EASA Business Jets Workshop

Introduction

The first EASA Business Jet workshop was help on 3rd and 4th December 2019 at EASA premises in Cologne. The event was dedicated to discussion between the Business Aviation Industry and Aviation Authorities covering the regulators’ achievements and ongoing activities to support industry and manufacturers’ expectations for their projects in the coming years. The event was hosted by the certification directorate but also included presentations from the flight standards directorate who deal with flight operations and crew training issues.

There were presentations on the following topics:

EASA Reorganisation

This session explained that EASA’s certification directorate is being reorganised to have a team dedicated to issues relevant to business jets. This comes about because of a recognition that whereas the certification standards for large and commuter category aircraft (CS-25 and CS-23 respectively) are applicable to all aeroplanes there are significant differences between the requirements for airliners and business jets.

Low visibility operations

Francisco Arenas of EASA provided an update on a rulemaking task for all weather operations (RMT.0379). The objective of the rulemaking task is to update the rules for all weather operations so that operators can take advantage of safety and economic benefits of new technologies and operational experience. RMT.0379 is a ‘cross-domain’ task as it will involve changes to regulations for airworthiness, aerodromes, operations and flight crew licensing. The proposed regulations will be performance based and technology independent, in that the implementing rules (IR) will state the safety objectives to be achieved and the means to be used to achieve those objectives will be described in acceptable means of compliance (AMC). If new technologies or operating techniques become available in the future, then these could be implemented via alternative means of compliance (AltMoC) proposed by an aircraft operator or AMC published by EASA. The IR should not need to be revised again.

The presentation concentrated on enhanced vision systems (EVS). There are currently more than 3000 business aircraft equipped with EVS yet very few operators have applied for approval to take advantage of improved aerodrome operating minima. An enhanced vision system consists of a sensor mounted on the outside of the aircraft and a display system, either a head-up display (HUD) or a head-worn display (HWD). A system that allows operation to lower aerodrome operating minima will be described as an enhanced flight vision system or EFVS whereas an EVS that is used only for enhanced situational awareness will continue to be known as EVS. The certification specifications for all weather operations (CS-AWO) are being updated to include the specifications for EFVS. The capabilities of certificated EFVS systems will be described in the aircraft flight manual (AFM).

The proposed regulation introduces a ‘family’ of operational approvals to meet the needs of different operators as follows:

EFVS-200: Commercial air transport (CAT) operators and non-commercial operators of complex motor-powered aircraft (CMPA) will be able to use an certificated enhanced flight vision system (EFVS) to conduct straight-in 3-D approach operations and to continue beyond the decision height provided that the pilot is able to see the runway using the EFVS. The pilot will need to have sight of the runway using ‘natural vision’ no lower than 200 feet above the runway threshold. The aircraft operator will be required to have appropriate operating procedures and provide specific training to flight crew. The RVR required for an EFVS-200 operation will be one-third less than the RVR required for ‘standard’ operations subject to a minimum of 550m.

EFVS-200 rules will appear in the AMC to Part-CAT and Part-NCC. EFVS-200 will not be available to specialised operators (i.e. aerial work) or non-commercial operators of other-than complex motor-powered aircraft.

EFVS-A: Operators will be able to apply for specific approval for EFVS-Approach operations. The approval process will be similar to existing low-visibility operations approvals (e.g. low visibility take-off or category II approach operations). Operators will need an aircraft equipped with a certificated EFVS, operating procedures, crew training and will need to present a safety case demonstrating an equivalent level of safety to ‘standard’ operations. Like EFVS-200, EFVS Approach operations will allow an approach to be continued beyond decision height provided that the pilot is able to see the runway using the EFVS. The pilot will need to have sight of the runway using ‘natural vision’ no lower than 100 feet above the runway threshold. The RVR required for the approach will be determined by the ‘visual advantage’ available for the installed EFVS system which will be specified in the aircraft flight manual (AFM). The RVR required could be less than 550m provided that the aerodrome has appropriate low visibility procedures. EFVS approach operations will be permitted to more runways than EFVS 200 operations provided that the operator establishes a procedure to verify the suitability of the approach procedure.

