Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
controllers and pilots in its use, limitations, maintenance and capabilities. The ILS is viewed
from the “safety” and not the “commercial perspective”. De-icing / Anti-icing services are not
mandated, nor do they have to be used when available: in both these cases departure during
“winter” conditions will not be possible. However, if de-icing / anti-icing services are available
and used, then, like an ILS, there does need to be clear, strict rules and guidelines for all
those involved on how these services operate. Currently this is not the case.
Status Quo
While some individual stakeholders argue that the existing situation is adequate and that
further regulation is not required, a majority of others (from all stakeholder groups) wish to
see changes.. This Study was launched on a wave of support, lobbying and
recommendations made during the past 5 years.
ZERO: Do nothing; maintain the status quo. Not recommended.
This is not an option for change, but it is still an option to be considered.
However, to select this option would ignore recommendations made by
accident investigators, regulators, industry stakeholders and also the available
data – all introduced above and elsewhere in this Report. Agency Opinion to
A-NPA-2007-11 dismissed this option for service providers and aerodromes,
but kept it as an option for operations.
Direct Regulation of Service Providers
Examining mechanisms for the direct regulation of service providers is part of the Study.
Some stakeholders consider this a difficult and unnecessary option; preferring to improve
standards through amendments to regulation of operators and aerodromes. However, a
large representation of service providers is supportive of a system of direct oversight and
certification.
REGSP: To implement direct regulation of de-icing / anti-icing service providers by
EASA or NAAs.
This option would provide a completely new and untested model. The Study
found that de-icing / anti-icing service providers are not regulated directly by
Member States. On the few occasions where an Authority declared it did
regulate service providers, it was found that this was actually only indirectly
achieved through The Ground-Handling Directive 96/67/EC, Aerodrome and
Air Operations regulations. Ultimate responsibility always remains with the
operator; and this requirement would probably need to always remain. This is
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