance activity simulation cannot be accommodated in a quantitative analysis scenario of this type, it is recommended that maintenance alert and MEL notification mechanisms be regularly exercised and displayed in conjunction with flight planning releases.

d) Configuration compliance. Not applicable, but it must be assumed that the "paper" airplane in the planning data base for the daily analyses is fully conformed to CMP and ETOPS MEL requirements.

e) Paper flight analysis. For each paper flight, planned versus actual weather and facility status must be analyzed. Items to be analyzed include:

1) Actual versus forecast enroute ETOPS alternate, destination, and terminal alternate weather (ceiling, visibility, crosswind component, icing, runway);

2) Actual versus forecast enroute weather;

3) Actual versus forecast condition of navigation, communication and airport facilities for enroute, alternate, and terminal phase of flight; and

4) Analysis of planned versus actual enroute wind and the resultant variation in planned fuel burnoff to determine impact on the critical fuel scenario.

f) Presentation of data.: During the course of the domestic simulation phase, results from the ongoing daily "paper airline" analyses must be made available for the POI and PMI to review and comment.


ETOPS validation flight or flights must be conducted under the supervision of a TCCA Inspector in accordance with the requirements Paragraph 1.4.3 e) of this manual. The flight(s) may be scheduled approval of the air operator’s 180 minute ETOPS application (see Subsection D.8 g) for guidance on conducting validation flight or flights during the demonstration phase).

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