ICAO SUMMARY REPORT OF THE DEPARTMENT OF CIVIL AVIATION BOTSWANA

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1 Universal Safety Oversight Audit Programme SUMMARY REPORT OF THE DEPARTMENT OF CIVIL AVIATION OF BOTSWANA (Gaborone and Maun, 17 to 23 November 1999) INTERNATIONAL CIVIL AVIATION ORGANIZATION

2 UNIVERSAL SAFETY OVERSIGHT AUDIT PROGRAMME Audit Summary Report of the Safety Oversight Audit Mission to Botswana (Gaborone and Maun, 17 to 23 November 1999) 1. BACKGROUND 1.1 The Department of Civil Aviation (DCA) of Botswana was initially assessed under the voluntary Safety Oversight Assessment Programme from 23 to 27 June 1997 by an assessment team. This audit was carried out from 17 to 23 November 1999 pursuant to Assembly Resolution A32-11 and in accordance with the updated Memorandum of Understanding (MOU) agreed on 21 May 1999 between Botswana and which is included in Attachment A to the audit interim report forwarded to Botswana on 23 December The objectives of this audit were twofold. Primarily, its objective was to fulfill the mandate given to pursuant to the above-mentioned Assembly Resolution. Secondly, the audit was conducted with the objective of ascertaining the progress made in the implementation of the recommendations forwarded during the voluntary assessment conducted in 1997 and to re-ascertain the safety oversight capability of the DCA of Botswana. The audit also aimed to ensure that Botswana is in conformity with Standards and Recommended Practices (SARPs), as contained in Annexes 1, 6 and 8 to the Chicago Convention, associated guidance material and good aeronautical practices. 1.2 On 28 February 2000, Botswana submitted an action plan addressing all the findings and recommendations contained in the audit interim report and also containing comments and clarifications of some of the items. The action plan submitted was reviewed by the Safety Oversight Audit (SOA) Section and was found to be satisfactory. The only concern raised is that some of the short-term actions (LEG/02, PEL/01 and 04 and OPS/01) would take up to seven months to be implemented, which is considered a little longer than short-term actions. On 30 March 2000, Botswana informed that it had advanced the implementation dates of these items by two months, which is satisfactory. 2. CIVIL AVIATION ACTIVITIES IN BOTSWANA During the audit period, there were eighteen air operators issued with an AOC and four approved maintenance organizations in Botswana. Six aircraft operations and nine aircraft airworthiness inspectors (including one each based at the Maun regional office) were recruited to ensure safety oversight of the operators and AMOs. A total of 350 active pilot licences and 182 non-pilot licences were issued. There were 157 aircraft registered in Botswana and two aviation training organizations were active. 3. SUMMARY OF FINDINGS 3.1 General statement The Civil Aviation Act provided the basic legal framework necessary in support of civil aviation safety oversight as it established the responsibility and provided for the making of and their enforcement. The Act, however, did not provide for the responsibilities and power of the DCA and its Director. This should be addressed through an amendment of the draft Act which was under development during the audit period.

