Comment Response Document RSRP.007/05 of Proposed Amendment NPA RSRP.007/05 on 01 March 2017 pursuant to Articles 4 and 30(8) of Law No. 15 of 2002 on Civil Aviation and with the QCAR

Comment Response Document RSRP.007/05

TE.RMP.00034-004 © Civil Aviation Authority of the State of Qatar. All rights reserved. Proprietary document. Copies are not controlled. Confirm revision status through the QCAA-Internet/Intranet.

Air Traffic Controller Licensing Regulation NPA RSRP.007/05 ISSUE 0.1 OF 14/03/2017

EXECUTIVE SUMMARY

Regulation establishing Technical Requirements and Administrative Procedures relating to Licensing of Air Traffic Controllers (ATCOs)

The Qatar Civil Aviation Authority (QCAA), under the Regulatory Structure and Regulations Program (RSRP), is in the process of restructuring its regulatory framework and aligning its operating regulations with those of the European Union.

The Objectives of the Qatar Civil Aviation Authority are specified in Emiri Decree 45 of 2014 and amongst others, are to attain best standards and competencies and ensure civil aviation safety in matters related to air transportation and aviation in general. Regulations related to licencing of ATCOs and certification of ATCO Training Organisations, issued pursuant to Articles 4 and 30(8) of Law No.15 of 2002 on Civil Aviation, have been proposed by Notice of Proposed Amendment (NPA) RSRP.007/05 on 14 March 2017.

Until 30 March 2017 forty-eight (48) comments have been received from four different stakeholders.

- PEL section of the authority (Personnel Licencing) - Qatar Aeronautical College (QAC) - Air Navigation Service Provider (AND) - Training department of the service provider (TO of ANSP)

Some of the stakeholders had the same comments, but with different proposals for changes, while others had the same comments and the same proposals. Similar comments with similar proposals were grouped. This way the total number of comments and answers became thirty-seven (37).

In general, the comments were constructive and contributed to improve the quality of the proposed regulation. One comment was received for a spelling mistake which was corrected without specific answer. There were also a few comments about unchanged Forms for licences and certificates, but apparently they were made using an older version of the draft document, where the Forms were still containing references to EU legislation.

Breakdown of the comments and answers: 18 rejected, 8 noted, 10 accepted and 1 partially accepted.

The authority will proceed with the adoption and promulgation of QCAR ATCO Licencing, as resulting from said accepted, partially accepted and noted comments.

The proposed Regulation will enter into force on 01 May 2017.

CRD RSRP.007/05

TE.RMP.00034-004 © Civil Aviation Authority of the State of Qatar. All rights reserved.

Proprietary document. Copies are not controlled. Confirm revision status through the QCAA-Internet/Intranet.

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Applicability Process map

Affected regulations:

QCAR ATCL Concept Paper: No

Affected stakeholders:

Air Traffic Controllers (ATCOs) ATCO Training Organisations (TOs) Aero-Medical Assessors (AMEs) Aero-Medical Centres (AeMCs) ATCO Licencing inspectors

Terms of reference: 15 March 2017

Driver/origin: RSR Programme

Technical consultation during NPA drafting:

Yes

Reference: RSRP 007/05 CRD and publication date of the Regulation

1 May 2017

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Table of Contents

1. Procedural information ............................................................................................... 4

2. Responses to received comments ............................................................................ 5

2.2. Statistics .................................................................................................................... 25

2.3. Overview of the impact of accepted or partially accepted comments ............... 25

3. Resulting text of new Regulation QCAR ATCO Licencing ................................ 26

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1. Procedural information

1.1. The rule development procedure

The Qatar Civil Aviation Authority (hereinafter referred to as the ‘QCAA’) published Notice of Proposed Amendment NPA RSRP.007/05 on 01 March 2017 pursuant to Articles 4 and 30(8) of Law No. 15 of 2002 on Civil Aviation and with the QCAR 11 Rulemaking Procedure.

This rulemaking activity is included in the QCAA’s Regulatory Structure and Regulations Programme 2016 – 2018.

As a result of the public consultation on the NPA, 48 comments from four

stakeholders have been received until 15 April 2017. Out of them 11 have been

accepted or partially accepted (30 %), 10 have been noted (21%) and 17 have been

rejected (49%) as presented in detail in this Comment Response Document (CRD).

1.2. The structure of this CRD

Chapter 1 of this CRD contains the procedural information related to this task.

Chapter 2 (responses to comments) explains why the comments have been accepted or not and specifies the resulting impact on the proposed rules.

Chapter 3 contains the resulting text of the affected rules on ATCO Licencing, related Annexes and Appendices.

