Time to Revamp Aerodrome Certification?
Again, I feel the need to post a disclaimer that the following is a personal opinion/thought piece. My current employer, CASA, is not exploring these concepts and given that it just revised its aerodrome certification system, it’s not likely to look at it again for a few years. I also want to acknowledge that my previous employer explored this idea in an early version of its aerodrome regulations (QCAR 006), but it was abandoned.
Aerodrome certification seems like both a mature system and an emerging concept. I acknowledge that while it has been in place in states like Australia for twenty years, some states are still working through the necessary regulatory development and implementation. Regardless, I’d like to go out on a limb and suggest that the concept is underdone. It takes an overly simplistic view of aerodromes and, as such, can hamper innovation and development.
A Bit of Background
Before I get contentious, let’s ensure we are on the same page. Aerodrome certification, as a requirement, is established under Annex 14 with international aerodromes covered by a standard and public aerodromes are subject to a recommendation. How each state implements these SARPs varies, with some delineating on aircraft size, passenger throughput or presence of an instrument flight procedure.
The details in the Annex are light. It says that certification shall be part of a regulatory framework and ensure that an aerodrome manual covering various topics, including safety management, is submitted. The notes direct the reader to Doc 9981 - PANS-Aerodromes and Doc 9774 - Manual on Certification of Aerodromes.
The PANS sets out a system for aerodrome certification, including the scope of certification, the certification process, ongoing oversight and lots of detail on the aerodrome manual. Doc 9774 is very similar but goes into more detail and provides a model set of regulations to support a certification system.
There are a lot of lists on these pages. Lists of what is included in the certification (scope), what steps are in the process, what things an aerodrome inspector needs to check during each step, and so on. I will point to these lists as evidence of what I think is “not quite right” in aerodrome certification.
Birds of a Feather
I like order and structure. And so, you would think I love ICAO’s material and its lists.
I like this approach, but it also gets to me when things on a list aren’t the same kind of thing. This “kind” can be very nuanced, and I want to acknowledge my privilege as a native English speaker working in a predominately English-language environment. So, this nuance comes easier for me than many.
Take, for example, this to-do list. Each item is, technically, something for the owner to do. But the context around the latter items is vastly different to the first few items. The processes around achieving these items are vastly different, and I would suggest that they impact the list’s utility. While not as extreme, some of the lists in the aerodrome certification guidance suffer from a similar issue.
In fact, some of these lists already recognise the distinction I will make below. For example, in PANS section 2.1.2, the list on scope of certification has two first-level items, a) mostly infrastructure things and b) operational things. And this is the distinction I want to make and the basis of my suggested revamp.
Two Sides of the Same Coin?
I agree that infrastructure and operations go hand in hand, but they are different. We recognise this in that list in the PANS, but then we conflate the two repeatedly. For example, the list describing what should be checked during the “technical inspection” includes a single point for all of the infrastructure (runways, OLS, marking, lights, etc.) and then adds RFFS and wildlife hazard management.
These last two items were on the operations list pages prior and are also included in the “on-site verification” step later in the document. Again, it might seem minor, and something inspectors can deal with during certification, but for developing states trying to get their minds around these concepts, blurred lines make it difficult.
And don’t get me started on the all-encompassing aerodrome manual - everything goes in the manual.
Separate Certificates
My suggestion is to certify the aerodrome and the aerodrome operator separately.
Treat the two processes separately. First, issue a certificate on the aerodrome confirming that it meets the physical standards for aerodrome facilities, visual aids and associated plant (fixed equipment). And then issue a certificate to the aerodrome operator whose processes and procedures meet the operational standards for things like inspections, vehicle control, wildlife hazard management, etc.
We already do this in aviation…
Airline Analogy
Aircraft operators already have this type of arrangement. An airline will hold its Air Operator’s Certificate (AOC) and then, for each of its aircraft, a different certificate or certificates (e.g. Certificate of Airworthiness (COA) or Type Certificate). This is not a perfect analogy, but it is pretty close.
While the certification process is generally standardised across domains, the details require specialists to apply specifically-designed tools and techniques. For example, I think we recognise that an aerodrome inspector can’t certify an aircraft even with a clear set of outcome-based standards, as there are always specifics that require background knowledge or mental models to bring them to life.
The same exists for certifying a runway and certifying a wildlife hazard management program. They require different processes and different expertise.
Don’t get me wrong, they don’t necessarily require different inspectors. A single inspector can learn both. After all, I believe I have those skills. But I recognise that they are different skills built on different knowledge and require a different application of a certification process.
But They are Not the Same Thing
Yes, this is just an analogy. It’s not perfect. But if your first point of difference is that an airline typically has more than one aircraft and an aerodrome operator only has one aerodrome. This is the very issue that I think is holding our industry back.
Firstly, not every aerodrome operator only has one aerodrome. In Australia, several specialist companies have been established to own/operate multiple aerodromes. In Qatar, the one aerodrome operator, Matar, holds the certificates for both aerodromes. And several large airport operators have established subsidiaries to bid for and operate aerodromes and airport facilities worldwide. Examples include DAA and Fraport.
I also acknowledge that aircraft certification is a little more complicated with Type Certificates belonging to the type of aircraft and a COA relating to maintenance. In the aerodrome environment, whether maintenance sits within the infrastructure or operations area could make for a good debate.
So could Obstacle Limitation Surfaces or Obstacle Control.
Conclusion
As noted above, this is more of a thought experiment. It describes what could be and helps explain why some aerodrome inspectors and standards departments still have difficulty developing and implementing their certification systems. The expectation that a single process can confirm compliance with the diverse requirements contained in Annex 14 and/or local regulations hides the complexity within.
I see a recognition of these challenges in some more recent aerodrome regulatory amendments. I believe Europe’s segregation of technical specifications into a separate “document”, the Certification Specifications, hints at this issue. I also think Australia’s establishment of trigger levels within operational requirements implicitly acknowledges these distinctions.* And as I mentioned at the top, Qatar thought to develop this concept explicitly in an early adaption of EASA’s aerodrome regulations but abandoned it for a more traditional approach.**
I am very interested in your thoughts on this concept. Please comment below or feel free to engage with this post on LinkedIn.
* I was not involved in this regulatory development project.
** I was involved in the regulatory development project that abandoned the concept.