3 The civil aviation are general in nature and do not cover the SARPs to the level of detail addressed in Annexes 1, 6 and 8. The have not been amended in the last twenty years and thus did not keep pace with amendments made to the international SARPs The DCA has a sufficient number of appropriately qualified staff and resources to discharge its safety oversight responsibilities. However, it lacked established working procedures and systematic staff training policy and programme. The DCA did not have the ability to retain qualified experts and thus faces serious difficulties in this respect The DCA issues the private pilot licence (PPL) aeroplane, some type ratings, the aircraft maintenance engineer (AME) licence and associated ratings as well as the air traffic controller licence and ratings. For the other licences and ratings, it relies on the conversion or validation of licences and ratings issued by other Contracting States. The personnel licensing system established offers the required level of consistency and integrity but it is based on which are incomplete and outdated. However, licences and ratings directly issued by Botswana are, in practice, issued in accordance with Annex 1 Standards in spite of the lack of established regulatory support The DCA has established a system of certification and surveillance of its operators based on which are incomplete and outdated. The level of oversight of small visual flight rules (VFR) operators is adequate while the oversight of larger operators needs to be strengthened The continuing airworthiness inspection and oversight system established is limited to the renewals of airworthiness certificates. The Air Navigation Regulations (ANRs), combined with the Airworthiness Inspectors Handbook and Aeronautical Engineering Notices (AENs), outlined a very basic oversight requirement. The airworthiness staff were knowledgeable with regard to their duties and responsibilities but lacked the organizational expertise needed to develop an inspection work plan, required inspection checklists and a system of records and reports. There was no evidence of the submission of the required reports expected from the air operators. 3.2 Primary aviation legislation and civil aviation in Botswana Abstract of findings The primary aviation legislation in Botswana is the Civil Aviation Act, 1977 referred to in this report as the Act. It was adopted by the Parliament in 1975 and became effective on 1 July The Act (CAP 71:01), inter alia, authorizes the Minister of Transport and Communications to make to better carry out the intent of the Act, 1977 (16 [1]); give effect to, and carry out, the provisions of the Chicago Convention and any Annex thereto relating to the SARPs (16 [2] [a]); make for the registration of aircraft in Botswana (16 [2] [b]); prescribe conditions for the issue or validation of certificates of airworthiness and for the maintenance and repair of aircraft (16 [2] [c]); prescribe conditions for the issue, validation, renewal, extension or variation of any certificate, licence or other document required under the Act (16 [2] [o]); authorize or require the cancellation, suspension, endorsement or surrender of any licence or certificate granted in pursuance of the Act (16 [2] [u] [iv]); and provide for the imposition of penalties for offences against the, including the seizure and detention of aircraft (16 [4]) The Act did not specifically provide for the establishment of a civil aviation organization nor did it give the Director of the DCA the necessary authority to develop, issue and amend civil aviation based on the provisions of the Annexes to the Chicago Convention. It did not clearly provide the

4 -3- right of access by DCA staff for inspection to all commercial air transport and aircraft maintenance activities. However, it provided the basic legal framework necessary to support civil aviation safety oversight as it established the responsibility and provided for the making of and their enforcement at the ministerial level The civil aviation of Botswana are the ANRs which were published in 1977 and amended in The ANRs are made by the Minister and covered, inter alia, the registration and marking of aircraft, AOCs, airworthiness and equipment of aircraft, aircraft crew and licensing, operation of aircraft, crew fatigue, documents and records, control of air traffic and aerodromes, aeronautical lights and dangerous lights. The ANRs are general in nature and do not cover the SARPs to the level of detail contained in Annexes 1, 6 and 8. In addition, they have not been amended for the last twenty years and, thus, they have not kept pace with current safety oversight requirements, procedures or practices and did not reflect amendments made to relevant SARPs in the last twenty years The ANRs often made to conditions established by the Director. This was effected through Flight Safety Notices, Flight Operations Instructions and AENs but these notices and instructions covered only a limited number of topics contained in the ANRs. A draft amendment to the ANRs showed that it would address some, but not all, of the missing Annex provisions. However, the DCA was determined to delay the promulgation of the draft in order to incorporate the recommendations made as a result of the audit During the audit, two findings relating to the primary aviation legislation and civil aviation in Botswana were made and two recommendations were put forward to rectify them Corrective action plan proposed/taken by Botswana With respect to the recommendation on the need to review and amend the Act and the ANRs to ensure full compliance with related Annex SARPs, the DCA indicated that this will be completed by 31 December In the meantime, the DCA will issue, by 30 June 2000, a Flight Safety Notice to incorporate the provisions of Annexes 1, 6 and 8 as a temporary measure, pending the promulgation of the draft Act and ANRs. On 30 March 2000, the DCA indicated that it was in the process of implementing the proposed action plan and complete the implementation of this action by 30 April 2000 instead of 30 June Civil aviation organization system in Botswana Abstract of findings The DCA is a department of the Ministry of Works, Transport and Communications charged with the responsibility for civil aviation oversight in Botswana. The duties and standards of the department are described in the Scheme of Service Department of Civil Aviation of the Government of Botswana which was revised in The Scheme of Service indicates that the Department of Civil aviation is responsible for the economic, technical and operational of civil aviation in Botswana as well as for the provision of civil aviation infrastructure, facilities and services The safety oversight functions of the DCA are the responsibility of the Flight Safety Division which has a staff of fifteen persons. The division has two sections, both involved with safety oversight activities: Operations and Airworthiness. Licensing responsibilities and activities are shared by the two

