FLIGHT OPERATIONS PANEL

International Civil Aviation Organization FLTOPSP/WG/2-WP/14 27/04/2015 WORKING PAPER FLIGHT OPERATIONS PANEL WORKING GROUP SECOND MEETING (FLTOPSP/WG/2) Rome Italy, 4 to 8 May 2015 Agenda Item 4 : Active work programme items 4.4: Rescue and Fire Fighting Systems guidance material (Rescue and Fire Fighting Systems guidance material) (Presented by L. Teodoro) SUMMARY Annex 6 part I requires each operator to assess the level of rescue and fire fighting service (RFFS) protection available at any aerodrome intended to be specified in the operational flight plan in order to ensure that an acceptable level of protection is available for the aeroplane intended to be used. Associated Attachment J provides aeroplane operators guidance for assessing the level of RFFS that may be deemed acceptable. The proposition contained in this working paper (WP) consists in amending current Attachment J so as to complete it. In particular, it addresses cases not mentioned till now in Attachment J; it also provides more flexibility for the determination of an acceptable aerodrome RFFS protection level, on the condition that a risk assessment is performed and allows. The amended Attachment J is attached as an appendix to this WP. Action by the FLTOPSP/WG/2 is in paragraph 3. COORDINATION The new Attachment J has been forwarded to the Aerodrome Panel (ADOP) with the aim of ensuring that its content was compatible with Annex 14. ADOP's feedback confirmed the absence of any interference. (11 pages) FLTOPSP WG02 WP-14 AI-4.4 RFFS guidance.docx

FLTOPSP/WG/2-WP/14-2 - 1. INTRODUCTION 1.1 Reminder of the changes introduced during FLTOPSP/WG/1 and previous OPS Panels Attachment J of Annex 6 part I addresses the RFFS protection levels that are deemed acceptable at the aerodromes selected by the aeroplane operator. Amendments to this guidance, as they resulted from FLTOPSP/WG/1 and previous OPS Panels, aimed at: - addressing the operational need for more flexibility (e.g. lower RFFS protection values that those implemented through table J-1) - in particular when levels of aerodrome RFFS protection defined in attachment J cannot be complied with - provided a risk assessment is performed and positive (SMS); - closing loopholes (e.g. no reference to what the acceptable aerodrome RFFS protection level is when temporary downgrades exceed 72 hours at en-route alternate aerodromes); - clarifying guidance if need be. These objectives are maintained: amendments to Attachment J included in this working paper encompass those presented during previous meetings of the FLTOPSP and OPSP. 1.2 In addition, a new change to Attachment J concerning acceptable RFFS protection levels is proposed according to which recommended RFFS protection levels at en-route alternate aerodromes (non EDTO ) and at EDTO en-route alternate aerodromes would become identical. 2. BACKGROUND/DISCUSSION 2.1 First, a formal change to table J-1 is proposed: this table is split into two tables, J-1-1 and J-1-2 in the amended Attachment J, to make a clear distinction between the acceptable RFFS protection levels at departure/destination aerodromes, which are aerodromes the operator will (most probably) use, and acceptable RFFS protection levels at alternate aerodromes for which the probability of use may be extremely low. 2.2 Operational need for more flexibility is the main driver for amending Attachment J. Whereas at many destination and alternate aerodromes, the RFFS protection levels will be compliant with those deemed acceptable in tables J-1-1 and J-1-2, at some, it will not be the case. Actually, an aeroplane operator will have to consider many factors to determine if e.g. an alternate aerodrome is adequate or not. The level of RFFS protection at said aerodrome is only one of them. Weather conditions, runway characteristics and conditions, length of diversion with the correlated need for additional fuel, increase in fatigue due to the extension of the flight duty etc. are other important, and sometimes prevailing, factors. Combination of all these factors will lead an operator to sometimes conclude that, between two candidate alternate aerodromes, the safest is the one with the lowest RFFS protection level, this protection level being possibly lower than foreseen in the tables J-1-1 and J-1-2. In that perspective, SMS is the adequate tool to find the right balance between all factors potentially affecting the safety of operations, with no specific emphasis to be put on the RFFS protection level when selecting an aerodrome.

