Recommendation

SUBJECT - USE OF UNLICENSED AERODROMES BY REGIONAL AIRLINE
OPERATORS





INTRODUCTION - REGIONAL AIRLINES SAFETY STUDY



Between October 1995 and July 1997, the Bureau of Air Safety
Investigation undertook a study of the safety of Australian
regional airlines. The objectives of this study were to:



(a) identify safety deficiencies affecting regional airline
operations in Australia; and

(b) identify means of reducing the impact on safety of these
deficiencies.



For the purpose of the survey, regional airlines were grouped
according to the number of passenger seats fitted to the largest
aircraft operated by that airline in January 1997. The groups are
defined as follows:



(a) Group 1: 1-9 seats;

(b) Group 2: 10-19 seats; and

(c) Group 3: more than 20 seats.



The study involved analysing data obtained from:



(a) responses to a survey of Australian regional airline
employees;

(b) discussions with Australian regional airline employees and
managers; and

(c) air safety occurrence reports involving regional airlines over
a 10-year period (1986-1995) from the BASI database.



This Safety Advisory Notice addresses one of the safety
deficiencies identified as a result of this study.





SAFETY DEFICIENCY



Some unlicensed aerodromes used by some regional airlines may not
be suitable for airline operations. In addition, reliable
information on some unlicensed aerodromes may not always be
available.





FACTUAL INFORMATION



Survey Results



A licensed aerodrome is required to meet all the appropriate
requirements in Civil Aviation Regulations (CARs) and has its
details published in Aeronautical Information Publications (AIP).
Any changes to the published status of a licensed aerodrome will be
published in Notices to Airmen (NOTAMs). However, when using
unlicensed aerodromes, it is the responsibility of flight crews to
obtain information on the state of the aerodrome from its
owner/operator. As not all pilots use unlicensed aerodromes, only
60% of pilots completing the survey answered the questions
pertaining to unlicensed aerodromes.



Twenty-two per cent of pilots responding to the question in the
survey relating to unlicensed aerodromes, agreed that the condition
of some unlicensed aerodromes they used was hazardous. The same
proportion of pilots answered that they could not always get
reliable information on the condition of the unlicensed aerodromes
they used.





Background



Airline operations into unlicensed aerodromes are permitted,
provided the aerodromes meet minimum prescribed standards and are
maintained to those standards. Unlicensed aerodromes of smaller
dimensions are permitted to be used by aircraft of lower operating
weights; however, such aircraft operating into these aerodromes
must be flown in visual, daylight conditions (Appendix 3 Civil
Aviation Order Part 82.3).



Many unlicensed aerodromes used by regional airlines were
previously licensed and established to aerodrome standards. The
main reason for delicensing, provided by aerodrome owners and
operators, was the administrative cost of maintaining the aerodrome
licence. Some financial benefit to the aerodrome owner may have
resulted by adopting the smaller dimensions of an unlicensed
aerodrome.





Reporting procedures



Use of an unlicensed aerodrome by regular public transport (RPT)
flights requires airline operators to establish a reporting system
(Civil Aviation Order Part 82.3). As part of this reporting system,
the airline operator must nominate a reporting officer to conduct
the aerodrome inspection and report on its status. The condition of
the aerodrome must be conveyed to the airline operator before the
arrival of each scheduled flight.



Many regional airlines use a "negative" reporting system whereby
only unserviceable conditions are reported. It is assumed that the
aerodrome is serviceable when a report is not received.



Responsibility for ensuring the serviceability of unlicensed
aerodromes used by RPT flights, lies with the airline and not the
aerodrome owner or operator. However, reporting officers are
charged with the responsibility of ensuring the aerodrome
serviceability is accurately reported to the airline.



The Civil Aviation Safety Authority (CASA) only approves the
airline operator's reporting system. It is the airline's
responsibility to ensure reporting officers are fully conversant
with the standards and have been appropriately trained, as required
by CAR 89V.





Related occurrences



A search of occurrences over a 3-year period revealed only a small
number of reported occurrences, the majority of which resulted from
the presence of people, animals or equipment on the movement area
during an aircraft's approach to land or following takeoff.
However, one occurrence resulted in serious damage to an
aircraft.



