A20-02 - “The Department of Transport review and simplify operating minima for approaches and landings at Canadian aerodromes.”
Transport Canada Response to Recommendation A20-02
The recommendations A20-01 and A20-02 are related and will be addressed in a single response.
TC agrees with Recommendation A20-01 and, as outlined below, has already initiated work to implement improvements to the regulations governing approaches and landings at Canadian aerodromes.
TC also agrees with Recommendation A20-02. While recognizing that it may be difficult to stop all approaches and landings that are prohibited through the regulations, introducing simpler regulations in keeping with Recommendation A20-01 will make them easier to follow and to enforce. Furthermore, TC will investigate possible improvements to education and enforcement as part of its upcoming work in this area.
The safety issues raised by the two recommendations are not unknown to TC. The complexity of the current approach ban regulations, promulgated in 2006, are the result of multiple compromises following consultations with industry to reflect the diverse realities facing Air Operators. As such, TC has already carried out significant work on this issue in the past five years:
- In 2015, TC developed an issue paper that was presented to the National Civil Aviation Management Executive Committee (NCAMX) recommending that the regulations should be revised to harmonize with international standards, and to update standards for calculating approach visibility.
- In November 2017, TC developed, and circulated through the Canadian Aviation Regulation Advisory Council (CARAC), a Preliminary Issue and Consultation Assessment (PICA) to establish a better understanding of industry concerns and to assist with regulatory development.
- In January 2018, the Assessment concluded that there was a need for consultation with all stakeholders through focus groups and to support to the harmonization with international standards and best practices.
Due to the complexity of the issue, stakeholders raised specific concerns related to the workload associated with implementation; potential service impacts in the North if changes to the approach ban are not done alongside infrastructure improvements; applicability of the changes to the approach ban to helicopter operations; and the need to harmonize proposed changes to the approach ban with changes to lighting standards.
Due to other competing priorities, this was the most recent work carried out by TC on this issue.
TC recognizes that more work needs to be done to mitigate the risks. To this end, revisions to the approach ban regulations (A20-01) must precede steps to ensure the new regulations are followed (A20-02). Building on the aforementioned work and comments received from stakeholders, TC is forming, and will lead, an industry working group on this issue. The working group will have the mandate to deliver on the following:
- Update to TP308/GPH209 - Criteria for the Development of Instrument Procedures Footnote1 to support new regulations with approach visibility calculations that account for runway approach lighting systems;
- Notice of Proposed Amendment (NPA) to update approach ban regulations as well as the supporting documentation and guidance; and,
- Review of potential measures to encourage and enforce compliance with updated approach ban regulations considering all tools in the regulatory toolbox and the experience of other jurisdictions.
In order to produce the deliverables above, the work will be divided into two phases:
- The first phase will involve a Policy review of the situation and will culminate with a Policy Discussion Paper and a Focus Group(s) with industry.
- During the second phase, the working group will begin the regulatory development that includes an NPA to be completed by January 2021 and have the draft instructions and the pre-publication of the new regulation in Canada Gazette Part I by the end of 2021. The final publication in Canada Gazette Part II will be approximately one year after Part I.