- 3 - FLTOPSP/WG/2-WP/14 Hence operational flexibility, consisting in giving the possibility to an operator to determine an aerodrome RFFS protection level different from the ones defined in the tables J-1-1 and J-1-2, should be more explicitly addressed in Attachment J and SMS be referred to as the enabler for this flexibility. Thus, developments concerning the use of the SMS and the introduction of flexibility are included in the new paragraph 3.1.3 Variations to the tables J-1 and J-2 of the amended Attachment J. 2.3 Temporary downgrades of the RFFS protection level Only those downgrades of the aerodrome RFFS protection level not exceeding 72 hours are currently mentioned in Attachment J. Deleting the 72 hours period in the definition of a temporary downgrade in paragraph 2 Glossary of terms allows addressing all temporary downgrades, whether they last less or more than 72 hours. 1) Downgrades of 72 hours or less are considered nominal, hence mentioned in the tables J-1-1 and J- 1-2, as was the case for the current table J-1. Yet, splitting the table J-1 into two tables has highlighted a gap: no acceptable RFFS protection level has been defined for alternate aerodromes in case of temporary downgrades not exceeding 72 hours. To fill this gap, the amended Attachment J allows that the RFFS protection level at alternate aerodromes be three categories below the aeroplane RFFS category during such temporary downgrades (see table J-1-2). The rationale for the 3 categories below has been exposed in WP27 presented during FTLOPS/WG/1. To sum it up, the risk severity may be higher if risk probability is lower (classical risk severity/risk probability matrix), that is to say the RFFS protection level at an alternate aerodrome level may be lower if exposure to risk (probability that the alternate be used) is lower. 2) Downgrades exceeding 72 hours, which are not currently referred to in Attachment J, are addressed in the new paragraph 3.1.3 Variations to the tables J-1-1 and J-1-2 : they are dealt with specifically under the SMS framework (see paragraph 2.2 above) 2.4 In addition to the amendments abovementioned which were already exposed in the previous Panel meetings, a new provision would be implemented consisting in having recommended RFFS protection levels defined for en-route alternate aerodromes ( non EDTO ) identical to those defined for EDTO en-route aerodromes. Till now, RFFS protection levels at EDTO en-route alternate aerodromes and at non-edto en-route alternate aerodromes have been addressed in two separate cells of the current table J-1. The probability that the en-route alternate aerodrome be used should be equivalent for any en-route alternate aerodrome, be it EDTO or non non EDTO. This supports the alignment of recommended RFFS protection levels in the future table J-1-2 for all en-route alternate aerodromes. The proposition would be the following: 1) If at least 30 minute notice is given to the aerodrome operator prior to the arrival of the aeroplane, the minimum acceptable Aerodrome RFFS protection level is not lower than Aerodrome RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg or not lower than Aerodrome RFFS Category 1 for all other aeroplanes. 2) If less than 30 minute notice is given to the aerodrome operator prior to the arrival of the aeroplane, the minimum acceptable aerodrome RFFS protection level is:

FLTOPSP/WG/2-WP/14-4 - Two categories below the Aeroplane RFFS category, or Three categories below the Aeroplane RFFS category in the case of a temporary downgrade of less than 72h. Consequently, this means that the only change would concern non EDTO en-route alternate aerodromes when at least a 30 minutes notice is given to the aerodrome operator prior to the arrival of the aeroplane. In that case the provision: Aerodrome RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg or not lower than Aerodrome RFFS Category 1 for all other aeroplanes would replace: Two categories below the aeroplane RFFS category, but not lower than Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg and not lower than Category 1 for other aeroplanes 2.5 Coordination with the ADOP Coordination so as to ensure that no interference existed between the amendment of Attachment J and Annex 14 was initially foressen with the Aerodrome Operations and Services Working Group. After consultation with the ADOP Chairman, members of the ADOP were eventually and directly questioned. Consultation was held by the ADOP chairman. ADOP's feedback confirmed the compatibility of the proposition with provisions of Annex 14. 3. ACTION BY THE FLTOPSP/WG/2 3.1 The FLTOPSP/WG/2 is invited to: a) Take note of the information of this working paper b) Check the relevance of the amendment to Attachment J providing more flexibility to aeroplane operators and recommending that acceptable RFFS protection be identical for all en-route alternate aerodromes, whether EDTO or non EDTO. c) If proposition agreed, forward to the ANC amendment to Attachment J as attached to this working paper. END

FLTOPSP/WG/2-WP/14 to WP concerning Rescue and Fire Fighting Systems guidance material CHAPTER 4. FLIGHT OPERATIONS 4.1 Operating facilities... 4.1.3 Subject to their published conditions of use, aerodromes and their facilities shall be kept continuously available for flight operations during their published hours of operations, irrespective of weather conditions. 4.1.4 An operator shall, as part of its safety management system, assess the level of rescue and fire fighting service (RFFS) protection available at any aerodrome intended to be specified in the operational flight plan in order to ensure that an acceptable level of protection is available for the aeroplane intended to be used. Note. Annex 19 includes safety management provisions for air operators. Further guidance is contained in the Safety Management Manual (SMM) (Doc 9859). 4.1.5 Information related to the level of RFFS protection that is deemed acceptable by the operator shall be contained in the operations manual. Note 1. Attachment J contains guidance on assessing an acceptable level of RFFS protection at aerodromes. Note 2. It is not intended that this guidance limit or regulate the operation of an aerodrome. The assessment performed by the operator does not in any way affect the RFFS requirements of Annex 14, Volume I, for aerodromes. (11 pages) FLTOPSP WG02 WP-14 AI-4.4 RFFS guidance.docx