5 -4- sections. The Flight Safety Division has no specific administrative support and relied on the DCA s pool of secretaries for secretarial and clerical assistance. The division has established a regional office at Maun airport manned by one airworthiness and one flight inspectors Since 1999, the training of the staff of the DCA was conducted in accordance with the practices of the civil services of Botswana. In that context, the DCA could manage directly the training provided inside the country and has established a training budget for this purpose. The technical and academic training provided outside Botswana is controlled by the Directorate of Personnel Services Management (DPSM), a Government unit responsible for providing training abroad. The DCA establishes and provides an annual training plan to the DPSM indicating its priorities. However, only a few of the requests for training abroad are accepted (three out of 125 in 1999). This arrangement constitutes a serious problem for the DCA to meet its technical training target as most of the training could only be given abroad The DCA has a sufficient number of appropriately qualified staff and resources to discharge its safety oversight responsibilities. However, it has not established adequate working procedures, and the training of staff was not organized in a systematic manner. The DCA also experienced difficulties in retaining its more experienced staff During the audit, three findings relating to the civil aviation organization in Botswana were made and three recommendations were put forward to rectify them Corrective action plan proposed/taken by Botswana With respect to the establishment of formal training policy and programme, the DCA indicated that a training policy, outlining the minimum initial, recurrent and upgrade training that an inspector should receive, will be established by 31 October 2000 and the Government will be requested to provide the necessary funds for training purposes by 15 September On the issue of the Government to take action on the recommendations made by the consultant in charge of the study on the re-organization of the DCA, the DCA indicated that the report of the consultant is being examined by the Ministry of Works, Transport and Communications and the recommendations are expected to be implemented by 31 December With respect to the provision of appropriate credentials to the DCA inspectors, the DCA indicated that action is in progress and credentials will be issued by 30 June Personnel licensing and training system in Botswana Abstract of findings The DCA directly issues the private pilot licence (PPL) aeroplane, some type ratings, the AME licence and associated ratings as well as the air traffic controller licence and ratings. The DCA relies on the validation and conversion of foreign licences for the private pilot helicopter, commercial pilot aeroplane and helicopter, airline transport pilot aeroplane and helicopter licences and the instrument and instructor rating. Flight engineers, flight navigator, glider pilot, free-balloon pilot, flight dispatcher and aeronautical station operators licences are not issued but the ANRs provide for the issuance of the first four licences and for the senior commercial pilot licence.

6 The flight crew and the air traffic control licences are issued by the Flight Operations Section while the aircraft maintenance licences are issued by the Airworthiness Section. The majority of licences are issued through the conversion of foreign licences. No written procedures existed for the process but applicants are required to obtain a Botswana medical assessment and, if they did not hold a Botswana licence of a lower grade, satisfactorily complete an air law examination Licences issued are of the non-expiring type although the professional licences have, in fact, a long-term limit of validity (ten years). To maintain the validity of a flight crew licence, the licence holder must maintain a valid medical certificate and meet the requirement for recent experience (certificate of experience) and for professional licences and rating, a pilot proficiency check (certificate of test). Proficiency checks are conducted by the authorized examiners During the audit, four findings relating to personnel licensing and training in Botswana were made and four recommendations were put forward to rectify them Corrective action plan proposed/taken by Botswana With respect to the recommendation of establishing the detailed conditions that the Director sees fit to issue a licence and rating, the DCA indicated that a Flight Safety Notice specifying the detailed requirements for the issue of a licence and ratings will be implemented by 31 October 2000 and included in Schedule 9 of the ANRs by 31 December The implementation date of the Flight Safety Notice was advanced to 30 April On the subject of ensuring that foreign licences presented for validation or conversion met the respective requirements contained in Annex 1, the DCA indicated that it will, by 31 October 2000, establish procedures to ensure that applicants for validation or conversion of foreign licences meet all the relevant requirements of Annex 1. The DCA will also issue a Flight Safety Notice notifying any additional conditions which may be required for the conversion of most common foreign licences Concerning the establishment of specific requirements and conditions for approving aviation training institutes and courses, the DCA indicated that, by 31 October 2000, it will develop the necessary requirements and conditions in line with guidance for the approval of aviation training institutes and courses With respect to the need to review and amend Flight Safety Notice No concerning medical standards, the DCA indicated that it will complete its review and amend it as necessary by 31 October The DCA also indicated that the designated medical examiners will be advised to use Doc 8984 as a guidance for the implementation of the medical standards contained in Chapter 6 of Annex 1. The implementation date initially indicated was advanced and the action was expected to be completed by 30 April Aircraft operations certification and supervision in Botswana Abstract of findings The certification and surveillance of operators are conducted by the Flight Operations Section which is part of the Flight Safety Division. The Flight Operations Section has six inspectors including one inspector based in Maun. The Flight Safety Division has difficulties in recruiting and retaining experienced inspectors. Only two inspectors had significant airline experience. The other four have been trained ab initio.

