INVENTORY OF ANSWERS to the consultation document on the basic principles and essential requirements for the safety and interoperability regulation of aerodromes Question 1 The Agency is interested in knowing if stakeholders agree that the establishment of dedicated high level essential requirements at Community level is the best means to set the safety objectives for the safety regulation of aerodromes. Comment From Nature number 0001 CAA Romania These stakeholders broadly support the adoption of Essential 0065 CAA Belgium Requirements (ER) at Community level as the best means to set the 0074 British Helicopter safety objectives for the safety regulation of aerodromes. Advisory Board 0081 CAA Spain Many of them at the same time emphasize certain aspects, which 0107 DFS should be taken into account when regulating in this field: 0142 AEA - maximum consistency with ICAO SARPs 0172 BAA Aberdeen Airport - proportionate rules for small or non-commercial aerodromes 0189 Gloucestershire Airport - consistency with the Single European Sky (SES) regulations 0198 BAA Central Airside in CNS/ATM Operations - setting ER on appropriately high level 0217 BAA Heathrow - harmonisation on minimum safety levels across all EU 0235 Guernsey Airport Member States 0265 Fraport AG 0509 CAA Slovak Republic 0564 CAA Netherlands 0582 CAA Denmark 0611 Glasgow Airport Airfield Operations 0637 Manchester Airport 0700 Nottingham East Midlands Airport 0727 AMS Schiphol Airport 0738 Belgian Gliding Federation 0784 CAA UK 0911 Birmingham Airport 0936 CAA Greece 1046 Irish Aviation Authority 1079 Airbus, France 1093 CAA Sweden 1111 Humberside Airport 1120 Dublin Airport Authority 1153 ENAC Italy 1172 Ministry of Transport Slovenia 1196 ECA 1208 CAA Norway 1219 Christian Marek 1269 Luton Airport Inventory - CRD to NPA-06-2006 page 1 of 43 1275 FOCA Switzerland 1286 Dutch Civil Airports Association 1331 IFATCA 2967 CAA-Czech Republic 2988 ECOGAS 2997,3004 EUROCONTROL 0029 Air League These stakeholders support the adoption of ER as appropriate means to 0098 Bickerton’s Aerodromes set the safety objectives provided that the small aerodromes used for Ltd recreational purposes or remote aerodromes would be excluded from 0253 CAA Iceland the scope of this legal action. 0308 Count of Atlas 0316 Chris Way For the majority of them the threshold to identify large aerodromes 0319 Ian L. Craig Wood should be set for commercial air transport or operations by aircraft 0327 John H.E. Wells with MTOM more than 10 tons. 0330 EGU 0339 Chris Lear 0359 Ian Rhodes 0367 Michael Shaw 0375 Helicopter Club GB 0383 Richard Bailey 0391 Helicopter Museum 0399 John Allwright 0415 Ian Wace 0416 Richard Kingston 0424 Chris Fox 0440 Swiss Aero Club 0461 Richard McLachlan 0469 Peter Stratten 0476 G.P. Glibbery 0521 Squirrel Helicopters 0530 GAAC 0539 David Marks 0545 Jason Tebaldi 0553 Edward and Susan Vandyk 0574 CAA Finland 0615 Tony Harrison-Smith 0709 Richard Dawson 0748 IAOPA 0756 Janet Christie 0773 Anthony Christie 0823 UK Flying Farmers Association 0847 Clifford P. Lockyer 0859 Roger Hopkinson 0888 C.J.H. Richardson 0989 AOPA Italy 1024 AOPA Norway 1074 British Hanggliding and Paragliding Association 1284 Dutch Civil Airports This stakeholder does not see any benefit from the safety regulation, Association but sees a potential benefit for the internal market. 0011 KLM These stakeholders do not support the development of ER as common 0125 British International safety objectives and would therefore rather continue existing practises 0448 Teuge Airport with sole national implementation of ICAO SARPs. 0681 BMV Germany 0875 Schweizer Inventory - CRD to NPA-06-2006 page 2 of 43 Flugplatzverein 0968 Avinor AS 0977 German Airport Association 1187 Finavia 1238 Prague Airport 1687 Hessian Ministry of Economics, Transport, Urban and Regional Development 0040 AOPA UK These stakeholders did not indicate a clear position. 0295 Aubrey Bristow 1003 DGAC France 1139 ACI Europe 1229 Lyon Airport Analysis The majority of stakeholders agree with the establishment of high level essential requirements at Community level. However, a considerable number of general aviation stakeholders would like to exclude aerodromes used only for recreational purposes. It can be noted that 15 Ministries (or National Aviation Authorities) expressed a favourable opinion, while only one Administration of a Member State is opposing the regulation at European level. Inventory - CRD to NPA-06-2006 page 3 of 43 Question 2 on essential requirements The Agency is interested in knowing whether the attached essential requirements actually meet the criteria developed here above and whether they constitute a good basis for the safety and interoperability regulation of the aerodromes bearing in mind the envisaged scope. Comment