UK Airlines Proposal for Alleviation from ICAO Annex 14 Recommendation 9.2.

4 Rescue and Fire Fighting (RFF), for Nominated Destination Alternate (NDA) only, in UK Overview ICAO Regulation and UK Policy on Rescue and Fire Fighting (RFF)
ICAO Annex 14 states that the rescue and fire fighting (RFF) level of protection provided at an aerodrome shall be equal to aeroplane category. However when there are fewer than 700 high category movements per quarter, then the level of protection provided may be one category below the aeroplane category. Recently ICAO has recommended that the RFF level of protection provided at an aerodrome should be equal to the aeroplane category, even when there are few high category movements. This recommendation is now applied by the UK CAA to both Destination and Nominated Destination Alternate. It is not applied by the majority of other major aviation states, including those in Europe. A UK airline may land and depart from an overseas airport with a lower RFF than that of a Nominated Destination Alternate in the UK.

UK Airlines Proposal
For Nominated Destination Alternate (NDA) only, it is proposed that the use of NDAs with RFF levels of protection which are one category below is permitted (in accordance with ICAO Annex 14 9.2.3 and subject to the proviso covering the maximum number of actual movements per quarter) It is not proposed to permit movements where RFF levels of protection are one category below at Destination aerodromes in the UK.

Basis for the UK Airlines Proposal

o o o o o o o o o o o High safety standards in place at UK aerodromes Extremely low rates of diversions from overhead Destination, especially in UK Low number of affected aeroplane types in UK UK applies Recommendation 9.2.4 for both Destination and Alternate aerodromes, but other states do not Other states apply lower RFF requirements for NDAs compared to Destinations Flight Safety Risk exists due to the use of more distant Destination Alternates Flight Safety Risk exists due to the use of busier Destination Alternates High cost and environmental penalties of current policy UK airlines operating at a competitive disadvantage EASA NPA proposes lower RFF requirements for NDAs compared to Destinations ICAO now proposing lower RFF requirements for NDAs compared to Destinations

Flight Safety remains the highest priority for UK airlines. However we believe that adopting this proposal will improve Flight Safety, yet bring no discernible increase in risk. At the same time

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financial and environmental costs will be reduced, and passenger convenience will be improved.

UK Airlines Proposal for Alleviation from ICAO Annex 14 Recommendation 9.2.4 Rescue and Fire Fighting (RFF), for Nominated Destination Alternate (NDA) only, in UK ICAO Annex 14 states that:
9.2.3 The level of protection provided at an aerodrome for rescue and fire fighting shall be appropriate to the aerodrome category determined using the principles in 9.2.5 and 9.2.6, except that, where the number of movements of the aeroplanes in the highest category normally using the aerodrome is less than 700 in the busiest consecutive three months, the level of protection provided shall be not less than one category below the determined category. 9.2.4 Recommendation.- From 1 January 2005, the level of protection provided at an aerodrome for rescue and fire fighting should be equal to the aerodrome category determined using the principles in 9.2.5 and 9.2.6.

Current Application
In the UK ICAO Recommendation 9.2.4 is now applied to both Destination and Nominated Destination Alternate (NDA) airlines can no longer operate to aerodromes one category below. In most other states, including European states, Recommendation 9.2.4 is not applied to either Destination and Nominated Destination Alternate (NDA). As a result UK airlines regularly operate to aerodromes one category below outside the UK.

High safety standards in place at UK aerodromes

UK airlines understand the importance of the CAAs efforts to raise the standard of RFF cover at UK aerodromes. UK aerodromes have now upgraded equipment and facilities in line with programmed movements. However there is no incentive to aerodrome authorties to incur further ongoing cost, in particular manpower cost, in anticipation of a very rare diversion by a larger aeroplane. Liverpool (LPL) is a good example of this. RFF equipment at LPL is sufficient for planned Cat 8 operations, which are infrequent. To raise RFF capability from the usual declared Cat 7 to Cat 8 requires two extra staff. During weekday office hours, this can often be achieved quickly, although at weekends it takes longer. As a result of this LPL cannot declare Cat 8, and is no longer routinely be used as the NDA for MAN arrivals. In certain circumstances aeroplanes may even divert and then hold overhead an aerodrome awaiting a declared RFF improvement undesirable from the environmental, cost and flight safety viewpoint. It is worth noting that aerodromes are well regulated, equipped and controlled in the UK much better than in most other countries. Therefore airlines are satisfied that flight safety is not compromised by operating at UK aerodromes which are one category below the requirement in the very rare event of a diversion.

