Take On The AZR Challenge
Airport Operators in Canada are avoiding the AZR challenge and taking on a gambling position to protect their capital investment. An aerodrome without an AZR is to sign a blank check to the local landuse authority. Your Amazing Airport is taking the path of least resistance but also the path of greatest failure. Airport Zoning Regulations (AZR) is a unique program for Canadian airports to protect their capital investment. An aerodrome in Canada is any area of land, water, ice or other supporting surface used, designed, prepared, equipped or set apart for use for the arrival, departure, movement or servicing of aircraft and includes any buildings, installations and equipment. In short, all of Canada is an aerodrome. An airport is an aerodrome with a certificate of certification. Certification of an aerodrome is required for operations of scheduled air service, if the aerodrome is within a built-up area, or if it is in the public interest that the aerodrome is certified.
NOTE: It is always in the public interest that an aerodrome is certified.
|Once upon a time there was an airport…|
There are no conditions under which an aerodrome is excused from being certified. However, there are conditions under which certain behaviors are unsuitable for a person to be the Certificate Holder or Airport Operator. The tasks a person, as a certificate holder or airport operator is required to perform to maintain their position are to design and maintain the Airport Operation Manual, maintain the Standards of TP312 5th Edition and maintain the Safety Management System.
A Regulator requires Operational Control of an Aviation Document, or Certificate. Pilots maintains operational control of their certificate by training and medical certificates, an airline maintains operational control of their flight crew qualifications and aircraft maintenance. Just as an aircraft certificate is dependent of the aircraft operator, an airport certificate is heavily dependent on the operator. The difference is that an aircraft is moving all the times, while an airport is stationary. The Regulator expects operational control of all aviation documents, not just for pilots and airline operators, but also of airport operators. Operational control of an airport certificate is very different, since the certificate is issued to a static parcel of land. Operational control of an Airport Certificate is achieved by the Airport Zoning Regulations.
Some years ago, a finding was issued to an airport operator because a tower was built about 3 SM away from the airport. The tower penetrated the airports’ OLS and therefore became a hazard to aviation safety. Pursuant to the SMS regulations, an airport operator has based its safety management system on the safety policy and that there is a clear commitment to safety. Without an AZR in place, there is no clear commitment to safety since the airport operator does not have a tool to remove aeronautical obstructions that are hazardous to aviation. Should a structure be erected and penetrate an approach surface, the only option available to the airport is to shorten the runway. Making a runway shorter must be approved in the Airport Operations Manual and it is known that an approval may take 3-6 months. Without an AZR, an airport operator is operating outside the parameters of public interest and safety in aviation. An AZR is established to prevent lands adjacent to or in the vicinity of an airport from being used or developed in a manner that is incompatible with the safe operation of an airport or aircraft.
|Without AZR the only way out is to move backwards for safety|
Without an AZR in place an airport operator finds themselves between a rock and a hard place for compliance with the Safety Management Regulations. The regulations requires that there is a process for identifying hazards to aviation safety and for evaluating and managing the associated risks, that there is a process for ensuring that personnel are trained and competent to perform their duties and that there is a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence.
"Let’s take a closer look at these three regulatory requirements as it relates to the TP312 5th Airport Certificate and required tasks by the Airport Operator."
The first requirement is that there is a process for identifying hazards to aviation safety and for evaluating and managing the associated risks. Intent is not a hazard to aviation safety. That someone intend to build a tower on short final at Your Amazing Airport is not a hazard to aviation safety itself, since there is no structure intruding on the approach surface. Under these conditions, and without an AZR, an airport operator or the Regulator has no rights to demand that a private citizen do not erect the structure. Since the structure is not erected, an airport operator does not have in place a process to identify hazards to aviation or to evaluate and manage the risks. A plan or proposal is not a hazard to aviation safety and does not become a hazard until the moment the structure penetrate an approach surface established pursuant to TP312 5th. The only option the operator has is to displace the threshold and shorten the runway. The Regulator has only one option, which is to issue a finding to the airport operator for not maintaining the Standards of TP312. A well-known public airport event is the Chatham silo.
The second requirement is that there is that there is a process for ensuring that personnel are trained and competent to perform their duties. Unless there is an AZR in place, airport personnel are without an option to be trained in obstacle management beyond the airport property and without the ability to affect the outcome of the plan.
The third requirement is that there is a process for the internal reporting and analyzing of hazards, incidents and accidents and for taking corrective actions to prevent their recurrence. Imagine for a minute a hazard report stating the following: “The Town is planning to build a 500-foot wind turbine 1 SM away from Your Amazing Airport inline with the approach path. When built, the wind turbine will penetrate the approach surface.”
The one question Your Amazing Airport needs to ask and come up with an answer, is what to do about the hazard. In the case of this report, the airport operator does not have one single tool to stop or prevent the construction of the wind turbine. The only option is to close the runway.
Operational control at an airport is not to manage pilots or aircraft, but to mange the integrity of the certificate and TP312 5th Standards. The only tool is the Airport Zoning Regulations.