Interim Report - Introduction - EASA

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INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 This Article is designed to prevent organisations subsidising their ground-handling services from other activities in order to maintain a false edge over rival companies, by making the fact transparent. Clearly this denies an airport the ability to include de-icing / anti-icing services as part of the aerodrome infrastructure, and charges through landing fees for example. Likewise, operators who decide to provide their own de-icing / anti-icing services by self-handling would need to separate those accounts from their main business. Yet if deicing / anti-icing, as declared in Doc9640 and Annex 6 is an operational activity, then there should be no requirement to do so; even if an operator considers it continuing airworthiness. This Article could be amended to exclude de-icing / anti-icing from the necessity to separate the accounts from other activities. The impact may be a less fair commercial playing field, where aerodromes could undercut other service providers by subsidising a loss-making activity, perhaps de-icing / anti-icing, from their other activities. However, it would also support the concept of aerodromes collecting revenues for de-icing / anti-icing through indirect means from all airport users. Article 5 – Airport Users' Committee 1. Member States shall ensure that, for each of the airports concerned, a committee of representatives of airport users or organizations representing airport users is set up. 2. All airport users shall have the right to be on this committee, or, if they so wish, to be represented on it by an organization appointed to that effect. Without recommended agendas and powers allocated to the AUC, this Article is pointless. An option would be to specify how decisions made by the AUC could, or should, be addressed by the airport users, and also what types of decisions ought to be made on what topics. The impact may improve the effectiveness of those AUC’s that rarely meet, and those that are ineffective in making change. Article 6 2. Member States may limit the number of suppliers (not below 2) authorized to provide the following categories of ground-handling services: — baggage handling, airsight GmbH - 76 -
INTERIM REPORT – OPTIONS FOR CHANGE – ATTACHMENT B <strong>EASA</strong>.2009.OP.21 — ramp handling, — fuel and oil handling, — freight and mail handling De-icing / anti-icing is not included, indicating that States cannot limit the number of de-icing / anti-icing suppliers at any location. To align this Article with clauses 11, 22 & 23, as discussed above, de-icing / anti-icing could be added to this list. It would seem fair to add a caveat that where a State provided a safety case in favour of limiting the number of suppliers in any category of ground-handling service, then it should be free to do so. Such safety cases should be scrutinised by an independent body. State involvement should not be to its own commercial benefit (directly or indirectly), and such a rule may also reduce commercial fairness. However, where a safety case can be made the impact on safety should be positive. Article 8 – Centralized infrastructures 1. Notwithstanding the application of Articles 6 and 7 (self-handling), Member States may reserve for the managing body of the airport or for another body the management of the centralized infrastructures used for the supply of ground-handling services whose complexity, cost or environmental impact does not allow of division or duplication, such as baggage sorting, de-icing, water purification and fuel-distribution systems. They may make it compulsory for suppliers of ground-handling services and self-handling airport users to use these infrastructures. 2. Member States shall ensure that the management of these infrastructures is transparent, objective and non-discriminatory and, in particular, that it does not hinder the access of suppliers of ground-handling services or self-handling airport users within the limits provided for in this Directive. Complimenting clause 13. Although there is no defining what centralised infrastructure constitutes de-icing / anti-icing, interpretation can include ramps, pads, lights, signs, communication, fluid storage and handling, and also the vehicles. These may all be argued on the case of cost and/or complexity. An option would be to allow the aerodrome to include de-icing / anti-icing vehicles as part of airsight GmbH - 77 -
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