"Towards the end of the landing roll the aircraft encountered a
soft wet area on the runway, resulting in mud and stones being
thrown up over the aircraft, causing stone damage to all propeller
blades, the right side fuselage panels, and right side cockpit, and
cabin windows. This soft area was not discernible from the air. The
NOTAMs obtained by the pilot prior to the flight indicated that
none were current for that aerodrome. Rain had fallen earlier at
the aerodrome, but not at the homestead; therefore, the property
owner was not aware of the soft wet areas on the runway."



BASI Report 9601565





Surveillance



As part of CASA's scheduled surveillance of an airline operator,
any unlicensed aerodrome serving as a destination on that
operator's Air Operator's Certificate (AOC) requires annual
inspection by an aerodromes inspector. The airline operator is
advised in advance of these inspections. In addition, and as a
courtesy, the aerodrome owner is also advised. Despite being
forewarned of an inspection, a number of unlicensed aerodromes did
not meet the required standards.



Aerodrome inspectors found large stones, sink holes, washouts,
ruts, sand drifts, overgrown vegetation, tussocks and soft patches
to be the main physical shortcomings of these aerodromes. They were
concerned that these conditions had not been reported to the
airline operator, as required, or that the reports were ignored by
flight crews.



Despite these reported conditions, only one aerodrome in the last
three years was considered to be in such poor repair as to warrant
having this destination removed from the operator's AOC.





Non-compliance notices



A non-compliance notice (NCN) is a formal notification from CASA
to an AOC holder, advising that a safety deficiency exists. NCNs
are issued to airline operators against deficiencies in airfield
reporting procedures and unlicensed aerodrome standards.



Aerodrome inspectors estimated that the majority of NCNs,
approximately 70%, were related to sub-standard physical
characteristics of the aerodrome. Aerodrome markings and inadequate
fencing were other significant deficiencies. Records show many NCNs
that were issued following each inspection for some aerodromes,
were for similar reasons. Inspectors cited ignorance of published
standards and inadequate maintenance as the main reason for the
reissue of some NCNs.





Aerodrome maintenance



Maintenance of aerodromes owned by municipalities is mostly funded
by rates. Some of the community aerodromes have access to funding
through government grants or subsidies but the majority of the
unlicensed aerodromes are owned and maintained privately. Revenue
raising measures such as landing fees to cover the cost of
aerodrome maintenance, are not feasible because of the limited
number of aircraft movements. Likewise, low passenger numbers
preclude the raising of funds from ticket taxes.



It was reported that maintaining an unlicensed aerodrome to
airline standards was difficult to justify when the average
utilisation by airline aircraft is only one or two movements per
week. Difficulty in obtaining access to suitable equipment such as
graders and heavy rollers for maintaining these airfields, was
cited by aerodrome inspectors as a major obstacle to the continued
upkeep of natural surface runways.





ANALYSIS



Aerodrome maintenance and adherence to published standards is
important to the safety of fare-paying passengers. Acceptance of
lower standards jeopardises that safety. In order that airline
flight crews can make informed decisions about the use of
unlicensed aerodromes, aerodrome owners and operators have a
responsibility to ensure that reporting officers are adequately
trained to perform their inspections and that they report aerodrome
conditions consistently and accurately.



Reporting procedures used by some regional airlines may not be
adequate to allow flight crews to make informed decisions about the
use of unlicensed aerodromes. "Negative" reporting systems can
create uncertainty in the minds of flight crews. When the
serviceability of an aerodrome is not communicated, flight crews
have no way of knowing whether an aerodrome inspection has been
carried out, or that the inspection report was not passed to them.
This lack of communication between airline operators and aerodrome
reporting officers appears to be the cause of much misunderstanding
about aerodrome serviceability.



Airline operators using unlicensed aerodromes should evaluate the
adequacy of the training given to reporting officers and consider
certification of that training as a means of establishing quality
control and standardisation.



The lack of reported incidents does not make an argument for the
relaxation of the existing aerodrome standards.