FLTOPSP/WG/2-WP/14-2 - ATTACHMENT J. RESCUE AND FIRE FIGHTING SERVICES (RFFS) LEVELS Supplementary to Chapter 4, 4.1.4 1. Purpose and scope 1.1 Introduction The purpose of this Attachment is to provide guidance for assessing the level of RFFS deemed acceptable by aeroplane operators using aerodromes for different purposes. 1.2 Basic concepts 1.2.1 While, for every single flight, an all aeroplane operators should aim to have the aerodrome RFFS category, as level of RFFS protection required by Annex 14, Volume I, Chapter 9, 9.2, matching or exceeding the aeroplane RFFS category, some of the aerodromes currently used do not meet these requirements. Furthermore, Annex 14, Volume I provisions relate to the level of aerodrome RFFS to be provided for aeroplanes normally using an aerodrome; hence, this level of RFFS protection does not take into account aeroplanes for which the aerodrome is selected as an alternate aerodrome. 1.2.2 If an aerodrome is exposed to a temporary reduction of its RFFS capability, Annex 14, Volume I, 2.11.3 requires that: Changes in the level of protection normally available at an aerodrome for rescue and fire-fighting shall be notified to the appropriate air traffic services units and aeronautical information services units to enable those units to provide the necessary information to arriving and departing aircraft. When such a change has been corrected, the above units shall be advised accordingly. 1.2.3 In order to determine the acceptability of an aerodrome RFFS protection level, the operator should consider: - For a departure or destination aerodrome, the difference between aerodrome RFFS category and aeroplane RFFS category on the one hand, frequency of flights to that aerodrome on the other hand. - For an alternate aerodrome, the difference between aerodrome RFFS category and aeroplane RFFS category on the one hand, probability that this alternate aerodrome be used on the other hand. 1.2.4 The following guidance is intended to assist operators in making the assessment required by Chapter 4, 4.1.4 with due consideration of the basic principles exposed in 1.2.1 to 1.2.3. It is not intended that this guidance limit or regulate the operation of an aerodrome. Assessment of the adequate RFFS protection level available at aerodromes an aeroplane operator selects highly depends upon their expected use: whereas the departure and destination aerodromes will most probably be used, the probability to use the destination alternate aerodrome(s) is extremely variable and may be extremely low. The proposed paragraph 1.2.3 is included to reflect this significant difference. The same rationale is also the ground for implementing two different tables (tables J-1-1 and J-1-2) in paragraph 3 instead of one table mixing very different cases. These two tables would address departure/destination aerodromes on the one hand (table J-1-1) and any kind of alternate in another table (table J-1-2)

- 3 - FLTOPSP/WG/2-WP/14 2. Glossary of terms Aerodrome RFFS category. The RFFS category for a given aerodrome, as published in the appropriate Aeronautical Information Publication (AIP). Aeroplane RFFS category. The category derived from Annex 14, Volume I, Table 9-1 for a given aeroplane type. RFFS category. Rescue and firefighting services category as defined in Annex 14, Volume I, Chapter 9. Temporary downgrade. RFFS category as notified, including by NOTAM, and resulting from the downgrade of the level of RFFS protection available at an aerodrome, for a period of time not exceeding 72 hours. RFFS category definition is not needed and is deleted. Deleting the 72 hours period in the definition of a temporary downgrade allows addressing all temporary downgrades in attachment J, whether they last less or more than 72 hours. - Downgrades of 72 hours or less are considered nominal, hence mentioned in tables J-1-1 and J-1-2. - Downgrades exceeding 72 hours are addressed in the new paragraph 3.1.3: they are dealt with specifically 3. Minimum acceptable aerodrome RFFS category 3.1 Planning 3.1.1 In principle, the published RFFS category for each of the aerodromes used for a given flight should be equal to or better than the aeroplane RFFS category. However, if the aeroplane RFFS category is not available at one or more of the aerodromes required to be specified in the operational flight plan, an operator should ensure that the aerodrome has the minimum level of RFFS which is deemed acceptable for the intended use in accordance with the SMS policy and its implied instructions contained in the operations manual. When establishing acceptable levels of minimum RFFS for these situations, the operator may use the criteria in Table J-1-1 and Table J-1-2. 3.1.1.1 Intended operations to aerodromes with RFFS categories below the levels specified in Annex 14, Volume I, Chapter 9, 9.2, should be coordinated between the aeroplane operator and the aerodrome operator. 3.1.1.2 Acceptable aerodrome RFFS protection level at a departure or at a destination aerodrome The pre-flight planning stage, the aerodrome RFFS protection level acceptable at a departure or at a destination aerodrome may be as follows.