1.3. The next steps in the procedure

Following the closing of the NPA public consultation period, and having responded

to all received comments in this Comment Response Document, the QCAA

proceeds towards promulgation of the resulting text of the new QCAR ATCO

Licencing (first edition, 2017). The outcome of the NPA public consultation, as well as of the focused consultation, is reflected in this Comment-Response Document (CRD), which is published simultaneously with the QCAR 007 of 2017 on ATCO Licensing.

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2. Responses to received comments

2.1. Individual responses

Comment No. 1 Originator of comment

PEL section Affected NPA paragraph

Article 2.3

NPA text “The overall objectives of the authority are defined in Article 2 of the Civil Aviation Law of 2016.” Comment: Reference made to Article 2 of Civil Aviation Law of 2016.

Alternative text: No alternative text proposed by commentator

Response: Noted

Details of Response:

The Article number and the year were provisionally set while waiting for the real reference to become available. Also the references in the Regulation are provisional. The final version will be amended accordingly before official publication.

Resulting text: Will be changed before final publication



ATCO.A.010

NPA text: “ATCO.A.010 Exchange of licences”

Comment: The term ‘exchange of licence’ is not specified in the definition and not in line with ICAO Annex 1.

Alternative text: Use ‘conversion of ATCO licences’

Response: Rejected

Details of response:

ICAO Annex 1 does not use specific terminology for ‘replacing’ a foreign licence with a national licence. Also, it does not use the term ‘conversion’ of licences neither for pilots, nor for ATCOs. The term ‘exchange of licences’ is commonly used among ATCOs. It comes from the fact that ATCOs cannot exercise their privileges (provide services) at an ATC unit located in another State, unless they move there permanently and obtain a new licence in ‘exchange’ of the old one. Pilots can exercise their privileges in another State while keeping their existing licences, because their licences are linked to the cockpit (e.g. aircraft type rating), which can move from one State to another, while ATCO licences are linked to the ATC unit, which cannot move from one State to another. The term ‘conversion’ is used only for ‘conversion training’ as explained in ATCO.D.085, which does not lead to an exchange of licences.

Resulting text: No change

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ATCO.B.005(c)(3)

NPA text: “hold a valid medical certificate”

Comment: Class of medical not specified


Response: Accepted


‘class 3’ added in both paragraphs

Resulting text: “hold a valid class 3 medical certificate”



ATCO.B.020(c)

NPA text: “Applicants for a unit endorsement following an exchange of a licence referred to in ATCO.A.010 shall, in addition to the requirements set out in point (b), meet the requirements of ATCO.D.060(f).

Comment: - Exchange on licences not established. ANS inspectorate to advise if it is required to include the unit endorsement as this will also require a change in the current format of licence - The terminology for the current process to be well established for applicants who obtain ATCO licences based upon their foreign licences. Refer to the current QCAR-ATCL 200.01


Response: Noted


Exchange of licences is established by this NPA, which gives sufficient details (requirements) for that. Also, it provides AMC/GM for almost every step of the exchange process.

Also see response to Comment No. 2.


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ATCO.B.030(c)

NPA text: “The applicant for all language proficiency endorsement shall demonstrate, …” Comment: No other language has been imposed by the State of Qatar except for English for radio telephony purpose


Response: Accepted


NPA updated accordingly.

Resulting text: “The applicant for all English language proficiency endorsement shall demonstrate, …”


PEL section TO of AND

Affected NPA paragraph

ATCO.B.035(a)(3)

NPA text “for expert level (level six), 9 years.”

Comment: For expert level 6, does not require any future assessment


Response: Accepted


For a number of reasons EU Member States insisted that native English speaking ATCOs also prove their English language proficiency every 9 years to ensure that all non-native speaking aviation personnel also understands them freely. Experience in Qatar does not show specific issues with native speaking ATCOs. Therefore, the proposal to remove the requirement of 9 years is accepted and the text is amended accordingly.

Resulting text: for expert level (level six), unlimited.



ATCO.C.020(e)

NPA text “..may be exchanged for …”

Comment: This terminology/process is not applicable for Qatar as there no such arrangement now or in the past. Consider amending this provision and also Refer to the current QCAR-ATCL 200.01


Response Noted


See response to Comment No. 2

Resulting text No change

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ATCO.C.045

NPA text: “Assessor privileges”

Comment: This will require qualification of an assessor who is required to have exercised privileges of an ATCO licence for at least 2 years” there’s no mention of an ANS Inspector. There’s a need to establish the means to qualify an assessor i.e. conduct an assessment of competence to qualify the assessor by the ANS inspector, as this is not specified. ATCO.AR.B.001(a)(2) makes reference to ‘inspectors’


Response: Noted


There is no mention of an ANS Inspector, because ANS inspectors certify and inspect ANSPs, while ATCO licencing inspectors issue new licences, validate and endorse new or existing privileges and certify ATCO TOs. The tasks of ANS inspectors are described in Part-ANS.AR of the ANS Regulation, while those for ATCO Licencing inspectors are described in ATCO.AR.A.010 of this Regulation.

