时间：2011-08-31 13:49来源：蓝天飞行翻译 作者：航空 点击：次
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Proposal 4; Commercial Air Transportation and Proposal 5; Commercial Air Transport Operation These two proposals generated 19 comments, the bulk of which led the DEFWG to conclude that proposal 5 is redundant, and it was thus deleted. A number of comments related to the status of the advisory material for corporate aviation and aerial work. Some proposed that it be deleted, whilst others wished to see it in the definition itself. The DEFWG noted the two conflicting positions, but to delete the IEM could cause a conflict in interpretation with related EU texts, whilst its inclusion in the definition would contradict them. Thus the IEM remains as an important clarification that serves to reflect the JAA’s intent in this area. One commentor proposed adding ‘mail’ to the definition as per ICAO, and one commentor requested that the definitions in EC Regulation 2407/92 be considered. The Regulation does not actually contain a definition of Commercial Air Transportation, but it is obvious, by implication, what they mean. The DEFWG could not see any contradiction between the two terms, but, for the sake of consistency, and to prevent any misunderstanding between JAA & EU requirements and ICAO, the phrase ‘or mail’, as per ICAO Annex 6, has been added. In any case, the addition (or exclusion) of the term does not appear to have any bearing on safety regulation. One comment noted that the use of the words ‘remuneration’ and ‘hire’, constitutes duplication, and thus the commentor proposed the deletion of ‘for hire’. Whilst the DEFWG concurs with the point, the phrase is so well known, and used by ICAO, that it is to be retained. The comment suggesting that a note be added to clarify that existing national rules apply for aerial work until the adoption of JAR–OPS Part 2 is not adopted even though the commentor is quite correct as this point is not part of a technical requirement or a definition. Comments received on Proposal 5 led the DEFWG to agree that the term was not necessary and it is deleted. The ICAO Annexes do not contain the term. |