FLTOPSP/WG/2-WP/14-4 - Table J-1-1 Minimum acceptable aerodrome category for rescue and firefighting (departure and destination aerodromes) Aerodromes Minimum acceptable Aerodrome RFFS category (Required to be specified in the (Based on published Aerodrome RFFS category) operational flight plan) (1) Departure and destination aerodromes Departure and destination aerodrome in case of temporary downgrade and Take-off alternate, destination alternate and en-route alternate aerodromes EDTO en-route alternate aerodrome RFFS category for each aerodrome should be equal to or better than the aeroplane RFFS category. One category (2) below the Aeroplane RFFS category may be accepted where provided as a remission in accordance with Annex 14, Volume I, 9.2 or Two categories below the Aeroplane RFFS Category, in the case of a temporary downgrade of 72 hours or less. but not lower than Aerodrome RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg and not lower than Category 1 for other aeroplanes. Two categories below the aeroplane RFFS category, but not lower than Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg and not lower than Category 1 for other aeroplanes. RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg or not lower than Category 1 for all other aeroplanes, under the condition that at least 30 minutes notice will be given to the aerodrome operator prior to the arrival of the aeroplane.. (1) If an individual aerodrome serves more than one purpose, the highest required category corresponding to that purpose at the time of expected use applies. (2) Annex 14, Volume I, determines the aerodrome category for rescue and firefighting according to 9.2.5 and 9.2.6 except that, where the number of movements of the aeroplanes in the highest category normally using the aerodrome is less than 700 in the busiest consecutive three months, the category provided may be one lower than the determined category. Table J-1-1 only addresses departure and destination aerodromes. Alternate aerodromes are considered in a different table, Table J-1-2. The fact that the Aerodrome RFFS category should be equal to or better than the aeroplane RFFS category is already mentioned in paragraph 1.2.1. The corresponding sentence is deleted (second line, second column). Concerning the remission factor : when performing the evaluation required by Annex 6 4.1.4, an operator can and shall only refer to the published information available to him. The use of a remission factor is an element the aeroplane operator is not necessarily aware of. As it may be confusing, deletion of this reference to the remission factor is proposed. Temporary downgrades addressed in this table are those downgrades of 72 hours or less as was the case before the current amendment was proposed. 3.1.1.3 Acceptable aerodrome RFFS protection level at alternate aerodromes

- 5 - FLTOPSP/WG/2-WP/14 So as to comply with the operational regulations applicable to a given flight, the operator selects alternate aerodrome(s) for various purposes of use. When selecting an alternate aerodrome, many considerations may prevail over the aerodrome RFFS category, among which for instance weather conditions, runway(s) characteristics, length of diversion etc. In addition, the probability to effectively use each of the alternate aerodrome(s) is mainly linked to the exact purpose of use (e.g. destination alternate first rank, second destination alternate) and depends on other various parameters. At the pre-flight planning stage, the aerodrome RFFS protection level acceptable at an aerodrome selected as an alternate may be as follows. Table J-1-2 Minimum acceptable aerodrome category for rescue and firefighting (alternate aerodromes) Aerodromes (Required to be specified in the operational flight plan) (1) Take-off alternate and Destination alternate aerodromes Minimum acceptable Aerodrome RFFS protection level (Based on published aerodrome RFFS category) Two categories below the Aeroplane RFFS category, or Three categories below the Aeroplane RFFS category in the case of a temporary downgrade of 72 hours or less. but not lower than Aerodrome RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg and not lower than Category 1 for other aeroplanes. En-route alternate aerodromes If at least 30 minute notice is given to the aerodrome operator prior to the arrival of the aeroplane, the minimum acceptable Aerodrome RFFS protection level is not lower than Aerodrome RFFS Category 4 for aeroplanes with maximum certificated take-off mass of over 27 000 kg or not lower than Aerodrome RFFS Category 1 for all other aeroplanes. If less than 30 minute notice is given to the aerodrome operator prior to the arrival of the aeroplane, the minimum acceptable aerodrome RFFS protection level is: o or o Two categories below the Aeroplane RFFS category, Three categories below the Aeroplane RFFS category in the case of a temporary downgrade of 72 hours or less. (1) If an individual aerodrome serves more than one purpose, the highest required category corresponding to that purpose at the time of expected use applies. Take-off alternate, destination alternate and en-route alternate aerodromes RFFS protection levels are considered in a separate table, Table J-1-2.

