Interim Report - Introduction - EASA

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INTERIM REPORT – DATA SUMMARY AND ANALYSIS <strong>EASA</strong>.2009.OP.21 2.3 Responsibilities of the National Aviation Authorities (NAAs) 2.3.1 Coordination of de-icing / anti-icing activities within the NAAs De-icing / anti-icing activities generally involve several departments of the Authorities, namely: Safety Regulation, Certification, Aerodrome, Flight Operations, Airworthiness, and Personnel Licensing department. According to representatives of the NAAs, responsibilities in this field are divided between the one or many of the above mentioned departments; 3 out of 10 NAAs stated that the Aerodrome department held responsibility, while the remainder mentioned divided responsibilities – involving principally the Aerodrome, Safety Regulations, Airworthiness (incl. maintenance) and Flight Operations departments. NAAs normally have no principal coordinator in the field of de-icing / anti-icing (exceptions: France and Switzerland). 2.3.2 National de-icing / anti-icing regulations directly applicable to aerodromes and service providers The answers provided by the stakeholders (aerodromes, service providers, aircraft operators and national aviation authorities) through the questionnaires on the regulations of de-icing / anti-icing services have to be taken with great caution. Therefore, no quantitative figures based on the answers are provided in this chapter. A cross-analysis of the responses provided by stakeholders operating at the same aerodrome or within the same Member State reveals many discrepancies and contradictions. For instance, in the United Kingdom, 5 service providers stated in the questionnaires that the UKCAA would regulate their operations and 5 other providers stated that it would not 24 . The UKCAA itself advised that contractual arrangements between airlines and their service providers are not regulated. Firstly, the questionnaires and interviews were aimed to collect information on binding regulations published by national authorities specific to de-icing / anti-icing which are directly applicable to service providers or aerodromes. However, the respondents have very different definitions or perceptions of the scope, applicability, nature or status of “regulations” – which makes comparison of answers difficult. Although only a minority of the aerodromes and 24 Service Provider Questionnaire – Question 4.1: What influence does your National Aviation Authority have over your operations? airsight GmbH - 37 -
INTERIM REPORT – DATA SUMMARY AND ANALYSIS <strong>EASA</strong>.2009.OP.21 service providers declared that their de-icing / anti-icing activities are regulated, this minority probably overestimated the extent of the regulations: − For instance, ICAO manuals or AEA recommendations, which are not binding regulations, are in some cases perceived as binding regulations by the service providers or aerodromes. − Similarly, some respondents (e.g. NAAs of Hungary, Czech Republic and Italy), referring to the fact that de-icing / anti-icing is a ground handling activity, answered in the questionnaire that de-icing / anti-icing is regulated by the national implementation of the Council Directive 96/97/EC – or by the Code of Civil Aviation. While these answers are semantically correct, these national ground handling regulations do not cover specifically or in great details de-icing / anti-icing services. − Additionally, many NAAs, aerodromes and service providers consider (correctly) that de-icing / anti-icing services are regulated, but with reference to indirect regulation through air operations regulations (EU-OPS). Therefore, in general, no specific, direct, binding National Aviation regulations are applicable directly to de-icing / anti-icing service providers. A regulatory document applicable to service providers and containing some detailed requirements on de-icing / anti-icing operations was provided by Finland 25 . This document, is however non-exhaustive and contains a few requirements in addition to those derived from Directive 96/97/EC. It makes reference to the “ICAO Manual of Aircraft Ground de-icing / anti-icing Operations” (ICAO Doc. 9640- AN/940), and therefore does not contain detailed binding specifications. 2.3.3 Direct oversight of de-icing / anti-icing service providers by National Aviation Authorities According to the responses provided by the service providers, NAAs perform very little oversight of de-icing / anti-icing service providers: only three of 54 service providers (less than 6%) stated that their NAAs conducted audits on their operations 26 . NAAs may conduct audits of the aerodrome de-icing / anti-icing infrastructure (against ICAO Annex 14 requirements) and approve or license ground handlers, but they do not conduct 25 GEN M1-3, 12.6.2002: Ground Handling at Airports (Chapter 4.2.2: De-icing and anti-icing); www.ilmailuhallinto.fi/files/lth/imt-gen-m/ger1_03.pdf - last accessed 27.10.2010. 26 Service Provider Questionnaire – Question 6.3: Who conducts audits on your Operations? airsight GmbH - 38 -
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