7 -6- The Flight Safety Division was in the process of concluding an agreement with Air Botswana to second two of the junior inspectors as first officers for a period of two years. However, Botswana did not have a bonding system and the two inspectors might as well decide to stay with the airline at the end of the secondment The DCA has established a procedure for the surveillance of commercial air transport operators which was essentially based on a yearly inspection at the time of the renewal of the AOC. Some unscheduled inspections were also conducted. When deficiencies are detected, the Head of the Flight Safety Division requested the operator to take corrective action by sending a letter to this effect. Inspections are conducted on the basis of the procedures contained in CAP 335. The surveillance system did not make allowance for monitoring the financial condition of operators During the audit, four findings relating to aircraft operations certification and supervision in Botswana were made and four recommendations were put forward to rectify them Corrective action plan proposed/taken by Botswana With respect to the need to review and amend the ANRs and update Flight Safety Notice No. 001 to ensure full compliance with Annex 6 requirements, the DCA indicated that the ANRs will be reviewed and amended by 31 December 2000 and Flight Safety Notice No. 001 would be updated by 30 April 2000 (implementation date advanced to 30 March 2000) to fully comply with the requirements contained in Annex 6 and the guidance contained in Doc On the subject of the establishment of effective inspection and surveillance procedures and schedule, the DCA indicated that, by 1 April 2001, it will complete the development of procedures for the surveillance of operators and implement an inspection schedule based on the guidance provided in paragraph of Doc With respect to the recommendation on the amendment of the relating to the transport of dangerous goods by air, the DCA indicated that the provisions of Annexes 6 and 18 and the Technical Instructions relating to the transport of dangerous goods by air will be incorporated into the ANRs by 31 December On the issue of ensuring that the training manuals presented by AOC holders contain details of requirements for initial, recurrent and type training for cabin crew, the DCA indicated that operators will be instructed to include such information in their training manuals, to be implemented by 31 October 2000, and that inspections will also be carried out to ensure compliance. 3.6 Airworthiness of aircraft in Botswana Abstract of findings The continuing airworthiness inspection and oversight system in Botswana is limited to the renewals of airworthiness certificates for the 157 aircraft on the Botswana registry. The ANRs combined with the Airworthiness Inspectors Handbook and AENs outlined a very basic oversight requirement. The airworthiness staff is knowledgeable with regards to their duties and responsibilities but lacked the organizational expertise required to develop an inspector work plan, required inspection checklists and a system of records and reports. There was no evidence of receipt of the required reports which should have been expected from the air operators. Some approvals, such as a MEL submitted as a MMEL, were drastically out