The assessment of the competences of an ATCO assessor is done by another assessor at the ATC Unit, not by an ANS inspectors at the authority. Then the assessor endorsement is approved by the authority if all the requirements laid down in ATCO.C.060 are fulfilled.

Applicants for ATCO Licencing inspectors must have an ATCO Assessor endorsement in their licence, as referred to in ATCO.AR.A.005(c). Once recruited at the authority, they need additional training in order to start carrying out out their authority tasks laid down in ATCO.AR.A.010.


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ATCO.AR.B.001(c)

NPA text “The authority shall establish procedures for the participation in the exchange of all necessary information and assistance with other authorities concerned…exercising activities in the territory of Qatar, but certified by the authority of another State”

Comment: There is no known activity(ies) in Qatar that has been certified by a competent authority in another State. No evidence to indicate that another competent authority has approved some activities undertaken by ATCOs in the State of Qatar. Consider amending this section or deleting as this does not apply in Qatar.


Response: Rejected


ATCO.AR.A.001(c) has been added to the NPA in support of Article 2.4 of the Cover Regulation to create a legal basis for Qatar to conclude agreements with other States (e.g. Bahrain) to ensure that ATCOs providing services in the airspace of Qatar have:

- licences issued in accordance with Annex 1 to the Chicago Convention;

- received training and have successfully passed examinations and assessments equivalent to those required by Part-ATCO, Subpart D, Sections 1-4.



PEL section QAC TO of AND


ATCO.B.030(d)

NPA text: “Notwithstanding point (c), extended level (level five) … may be required…where the operational circumstances …”

Comment: Approval only specified to ELPR level five (5). The provision to specify a higher level of language proficiency may not apply to Qatar. The operational level is the min in line with ICAO annex 1.

Alternative text: Text to be deleted

Response: Accepted

Details of Response:

ATCO.B.030(d) gives an option to Qatar to choose ELPR level five (5) “where the operational circumstances of the particular rating or endorsement warrant a higher level of language proficiency for imperative reasons of safety”. Three stakeholders (PEL section, QAC and AND) have indicated that this option is practically not needed in Qatar, therefore this text has been removed from the NPA.

Resulting text: ATCO.B.030(d) deleted

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ATCO.MED.C.015

NPA text “Training courses in aviation medicine”

Comment: Does this apply to courses to be attended by the AMEs or conducted within the AeMC? This subsection is not applicable to QCAA as it does not approve such courses. Check and confirm with QCAA Medical Assessor.

Alternative text: Proposal to remove the entire requirement

Response: Rejected


This requirement applies for courses to be attended by AMEs at any place. Currently the QCAA may not approve courses in aviation medicine, but the ATCO Licencing Regulation will require it. This requirement is necessary, because otherwise the authority could not know to which medicine the training courses are oriented - to aviation, or to other medicine the AME wants to specialise. The titles of the certificates of completion, or the titles of the courses may be misleading. Finally, it is the authority who bears the responsibility for relying on AMEs with proper medical training.




AMC1 ATCO.B.035(a)(3)(i)

NPA text “The nine-year validity period … shall be counted from…”

Comment: Validity period of nine years for expert level is not in line with the ICAO standard for language proficiency or the Qatar Aircrew licensing regulations. It is recommended that the expert level remains for life(unlimited) in the ATCO regulations,


Response: Accepted


This comment relates to Comment No. 6, which was accepted and the text of AMC1 ATCO.B.035(a)(3)(i) was amended accordingly.

Resulting text: Entire AMC1 ATCO.B.035(a)(3)(i) deleted

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ATCO.D.085

NPA text “Conversion training course(s) shall be developed…” Comment: Paragraph 1: The term conversion as described in ATCO.D.085 applies to existing licences, whiles ‘exchange’ refers to foreign licences but this may not apply in the situation in Qatar. ANSP to confirm if this part of the regulations will be applicable and if so how will that be differentiated from ‘exchange’ (licences issued based on the applicant’s foreign licence) of licence which is the predominant situation in Qatar. Refer to the current QCAR-ATCL 200.01


Response: Noted


The ‘conversion courses’ referred to in ATCO.D.085 are not used to prepare ATCOs to ‘exchange’ or ‘convert’ their existing or foreign ATCO licences. As mentioned in the text of the NPA, these training courses are needed to “provide knowledge and skills appropriate to a change in the operational environment”. At the end of these courses, no ATCO licence is subject to replacement or exchange. The conversion courses are mandatory to re-validate a licence when the operational environment changes. Therefore, no link should be made with QCAR-ATCL 200.01 which refers to ‘conversion’ of foreign licences, or with Article 6(1) which refers to “alignment” of existing licences.