EFVS-L: Operators may also be approved for EFVS landing operations (EFVS-L). This requires an aircraft to be equipped with a certificated EFVS landing system which includes flare guidance. The requirements will be similar to EFVS-A but the minimum height to which the approach may be continued without natural visual reference will depend on the certification of the equipment as described in the AFM, so it may be less than 100 feet.

Aircraft operators will have the responsibility to determine which runways and approach procedures are suitable for EFVS operations depending on the capability of their aircraft and the requirements stipulated in AMC. An amendment to the regulations for aerodromes will require airports to promulgate the required information in the national aeronautical information publication (AIP). Airports will also be encouraged to promulgate a runway as ‘EFVS ready’ if all the requirements for EFVS are known to be satisfied for that runway.

Personnel from Dassault have been closely involved in the rulemaking process and made a presentation including a pilot-eye video presentation of various approaches using the ‘Falcon Eye’ EFVS-L system. They emphasised the potential operational benefit of being able to operate to more secondary airports that are not equipped with sophisticated approach aids. It is anticipated that EFVS will also be of interest to regional airlines. It is planned that the revised regulations will come into effect in 2021.

Risk-Based Approach for Business Aviation

This session was presented by the Kyle Martin of General Aviation Manufacturers Association (GAMA). GAMA is a global trade association representing aircraft manufacturers and operators.

17,000 aircraft registered in the EASA States may be classified as business jets. This represents 5% of all aircraft. The certification standards for business jets are divided between CS-23 (for aircraft with a maximum take-off mass of less than 5700kg) and CS-25 (for aircraft with a maximum take-off mass of 5700kg or greater). CS-23 subdivides the requirements into different levels according to seating capacity and performance so that the rules are proportionate. The requirements for design and construction of a single-engine piston aeroplane like a C172 are less demanding than for a 10-seater jet like the Citation CJ4. CS-25 has a single set of rules for all transport category aeroplanes. An aircraft like the 12-seat Citation XLS+ has to meet the same requirements as a Boeing 777 with 300 seats and a maximum take-off mass more than 30 times that of the XLS+. GAMA would like to see the proportionate approach of CS-23 used in CS-25 with a specific category for business aircraft.

GAMA would also like to see this ‘safety continuum’ approach extended to the operational rules. They supported the approach used in rulemaking task 379 for all weather operations (see above) which aims to develop technology-independent rules. GAMA also perceive the cost and complexity of training for pilots and technicians to be an issue for business jet operators. They would like to see a simplification of the type-rating requirements for Part-66 licences.

Cockpit Door

The session was presented by Eduard Ciofu, Head of Flight Operations for EASA.

The requirements for a reinforced cockpit door were adopted as an ICAO standard following ‘911’. The requirements were intended to mitigate the risks of ‘unlawful interference’ on airliners. The security risk profile of business jet operations is different to airlines. The reinforced cockpit door requirements were not aimed at business jets. At the time when the ICAO standard was adopted aircraft with a maximum take-off mass (MTOM) of less than 45,500 kg and less than 19 seats were excluded. There are now business jet types with an MTOM of more than 45,500 kg so the rules have been reviewed. Reinforced cockpit doors are now required for all aircraft with a MTOM of more than 54,500 kg, for aircraft with an MTOM of more than 45,500 and a maximum passenger seating capacity of more than 19 and for all aircraft with a maximum seating capacity of more than 60. The relevant seating capacity is the maximum operational passenger seating capacity (MOPSC), i.e. the seating capacity for the particular aircraft as specified in the operations manual. The European rule (ORO.SEC.100) is aligned with the ICAO standard.

Cabin Interior Requirements for Business Jets

Fabrizio Negri and Peter Crittenden of EASA provided an explanation of the new Annex S to CS-25.

