The team at Aviation Info Tech are here to help your operator’s requirements by producing your Safety Management System, Fatigue Management Scheme and Operations Manual for your Part NCC Declaration
The Part NCC regulations were introduced to ensure that safety levels for private operators were proportionately matched to the requirements of the largeer commercial airlines.
But instead of the requirement to hold an AOC (Air Operator Certificate), operators instead must submit a declaration regarding their operation, regardless of the aircraft’s location
If you privately operate a business jet (operate non-commercially a Complex Motor Powered Aircraft) on a European register or a foreign registered one based in the European Community (and probably those states that have a special relationship with the EU such as the Isle of Man and the Channel islands) by 25th August 2016 you will have to do what your colleagues on the Cayman and Bermuda registries have been doing since 2009; have an Ops Manual with an SMS and a Fatigue Management Scheme and a proper MEL.
The big difference is that following the requirements of the UK Overseas Territories (the Cayman Islands and Bermuda for example) is straightforward.
Their legislation and requirements are clearly laid out and very easy to find and their Airworthiness Inspectors and Flight Operations Inspectors are very well aware of the difficulties, complexities and special nature of private aviation.
Their standards, however, are higher than Europe’s in that for six years VP-B and VP-C operators have been regularly audited and their ops manuals with all their procedures and processes have been reviewed.
As for those on a European register, or on any register but based in Europe, the situation is different. At the moment, unless you are managed by a AOC, you are following hardly any regulations but from August next year you must comply with EASA’s requirements.
Its rules (Decisions, Regulations, Implementing Rules, Acceptable Methods of Compliance, Guidance Material and Certification Specifications) were not designed to be pilot or engineer friendly; they are promulgated in accordance with Europe’s framework for the preparation and announcement of legislation that affects everything from bananas to bridges.
Some lawyers may love it; most of us pilots and engineers hate it, except perversely people like myself who having ceased flying and now make a living helping those who need manuals, to allow them to do what they do best, fly complex business jets or manage those who operate these expensive, complex and in many cases beautiful pieces of machinery.
You’ve heard of Part-NCC. It is Annex VI of a “Covering Regulation”, Air Operations. It’s shorthand for the specific section of some of the rules that apply to private aviation.
As an operator, as well as Part NCC you have to comply with Annex III – Part-ORO (Organisation Requirements Operations – which covers items such as flight crew (including CRM), cabin crew, security, manuals logs and records, flight time and duty time limitations and rest periods and last, but not least, general requirements.
Also to be followed is Annex V – Part-SPA (Operations requiring Specific Approvals – such as RVSM, MNPS, Low Vis Ops (Cat II/III, EVS Approaches etc), PBN, FANS etc)
If you can find ORO.MLR.100, you will see the rule that requires you to have an operations manual. Its Acceptable Method of Compliance AMC2 ORO.MLR.100 shows a list of what “at least” should be in the manual.
But where do you get the actual information for such items as
- (a) Description of the management system,
- (b) Operational control system;
- (c) Flight time limitations;
- (d) Standard operating procedures (SOPs);
- (e) Weather limitations;
- (f) Accidents/incidents considerations;
- (g) Security procedures;
- (h) Personnel qualifications and training;
- (i) Record-keeping;
- (j) Performance operating limitations; and
- (k) Handling of dangerous goods? Moreover, how do you lay out the information?
You will also be familiar with the OM Part C that covers some of the text required for some Navigation Approvals such as RVSM and MNPS. The requirements of training are in the OM D.
But if you think that you can borrow a mate’s suite of AOC manuals, convert them from PDF to Word and replace its logo and name with yours, think again.
The AOC suite is not only very detailed and contains rules that you do not have to follow but also is totally tuned the its Certificate holder’s operation. It’s a sure bet it that it does not reflect your single aeroplane and simple operation.
The layout of an AOC suite of manual is useful for the way its information is displayed, how the chapters are organised, but that’s just about all.
(But it’s not the only layout. If you Google “operations manual for Part 135 operators” it will bring up a suggested format for a type of commercial air transport that follows the FAA’s rules)
Once your interest is raised in Part NCC, you will be drawn to EASA’s website. The good news is that it is becoming a bit more user-friendly than the original mess.