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GM1 ATCO.D.055

NPA text “Guidance … can be found in EUROCONTROL’s documents …”

Comment: Reference to EUROCONTROL’s document as guideline. Is it acceptable to refer to a document that is not under the control of QCAA? What then will be the means to track any future amendments? Further clarification to be provided on this if it is the best practice.


Response: Accepted


Indeed, EUROCONTROL documents are not QCAA Guidance Material. In order to become such, they need to be transposed and published by the QCAA as AMC/GM.

EUROCONTROL’s ‘Guidelines for the Development of Unit Training Plans’ and its Annex have been published 12-15 years ago and have never been amended since then. They have proven that they contain best practices, and are currently used by a large number of States in the world as “Industry Standard of Excellence”. Currently, this document is available only in PDF format, which is not easy to be edited, but it is accepted to transpose it (remove EUROCONTROL the references to the ESARRs and adapt it to the current environment of Qatar) and publish it as AMC/GM of QCAA before the 1st of January 2018, when the new regulation is expected to become applicable.

Resulting text: Entire GM1 ATCO.D.055 Unit training plan deleted. New GM of QCAA containing ‘Guidelines for the Development of Unit Training Plans’ will be published in a separate document.

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GM1 ATCO.AR.E.015

NPA text “Only the certifying competent authority may take action on the certificate.”

Comment: Is there any other certifying authority aside from the QCAA? Clarification to be provided, otherwise replace ‘other authority’ by ‘QCAA’

Alternative text: replace ‘other authority’ by ‘QCAA’

Response: Rejected


As already mentioned in the answer to Comment No. 9, two authorities are involved in the airspace of Qatar – of Bahrain and Qatar. The authority of Bahrain issues licences to ATCOs who provide services in both States, while the authority of Qatar has the sovereign right to ensure that ATCOs providing services in the airspace of Qatar have:

- licences issued in accordance with Annex 1 to the Chicago Convention;

- received training and have successfully passed examinations and assessments equivalent to those required by Part-ATCO, Subpart D, Sections 1-4.

The sovereign right of Qatar shall be ensured through agreements signed between the two States, as referred in Article 5 of this NPA.




GM1 ATCO.OR.B.030(c)

NPA text “When reference is made to the authority, this means either the authority that has issued the certificate or the authority ensuring oversight of activities, if they are different, based on the agreement concluded between the authorities.”

Comment: Simplify the definition of competent authority as QCAA if there’s no other ‘competent authority’ in the State of Qatar for ATCO training organisation. Clarification to be provided, otherwise replace ‘other authority’ by ‘QCAA’

Alternative text Proposed:

No change, or replace ‘other authority’ by ‘QCAA’

Response: Noted


See response to Comment No. 9


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QAC TO of AND


ATCO.A.010 ATCO.B.005

NPA text ATCO.A.010: “…if the licence is not issued by the authority of Qatar…” ATCO B.005: “Air traffic controller licence”

Comment: N/A

Alternative text: Add: “(e) Be at least 21 years of age” in ATCO.A.010 and Add: “(5) at least 21 years old”

Response: Rejected


Although ICAO Annex 1 requires an ATCO to hold a licence only at the age of 21 years (compared to 18 years for flying staff), many States have opted for an age limit of 18 years to allow for young and skilled people to choose their destiny at the right time. The age of 18 is when new generation people decide their future and start preparing for their professional life. If the alternative text is accepted, many potential Qatari young people may orient themselves to a different profession. Also foreign ATCOs below the age of 21 will apply for a job in another State. This way the service provider will miss the opportunity to recruit skilled and prosperous candidates.



QAC Affected NPA paragraph

ATCO.A.001(b) ATCO.A.005(c)

NPA text ATCO.A.001(b): “Applicants for the issue of a Student air traffic controller licence…” ATCO.A.005(c): “Applicants for the first issue of an air traffic controller licence…”

Comment: N/A

Alternative text: In ATCO.A.001(b) insert “QCAA” before “Student”: “Applicants for the issue of a QCAA Student…… In ATCO.A.005(c) also insert “QCAA”: “Applicants for the first issue of a QCAA Student air traffic …”

Response: Rejected


No rationale has been provided why there is a need to distinguish two types of ATCO licences. All the ATCO licences in Qatar are issued by the QCAA, therefore they are all deemed to be “QCAA” licences by default, whether they have been issued for the first time in Qatar (to students initially trained in the QAC) or not.


