207-Minute Extended Range Operations with Two-Engine Aircraft (ETOPS)

RE: PROPOSED ADVISORY CIRCULAR NO. 135-42, EXTENDED OPERATIONS (ETOPS) AND OPERATIONS IN THE NORTH POLAR AREA The National Air Transportation Association (NATA), the voice of aviation business, is the public policy group representing the interests of aviation businesses before Congress, federal agencies and state governments. NATA?s 2,000 member companies own, operate, and service aircraft. These companies provide for the needs of the traveling public by offering services and products to aircraft operators and others such as fuel sales, aircraft maintenance, parts sales, storage, rental, airline servicing, flight training, Part 135 on-demand air transportation, fractional aircraft program management and scheduled commuter operations in smaller aircraft. NATA members are a vital link in the aviation industry providing services to the general public, airlines, general aviation, and the military. NATA appreciates the opportunity to provide comments on this Advisory Circular (AC) on behalf of our members that operate aircraft that may be impacted by the Extended Operations (ETOPS) requirements. General NATA has reviewed AC 135-42, Extended Operations (ETOPS) and Operations in the North Polar Area, and has specific concerns with the content of the AC; but more importantly, the association is disappointed that the Federal Aviation Administration (FAA) has did not avail itself of an opportunity to address the fundamental issue of applicability ? which is that it remains unclear how to determine whether ETOPS requirements apply. Unfortunately, it is difficult for most Part 135 operators to know if they should be preparing to obtain ETOPS approval because the FAA has not provided a step-by- step process for operators to use in evaluating their aircraft and areas of operation. Many operators remain unaware that their operations could actually be required to comply with ETOPS requirements. The AC presumes that an operator intends to pursue ETOPS authorization and then provides information on how to obtain FAA approval. Absent is any objective discussion on the process to determine that ETOPS authorization is in fact necessary. By skipping such a fundamental step, the FAA does a great disservice to the industry. This should be corrected immediately. NATA asks that the FAA amend the AC to include the thought process and steps an operator would follow to determine the appropriate speeds. Determining whether a specific operation is an ETOPS flight requires an operator to use an ?approved one-engine inoperative cruise speed under standard conditions in still air? that is ?chosen? by the operator. Existing one-engine inoperative speeds are not based on meeting ETOPS objectives, and no elaboration on what speeds would be appropriate for an operator to choose from is offered. Also not addressed is the commitment accepted by airframe manufacturers to provide ETOPS one-engine inoperative data for the aircraft most likely to be affected by these regulations. When the FAA published the ETOPS final rule, it agreed with comments from NATA and others that the airplane manufacturers must determine the airspeeds needed by industry. The FAA responded that the manufacturers had agreed to provide this data and that it would be available prior to the effective date of the rules. It would appear that this data has not been provided by all manufacturers for all potentially affected airplanes. By failing to provide any guidance whatsoever regarding how an operator ?chooses? a one-engine inoperative cruise speed or how an operator can evaluate their operations to determine if ETOPS applies, this AC falls far short of its intended goal. Without this key information, the AC is not useful to the industry. The AC states that an operator will request an ETOPS area of operation based upon an analysis of proposed routing. This implies that the FAA believes an operator will have specific departure and arrival dest…

Comments regarding application of ETOPS to Part 135 operations

Filed on regulations.gov — full text not in the inline record.