UK VIEWS ON US ICAO SAFETY PAPER

UNCLAS LONDON 002943 SIPDIS SIPDIS E.O. 12958: N/A TAGS: EAIR ICAO UK SUBJECT: UK VIEWS ON US ICAO SAFETY PAPER REF: STATE 77572 ¶1. Post received the following comments in response to ref cable, from Adrian Sayce at the UK Mission in Montreal, via Glenn Cronin of the UK Dept for Transport: Agenda Item 13 Vision for the future of USOAP. This WP proposes the application of a system safety approach to the future USOAP. This concept is not new and was the reason that the current USOAP was expanded in 2004 to apply 'a comprehensive systems approach'. The systems part of this was to apply a risk assessment methodology - or so the Commission was told - but this does not seem to have happened. The idea was that auditors would spend more time assessing the data before an audit and would then audit all 16 Annexes using a targeted approach. To my knowledge this has not happened. In view of this, I strongly support the US WP. The only problem is getting some idea how ICAO would go about accomplishing the safety risk analysis. At the moment the Secretariat has established an Audit Results Review Board which is supposed to serve as a link between USOAP, USAP and the Unified Strategy Programme (USP). The ARRB is a new concept that has not been described in detail to the Commission. It is supposed to review USOAP data and provide an early warning of problems. This is nice in theory and will sound good at the Assembly, but how it will work in practice will be interesting to see. In summary, I support this WP. Agenda Item 23 Electronic sharing of AIP. I support this WP. It is good that ICAO is doing at least something to help the environment! However, I believe the WP does not emphasize the safety benefits from this. This subject has become very controversial as ICAO's role in all this has been questioned by Eurocontrol and FAA, as well as data originators, processors, publishers, regulators, system designers, service providers and end users. There was a Eurocontrol AIS Congress in 2006 which ruffled ICAO feathers. (Note AIS is the Aeronautical Information Service, as detailed in Annex 15 and AIPs are the most important Aeronautical Information Publications provided by States under AIS). This WP may simply be used as part of a wider discussion on the future of AIS. Agenda Item 25 ICAO Safety Evaluations/Audits of International Air Operations. I believe that this presents a rather narrow view of the role of ICAO in evaluating/auditing a State. We have known that there are States where the national authority is poor but national operators are excellent. Although we can probably assume that there is some correlation between a State having appropriate oversight capability and operators being safe (this is the ICAO position),the strength of this correlation is open to question. Often national operators have working-relations with operators in other States and this can improve their level of safety (for example KLM and Kenya Airways, but this may not be the best example!). I do not believe there is a very strong correlation. For this reason, ICAO audits have included some assessment of a state's international air operators (during the UK Audit both easyJet and Air 2000 were visited). Also, ICAO is supposed to be working more closely with IATA so that combined USOAP and IOSA results can give a better picture of a State's level of oversight. I also believe the US position is slightly flawed because ICAO's objective to 'meet the needs of the peoples of the world for safe, regular, efficient and economical air transport'. This implies that as airlines provide the service to 'the peoples of the world', ICAO must try to ensure the operations are safe either directly or indirectly through their State. In spite of all this, I understand the US is trying to keep USOAP focused and this is a good thing to aim for. But some flexibility must be allowed. If a State has an excellent airline, this may be because the airline has acted responsibly and does not need to be spoon-fed by a State regulator. We could talk around the need for regulation and the value of self-regulation for a long time. Agenda Item 28 Analyzing Precursors of Accidents. It is hard to disagree with most of this. It is very ambitious and many of the subjects have been seen before. I agree with the Actions by the Assembly. My only reservation is that Annex 13 should really be examined to firm up the reporting requirements for Serious Incidents. At the moment, para. 7.7 states 'If a State conducts an investigation into an incident' it shall send a report to ICAO 'as soon as practicable'. This doesn't seem worth the paper it is written on. Even the new USOAP reports from States for Annex 13 will not reveal much. Perhaps we need another WP that highlights the weakness in Annex 13. I was once told that only about 5% of world reportable aviation accidents are produced as a Final Report. Needless to say, the UK does a terrific job. As Peter Hunt is producing a UK Information Paper on the UK Airprox scheme, perhaps the CAA should do the same for its MOR Scheme. Agenda Item 31 - Transforming today's ATS to meet tomorrow's challenges. This seems more of an Info Paper. Concerning the Action by the Assembly, para. 5.1 a),this seems to be asking the Assembly to promote the US systems. I am not sure this is what the Assembly should be asked to do. Perhaps it should instruct ICAO Council to examine such systems and recommend to States what they must do to harmonize with them. As for 5.1 b),I am a bit concerned about reference to 'development and acceleration of standards for required future systems'. I would hope that ICAO will develop performance-based standards, or detailed specifications outside the Annexes TUTTLE