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ATCO.B.010

NPA text Air traffic controller ratings: “(1) the Aerodrome Control Visual (ADV) rating, indicating that … is competent to provide … instrument approach or departure procedures” “(2) the Aerodrome Control Instrument (ADI) rating, indicating that … is competent to provide … without surveillance equipment”

Comment: Not in accordance with ICAO Doc 10056 page 10

Alternative text: Delete (1) and (2) and reorder numbering

Response: Rejected


Page 10 of Doc 10056 refers to Annex 1, which does require an aerodrome control rating. The NPA also requires an aerodrome rating, but it is split in two categories (visual and instrument) to further specify the equipment used. For example, the ‘Ground Movement Control (GMC) endorsement’ will indicate that the licence holder is competent to provide only ground movement control, while the ‘Ground Movement Surveillance (GMS) endorsement’ will indicate that the licence holder is competent to provide ground movement control with the help of A-SMGCS;

Rating endorsements are not in contradiction to ICAO Annex 1. They are an enhancement above the ICAO Standard 4.5.1.

If sub-items (1) and (2) are deleted from ATCO.B.010, there will be no aerodrome rating at all, which is not in line with ICAO Annex 1.




ATCO C.001(b)(1)

NPA text “holds an air traffic controller licence and/or holds a professional qualification appropriate to the subject being taught …”

Comment: N/A

Alternative text: Insert: Holds ”or has held” an ….

Response: Rejected


A person who holds an ATCO licence is supposed to have current qualification appropriate to the subject being taught, while a person who ‘has held a licence’ may not have current qualification any more. In this case he/she will have to demonstrate it, as required in the second part of ATCO.C.001(b)(1).


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ATCO B.020

NPA text “Unit endorsements shall be valid for a period defined in the unit competence scheme. This period shall not exceed three years.”

Comments: N/A

Alternative text: “(e): Unit endorsement shall be valid for a period of 1 year…. This period shall not exceed three years”

Response: Rejected


Unit endorsements depend on the complexity of the ATC Unit. Therefore, the period of validity can only be defined by the Unit Competence Scheme (UCS) of the specific ATC unit. It cannot be the same value for all the ATC Units, as it will discriminate ATCOs working under different workloads. The validity of the unit endorsements also depends on the real number of working hours, as referred to in ATCO.B.20(g)(1), not on the duration of a calendar year, where an ATCO may not work at all. The period of validity shall not exceed 3 years to ensure that ATCOs have undertaken refreshment courses as required by ATCO.B.20(g)(2). Refreshment courses are not needed every year.




ATCO C.015

NPA text Application for on-the-job training instructor endorsement: “This period can be shortened to not less than one year by the authority when requested by the training organisation …”

Comment: N/A

Alternative text: “This period can be shortened to not less than one year by the authority when requested by the training organisation …”

Response: Rejected


This would allow for very quick promotion of unexperienced ATCOs who want to become on-the-job training instructors. One year is the minimum period during which a person can acquire practical experience at a working position and successfully complete a practical instructional techniques course.


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ATCO C.030(a)(3)

NPA text “Where the STDI is providing pre-OJT, he/she shall hold or have held the relevant unit endorsement. …”

Comment: N/A

Alternative text: “Where the STDI is providing pre-OJT, he/she shall hold or have held the relevant unit endorsement, or be deemed acceptable by the authority. …”

Response: Rejected


This proposal suggests an alternative, which would allow for a person to provide pre-OJT at a simulated environment without having (or having had) practical experience in that environment. The only acceptable condition is to hold or have held a unit endorsement for the specific ATC Unit where the STDI is giving pre-OJT. There are no other alternatives that can be deemed acceptable by the authority.



QAC TO of AND


ATCO C.040(a)

NPA text “The STDI endorsement shall be valid for a period of three years…“

Comment: N/A

Alternative text: “The STDI endorsement shall be valid for a period of five years…“

Response: Rejected


The practical skills and the operational practices of the STDIs cannot be maintained for such a long period of time without receiving refresher training and without passing a practical instructor competence assessment, as referred to in ATCO.C.40(c)(1) and (2).


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ATCO D.010(i) and (ii)

NPA text “(i) Aerodrome Control Visual Rating - ADV, defined in …Appendix 3 of Annex I; (ii) Aerodrome Control Instrument Rating for Tower - ADI (TWR), defined in Appendix 4 of Annex I.”

Comment: N/A

Alternative text: Delete the training on aerodrome control ratings

Response: Rejected


An aerodrome cannot function without proper training of its aerodrome controllers.



QAC TO of AND


ATCO.D.025(b) ATCO.D.035(b)

NPA text “A pass in theoretical examination(s) shall be awarded to an applicant achieving a minimum of 75 % of the marks allocated to that examination.”

