Interim Report - Introduction - EASA

INTERIM REPORT – OPTIONS FOR CHANGE
EASA.2009.OP.21
4.9 Regulating de-icing / anti-icing through regulation of
aerodromes
Some aerodromes are in a privileged position, in that they can choose whether to provide deicing
/ anti-icing services themselves when it is profitable. Some benefit from being the sole
provider of these services, whereas others, who are also acting as sole providers, do so at a
financial loss. The Data Summary and Analysis section of this Report provides more details
concerning the varying degrees of involvement aerodromes have in de-icing / anti-icing
provision. Regardless of whether an aerodrome provides these services themselves, or not,
they do have responsibilities for facilitating the infrastructure and also for the safety of
activities conducted at the aerodrome. How much responsibility, and in what areas, can be
debated. Whether de-icing / anti-icing vehicles, fluid storage and equipment are considered
“infrastructure”; and, whether activities conducted by parties under contract to operators have
anything to do with the aerodrome management can be, and are being, debated. The lack of
clarity may be considered by some to be useful in providing some degree of practical
flexibility, whereas others may consider it to be a source of confusion.
REGSP3, above, is an Option to make de-icing / anti-icing service provision fully a
responsibility of the aerodrome. An alternative pathway to raising standards of de-icing /
anti-icing service provision could be to utilise existing, and proposed, aerodrome regulation
to encourage closer scrutiny and a greater involvement in de-icing / anti-icing operations by
the aerodrome. This need not be in conflict with operators’ programmes and contracts, nor
interfere with any market access that may exist.
Furthermore, the aerodrome is in a unique position in hosting airport users’ committees and
boards, where all relevant stakeholder groups are represented. These bodies can generate
opportunities to establish local consensus on infrastructure, traffic management, procedures
and to address local hazards.
An aerodrome’s certification by the appropriate Authority includes the acceptance/approval of
the airport manual, which shall contain details of the de-icing / anti-icing facilities and
services (ICAO Annex 14, 1.4.4). Interpretation of, and compliance with, Annex 14 is nonstandard
within EASA Member States (airsight Study on Annex 14 Implementation).
Depending on an Authority’s interpretation of Annex 14 in respect of de-icing / anti-icing
facilities, services and location, determines how the responsibilities of aerodromes are
currently defined and therefore their compliance with these responsibilities. EASA is currently
undertaking the task of creating Implementing Rules for aerodromes, and following this
process the question of varied interpretation and application should be resolved.
Aerodromes must also comply currently with ICAO SMS Standards, which NAAs are obliged
to enforce. Options SAF1, SAF2, and SAF3 above, address the need for specific focus onto
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