8 -7- of date and not reviewed or approved by the Operations and/or Airworthiness Inspectorate. Support staff was non existent and documents were produced by a typing pool dissociated from the Air Safety Division The Airworthiness Section was staffed by nine airworthiness inspectors reporting to the Head of Airworthiness. There was no formal initial or recurrent training programme. Some training has been conducted either at the United Kingdom CAA inspectors course, the Federal Aviation Administration (FAA) Training Academy or at manufacturers systems courses and seminars. Airworthiness inspectors are required to possess an AME licence. Although requirements for continuing surveillance existed, there was little documentary evidence that any recent surveillance had taken place. Inspectors claimed to have conducted visits to the air carrier; however, without a record-keeping system, surveillance could not be verified. Since there were few checklists available for the conduct of inspections, any inspections which may have been conducted were most likely non-standardized. The Airworthiness Section was staffed by nine Airworthiness Inspectors reporting to the Head of Airworthiness. There was no formal initial or recurrent training programme. Some training have been conducted at either the United Kingdom CAA inspectors course, the Federal Aviation Administration (FAA) Training Academy or at manufacturers systems courses and seminars. Airworthiness Inspectors are required to possess an AME licence. Although requirements for continuing surveillance existed, there was little, if any, documentary evidence that any recent surveillance had taken place. Inspectors claimed to have conducted visits to the air carrier, however, without a record keeping system, surveillance could not be verified. Since there were few checklists available for the conduct of inspections, any inspections that may have been conducted was most likely non-standardized During the audit, ten findings relating to airworthiness of aircraft in Botswana were made and ten recommendations were put forward to rectify them Corrective action plan proposed/taken by Botswana With respect to the need for the DCA to review its surveillance needs and consolidate all task instructions and checklists into an inspectors handbook, the DCA indicated that the existing inspector handbook was being reviewed and checklists will be developed on the basis of guidance contained in Doc The revised handbook and checklists are expected to be completed by 31 October The DCA also indicated that the inspectors indoctrination programme will be developed following the completion of the revised inspectors handbook to enable them to use it effectively On the subject of maintaining a copy of the latest maintenance programmes approvals in the technical library of the DCA and the assignment of a librarian to ensure proper maintenance and management of the library, the DCA indicated that the responsibility will be assigned to a staff member and all the necessary documents will be procured for the library by 31 October With respect to the development of procedures for the issue of initial airworthiness certificates, the DCA indicated that it will develop such procedures on the basis of guidance, provide training to its airworthiness inspectors on the developed procedures and issue an AEN to the industry indicating the new requirements and procedures by 31 December On the issue of notifying operators on the use and limitation of the Botswana issued flight permits in the airspace of other Contracting States, the DCA indicated that an AEN will be issued to this effect by 30 June 2000 and will be included as part of the procedures and requirements for requesting a permit to fly into foreign airspace On the subject of the need to develop guidelines and procedures for the issuance of export approvals and notifying operators of the limitations of approvals, the DCA indicated that guidance will be

9 -8- developed and incorporated into the inspectors handbook by 31 December An AEN will also be issued on export approvals by the same time With respect to the development of an inspector work programme and formal checklist, the DCA indicated that such a programme and formal checklists will be developed by 31 December 2000 and included in the inspectors handbook. In addition, a computerized system will be developed using the existing software and new checklists will be developed to complement the existing ones which will also be revised and improved Concerning the need to institute a system of review of maintenance arrangements for new carrier certification purposes and the need for the Airworthiness Section to be involved in the certification of operators, the DCA indicated that a review of maintenance arrangements for new carrier certification will be instituted per guidelines by 31 December 2000 and that it will review the existing inspection programmes to include maintenance issues. AOC inspections will also be included in the airworthiness inspection programme With respect to the recommendation of requiring operators to submit regular reliability programme reports and MELs and ensuring that a structural integrity programme exists, where applicable, the DCA indicated that a reliability programme will be developed with the airline by 31 October The airline will then be required to report regularly to the DCA and the operators will be instructed to produce a MEL by 31 December Procedures for the approval of MELs will be developed and incorporated into the inspectors handbook by the same time. Procedures for ensuring the existence of a structural integrity programme, as applicable, will be established by 31 December COMMENTS 4.1 Botswana has addressed, in its proposed action plan, all the recommendations which were raised in the audit interim report. Following feedback from, Botswana further adjusted its implementation schedule and advanced several of the implementation dates to have actions completed earlier than originally proposed. Botswana is therefore urged to inform of actions completed and also provide evidence that implementation was effected as proposed, as soon as possible, so that the summary report could reflect actions completed. 4.2 Differences identified during the course of the audit are found in Attachments A and B to this summary report and differences vis-à-vis Standards will be included in the relevant Annex Supplement in line with Article 17 of the MOU signed between Botswana and.

10 ATTACHMENT A STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES TO STANDARDS (ANNEX 1 PERSONNEL LICENSING) Standard Differences between the national of Botswana and Standards Not systematically implemented No on the subject but implemented in practice No waivers are issued Implemented for flight crew only Not implemented No on the subject but implemented in practice No on the subject but implemented in practice c) Not implemented No on the subject but implemented in practice Implemented only for aircraft with a maximum certificated take-off mass of more than kg No exist on the requirement for knowledge, experience, flight instruction, skill and medical fitness but the provisions of Annex 1 are implemented in practice Private pilots can receive remuneration when giving instruction to a person who is a member of the same flying club Night flying training experience is required only for passenger-carrying flights. 2.4 Commercial pilot licences (CPL) are issued only through the conversion of a CPL issued by another member State The privileges of the licence include the instrument meteorological conditions (IMC) rating (flight under instrument flight rules [IFR] in an uncontrolled airspace). The dividing line between the command privileges of the CPL and the airline transport pilot licence (ATPL) in commercial air transport is still based on a kg mass limit rather than on flight crew complement.

