The objective of this Opinion is to modernise the European Union (EU) aviation regulatory framework applicable to all-weather operations (AWOs) and flight crew training to ensure the highest level of safety while enabling efficiency gains based on the latest technological advancements.

As regards AWOs, this proposal follows a performance- and risk-based approach. It sets the appropriate balance between performance-based and prescriptive principles depending on the type of air operations. The rules are not technology-dependent and may accommodate future changes.

It addresses all relevant disciplines and proposes to update the AWO-relevant rules in the domains of air operations, aircrew and aerodromes, in a coordinated manner. In this context, the proposal:

• allows for a better integration and use of new, advanced technology as well as new operational procedures to support AWOs;
• ensures the availability of aerodrome infrastructure (including meteorological equipment), information and procedures to support AWOs;
• allows for the use of enhanced flight vision systems (EFVS) to the maximum extent possible (e.g. EFVS to land) and includes ‘light operational credits’ for EFVS 200 operations, not requiring the use of specific low-visibility procedures (LVPs); and
• allows for safe helicopter flights under instrument flight rules (IFR), using of point-in-space (PinS) approaches and departures.

As regards flight crew training, this proposal improves the existing mandatory crew training and checking requirements for air operators. It addresses initial and recurrent training and checking, the conditions for the operation on more than one aircraft type or variant, the acceptance of previous training and checking by non-commercial operators, and multi-pilot operations of single-pilot certified helicopters.

Certain changes to crew training are expected to increase safety in a cost-effective way. The other changes are expected to maintain safety, reduce the regulatory burden, increase cost-effectiveness, improve harmonisation regarding AWOs (e.g. with the Federal Aviation Administration (FAA)), and transpose as much as feasible the Standards and Recommended Practices (SARPs) of the International Civil Aviation Organization (ICAO).

Summary of the comments and the responses to them
502 comments were received during the public consultation of NPA 2018-01 ‘Instructions for continued
airworthiness’
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The more relevant comments can be summarised as follows:
— The NPA is missing the necessary period to implement the control of changes to the ICA in
accordance with Subpart D of Part 21.
— The NPA proposes to merge all the requirements for ICA, manuals and record keeping: the
specificities like for repair design should not be missed with the grouping.
— The NPA is missing the impact that the proposed amendments will have on Part-M.
— Several commentators are concerned with the strengthening of the control of changes to the ICA
under the design approval holder (DAH), considering that it will limit their ability to amend the
ICA.
— The NPA proposes to introduce a statement indicating that a document is part of the ICA, which
could be challenging for documents referred to by several ICA.
— The NPA proposes to add the ICA to the type certificate (TC), which creates disharmonisation with
the FAA.
The comments related to the proposed amendments to Part 21 were published with Opinion No 07/2019
‘Instructions for continued airworthiness | Installation of parts and appliances that are released without
an EASA Form 1 or equivalent’
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in CRD 2018-01 ‘Instructions for continued airworthiness’
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The comments related to the proposed AMC and GM by the NPA 2018-01 are published here.