Interim Report - Introduction - EASA

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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 airsight GmbH 57
INTERIM REPORT – OPTIONS FOR CHANGE EASA.2009.OP.21 de-icing / anti-icing. Similarly, the requirement for aerodromes to define lines of safety responsibility will help support Option SME5, above. Often, the choice of an operator to undergo two-step de-icing / anti-icing is considered as an “additional” requirement, especially at aerodromes where one-step is the norm. In such cases, the aerodrome may be planning its winter operations around traffic flow times associated with one-step de-icing / anti-icing. However, ICAO Doc 9640 is clear in its statement that, concerning facilities, aerodromes should plan for the two-step de-icing / antiicing procedure for all de-icing / anti-icing operations even though some operators may choose the one-step procedure on some occasions. Doc 9640 also defines an aerodromes facilities as having the following components: a) de-icing / anti-icing pads for the manoeuvring of aeroplanes; b) de-icing / anti-icing system comprising one or both of the following: 1) mobile vehicles, and 2) fixed equipment; c) bypass taxiing capability; d) environmental run-off mitigation measures; e) permanent or portable night-time lighting system; and f) support facilities that may include: 1) storage tanks and transfer systems for de-icing / anti-icing fluids; and 2) de-icing crew shelter. The inclusion of vehicles supports Option GHDAD2, below. De-icing / anti-icing fluids are not specifically mentioned, however, if an aerodrome has some responsibility over the de-icing / anti-icing vehicles (directly or indirectly), and it needs to plan for two-step operations, then having Type I fluid available must be an inferred requirement. Two key elements of an aerodrome’s de-icing / anti-icing facilities are the location and size of the de-icing / anti-icing areas (pads, aprons, ramps). Specifically, they should present the shortest distance possible to departure runway thresholds to preserve HoTs (Doc 9640 9.5), and they should be able to cope with all expected weather conditions, all relevant aircraft types, all de-icing / anti-icing application methods, and the capability of the de-icing / antiicing vehicles and equipment (Annex 14, 3.15.6). NAAs could require aerodromes to explain how they ensure that the de-icing / anti-icing facilities available at their aerodrome meet the requirements of their winter traffic plan. In some cases, this may require aerodromes to explain how the desired winter traffic plan is not met, due to inadequate de-icing / anti-icing facilities and/or services. airsight GmbH 58
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Interim Report - Introduction - EASA

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