Flight Time Limitations for Business Aviation
A Snapshot of EBAA Activity
Andrea Němec
Manager Safety and Rulemaking
BBGA Annual Conference
12 March 2013
Past FTL activities
Current FTL activities
Main issues under consideration
Future developments
12 March 2013
Past FTL Activities
EASA Rulemaking Activity
EBAA Working Group
• EASA → began writing new FTL rules
• Creation of EBAA Working Group on FTL
• Collection of different FTL national regulations
• First draft NPA FTL available
• Drafting of EBAA’s position on FTL based on the
available draft NPA and BizAv best practice.
• Publication of NPA 2009-22 on FTL
• EBAA Position → CS structure.
• EBAA launched FTL Survey in conjunction with Dr
Mark Rosekind (Alertness Solutions).
• Strong reaction from the community against
the NPA 2009-22.
• EASA creates the Rulemaking group OPS
0.55 FTL (CAT)
• EBAA Participates in OPS 0.55 FTL WG
• OPS 0.55 FTL → ”Air Taxi” rules to be drafted in a
future rulemaking group OPS 0.71 FTL (now split
in two rulemaking groups on Air Taxi and on EMS).
• BizAv FTL separate from airline rules.
• Publication of NPA 2010-14
on FTL
• EBAA Position → IR + CS structure.
Past Achievements
Common position on FTL for Business Aviation
Scientific study providing solid basis for the future development of sector rules
Collection of operational experience of BusAv operators
EASA acceptance of a future separate regulation on FTL for BusAv Operations
Current FTL Activities
EASA Rulemaking Activity
FTL requirements for CAT
operations - EMS (Airplane +
EBAA Working Group
• EBAA ensured participation of 1 expert in the
EASA WG: Uwe Marks (Aero-Dienst)
[RMT.0346 (OPS.071(a))]
FTL requirements for CAT
operations - Air taxi and singlepilot operations (Airplane)
[RMT.0429 and RMT.0493 (OPS.071(b))]
12 March 2013
• EBAA ensured participation of 2 experts in the
EASA WG: Marco Pereira (NetJets) and Dannys
Famin (Unijet)
Objectives of the EASA Rulemaking Tasks
Development of FTL requirements for CAT operations of air taxi and single-pilot (aeroplane) and EMS
(aeroplane + helicopter) by:
• Reviewing and assessing
EU-OPS Subpart Q provisions and outcome of Common Response Document to the
Notice of Proposed Amendment (NPA) 2010-14;
Existing applicable FTL national provisions.
Carrying out a Regulatory Impact Assessment
Best option to achieve the objectives while minimising negative impacts.
Submitting regulatory proposals
For Implementing Rules, Certification Specifications, Acceptable Means of Compliance
and Guidance Material
Current activities on FTL: Air taxi and single-pilot
FTL - Air taxi and single-pilot operations with
airplane Reference Documents:
EBAA Working Group Inputs
EU-OPS Subpart Q - Flight and duty time limitations and rest
Opinion 04/2011 on Air Operations – Notice of Proposed Amendment
(NPA) 2009-02
Common Response Document (CRD) 2010-14 to NPA 2010-14
ICAO Annex 6:
 Part I – International Commercial Air Transport - Aeroplanes
 Chapter 4 – Flight operations § 4.10 Fatigue Management
 Attachment A – Flight time and flight duty period
 ICAO latest amendments on flight time limitations and rest requirements
nad related GM (Amendment No 33 to Annex 6 Part I)
Fatigue Risk Management System
• FRMS Manual for Regulators (ICAO Doc©
• FRMS Implementation Guide for Operators
Provided inputs to the Regulatory Impact Assessment of the NPA 2010-14:
 2.2 Fatigue Hazard Identification
• 2.2.2 Hazard/Mitigation table
Main Issues Under Consideration (1/3)
• Important issue in Business Aviation
• Positioning duties before or immediately after a FDP
Duty Hours
• Combination of flight duties with ground duties
 Use of Fatigue Risk Management Systems?
Cumulative Duty
• Risk of fatigue deriving from high cumulative workload
• In BusAv fatigue less of an issue than for Airliners
Night, early and late duties
• Consecutive Night Duties
 Increase minimum rest after consecutive night duties?
• Consecutive series of early starts and/or late arrivals
 Limit the number of consecutive early starts, additional rest after a series of early starts?
Main Issues Under Consideration (2/3)
Calculation of FDP
• Clear maximum FDP limit
• Table or other means but must remain simple
• Must take into account the restorative sleep during WOCL period
Extension of FDP due to split duty
• Split duty with rest should enable longer flight duty periods
Extension of FDP due to in-flight rest
• Common practise but need to be managed
Pilot-in command discretion
• For extension of FDP based on particular circumstances
 All affected crew members to agree with extension of FDP
• For reduction of FDP and/or increase of rest in case of fatigue risk
Main Issues Under Consideration (3/3)
• Airport Standby
 Definition of facilities for Airport Standby Accommodation
• Standby other than airport
 Standby at home should not count as duty time for BusAv
Basic Rest - Reduced rest arrangements
• Suitable accommodation
• Minimum duration of reduced rest
• Requirement for reduced rest to occur in the WOCL
Compensation for effects of time zone differences (for long haul operations)
• Rest after flights with time zone differences should take into account the operational specifics of BusAv
EBAA Working Group Inputs Example
Hazard Reference
Fatigue hazard
Possible mitigation
Duty Hours
All operations
Combination of flight duties with
ground duties (e.g. administrative,
managerial, simulator, etc.)
Reduced duty/flight duty periods
Limitations on combining flight
and ground duties
Limit number of flying sectors
Use of FRMS
Include any ground duties
prior to a flight as FDP
Allow provisions as for split
2. Cumulative Duty
All operations
High cumulative workload
Future Developments (1/2)
RMT.0429 and RMT.0493 Milestone
Foreseen date
Notice of Proposed Amendment (NPA)
Comment Response Document (CRD)
+ Opinion
Future Developments (2/2)
RMT.0346 Milestone
Foreseen date
Notice of Proposed Amendment (NPA)
Comment Response Document (CRD)
+ Opinion
FTL - Emergency Medical Services (EMS)
by Aeroplanes and Helicopters
FTL - Air Taxi and Single-Pilot Operations
with Aeroplane
12 March 2013

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