The certification standards governing the design of large aircraft interiors in CS-25 are not always a good fit for business jets. Many business jet interiors have been certified on the basis of special conditions (SC) and certification review items (CRI). Appendix S has now been added to CS-25 to formalise some of the commonly used SC/CRI and to provide an alternative to the basic conditions of CS-25. Appendix S is applicable to:

  • non-commercially operated aeroplanes that have a passenger seating capacity of less than 19 or (for larger aircraft) have a passenger seating capacity of less than half the maximum seating capacity allowed by the type certificate and
  • low-occupancy aeroplanes whether operated commercially or non-commercially. ‘Low-occupancy’ means either that the seating capacity is less than 19 or the capacity of each seating zone between emergency exits is less than one third of the capacity that would be allowed and less than 100 per deck.

Appendix S allows some cabin fitments that are not permitted by the basic requirements of CS-25. For example, internal doors may be allowed in the cabin even if the door is in an evacuation route. Some of detailed requirements are different for commercially and non-commercially operated aircraft because of the different level of risk that is accepted for each type of operation. If an aircraft is certified according to the requirements for non-commercial operation, then it may be difficult or impossible to use the same aircraft for commercial operations. Other aircraft may be certified for both types of operation subject to particular conditions for commercial operations, such as restricting the seating capacity or locking internal doors open.

Fabrizio and Peter provided an overview of some of the provisions of Appendix S as follows:

Internal doors: Internal doors may be permitted in the aircraft cabin. For non-commercial operations the door must be frangible, there must be a dual latch and an alert in the flight deck if the door is not in the correct position for taxi, take-off and landing (TTL); passengers must be provided with a briefing about opening or breaking down the door. For commercial operations the door must also be placarded and must open automatically (powered) unless cabin crew are carried.

Access to emergency exits: It may be permissible for emergency exits to be partially obstructed in flight provided that they are unobstructed for TTL. This might be because a seat can slide or recline across an exit. The designer would need to demonstrate that the actual number of passengers could be evacuated despite the obstructed exit or else there must be a ‘compelling alert’ in the cabin to remind the passenger to move the seat clear of the exit.

Isolated compartments (e.g. bedrooms): Must be equipped with smoke/fire detection with a flight deck indication unless the designer can show that any fire would be detected quickly.

De-activation of emergency exits: Emergency exits may be blocked off if the distance from passenger seats to an active exit is acceptable and the number of passengers is restricted.

Aisle Width: May be reduced in-flight (e.g. due to moveable seats) if the designer can demonstrate that it’s still possible to access all parts of the aircraft within 30 seconds (for firefighting).

Signs and placards: The number of ‘no-smoking’ and ‘fasten seatbelt’ signs may be reduced. If the aircraft is designated as a ‘no-smoking’ aircraft, then no-smoking signs in the cabin can be replaced by a single placard visible as passengers board through the main entry door. In this case ashtrays are not required.

Cabin Attendant Seats: Cabin crew seats are not required to have a direct view of seated passengers for non-commercial operations but at least half of the cabin crew seats should face the cabin.

Cargo Compartments: The size of a class B cargo compartment is dictated by the need to be able to fight a fire from the aircraft cabin without stepping into the compartment. AMC stipulates that this allows a reach of 52 inches from the door to the end of the compartment. This may now be varied if the designer can demonstrate that a fire can be extinguished.

Extended Range Operations

Herve Julienne, the EASA rulemaking office responsible provided a description of the requirements for operation of more than 60 minutes from an adequate airport (CAT.OP.MPA.140).

A recent rule change (Regulation 2019/1387) has amended the requirements. Previously any aircraft with a MTOM of more than 45,360 kg required ETOPS approval to operate more than 60 minutes from an adequate airport on a commercial flight. The requirement for ETOPs approval now applies only to aircraft with a passenger seating capacity of more than 19 regardless of MTOM. Aircraft with 19 seats or less may operate up to 120 minutes from an adequate airport and up to 180 minutes with approval of the competent authority. The rulemaking task for this topic is not yet complete so whereas the rule has been amended the AMC still refers to the MTOM limit. A revised AMC is expected in the first quarter of 2020.

Crew Altering and Human Factors

Nicolas Durandeau of EASA described the certification standards for crew altering and the subdivision of messages into warnings, cautions and advisories. Cautions, which demand immediate crew awareness, require ‘dual sense’ altering, for example a visual and an aural warning. Nicolas explained that EASA find many non-compliances with the requirements including inappropriate use of colours reserved for warnings and cautions (red and amber) for other annunciations and ambiguous presentation of alert elements.

