時間：2011-08-31 13:49來源：藍天飛行翻譯 作者：航空 點擊：次
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One commentor addressed Harmonisation from the point of view of EU – JAA Harmonisation, recommending that the JAA not deviate from existing EU requirements. The point is noted, and it is within the TofR of the DEFWG to consider what EC requirements exist. The example quoted (Directive 2407/92, (5)(7)(a)), relates to economic regulation, not air safety, and JAR–OPS, whilst not being identical, does not contradict the EC Directive. Proposal 1; Authority 12 comments were received to this proposal. A number of them indicated that there was confusion (especially from non-native English speakers) as to what ‘regulation’ means. Confusion centred around the difference between the writing of requirements, and their implementation. This was especially a problem for states with more than one authority. A number of clarifications were proposed to cover the above points. Some proposed that JAR–1 need not even define it, as national law states who does what in each State. A specific comment on the relationship between the Authority and JAA Teams was made. It should be recalled that PCMs, MAST Teams etc are not ‘responsible’ for final agreement or adoption; that is the prerogative of the NAA. After reviewing the various combinations of wording offered by commentors, the DEFWG came to the conclusion that the definition should address the fact that the JAA covers Civil Aviation (the use of capitals is intended to express the widest possible use of the words; the JAAs are involved in safety regulation; and that the term ‘competent body’ allows for the all possible combinations of regulatory agency. Proposal 2; Approved and Proposal 3; Accepted/Acceptable These proposals caused concern with many commentors, with 29 commentors expressing views on the two terms. Three basic issues arose from the comments: The need for a definition at all, especially for Accepted; and ‘..pronounced..’ is too weak a word for ‘Approved’, it must be a written approval; and Consideration of ‘indirect approvals’, as in JAR–21, must not be forgotten. |
