+ RMA Rural Municipalities
of Alberta

Resolution 8-22S

Reversing Changes to Aerodrome Standards Implemented by Transport Canada

March 15, 2022
Expiry Date:
April 1, 2025
Active Status:
MD of Smoky River
4 - Northern
Transportation and Infrastructure
Sent to Government
Vote Results:

WHEREAS aerodromes are non-certified facilities that provide essential transportation services such as emergency services, medical services, and wildfire suppression; and

WHEREAS section 803.02 of the Canadian Aviation Regulations provides the development and publication of instrument procedure requirements for aerodromes in Canada; and

WHEREAS Transport Canada’s TP312 5th Edition Aerodrome Standards introduced changes relating to the physical characteristics for aerodromes; and

WHEREAS the AC 301-001 Advisory Circular changed the Instrument Approach Procedures (“IAP”) requirements for aerodromes; and

WHEREAS the AC 803-007 Advisory Circular changed the Aerodrome Operator Attestation requirements; and

WHEREAS the changes for aerodromes will increase the approach and departure minimum weather requirements for runways; and

WHEREAS the requirements will reduce accessibility for aircraft, including air ambulances, to approach and depart aerodromes;

Operative Clause:

THEREFORE, BE IT RESOLVED that the Rural Municipalities of Alberta requests that the Government of Canada either reverse the newly amended Instrument Approach Procedures to maintain aircraft accessibility to community aerodromes in Alberta, or suspend the new requirements to carry out the necessary studies such as a risk assessment or impact assessment associated with the new standards.

Member Background:

In 2015, TP312 5th Edition Aerodrome Standards and Recommended Practices document introduced changes relating to the physical characteristics needed to support Instrument Approach Procedures for airports. While it was not binding on aerodromes, it established a new standard for runways.

In 2017, Transport Canada introduced changes to aerodrome standards in order to align with international standards reflected in the International Civil Aviation Organization (ICAO). At that time, Transport Canada did not complete an impact assessment to determine the affect the proposed requirements may have on aerodromes across Canada. Despite the lack of evaluation and reporting, the changes created more onerous requirements for physical characteristics of aerodrome runways as compared to those introduced in 2015 (TP312 5th Edition Aerodrome Standards and Recommended Practices) for airports. Transport Canada gave aerodromes until December 31, 2020 to comply. In response to COVID-19, Transport Canada amended the deadline to September 30, 2021. That deadline had been extended to December 31, 2021, then again to March 31, 2022.

Section 803.02 of the Canadian Aviation Regulations (CARs) regulates the development of instrument approach procedures in Canada through the standards manual entitled Criteria for the Development of Instrument Procedures, known as TP308. At paragraph 120(a) of the manual, the aerodrome minimum physical characteristics are set out requiring an obstacle-free environment in the vicinity. An aerodrome must meet these infrastructure requirements prior to publishing instrument approach procedures.

By linking the physical characteristics of an obstacle-free zone with the instrument approach procedures, the requirements severely impacted the elevation threshold for aircraft arrivals and departures to aerodromes. For a given aerodrome to obtain a minimum elevation threshold lower than 500 feet for restricted instrument approach procedures at non-certified aerodromes, the obstacle environment must be compatible with the requirements.

Some aerodromes cannot complete physical works due to financial or topographical constraints, and therefore cannot meet the obstacle-free requirement. Other aerodromes are unable to comply because of immovable infrastructure such as hangers or gasoline tanks. In those circumstances, aircraft access to those aerodromes is set at the 500 foot mark with regard to the weather elevation threshold. The 500 foot limit for instrument approach procedures is projected to decrease accessibility to a given aerodrome by 4% over the course of 365 days, given Alberta’s weather and cloud conditions. In other words, an aerodrome that is unable to meet the physical characteristics required cannot then obtain a minimum elevation threshold lower than 500 feet, and as a result will not be accessible by aircraft for approximately 14 days per year given Alberta’s climate.

Because it is weather dependent, this impacts all aircrafts, including air ambulance aircrafts. Most rural communities in Alberta are dependent upon an aircraft medical evacuation system that is reliable, safe and dependable because these communities do not have major hospitals in close proximity. In an emergency situation, air ambulances may be prohibited to land at a non-certified aerodrome that has not obtained a minimum lower than 500 feet if the weather conditions are not appropriate. That circumstance will not change whether someone’s life is in the balance or not.

While not as severe, these new requirements will also have dire consequences for those working at remote resource sites, or for those businesses dependent upon tourism.

Recent activities by the aviation community such as JetPro and others, have gone unnoticed by Transport Canada. NAV Canada has had a similar result when addressing the issue with Transport Canada.

Supporting Documentation

RMA Background:

RMA has no active resolutions directly related to this issue.

Federal Ministries and Bodies:
Transport Canada
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