But there is no JAR-OPS or EU-OPS type manual where almost everything we needed was in a handful of books.
You may be able find a consolidated list of Rules and AMCs and even buy a CD, albeit a bit-out-of date, that bundles a lot of useful information together, and this is a good place to start browsing.
You may find items such as:
NCC.OP.105 Specification of isolated aerodromes — aeroplanes
For the selection of alternate aerodromes and the fuel policy, the operator shall consider an aerodrome as an isolated aerodrome if the flying time to the nearest adequate destination alternate aerodrome is more than…….
NCC.OP.110 Aerodrome operating minima — general
(a) For instrument flight rules (IFR) flights the operator shall establish aerodrome operating minima for each departure, destination and alternate aerodrome to be used. Such minima shall………
NCC.POL.110 Mass and balance data and documentation
(a) The operator shall establish mass and balance data and produce mass and balance documentation prior to each flight specifying the load and its distribution in such a way that the mass and balance limits of the aircraft are not exceeded. The mass and balance documentation shall contain the following information……..
NCC.IDE.A.105 Minimum equipment for flight
AMC1 ORO.GEN.200(a)(1);(2);(3);(5) Management system
NON-COMPLEX OPERATORS — GENERAL
(a) Safety risk management may be performed using hazard checklists or similar risk management tools or processes, which are integrated into the activities of the operator.
ORO.FC.235 Pilot qualification to operate in either pilot’s seat
(a) Commanders whose duties require them to operate in either pilot seat and carry out the duties of a co-pilot, or commanders required to conduct training or checking duties, shall complete additional training and checking as specified in the operations manual.
The check may be conducted together with the operator proficiency check prescribed in ORO.FC.230(b).
But where will you find what a the Right hand seat check” comprises?
Would it not be good idea to cover the above in the manual, somewhere? Or not? What should be included and what can be omitted?
But why bother too much, you may say. After all, a permission to operate a private aeroplane in Europe will not require your obtaining an Approval or a Certificate.
It “just” requires that you submit a Declaration to your CAA. A sort of promise that you will be safe and have an ops manual, a Safety Management System, a Fatigue Management Scheme and an MEL.
No one is going to read the manual or audit you before August 25th.
Surely someone will come up with “Everymans” Ops Manual. But how effective will it be?
Probably any old rubbish will initially suffice but what is the point and how safe is a lazily or ignorantly constructed document that no-one will read, or check.
But your CAA will eventually!
EASA requires that the CAA must ensure that operators comply with its rules so it is certain that some form of auditing and checking will be implemented.
To partially quote AMC1 ARO.GEN.305(d), At least one inspection should be performed within each 48-month cycle starting with the date of the first Declaration received.
In addition, be aware that it is a criminal offense to operate a UK-registered aircraft otherwise in accordance with the terms of an Approval.
Therefore, good luck if to want to write your own manual.
It is surely better to subcontract the task to a specialist, especially to Aviation Info Tech Ltd, a company that has been writing this type of manual for private operators since 2008.
NOTE: For my current Overseas Territories’ clients, worry not.
If you are based in the EU and in the unlikely event that an Article 134 or Private Flight Operations Approval will not be recognised by EASA as an Alternative Method of Compliance with Part-NCC, I will supply you with a suitable manual, based on your current one either as a supplement or as a separate document.
*A Complex motor-powered aircraft is:
a) An aeroplane:
(i) With a maximum certificated take-off mass exceeding 5700 kg, or
(ii) Certificated for a maximum passenger seating configuration of more than 19, or
(iii) Certificated for operation with a minimum crew of at least two pilots, or
(iv) Equipped with (a) turbojet engine(s) or more than one turboprop engine, or
b) A helicopter certificated:
(i) For a maximum take-off mass exceeding 3175 kg, or
(ii) For a maximum passenger seating configuration of more than 9, or
(iii) For operation with a minimum crew of at least two pilots, or
c) A tilt rotor aircraft
For more information about how Part NCC will affect your operation, please contact Aviation Info Tech today