Consultation on Deviation UK.DEV.F.0001: Flight Crew Alerting

For comments on the proposal that the CAA introduces a deviation concerned with flight crew alerting on a large transport aeroplane.

The UK CAA is consulting on a Deviation that is applicable to CS-25 Large Aeroplanes. This Deviation provides the compensating factors to reach an acceptable level of mitigation to allow issuance of the type certificate with the non-compliance to CS 25.1322.

This is based the use of an approach to the cockpit philosophy on flight crew alerts which has been approved and is common to previous types certified by the same manufacturer.

The Consultation Paper Deviation UK.DEV.F.0001 Issue 1 provides the full detail of the identified issue, and the associated Deviation.

We received 2 responses.
The first response primarily related to the number of memory actions required, and pilot training when multiple ratings are held.

The second response proposed a number of wording changes aimed at making the text more specific to flight crew alerts, and proposes eliminating some text perceived by the commenter to be redundant. In addition, the commenter considers that CS 25.1322(c)(2) has not been addressed and should be addressed.

We acknowledge the responses and thank the responders for their suggestion.
For response 1, the comment is not incorporated. While the comments are relevant, their incorporation would is not considered to address the intent of the deviation and mitigations presented to the non-compliance.

For response 2, the comment is not incorporated. The deviation scope is considered to be clearly centred around Flight Crew Alerting, and the current text is considered to be clear within this context.

Further, the CAA consider that the text proposed for deletion by the commenter is not redundant, but is necessary and focussed on the requirements addressed by the deviation. CS 25.1322(c)(2) is addressed in Appendix A Table 4.