FLTOPSP/WG/2-WP/14-6 - Protection levels are unchanged compared to the initial table except that temporary downgrades concerning alternate aerodromes are now included, allowing the Aerodrome RFFS protection level to be temporarily three categories below the Aeroplane RFFS category, based on the limited exposure to risk. EDTO and non-edto en-route alternate aerodromes are merged into one single category, with protection levels identical to those previously required in the initial table for EDTO en-route alternate aerodromes 3.1.2 For all-cargo operations, further reductions might be acceptable provided that the RFFS capability is adequate to arrest fire around the flight deck area long enough for the persons on board to safely evacuate the aeroplane. 3.1.3 Variations to the tables J-1-1 and J-1-2 The operator should continuously seek the most appropriate aerodrome RFFS protection level available for the aeroplane operated, for each of the variation(s), when used. Whereas a great proportion of the flights to be performed by an operator should meet the criteria in the tables J-1-1 and J-1-2, the operator may encounter difficulties to comply with these protection levels at some airports. Notwithstanding the provisions in 3.1.1., an aerodrome RFFS category below the protection levels defined in tables J-1-1 and J-1-2 may be acceptable. Such variation should be based on a case by case specific risk assessment conducted by the operator as part of its Safety Management System. 3.1.3.1 Variations to the aerodrome RFFS category may concern, among other cases: - An occasional flight; or - Regular flights for which a same aerodrome is selected for a same purpose of use, for a given aeroplane type; or - Temporary downgrades exceeding 72 hours. Where applicable, a variation may be used for a group of aerodromes selected for a same purpose, for a given aeroplane type. A variation may be time limited. A variation may also be modified to reflect the changes of the RFFS protection level available at the concerned aerodrome(s). In accordance with Annex 6, Part I, chapter 4, 4.1.5 the authorised variations and their validity period should be included in the operations manual. 3.1.3.2 Variation for a destination (departure) aerodrome The aeroplane operator s specific safety risk assessment for an aerodrome intended to be used as a destination (or departure) aerodrome may be based on the following elements: - The frequency for the flights intended by the aeroplane operator, in relation with a lowered RFFS protection level (use of a remission factor) as permitted by Annex 14 9.2.3. - A coordination between the aeroplane operator and the aerodrome operator. This coordination may not be practicable or necessary when the flights are extremely occasional. For regular flights the coordination should take into account the principles of Annex 14 9.2.5 and 9.2.6 which are applicable to the aerodrome operator as well as the possibilities to modulate the RFFS protection level available on a daily cycle or seasonal cycle. 3.1.3.3 Variation for an alternate aerodrome

- 7 - FLTOPSP/WG/2-WP/14 The aeroplane operator s specific safety risk assessment for an aerodrome selected as a take-off alternate aerodrome, a destination alternate aerodrome or an en route alternate aerodrome may be based on the following elements: - The probability of effective use of the concerned aerodrome, in relation with - The frequency of selecting the aerodrome for the corresponding purpose of use. Whereas a great part of the flights an operator intends to fly can meet the criteria for selecting aerodromes using the two tables, a certain number of flights (or proportion of flights of a given network) might need variations to the tables. The proposed amendment is intended to address these cases. The amendment introduces the possibility for variations, where the recommended RFFS protection levels cannot be complied with. The use of a risk assessment as part of the operator s SMS is the adequate tool to analyse each individual situation and propose variations for further reduction of the protection level. The variations used by the aircraft operator s may be revised, considering the evolution of the aerodrome concerned and the feedback of the aircraft operator s SMS. 3.2 In flight 3.2.1 The information about the aerodrome RFFS level acceptable at the pre-flight planning stage (including tables J-1-1, J-1-2 and where usable the variations under the specifications in 3.1.3), published in the operations manual according Annex 6 4.1.5, are applicable at the in-flight re-planning point. According to an ICAO basic principle, decision making process for in flight re-planning should be the same as for the planning phase. 3.2.12 In-flight, the pilot-in-command may decide to land at an aerodrome regardless of the RFFS category if, in the pilot s judgement after due consideration of all prevailing circumstances, to do so would be safer than to divert. ----- END ----