OPS.055 Comment Review Group Meeting # April OPS.055 Comment Review Group Mtg#1
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1 OPS.055 Comment Review Group Meeting # April
2 Membership Chairman: CHÊNE, Claude Independent Advisor HERNÁNDEZ ANTÚNEZ, María Aránzazu EC DG-TREN (Observer) Secretary: CLUZEAU, Jean-Marc EASA HUGUENOT, Nicole ERA BARBA, Gustavo ECA JONES, Kathryn CAA-UK BAUER, Kai EASA THEODORO, Louis DGAC France BOER, Leonard CAA-NL PELAN, Jill ETF CERTAIN, Jean-François AEA SIMONCINI, Luigi ENAC COUTELIER, Daniel ETF TRAP, Leo IACA CLAYTON, Ian ELFAA ULLVETTER, Christer CAA-Sweden EGERER, Julia EASA VON SCHÖPPENTHAU Philip ECA FAMIN, Dannys EBAA WILLIAMS, Russell ECA 3 3
3 EASA Rulemaking Procedure Kai Bauer Rulemaking - Impact Assessment 4
4 Rulemaking Procedure - Outline EASA Phase 1: Programming Phase 2: 4-year Rule making Programme Rule Development Opinion Decision Directly applicable soft law: CS, AMC & Guidance material 5 5
5 Rulemaking Procedure - Outline EASA European Commission Phase 1: Programming Phase 2: 4-year Rule making Programme Rule Development Opinion Decision Drafting Drafting, Comitology, Scrutiny Proposal CION Regulation Commission Regulation Implementing Rules Regulatory with scrutiny Parliament or Council may oppose the proposal 6 6
6 Rulemaking Procedure - Outline EASA European Commission Parliament & Council Phase 1: Programming Phase 2: 4-year Rule making Programme Rule Development Opinion Decision Drafting Drafting, Comitology, Scrutiny Proposal CION Regulation Co- Decision Regulation Council & Parliament Regulation Basic Regulation 7 7
7 Rulemaking Procedure Phase 2: Rule development 4-year Rule making Programme Develop and consult ToR ToR Analyse issue and develop options NPA Phase RIA Draft 2: Rule development Rule RIA Public Consult ation CRD Final review Decision Opinion 8 8
8 Rulemaking Procedure Phase 2: Rule development 4-year Rule making Programme Task initiation ToR Analyse issue and develop options RIA Draft Rule NPA Public Consult ation CRD Final review Decision Opinion 9 9
9 Rulemaking Procedure Phase 2: Rule development Rule development can take place in three formats: Agency, group or international 4-year Rule making Programme Task initiation ToR Analyse issue and develop options RIA Draft Rule NPA Public Consult ation CRD Final review Decision Opinion 10 10
10 Rulemaking Procedure Phase 2: Rule development In the case of a group task, these are the phases, where the groups may contribute 4-year Rule making Programme Task initiation ToR Analyse issue and develop options RIA Draft Rule NPA Public Consult ation CRD Final review Decision Opinion Contribution by Rulemaking Groups Contribution by Review Group 11 11
11 Rulemaking Procedure The role of rulemaking groups Provide technical expertise and experience to the rulemaking effort Provide input to milestone documents: Draft RIA, Draft NPA, Draft CRD Review milestone documents: Draft RIA, Draft NPA, Draft CRD 12 12
12 OPS.055 Terms of Reference 13
13 OPS.055 ToR subject matter Updating of Flight and Duty Time Limitations and rest requirements for commercial air transport (CAT) with aeroplanes taking into account recent scientific and technical evidence 14
14 OPS.055 ToR objectives To fulfil the task as required by the legislator taking into consideration all relevant recent publicly available studies/evaluations and operational experience: by reviewing the flight and duty time limitations and rest requirements specified in Subpart Q, by addressing those areas/points in EU-OPS Subpart Q currently subject to national provisions in accordance with Article 8.4 of Regulation 3922/91 (e.g. extended FDPs with augmented flight crew, split-duty, time-zone crossing, reduced rest and standby), and by submitting regulatory proposals (IR, CS, AMC, GM) based on the preferred option retained after completion of a regulatory impact assessment. 16
15 NPA Comments comments from 2715 Commenters 2629 individual commenters placed comments ~95% of them are UK pilots placing an average of ~18 identical/similar comments More than comments are duplicate Same comments often assigned several times to irrelevant paragraphs, makes the review even more difficult. Actual total number of single comments ~3700 EASA in the process of sorting/grouping comments, using Discover Text (designed by the University of Massachusetts for Government Agencies to deal with large amounts of comments on legislative proposals. ) Detailed review of comments will start after that phase. First phase will focus on the questions to Scientists based upon comment screening. 21
16 NPA Comments Number of comments per group NAAs 384 Crew Association Individual Operators Airline Association Personal
17 NPA Comments Number of comments per group (without duplicates) NAAs 384 Crew Association Individual Operators 748 Airline Association 199 Personal
18 NPA Comments Number of comments per NAAs UK Hungary The Netherlands Norway France Italy Irland Germany Austria Sweden Finland
19 NPA Comments Number of comments by operators per region UK Ireland Germany Austria Portugal The Netherlands International Belgium Spain Sweden Norway Luxembourg US Denmark Slovenia Latvia Finland
20 NPA Comments Number of comments per nationality (excluding individual comments) UK Germany European Austria Ireland Norway The Netherlands France Czech Republic Sweden Italy Spain Latvia Switzerland Hungry International Portugal Belgium Finland Luxembourg Denmark US Slovenia None European
21 NPA Comments Number of comments by Individual per region 1% UK Other 99% 27
22 Scientists Selected NAME NAME Organisation NAME NAME Organisation NAME NAME Organisation Mick Spencer Independent Philippe Cabon Université Paris 5 René Descartes Alex Gundel Alertness Management Institute of Aerospace Medicine DLR German Aerospace Centre 28
23 Planning 29
24 Thank you for your attention 31
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