Comment: N/A

Alternative text: “A pass in theoretical examination(s) shall be awarded to an applicant achieving a minimum of 75 % 70 % of the marks allocated to that examination.”

Response: Accepted


If this has been the practice for many years in Qatar and the assessors are used to the 70% success rate, it can remain.

Resulting text: “(b) A pass in theoretical examination(s) shall be awarded to an applicant achieving a minimum of 75 70 % of the marks allocated to that examination.”

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ATCO D.040(c)

NPA text “(c) In addition to point (b), rating training performance objectives for the Aerodrome Control Visual (ADV) and Aerodrome Control Instrument (ADI) rating shall ensure that applicants:

(1) manage the workload and provide air traffic services within a defined aerodrome area of responsibility; and

(2) apply aerodrome control techniques and operational procedures to aerodrome traffic.”

Comment: Delete aerodrome control ratings

Alternative text: N/A

Response: Rejected


See Comments No. 19 and 25




ATCO D.040(c)

NPA text “(c) In addition to point (b), rating training performance objectives for the Aerodrome Control Visual (ADV) and Aerodrome Control Instrument (ADI) rating shall ensure that applicants:

(1) manage the workload and provide air traffic services within a defined aerodrome area of responsibility; and

(2) apply aerodrome control techniques and operational procedures to aerodrome traffic.”

Comment: Delete aerodrome control ratings


Response: Rejected


See Comments No. 19 and 25


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Appendix 2 of Annex 1

NPA text N/A

Comment: Copy and paste from ICAO Doc 10056. Some requirements: European Law etc... are meant for European environment. Text is not in line with ICAO environment.


Response: Partially accepted


Both the Basic training syllabi of Doc 10056 and Appendix 2 of Annex 1 have been developed based on the Common Core Content (CCC) Document of EUROCONTROL published in 2008. The differences are mainly in Subject 2: Aviation Law, where EUROCONTROL refers to its ESARRs (safety regulations), EASA refers to the EU regulations and its Implementing Rules, while in ICAO 10056 all the references to EU structures and regulations have been removed and replaced by worldwide structures.

Instead of copying and pasting from ICAO Doc 10056, it would be better to adapt Appendix 2 of Annex 1, so that trainees obtain basic knowledge about EU Organisations such as EASA and EUROCONTROL. For example, explain the purpose and functions of the Network Manager, which plays an important role for traffic flows affecting aircraft departing from the Gulf region, or explain the role of EASA and explain the differences between the new ANS and ATCO Licencing regulations and the EU ATM/ANS regulatory framework.

Therefore, it has been accepted to replace Appendix 2 of Annex 1 with ICAO Doc 10056, but the new document must be complement with sub-topics about EU organisations and it must be published as a separate GM of the QCAA.

Resulting text: New GM of QCAA containing adapted Doc 10056


TO of AND Affected NPA paragraph

ATCO.B.001

NPA text “Be at least 18 years old;”

Comment: N/A

Alternative text: “Be at least 18 years old, but not older than 30 years;”

Response: Accepted


N/A

Resulting text: “Be at least 18 years old, but not older than 30 years;”

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AND Affected NPA paragraph

NPA text N/A

Comment: “Under the new regulations, both QAC and the ANS Training Department would need to be approved Training Organisations by QCAA, with specific scope of training in their approvals – QAC is presently approved and needs to remain as such, similar to Entry point North in Europe.” SMS requirements appears different between EASA and ICAO with regards to Approved Training Organisations, this would need to be checked and clarified before implementation.”


Response: Noted


QAC will remain an Approved TO. This NPA does not cancel the current statute of QAC. It simply adds two new terms: “Certified TO” and “Contracted TO”. The first term implies that the certified TO must have an organisational structure, management system, monitoring and reporting mechanisms, facilities and equipment, staff qualification, etc. that comply with the requirements of Part-ATCO.OR. The second term is used for TOs which provide partial training (the case of QAC) to a certified TO. They may or may not be certified, depending on whether they are exposed to safety risks related to aircraft operations during the provision of their services (paragraph 4.1.2 of ICAO Annex 19). If they are certified, an SMS is required. If they are not certified, they can provide training only under the SMS and the terms of approval contained in the certificate issued to the contracting TO.

Entry Point North is not only an ICAO approved TO, but also a TO certified by the Swedish CAA. The QAC can also become a certified TO. Then it will continue acting as a Contracted TO for the TO of the AND (i.e. to provide licenced Student ATCOs), but it will work under the privileges of its own certificate.


