The new EASA Aerodrome rules entered fully into force on 1 January 2018. Over 400 European airports have met the highest European safety standards in infrastructure and operational processes. So, what’s next? Ensuring efficient compliance and change management regarding safety regulatory requirements. Report by Panos Spiliotis & Ansgar Sickert.
Until just a few years ago, aviation safety did not have an EU dimension as far as airports were concerned. Naturally there was supervision based on ICAO’s regulatory material, but the way that each Civil Aviation Authority implemented this material tended to vary. This meant that an otherwise highly integrated aviation system approached aerodrome safety in a manner that was, in many ways, inconsistent and without a common European baseline. Fast forward to 2014 and Commission Regulation 139/2014 set out essential requirements (supported by EASA soft law) that the vast majority of European airports would have to be certified against by their authorities by the deadline of 31 December 2017.
So, understandably, nerves began to fray at the European Aviation Safety Agency when a survey of National Aviation Authorities (NAAs) in October 2017 revealed that a large number of airports in the Agency’s scope had not been certified. With less than three months remaining before the rapidly approaching deadline of 31 December 2017 for the conversion of national aerodrome operations certificates to the EASA rules of Reg. (EU) 139/2014, the risk of a large number of airports missing the deadline looked entirely possible.
Happily, Christmas turned out brighter than feared, as 95% of the 459 airports to be certified met the deadline. National Aviation Authorities had almost 4 years from the time the Reg. 139/2014 entered into force on 12 February 2014 to work with the airports under their jurisdiction, to implement the requirements and administrative procedures related to aerodromes.
During the certification process many airports in the scope of EASA had raised concerns about the time, effort and cost involved in meeting regulation requirements. ACI EUROPE is currently carrying out a survey about certification managers’ experiences and views of the certification process. The survey also includes the challenges of implementation and perception of the benefits of the certification compared with the previous licencing/certification at national level.
So far, there are three main trends emerging from the initial responses of the survey:
Firstly, airports were struggling in their coordination with stakeholders – particularly their Competent Authority (CA) but also their Air Navigation Service Provider (ANSP) which were partly to blame for the slow pace of certification.
Secondly, more than half of responding airports felt that their NAA had a tendency to interpret EASA rules more strictly than envisaged by the Agency. One frequently mentioned example was the treating of Guidance Material as mandatory for their certification. Clearly this is something the Agency will need to look into in their Standardisation Inspections of the Competent Authority. The different use of EASA’s flexibility tools by the competent authorities is also an indication that we are far from a uniform European application of aerodrome rules. Its four main tools “Equivalent Level of Safety” (ELoS), “Special Condition” (SC), “Deviation Acceptance and Action Document” (DAAD) and “Alternative Means of Compliance” (AltMoC) allow for flexibility at the national level. All responding airports issued DAADs. These generally document and accept a current situation to be corrected at a later time – for instance when major maintenance or expansion projects are undertaken. Over 90% of airports made use of SC which are often the result of virtually unchangeable topographical conditions at an airport. Less frequent use was made of ELoS (46%) or AltMoC (38%) tools. Some CAs avoid these tools altogether possibly because the use of flexibility tools is regarded as longwinded and complex.
On the critical question about the perceived benefits of certification according to Reg. (EU) 139/2014, the view that the exercise was largely beneficial prevailed – but only just. Standardisation of rules and procedures across EASA member states, development of closer relationships with stakeholders including the competent authority as well as the identification of non-compliances and updating of outmoded procedures were mentioned on the plus side. However, the significant workload and required investments in infrastructure personnel, systems and procedures, especially for smaller airports with less flexibility on the resource side was seen as a major challenge. The more sceptical airports also had their doubts about the additional safety benefits of the certification based on EASA rules when compared with the status quo ante. Surely on the latter point the jury is still out? The benefits will only be seen after the new regime has been in place for a number of years, allowing for a real “before and after” comparison.
We should mention here that though implemented in their current form, EASA aerodrome rules are designed to be a dynamic set of texts that changes every year through rulemaking. So, what’s coming around the corner?
Looking ahead, airports have three main expectations of EASA rulemaking:
- Simplification & clarification of existing rules
- Significant slow down of rulemaking including fewer revisions of existing rules
- Ensuring new rules/amended rules are performance based (PBR)
The Agency has already committed to cooling down its rulemaking. It has also taken organisational steps, by combining rulemaking and standardisation functions in order to ensure that these activities work more closely together. EASA also proscribes to PBR – this is an area, however, where the industry needs to continually remind the agency of its worthy goals and actively participate in rulemaking groups.
As a next step, authorities will focus on harmonising how these common rules are applied in the different EU Member States. Meanwhile, airports will implement a more permanent and dynamic system of compliance management, partly to enable them to implement rule updates as those happen in the future.
The process known in EASA circles as “standardisation” has already begun earlier this year and it involves a series of EASA inspections of Member State authorities to assess how Regulation 139/2014 on aerodrome regulation has been applied. The first countries visited this year were Portugal and Croatia, to be followed by Lithuania (June 2018) and France (September 2018). It is important to note that these standardisation visits are not audits of the airport processes directly, but audits of the Civil Aviation Authorities (CAAs). However, they consistently involve a visit of the airport and can involve findings against an authority with a bearing on the airport operator. Overall, an effective standardisation process will be essential in shaping a consistent application of EU rules across all the Member States.
From the airport perspective, the period that begins now is focused on compliance management. Compliance management is how an ever-changing airport operation can ensure that it meets regulatory requirements whether EU or national in origin. As aviation authorities have already given their approval to existing processes, equipment and operations, the focus going forward will be on changes (both in airport operations as well as the rules themselves). As a result, the process where new ways or means of airside operations will be checked for alignment with safety and other objectives is known as “change management”.
Efficient compliance and change management can enable an airport to easily adopt innovative solutions, new regulations, as well as new equipment in order to keep improving its operation. Airport directors, take note – agile responses will be key, going forward.
ACI EUROPE helps airports to exchange EASA certification experiences through the Aerodrome Rules Implementation Exchange (ARIE) Forum
In 2015, ACI EUROPE launched a specialised forum named the Aerodrome Rules Implementation Exchange (ARIE) to obtain a clear picture of how aviation authorities and airports were managing the new EU safety rules on aerodromes. This has facilitated a seamless and robust EASA certification process that maintains high standards of safety without creating undue burdens for airport operators. The ARIE forum has so far met in Frankfurt Airport (July 2015), Paris-Charles De Gaulle Airport (February 2016), Rome Fiumicino Airport (November 2016), Copenhagen Airport (June 2017) and Madrid-Barajas Airport (May 2018). These meetings are organised under the auspices of ACI EUROPE’s Safety Regulation Steering Group.
The ARIE platform meets on a yearly basis to allow safety experts and certification & compliance managers from a wide variety of airports and national associations to learn more about efficient and effective ways to comply with EASA rules.
If your airport is interested in participating in or hosting future ARIE meetings, please contact Panos Spiliotis, ACI EUROPE Safety, Capacity, ATM & Single European Sky Manager (firstname.lastname@example.org).
Panos Spiliotis is Safety Manager at ACI EUROPE.
Ansgar Sickert is ACI EUROPE’s Liaison Officer to EASA.