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Extremely Low Rates of Diversions from Overhead Destination, especially in UK

Diversions from overhead Destination are very rare. Whilst the need for appropriate RFF cover is clear, it is questionable whether full cover is appropriate for rare unplanned use of an aerodrome as an NDA. From a risk management viewpoint, it is the view of UK airlines that the level of protection should take into account the number of movements of the most critical aircraft, and not just the size of the aircraft. In Thomsonflys case, just over one in every one thousand flights will actually divert to the NDA (a rate of 0.116% based on 29,000 flights in 2007). Therefore the Likelihood Criteria in the attached Risk Assessment is assessed as Improbable. Thomsonfly B767 example Destination Current NDA GLA NCL MAN BRS CWL DSA MAN MAN EMA BHX BHX EMA Proposed NDAs PIK/EDI MME/EDI LPL/LBA CWL BRS LBA Aeroplane Type affected B767 B767 B767 B767 B767 B767 No of planned movements per annum 120 123 1602 86 24 18 Likely No of diversions per annum .14 .14 1.86 1.00 .28 .21

The likely number of diversions is under four per quarter for the 15 strong Thomsonfly 767 fleet. This is a clearly a very small proportion of the 700 movements per quarter limit for an aerodrome permitted under ICAO Annex 14, 9.2.3.

Low number of affected aeroplanes types in UK

Most major UK aerodromes provide at least RFF Category 6 level of protection this covers smaller jets such as B737 and A320. Difficulties mainly arise with Categories 7 and 8 in particular - in practice the following aeroplanes types are those mainly impacted by the Recommendation: B767 (Cat 8), A330 (Cat 8), B757-200 (Cat 7), B737-800 (Cat 7) A321 (Cat 7)

UK applies Recommendation 9.2.4 for both Destination and Alternate aerodromes, but other states do not
Most European states do not apply Recommendation 9.2.4 for Destination or NDA aerodromes, which leads to anomalous situations.

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For example aeroplanes may be forced to stop enroute inbound to the UK due to fuel shortfalls as a result of the RFF 9.2.4 Recommendation being applied to NDA in the UK. However it is permissible for the non-UK enroute diversion aerodrome to be one category below. Therefore in this case the aeroplanes will operate into a non-UK aerodrome one category below enroute instead of continuing direct to UK Destination with full RFF (albeit with a one in a thousand risk of diversion to NDA operating one category below). The situation is clearly even more anomalous when the flights non-UK departure aerodrome is itself at one category below.

Other states apply lower RFF requirements for NDAs compared to Destinations
A number of states applies Recommendation 9.2.4 for Destination aerodromes, but permit the use of NDAs with RFF one category below. The GCAA (NAA of the United Arab Emirates) has adopted this approach.

Flight Safety Risk exists due to the use of more distant Destination Alternates
There is a flight safety risk in reducing the number of available Alternate aerodromes for a Destination. Crews may be forced to fly past usable regional aerodromes on their way to a single larger, busier hub aerodrome - this reduces available options for crews and increases airspace congestion. This is especially undesirable if poor weather is widespread. Glasgow is a good example of this. A temporary runway closure at GLA would result in all Cat 8 aeroplanes being unable to divert to any one of EDI, PIK, MME, LPL, DSA, or LBA aerodromes (all Cat 8 but temporarily downgraded to Cat 7 due to the manpower issue noted at LPL above). Instead all Cat 8 aeroplanes would be required to divert to MAN, the nearest permanent Cat 8 aerodrome. This is clearly undesirable from a Flight Safety viewpoint, as well as causing much additional disruption and cost for airlines and passengers alike. Also the extra fuel required for more distant Alternates reduces flexibility available for crews. This may result in an increase in diversion rates, as crews find themselves unable to await weather improvements at Destination. It also leads to pressure on crews to make an approach when conditions are less than suitable.

Flight Safety Risk exists due to the use of busier Destination Alternates
There is a flight safety risk in concentrating diversions into a small number of larger, busier hubs such as MAN and BHX. The resulting pressure on ATC brings flight safety risk, especially in busy UK airspace. Landing delays are much more likely to occur, due to congestion in the air or on the ground, when diversions are concentrated into a small number of aerodromes. An additional flight safety risk exists if diverting with limited fuel.