11 A-2 Standard Differences between the national of Botswana and Standards 2.5 ATPL licences are issued only through the conversion of an ATPL issued by another member State The privileges may not include the instrument ratings. 2.6 Instrument ratings are issued only through the conversion of an instrument rating issued by another member State Not implemented. 2.7 PPL helicopter licences are issued only through the conversion of a PPL helicopter issued by another member State Private pilots can receive remuneration when giving instruction to a person who is a member of the same flying club Night flying training experience is required only for passenger-carrying flights. 2.8 CPL helicopter licences are issued only through the conversion of a CPL helicopter issued by another member State The dividing line between the command privileges of the CPL and the ATPL in commercial air transport is still based on a kg mass limit rather than on flight crew complement. 2.9 ATPL helicopter licences are issued only through the conversion of an ATPL helicopter issued by another member State Instrument ratings helicopter are issued only through the conversion of an instrument rating helicopter issued by another member State Instructor ratings are issued only through the conversion of an instructor rating issued by another member State and 2.13 The glider and free balloon licences are not issued. 3.2 and 3.3 The flight navigator and flight engineer licences are not issued e) Knowledge requirements on human performance and limitation are not implemented a) 1) Minimum experience could be three years in some circumstances b) and c) Not implemented.

12 A-3 Standard Differences between the national of Botswana and Standards 4.4 and 4.5 No exist on the requirements for knowledge, experience, skill and medical fitness but the provisions of Annex 1 are implemented in practice. Chapter 6 There are no specifying the requirements for the issuance of a medical assessment but the provisions of Annex 1 are implemented in practice.

13 A-4 STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES TO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART I International Commercial Air Transport Aeroplanes) Standard Differences between the national of Botswana and Standards The following Annex 6 provisions are not implemented in Botswana: 3.3, 4.1.2, 4.1.3, , , , 4.2.8, 4.2.9, , , , , 4.4.2, 4.4.3, to 4.4.9, 4.5.5, 4.6 to 4.8, to , 5.3, to , 8.5.1, 8.5.2, , and Appendix 2, paragraphs 1, 2 and 10 to Not implemented with the exception of paragraph Not implemented with the exception of paragraph Not implemented with the exception of paragraph to 7.3 Not implemented with the exception of paragraphs 6.7.2, 6.9.1, , 6.10, 6.12, 6.14, 6.19, 6.20, 7.1 and to Not implemented with the exception of paragraphs and to Not implemented with the exception of paragraph 13.1.

14 A-5 STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES TO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART II International General Aviation Aeroplanes) Standard 4.6 through to Differences between the national of Botswana and Standards The following Annex 6 provisions are not implemented in Botswana: 3.1, 3.7, 4.14, 4.16 to 5.2, , , , 7.1.5, to and 9.1. Not implemented with the exception of paragraphs 4.6.3, 4.6.4, 4.8, 4.9 and Not implemented with the exception of paragraphs , 6.1.4, 6.2, 6.3.1, 6.5.1, 6.6, , , , and

15 A-6 STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES TO STANDARDS (ANNEX 6 OPERATION OF AIRCRAFT) (PART III International Operations Helicopters) Standard Differences between the national of Botswana and Standards Section II 1.1 to Not implemented with the exception of paragraphs 1.2, 2.1, 2.2 to , 2.2.2, , 2.2.4, 2.2.5, and to The following Annex 6 provisions are not implemented in Botswana: 2.3.2, 2.3.4, to 2.4.9, to 7.4.2, , 8 and Appendix paragraphs 2, 5.16 to 5.20, 8, 9, 13.1, 13.2 and 14. Not implemented with the exception of paragraphs , , and to Not implemented with the exception of paragraphs 2.7, and to 5.3 Not implemented with the exception of paragraphs , 4.4.1, 4.4.2, , to , 4.7.1, 4.7.2, 4.7.4, 4.8.1, 4.8.2, , 4.15, 4,16, 5.1.1and to 11.3 Not implemented with the exception of paragraph Section III 1.3 to 1.7 Not implemented with the exception of paragraphs 1.4 and to Not implemented Not implemented. Not implemented with the exception of paragraphs and to 3.3 Not implemented with the exception of paragraphs 2.19 and to Not implemented with the exception of paragraphs , 4.4, 4.5.2, 4.6, 4.7, 4.9, 4.9.2, 4.9.4, , 4.9.6, , 4.10, , 4.11, 5.1, 5.1.3, and Not implemented.