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ATCO.B.001

NPA text N/A

Comment: Add one more requirement to applicants for Student licence

Alternative text: Add: “5) successfully completed a unit psychometric test”

Response: Accepted, but AMC/GM are needed


Psychometric tests typically consist of numerical reasoning, verbal reasoning and diagrammatic reasoning tests. Situational judgement tests are increasing in popularity and are used as an initial screening method for the biggest employers. ANSPs also use psychometric tests not only for Student ATCO candidates, but also for the recruitment and evaluation of other staff. Therefore, the proposal to include an additional item to this point of the regulation is acceptable, but requires additional preparation. Conducting psychometric tests requires not only experienced assessors, but also relevant measurement equipment. In order to comply with such requirement, the authority will have to develop appropriate unit-oriented AMC/GM, while the certified TO will have to ensure relevant assessor expertise and equipment.

Resulting text: “5) have successfully completed a unit psychometric test.”



ATCO.C.001

NPA text N/A

Comment: There should be a difference between the instructor requirements for an TO that provide basic training and a TO providing advanced and unit training.


Response: Noted


Instructors who provide basic (theoretical) training are called ‘Theoretical instructors’, while instructors who provide advanced (practical) training are called ‘on-the-job training instructors’ (OJTIs). In addition, instructors who provide practical training (other than OJT) on simulators are called ‘synthetic training device instructors’ (STDIs). Theoretical instructors do not have an endorsement in their ATCO licences, while OJTIs and STDIs do have.


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ATCO.B.015

NPA text “(1) the Precision Approach Radar (PAR) endorsement”

Comment: Precision Approach Radar (PAR) endorsement should be changed with Final Director, because Qatar do not use PAR’s


Response: Rejected


The use of PAR is in line with the rating endorsement principle, while Final Director isn’t. Rating endorsements are endorsements associated with particular ratings to indicate the type of equipment associated with the provision of an ATC service in that rating discipline. For example, the ICAO Approach Radar Control rating becomes the Approach Control Surveillance (APS) rating with a radar endorsement, which indicates that radar is the surveillance equipment used in providing the ATC service. Final Director is neither a rating, nor a rating endorsement. It is the role of a controller (APS or ACS) who directs the traffic towards an aerodrome ensuring safe separation and right sequence of arrival aircraft on final. Therefore, the role of Final Director can be carried out by any ATCO licence holder who has a rating with radar endorsement. The AND may not have a PAR for the time being, just like there is no ACC in Qatar, but in the future they may be needed.




ATCO.C.055

NPA text Application for assessor endorsement “(a) have exercised the privileges of an air traffic controller licence for at least two years;”

Comment: N/A

Alternative text: (a) have exercised the privileges of an air traffic controller licence for at least two three years;

Response: Accepted


A more experienced ATCO will better assess ATCO skills.

Resulting text: “(a) have exercised the privileges of an air traffic controller licence for at least two three years;”

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ATCO.C.020(a)

NPA text “(a) The OJTI endorsement shall be valid for a period of three years.”

Comment: N/A

Alternative text: “(a) The OJTI endorsement shall be valid for a period of three five years.”

Response Rejected


Five years is too long without receiving refresher training on practical instructional skills and without passing a practical instructor competence assessment.




ATCO.C.060(a)

NPA text “(a) The assessor endorsement shall be valid for a period of three years.”

Comment: N/A

Alternative text: “(a) The assessor endorsement shall be valid for a period of three five years.”

Response Rejected


Five years is too long without receiving refresher training on assessment skills and current operational practices.


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2.2. Statistics Duration of consultation: 2 months; Received comments: 48; Grouped in 37 different comments; Commentators: 4: - PEL Section of authority; - ATM section of Qatar Aeronautical College (QAC); - Training Department of service provider (TO of AND); - Air navigation service provider (AND). The following Pie chart depicts the percentage of comments accepted, partially accepted, noted and rejected comments:

2.3. Overview of the impact of accepted or partially accepted comments Based on the accepted, or partially accepted comments, the general structure and content of the new QCAR ATCO Licencing have not significantly changed in respect of the main text of the regulation. However, it was clarified that three additional AMC/GM documents will have to be published in support to the new QCAR ATCO Licencing. The first is about the EUROCONTROL’s ‘Guidelines for the Development of Unit Training Plans’ (and its Annex), which were not incorporated in the original EASA regulation, but only referenced. As it is not acceptable for Qatar regulations to refer to other States’ documents (that may change at any time), there is a need to amend and incorporate the EUROCONTROL’s ‘Guidelines (see Comment no. 14) as an additional AMC/GM of QCAA. The second AMC/GM document is about Appendix 2 of Annex 1 (see Comment No. 29), which has references to EU regulations that are not needed for Qatar. This Appendix has to be aligned to ICAO Doc 10056 and incorporated in the Qatar regulatory system as a separate ACM/GM of QCAA. The third document is an AMC/GM of QCAA for unit psychometric test in support of the new point ATCO.B.001(5).

