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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Of the 17 definitions proposed in the NPA all were commented upon to some extent or another. The following pages provide a summary of those comments and the Definitions WG’s response: General Comments A number of general points were raised that dealt with either JAR–1 or NPA 1–7 in general. One commentor preferred to see Notes used in place of advisory material. Legal advice received by the DEFWG suggests that Interpretative and Explanatory Material (IEM) is more appropriate than a note. Readers should note that this Change to JAR–1 has changed ACJs into Acceptable Means of Compliance (AMC) and Interpretative and Explanatory Material (IEM). This is in line with the JAR–11 WG’s thinking, and clarifies the meaning or status of the material. In general a number of comments reflected the confusion between the purpose of a definition and a requirement. A definition is not meant to contain requirements. The layout of the NPA was criticised by one commentor, and this will be reviewed for subsequent NPAs to JAR–1. The same commentor felt that the NPA had not been properly prepared and consulted upon prior to the formal circulation of the NPA. Thus, in their opinion, the NPA should be re-developed and re-circulated. A good deal of co-ordination was achieved between the various technical committees prior to NPA circulation, and thus the DEFWG disagrees with the claim that the internal circulation was inadequate, but recognises that a formal procedure will need to be developed (and then followed by all) as part of JAR–11. The JAR–11 WG has been made aware of this. Two commentors suggested deleting ‘means a...’ from the beginning of all definitions for the sake of consistency. In fact the words were included to make the NPA consistent with JAR–1. In answer to a comment, the DEFWG agrees to take into account the WATOG definitions in its future work. Harmonisation Readers will be aware that JAA/FAA Harmonisation is an important goal, and the Terms of Reference for the DEFWG stated that both ICAO and FAA definitions should be used where possible. Where adopted definitions differ from FAR Part 1 the FAA will be advised, and the terms will be proposed as future harmonisation topics. This position answers a number of comments. One commentor, in making reference to the Harmonisation process requested a delay until autumn 1995. Such a long delay is not possible, and the JAA has had to work without that commentors input. |
