Developing Policy for Safe Landings: the Global Reporting Format in Australia

Disclaimer: Nothing I write here should be considered CASA’s formal policy on the Global Reporting Format or any other regulatory development project. I wrote about the role of my blog a long time ago, and now that I am back with the regulator, it is as relevant as ever. For CASA’s policy on the GRF, go to its Consultation Hub. 

Complete alignment with ICAO is, generally, a good policy to have. Their standards and recommended practices (as well as guidance material) are developed in a thoughtful and considerate way. This process is slow and methodical (perhaps frustratingly so at times). Experts from around the world participate, often in their own time and in addition to their day job, with further support from the ICAO Secretariat. For my part, I enjoy being a part of this process.

But what happens with the standards that don’t quite gel with the operational environment in your state?

Filing Differences

The reasons why a country would deviate from ICAO vary. I’ll go through a few below, but first, it is worth acknowledging that the need to deviate was envisaged in the Chicago Convention (ICAO’s foundation treaty). Article 38 recognises that implementing ICAO standards may be “impracticable” and creates an obligation to notify ICAO of differences. And having administered the Annex 14 differences in two states, I am familiar with “impracticable” standards.

So, what are some of these reasons?

Non-applicability is the easiest to identify and register. For tropical countries, anything snow and ice-related can be quickly identified as not applicable. Although, it’s not always a bright line distinction. Sometimes, the applicability of a standard might rest on whether a specific type of operation is being undertaken, permissible, or even possible.

For example, Annex 14 Volume II could be deemed not applicable if international helicopter operations are:

• not undertaken due to no market for it, 

• are not permissible, perhaps by security/border control laws, or 

• impossible at, say, an island nation beyond the operational range of today’s helicopters.

The state gets to make this argument, but it is tested and assessed during ICAO’s audits of its member states.

Other differences, whether more strict, equivalent but different in character, or less protective, can be triggered by various circumstances. The most straightforward case to imagine is a country whose aviation system is still maturing. Whether the infrastructure does not yet exist or the capability is still being developed within the local regulator, a standard may simply be beyond the reach of that state.

Another is diversity.

A Multi-Operational Australia

Australia has an extensive and diverse aviation industry. It is easy to see why. We have a big country of extremes, especially in terms of distances and populations. You can fly from some of our biggest cities to some pretty small towns. Throw in a connecting flight, and you can find yourself in some of the most remote places in the world.

As such, our airport industry comprises international gateway airports, busy regional aerodromes, mining aerodromes and small community airstrips. And they are serviced by fleets of wide-body airliners, squadrons of commuter aircraft and a swarm of bug-smashers.

In relation to the GRF, section 4 of CASA’s policy proposal document outlines the challenge.

I grabbed these pics from different places a long time ago. Sorry for the lack of attribution.

Homogeneity 

In contrast, many of the experts on ICAO’s panels, working groups and task forces come from fairly consistent aviation operational environments. Whether through their limited number of aerodromes, access to resources or their historical development, their aviation systems tend towards “complete”.

They tend to operate in a world with large aircraft, air traffic control, and 24/7, dedicated aerodrome personnel.

And it was against this backdrop that the GRF was implemented.

Challenges & Opportunities

In short, this makes the implementation of GRF in Australia a challenge. Before we get to the discussion on airport resources, let’s look at the system design. ATC is the communication lynchpin in ICAO’s GRF. The timely communication of runway condition reports is funnelled through the tower, either through voice communications or ATIS. Yet, less than 10% of Australia’s certified aerodromes have a tower, and very few operate 24 hours a day.

And then, we have to consider the aerodrome operator’s resources. Many of Australia’s aerodromes are operated by organisations whose primary “business” is not aviation. They are local government organisations that run the airport as a public service. The safety officers and management team typically have other jobs. They may be part of the infrastructure, maintenance or other public facilities teams (think roads, pools, sewage facilities).

On the other side of the equation, the primary risk that the GRF was developed to address is not a regular or even remote occurrence in Australia. Snow & ice are not unprecedented*, but their presence rarely coincides with a critical operation. Nevertheless, standing water can potentially be a problem, and this contaminant is driving our efforts.

The discussion around the safety benefit of the GRF was had over a decade below. The work of the FAA’s TALPA ARC and ICAO’s FTF (see yesterday’s post for details) established this system as the best way of addressing the risk of contaminated runways. At its core, this assessment would have been a combination of a risk assessment and a cost-benefit analysis.

The work of the Australian working group providing advice to this project has been tailoring that risk assessment and associated analysis to suit the Australian environment.

Policy Approach

Often regulators will talk about different types of regulations. I wrote about this about ten years ago, and in that time, I have seen some good examples of movement towards, what I call, context-sensitive standards. For instance, I liked working with the EASA-based aerodrome standards with their outcome-based rules supported by their AMC/GM system.

While the policy is still being finalised, I would like to discuss the proposed GRF applicability policy (section 5.3 in the PPD) from this perspective. The critical points of the policy are:

Implementation of a runway surface condition assessment process would be mandatory for controlled aerodromes that are certified and service air transport operators. 

For non-controlled aerodromes that are certified with regular air transport operations the mandatory requirement would be to consult with their stakeholders prior to making any decision to voluntarily implement a runway surface condition assessment process. The consultation process would establish the safety benefits, other benefits, and resource implications of implementing the GRF at their aerodrome.

This is an interesting policy because it is prescriptive within a specific operational environment and flexible outside that environment. 

The policy makes some assumptions about the context in which controlled, certified aerodromes with air transport operators operate. It essentially says that the operating parameters within this group (<29 aerodromes) are sufficiently known to the regulator that their risk assessment and cost-benefit analysis justify the imposition of this requirement. Within the broader context of the ICAO model, this would seem reasonable.

For non-controlled, certified aerodromes with regular air transport operations, the policy shifts towards consultation and, essentially, consideration of an aerodrome’s specific context. Here, the policy acknowledges that the assumptions underlying ICAO’s risk assessment and analyses aren’t as strong. The response is to establish a requirement for the aerodrome operator to make its own assessment by consulting with its stakeholders. Based on its context, the endgame of this assessment is a decision by the aerodrome operator to either implement the GRF or not.

In different ways, the other policy proposals contained in the PPD walk the line between universal and individualistic requirements depending on context. 

Consultation & Finalisation

The entire policy proposal document was subject to public consultation to test our assumptions about the assumptions. The feedback received will be processed with the assistance of the project’s industry working group before being finalised.

And then the fun begins because we have to turn these policies into standards. But with such comprehensive policy work done, this should be a more straightforward process than writing standards from scratch. In about 6 months or so, these standards should be back out for public consultation. Much like ICAO, regulatory development needs to be methodical.

* Yes, we have an ice runway down in the Antarctic, but their ice “contamination” is the norm by design.