From Nature number 0002 CAA Romania These stakeholders can broadly accept the proposed draft ER as a 0099 Bickerton’s Aerodromes good basis. In addition, many of them also proposed 0143 AEA improvements to draft ER. These proposed improvements have 0173 BAA Aberdeen Airport been individually analysed in the 'CRD - Essential Requirements + 0199 BAA Central Airside General Comments'. Operations 0218 BAA Heathrow Following more general issues were also raised by stakeholders in 0236 Guernsey Airport this context: 0317 Chris Way - enforcement of applicable rules 0484 British Airport Operators Ass. - proportionality of rules 0565 CAA Netherlands - need to ensure compatibility with ICAO SARPs 0575 CAA Finland - need to explain better flexibility and risk assessment in 0583 CAA Denmark the proposed framework 0785 CAA UK - competence scheme of ground handling personnel 0914 Birmingham Airport 0937 CAA Greece 1024 Irish Aviation Authority 1080 Airbus, France 1094 CAA Sweden 1112 Humberside Airport 1154 ENAC Italy 1188 Finavia 1220 Christian Marek 1239 CAA Czech Republic 1276 FOCA Switzerland 2968 Prague Airport 2998 EUROCONTROL 0030 Air League These stakeholders consider that the proposed draft ER are not 0301 G.M. Tipler satisfactory due to their too general nature. 0309 Count of Atlas 0320 Ian L. Craig Wood Most of the comments also invited the Agency to consider 0360 Ian Rhodes national legislation and experience in this field. 0368 Michael Shaw 0392 Helicopter Museum 0400 John Allwright 0417 Richard Kingston 0425 Chris Fox 0433 Michael Taylor 0462 Richard McLachlan 0477 G.P. Glibbery 0522 Squirrel Helicopters 0546 Jason Tebaldi 0554 Edward and Susan Vandyk 0616 Tony Harrison-Smith 0638 Manchester Airport 0749 IAOPA 0757 Janet Christie Inventory - CRD to NPA-06-2006 page 4 of 43 0774 Anthony Christie 0815 Michael Jacobsen 0824 UK Flying Farmer Association 0848 Clifford P. Lockyer 0860 Roger Hopkinson 0889 C.J.H. Richardson 0990 AOPA Italy 1025 AOPA Norway 0912 Birmingham Airport These stakeholders consider that the proposed draft ER are not 0108 DFS satisfactory due to their too detailed nature. 0127 British International 0266 Fraport Some see the risk of expanding too much the responsibilities of 0682 BMV Germany aerodrome operators. 2988 ECOGAS 0296 Aubrey Bristow These stakeholders did not express a clear statement to the 0540 David Marks question itself, but proposed: 1230 Lyon Airport - need of clearer definitions 2977 Teuge Airport - need to exclude small aerodromes used for recreational purposes from the scope of this legal action - improvement of first aid requirements 0331 EGU These stakeholders would rather continue existing practises with 0348 E.A. Sturmer sole national implementation of ICAO SARPs. 0441 Swiss Aero Club 0470 Peter Stratten In most cases this is because they do not regard draft ER as a good 0712 John Brady basis specifically for their activity, such as gliding or recreational 0876 Schweizer Flugplatzverein flying. 1688 Hessian Ministry of Economics, Transport, Urban and Regional Development 0969 Avinor AS These stakeholders did not indicate a clear position. 1146 ACI Europe 1259 Luton Airport Two of them consider that not enough information on the risk 1289 Dutch Civil Airports analysis and process has been given. Association Analysis The majority of stakeholders can broadly accept the proposed draft ERs as a good basis. Many of them propose improvements to the text. These proposed improvements have been analysed individually and separately in the Annex to the CRD. On the contrary, a significant minority is of the opinion that the proposed ER are not a good basis either because they are too general or too detailed. A few stakeholders do not regard draft ER as a good basis specifically for their activity. In any case an overwhelming majority stressed the need for clear definitions and clear scope of the regulation, as well as for proportionate requirements addressed to “small” aerodromes. Inventory - CRD to NPA-06-2006 page 5 of 43 Question 2 on rescue and fire fighting The Agency also welcomes any suggestion to improve these essential requirements, in particular as regards the requirements for rescue and fire fighting services. Comment From Nature number 0012 KLM These stakeholders have commented the issue of Rescue and Fire 0173 BAA Aberdeen Airport Fighting Services (RFFS) stressing for a need to follow exactly the 0199 BAA Central Airside line taken by ICAO in this matter. Operations 0218 BAA Heathrow 0266 Fraport 0331 EGU 0449 Teuge Airport 0470 Peter Stratten 0712 John Brady 0728 AMS Schiphol Airport 0969 Avinor AS 1094 CAA Sweden 1146 ACI Europe 1188 Finavia 1276 FOCA Switzerland 1287,1288 Dutch Civil Airports Association 0030 Air League These stakeholders have commented the issue