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;
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.
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 has no active resolutions directly related to this issue.
Transport Canada
Thank you for your letter of March 30, 2022, in which you informed me of a resolution adopted by the Rural Municipalities of Alberta pertaining to aerodrome standards. I apologize for my delay in replying.
The change to the specifications in Advisory Circular 301-001 was needed to standardize the level of safety with that of runways supporting instrument approach procedures (IAPs) at Canadian airports. This will provide a consistent and recognized level of safety for all instrument approaches in Canada during the transition from the instrument approach procedure throughout the visual manoeuvre and landing.
As part of the publication of AC 301-001 Issue 05 Procedure to be followed in order to support Instrument Approach Procedures at a non-certified aerodrome, a one-hour web-based information session was conducted with industry stakeholders on March 17, 2022, to review the changes to the attestation specifications.
With reference to the Aircraft Group Number (AGN) methodology in AC 301-001 Issue 05, it will be up to an aerodrome operator, in consideration of the needs of the community, to formally attest as to what category of aircraft their runway obstacle-free environment is suitable for supporting IAPs. Due to the structure of the technical specifications, the AGN methodology allows the use of smaller protected airspace for some aerodromes and will therefore allow access to most aerodromes for the common medevac airplane types, such as the Beech King Air class, operating at these locations.
With the subsequent publication of the attested AGN in the Canada Flight Supplement, air operators and air crews will have access to supplemental information to assess if an aerodrome is suitable for their operation and aircraft. I would note that the publication of a particular AGN for a runway does not in itself impose any additional regulatory restriction to the runway’s use at the aerodrome. The air crew’s assessment of the suitability of the aerodrome is a current Canadian Aviation Regulations requirement that is always applicable to all aircraft operations. It is the aerodrome operator’s decision to decide to attest or not based on the needs of the community.
Transport Canada’s first and foremost objective remains safety, and it is our intent to continue to uphold a high level of safety at Canada’s aerodromes supporting instrument approach procedures. Using the same set of specifications with regards to obstacle separation for all runways in Canada achieves this level of safety.
Transport Canada’s response indicates that the changes made to aerodrome standards are intended to enhance safety measures at Canadian airports that support instrument approach procedures (IAPs). The changes are also required in order to establish a standard and recognized level of safety for all instrument approaches across Canada.
RMA appreciates Transport Canada’s response. However, the resolution specifically calls for reversing the amendment to the instrument approach procedures or postponing the implementation until an impact assessment can be conducted. Transport Canada’s response indicates no intention to reverse the implemented amendment. Therefore, this resolution is assigned a status of Intent Not Met.
To better understand this issue and its impacts on rural airports, RMA has engaged with the Alberta Aviation Council (AAC) and the Canadian Operators and Pilots Association (COPA). These associations are aware of the impacts that these changes will have on local airports, however they are focused on mitigation of the impacts. The AAC and COPA expressed that since the changes fall within international standards, they are unlikely to be reversed or modified and that efforts will be best utilized advocating for mitigation strategies. Specifically, through use of collaboration agreements between airports and providing training and resources to airports. Although mitigation is not the intent of the resolution, RMA plans to support mitigation efforts while continuing to advocate for impact assessments.