16 A-7 STATUS OF IMPLEMENTATION AND LIST OF DIFFERENCES TO STANDARDS (ANNEX 8 AIRWORTHINESS OF AIRCRAFT) Standard Part II, 2.2 Differences between the national of Botswana and Standards No comprehensive airworthiness code is identified.

17 ATTACHMENT B STATUS OF DIFFERENCES AND LIST OF DIFFERENCES TO RECOMMENDED PRACTICES (ANNEX 1 PERSONNEL LICENSING) Note: The Chicago Convention requires that a Contracting State files differences existing between its and Annex Standards. However, due to the specific mandate given to for the implementation of the universal safety oversight audit programme, it is necessary to include differences existing between the National Regulations and Annex Recommendations, including definitions to encourage implementation and for inclusion in the summary report. Differences with Annex Recommended Practices will not be included in the Supplement to the relevant Annex if they should remain unimplemented by the time the final report is published. RPs Differences between the national of Botswana and Annex Recommended Practices The following Annex 1 provisions are not implemented in Botswana: , , and

18 B-2 STATUS OF DIFFERENCES AND LIST OF DIFFERENCES TO RECOMMENDED PRACTICES (ANNEX 6 OPERATION OF AIRCRAFT) (PART I International Commercial Air Transport Aeroplanes) Note: The Chicago Convention requires that a Contracting State files differences existing between its and Annex Standards. However, due to the specific mandate given to for the implementation of the universal safety oversight audit programme, it is necessary to include differences existing between the National Regulations and Annex Recommendations, including definitions to encourage implementation and for inclusion in the summary report. Differences with Annex Recommended Practices will not be included in the Supplement to the relevant Annex if they should remain unimplemented by the time the final report is published. RPs Differences between the national of Botswana and Annex Recommended Practices The following Annex 6 provisions are not implemented in Botswana: 3.5 to 3.8, , , , and to to7.3 Not implemented with the exception of paragraphs 6.7.2, 6.9.1, , 6.10, 6.12, 6.14, 6.19, 6.20, 7.1 and to to Not implemented with the exception of paragraphs and Not implemented with the exception of paragraph 13.1.

19 B-3 STATUS OF DIFFERENCES AND LIST OF DIFFERENCES TO RECOMMENDED PRACTICES (ANNEX 6 OPERATION OF AIRCRAFT) (PART II International General Aviation Aeroplanes) Note: The Chicago Convention requires that a Contracting State files differences existing between its and Annex Standards. However, due to the specific mandate given to for the implementation of the universal safety oversight audit programme, it is necessary to include differences existing between the National Regulations and Annex Recommendations, including definitions to encourage implementation and for inclusion in the summary report. Differences with Annex Recommended Practices will not be included in the Supplement to the relevant Annex if they should remain unimplemented by the time the final report is published. RPs to to Differences between the national of Botswana and Annex Recommended Practices The following Annex 6 provisions are not implemented in Botswana: 3.5, 4.4.2, and Not implemented with the exception of paragraphs , 6.1.4, 6.2, 6.3.1, 6.5.1, 6.6, , , , and

20 STATUS OF DIFFERENCES AND LIST OF DIFFERENCES TO RECOMMENDED PRACTICES (ANNEX 6 OPERATION OF AIRCRAFT) (PART III International Operations Helicopters) Note: The Chicago Convention requires that a Contracting State files differences existing between its and Annex Standards. However, due to the specific mandate given to for the implementation of the universal safety oversight audit programme, it is necessary to include differences existing between the National Regulations and Annex Recommendations, including definitions to encourage implementation and for inclusion in the summary report. Differences with Annex Recommended Practices will not be included in the Supplement to the relevant Annex if they should remain unimplemented by the time the final report is published. RPs Differences between the national of Botswana and Annex Recommended Practices Section II The following Annex 6 provisions are not implemented in Botswana: , , , , 2.3.7, 2.4.6, 3.1.3, 3.1.5, , , , , to , 4.7.3, 4.8.4, and 9.4. Section III The following Annex 6 provisions are not implemented in Botswana: 2.7.3, 3.4, , to , 4.7.2, , , and END

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