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High cost and environmental penalties of current policy

The application of Recommendation 9.2.4 to NDA in the UK brings significant financial and environmental cost, as airlines are forced to carry extra fuel for more distant NDAs on affected flights. For Thomsonflys B767 fleet alone, the annual cost penalty of carrying this unused fuel is over $400,000, which results in over 1200 tonnes of additional CO2 emissions. On range limited sectors it can even result in enforced enroute diversions, incurring further cost and passenger inconvenience. In the rare event of an actual diversion from overhead Destination in the UK, it will be to a more distant Alternate, making the diversion more costly in both financial and environmental terms, and more inconvenient for passengers.

UK airlines operating at a competitive disadvantage

The application of Recommendation 9.2.4 to NDA in the UK means that operations at UK aerodromes are more costly than those at other European aerodromes. For example, airlines operating at Manchester will face higher costs than competing operations at Paris or at Amsterdam.

EASA NPA proposes lower RFF requirements for NDAs compared to Destinations
EASA NPA 06 2006 notes that: .. the Agency met with the difficulty of providing for flexibility while ensuring consistency with ICAO Standards as regards rescue and fire fighting services. Whilst the need for such services is not questioned, as they are important to save lives in case of accident or incident at an aerodrome or at its immediate vicinity, the level of protection needs further consideration. It is agreed that such level should reflect the size of aircraft using the aerodrome; it is questionable however whether they should be appropriate to the most critical aircraft using only occasionally the aerodrome. The answer to the question is of particular importance as it may affect the ability of an air operator to use an aerodrome as an alternate or not. From a pure risk management perspective, it is clear that the level of protection should take into account the number of movements of the most critical aircraft and not just the size of the aircraft UK airlines are aware that certain States have responded to this NPA proposing that the RFF requirements for NDAs are considered differently from requirements at Destinations. Switzerlands FOCA (Federal Office of Civil Aviation) is one of these and has proposed that lower RFF requirements should apply for NDAs.

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ICAO now proposing lower RFF requirements for NDAs compared to Destinations
The ICAO Operations Working Group has recently produced, through Working Paper OPSPWG/WHL/8-WP/10.Rev01 dated May 2008, a proposal for RFF requirements at Alternate aerodromes This Working Paper proposes that RFF required at NDA may be two categories below, and as low as Category 4 when RFF temporarily downgraded by NOTAM. The basis for this proposal is that . alternate aerodromes are so infrequently used for diversion that the exposure to the risk of a lower RFFS category is very limited (low probability of diversion to that aerodrome multiplied by very low risk of a diverting flight needing to use the RFFS) (OPSPWG/WHL/8-WP/10.Rev01 Section 2.5) Interestingly the Working Paper also notes that currently..Alternate aerodrome RFFS categories are not stipulated in Annex 14 (OPSP-WG/WHL/8-WP/10.Rev01 Section 2.5). In addition the Working Paper notes that Annex 14 clearly states that: This annex contains standards and recommended practices and certain facilities and technical services normally provided at an aerodrome. It is not intended that these specifications limit or regulate the operation of an aircraft. (OPSP-WG/WHL/8-WP/10.Rev01 Section 2.1). Clearly this brings into question the current practice of applying Annex 14 to NDAs in the UK.

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Summary
UK airlines accept the application of Recommendation 9.2.4 to Destination and Departure aerodromes, although they continue to operate to foreign aerodromes with RFF one category below in accordance with ICAO Annex 14 9.2.3. It is accepted that the application of this Recommendation in the UK has raised the general RFF standard at certain UK aerodromes. However UK airlines view the application of this recommendation to Nominated Destination Alternates as being undesirable from cost, competition, environmental and flight safety perspectives. Due to the extremely low rates of diversion from overhead Destination, the application of this Recommendation brings no measurable improvement in overall safety levels. Neither does it result in any further improvement in the general standard of RFF provision at UK aerodromes.

Proposal
UK airlines therefore propose that, for Nominated Destination Alternate (NDA) only, the use of NDAs with RFF levels of protection which are one category below is permitted (in accordance with ICAO Annex 14 9.2.3 and subject to the proviso covering the maximum number of actual movements per quarter) It is not proposed to permit movements where RFF levels of protection are one category below at Destination aerodromes in the UK. Flight Safety remains the highest priority for UK airlines. However we believe that adopting this proposal will improve flight safety, yet bring no discernible increase in risk. At the same time financial and environmental costs will be reduced, and passenger convenience will be improved.

Chris Turner, Thomsonfly 15 June 2008 One attachment: RFF Safety Risk Assessment v2

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