CRD 2014-13 - Issue 2

Assessment of changes to functional systems by service providers and the oversight of these changes by competent authorities

The overall objective of RMT.0469 & RMT.0470 is to provide a harmonised set of rules (by clarifying and enhancing the existing ones) for certified service providers of ATM/ANS and other ATM Network functions to perform the assessment of changes to functional systems and for competent authorities regarding the oversight of these changes. These proposed rules will amend the ones in CRD 2013-08 ‘Requirements for service providers and the oversight thereof’ published on 6 June 2014 (and initially proposed through Notice of Proposed Amendment (NPA) 2013-08 — published on 10 May 2013).

During the NPA 2014-13 public consultation, the Agency received 1 277 comments. The Agency expresses its appreciation to the stakeholders who have not only provided their individual comments to the draft proposals, but also expressed their coordinated views through the relevant European stakeholder groups. The Agency considers that the comments received contributed essentially to the improvements of the proposed rule.

The Agency has reviewed all the comments received, but regarding the issue of the related Opinion No 03/2014, priority has been given to the comments related to the Implementing Rule, leaving for a later stage the analysis and completion of the responses to the comments related to the AMC/GM. However, the Agency has concluded that the NPA 2014-13 public consultation has brought real benefits to the development of the above-mentioned Opinion.

Note: This document is Issue 2 of the CRD published on 12 December 2014. This amended version of the CRD contains the analysis of and responses to all comments, including those related to the AMC/GM.

The most contentious issues during the consultation were the definition of functional system; the content of oversight audits in this respect; the competent authority’s risk-based decision to review notified changes; the handling of multi-actor changes to functional changes; the identification of change drivers; and the criteria for the safety and safety support assessments.

The Agency trusts that the related to the Implementing Rule responses in this CRD to NPA 2014-13 satisfy the commentators insofar as they provide further clarification on the subject addressed.

Based on the comments and responses thereto provided with this CRD, Opinion No 03/2014 was developed.