49%

21%

27%

3%

Comments

Rejected Noted Accepted Partially accepted

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3. Resulting text of new Regulation QCAR ATCO Licencing The resulting text of the articles or paragraphs of the new QCAR ATCO Licencing affected by the accepted or partially accepted comments, is presented in this Chapter, arranged to show deleted text, new or amended text in relation to the text proposed in the NPA as shown below: (a) deleted text is marked with strikethrough;

(b) new or amended text is highlighted in grey;

Below the resulting text of the proposed new QCAR affected by the comments: ATCO.B.005 Air traffic controller licence

(a) Applicants for the first issue of an air traffic controller licence shall:

(1) hold a student air traffic controller licence;

(2) have completed a unit endorsement course and successfully passed the

appropriate examinations and assessments in accordance with the requirements

set out in Part ATCO, Subpart D, Section 3;

(3) hold a valid class 3 medical certificate;

(4) have demonstrated an adequate level of language proficiency in accordance with

the requirements set out in ATCO.B.030.

ATCO.B.030 Language proficiency endorsement

(b) (c) The applicant for any English language proficiency endorsement shall demonstrate, in accordance with the rating scale referred to in point (b), at least an operational level (level four) of language proficiency.

(d) Notwithstanding point (c), extended level (level five) of the language proficiency rating

scale set out in Appendix 1 of Annex I may be required by the air navigation service

provider, where the operational circumstances of the particular rating or endorsement

warrant a higher level of language proficiency for imperative reasons of safety. Such a

requirement shall be non- discriminatory, proportionate, transparent, and objectively

justified by the air navigation service provider wishing to apply the higher level of

proficiency and shall be approved by the authority.

(d) Language proficiency shall be demonstrated by a certificate attesting the result of the

assessment.

ATCO.B.035 Validity of language proficiency endorsement

(a) The validity of the language proficiency endorsement, depending on the level

determined in accordance with Appendix 1 of Annex I, shall be:

(1) for operational level (level four), three years from the date of assessment; or

(2) for extended level (level five), six years from the date of assessment;

(2) for expert level (level six), 9 years unlimited.

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AMC1 ATCO.B.035(a)(3)(i) Validity of language proficiency endorsement VALIDITY OF THE LANGUAGE ENDORSEMENT OF PROFICIENCY LEVEL 6 IN ENGLISH LANGUAGE

When replacing the licences according to Article 8(1) of Regulation (EU) 2015/340, the validity period for the expert level (level six) language proficiency endorsements shall be introduced into the new licence.

The nine-year validity period for an expert level (level six) language proficiency endorsement in English acquired before 30 June 2015 shall be counted from the date of the issue of the new licence or from the date of the assessment, whichever occurs first.

GM1 ATCO.D.055 Unit training plan

GENERAL

Guidance for the development of unit training plans can be found in EUROCONTROL’s documents ‘Guidelines for the Development of Unit Training Plans’, Edition number 1.0, dated 31.08.2005 and ‘Annex to the Guidelines for the Development of Unit Training Plans: Examples of UTP’, Edition 2.0, dated 10.06.2010.

Note: New GM of QCAA ‘Guidelines for the Development of Unit Training Plans’ will be

published in a separate document.

ATCO.D.025 Basic training examinations and assessment

(b) A pass in theoretical examination(s) shall be awarded to an applicant achieving a

minimum of 75 70 % of the marks allocated to that examination.

ATCO.D.035 Rating examinations and assessment

(b) A pass in theoretical examination(s) shall be awarded to an applicant achieving a

minimum of 75 70 % of the marks allocated to that examination.

Appendix 2 of Annex I Basic Training

(Reference: Annex I - Part ATCO Subpart D, Section 2, ATCO.D.010(a)(1)) TABLE OF

CONTENTSSUBJECT: INTRODUCTION TO THE COURSE

ATCO Basic training is published in QCAA GM for ATCO Basic training.

Note: New GM for ATCO Basic training will be published in a separate document.

ATCO.B.001 Student air traffic controller licence

(b) Applicants for the issue of a Student air traffic controller licence shall:

(1) be at least 18 years old, but not older than 30 years;

… (5) have successfully completed a unit psychometric test.”

Note: New GM for ATCO Basic training will be published in a separate document.

ATCO.C.055 Application for assessor endorsement

Applicants for the issue of an assessor endorsement shall:

(a) have exercised the privileges of an air traffic controller licence for at least two three

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years; and

Documents

Comment Response Document RSRP.007/05 of Proposed Amendment NPA RSRP.007/05 on 01 March 2017 pursuant to Articles 4 and 30(8) of Law No. 15 of 2002 on Civil Aviation and with the QCAR