Nicolas also explained that a rigorous approach must be applied to the evaluation of human factors during the certification process and that this should involve human factors experts. This took 1 ½ hours.

Part-26 and Halon Replacement

Youri Auroque of EASA provided an update on ‘Part-26’. Part 26, implemented through Commission Regulation 2015/640, as amended transposes the requirements that previously appeared in. JAR-26. It applies to commercially operated large aircraft Unlike certification specifications, which apply at the time of certification, Part-26 applies to products that are already in service so changes to Part-26 may require operators to make modify aircraft that are already in service. CS-26 provides guidance on the implementation of Part-26.

A regulation amending Part-26 (2019/133) has recently been published. This amends the requirements for fire extinguishers, seat crashworthiness and thermal/acoustic insulation. ‘Low occupancy aeroplanes’, including most business jets, are excluded from the requirements for seat crashworthiness.

Halon fire extinguishers are being phased out because of the damage that halon causes to the ozone layer. ICAO standards have been updated to require implementation of alternative extinguishers. In Europe use of halon is regulated through a general ‘Ozone Regulation’ (1005/2009) as well as thorough aviation-specific regulations. There are different implementation dates and requirements for the replacement of different extinguishers fitted to aircraft, for example portable extinguishers in the cabin and installed extinguishers in cargo compartments or engines. We were reminded that replacement of portable extinguishers with a different type of extinguisher is a major modification requiring input from a Design Organisation Approval holder.

Landing Distance Computations

Giovanni Cima, the responsible rulemaking officer at EASA, introduced some changing requirements for calculation of required landing distance in-flight. The objective of the changed requirements is to reduce the number of runway excursion accidents and to provide additional operational flexibility for business jet operators.

ICAO standards have been amended to introduce a global reporting format (GRF) for runway condition and braking action. These revised standards mean that the runway condition report received from ATC can be correlated directly to performance information available for the aircraft. Aircraft manufacturers are expected to update aircraft flight manuals (AFM) to the new standard. Pilots will need to use this data to make a landing performance calculation in-flight, based on the latest available weather and runway conditions. At this stage, the landing distance must be 15% longer than the distance required by the calculation [CAT.OP.MPA.303]. If updated AFM data is not available then generic factors can be used for various runway conditions, but these will be more restrictive and may, therefore, impose an operational penalty.

Reduced Required Landing Distance Operations.

Giovanni also introduced a separate rule change as part of the same amending regulation that will allow ad-hoc charter operators and regional airlines serving public interest services to use alternative criteria for making a landing performance calculation during flight planning. Currently all commercial air transport operators are required to plan flights on the basis that the aircraft will be able to land and stop within 60% of the landing distance available at the destination airport. Under the revised rules operators will be able to apply for approval to use 80% instead of 60% for specific airports. This may open up a wider range of destination airports of allow increased payload. To get this approval there will need to be a specific statement in the AFM that the aircraft is suitable, pilots will require additional training and the operators will have processes to monitor that approaches and landings are flown correctly. The applicable rule is already published (CAT.POL.A.255). An EASA decision including the related AMC and GM is expected with an effective date of November 2020

Innovation

The final session of the workshop did not discuss rule changes but explained some work that EASA is undertaking to encourage innovation in partnership with industry. The session was presented by a man with a beard who didn’t introduce himself.

The beard-man spoke eloquently using the latest management jargon. He has established an innovation cell and a network community within EASA. They use an intranet-based community tool for cross-domain knowledge sharing, foresight activities and collaboration. They aim to partner with industry for early stage cooperation.

Companies planning to develop a product or service that is not permitted by regulation can enter into a contract to meet with EASA experts and discuss their proposals. These companies will be charged an agreed hourly rate. Several contracts have already been signed with innovative companies, but the details are all secret. EASA is keen to enter into further contracts to discuss subjects like reduced crew operations, autonomous aircraft, flying cars and jetpacks.

Andrew McKechnie

December 2019