TSB Recommendation A18-02

Transport Canada (TC) agrees with the recommendation and is collaborating with air operators and airport authorities to take urgent action to address this safety risk.

TC recognizes the need for additional actions to address the safety risks posed by icing. Immediately in response to this recommendation, TC gathered information to create an accurate account of the de-icing and anti-icing resources that are currently available.

On January 22, 2019, TC requested that its regional offices reach out to air operators and airport authorities in order to consolidate information on the de-icing and anti-icing services available at the airports. Specific emphasis was placed on remote and northern airports, and how operators conduct their operations at these locations.

Overall, the information gathered indicates that very few northern or remote airports in any of the regions have de-icing and anti-icing equipment available. Those that do often have very limited capabilities. Air operators will often carry their own de-icing equipment, or have access to portable equipment at certain locations, but capacity is limited. Given that access to aircraft surfaces (e.g., wings and tail) and appropriate space to perform de-icing is often lacking at northern and remote airports, use of this equipment also presents challenges related to crew safety.

The results of the survey are concerning. The importance of this safety issue requires greater awareness and action by operators and airports. To achieve this, the Minister of Transport will issue a letter to all operators reiterating that it is the responsibility of the air operator and their pilots to comply with all requirements outlined in the Canadian Aviation Regulations (CARs) subsection 602.11(2), as well as Commercial Air Services Standards (CASS) 622.11. The letter will also ask operators to work with the airports they serve to increase the provision of adequate de-icing and anti-icing equipment. Finally, it will request that air operators submit their approved ground icing program (AGIP) plans no later than June 30, 2019. The submissions will be reviewed against industry-accepted standards and assist in identifying current deficiencies.

TC will also send a letter to airport authorities asking that they actively engage and collaborate with air operators on solutions to address the safety issue as it has a direct link to northern and remote airport operational realities.

In addition, TC will also meet with air operators and airport authorities at the April 2019 Northern Air Transport Association (NATA) Annual General Meeting (AGM) in Yellowknife, NT. The work done at this event will aim to identify initiatives in the short and medium-term to address this urgent safety risk. The outcomes of this collaboration will help direct immediate additional initiatives that will be taken by stakeholders in advance of the 2019-20 winter season.

Airports possessing de-icing and anti-icing equipment for operator use publish this capacity in the Canada Flight Supplement (CFS). This information is available to all aircraft operators. If an airport does not have de-icing and/or anti-icing services published in the CFS, air operators are to assume that the equipment or services are not available at that location. However, TC recognizes that many operators choose to avoid flying when icing is present instead of carrying or using their on‑board or portable de-icing equipment. While TC recognizes that this is one strategy in mitigating the risks associated with icing conditions, it also presents challenges in emergency situations and in ensuring reliable access to northern and remote communities.

Therefore, in the short-term, TC is working with air operators and airport authorities to increase the awareness and understanding of the regulatory requirements. Using the information from the survey of northern and remote airports, air operator AGIP submissions, existing information available in the CFS, and looking to potential methods for predicting icing conditions will help inform risk-based actions that target areas where icing is most likely to occur.

TC believes that the targeted education of pilots, air operators (including all those involved with air operations, such as dispatchers, etc.) and airport operators is the most effective short-term method to increase compliance with the CARs and encourage the provision of adequate de-icing and anti-icing equipment. Planned actions related to education of pilots and operators are described below in the response to Recommendation A18-03.

In the medium term, in fiscal year 2019-20, the department will initiate an in-depth regulatory examination of the issue. TC will establish a working group (made up of key stakeholders including: air operators, airport authorities, communities, and pilot associations) to conduct a risk assessment and examine measures, including additional education and awareness campaigns, policy, standards and/or regulations to further reduce the likelihood of aircraft taking off with contaminated surfaces. This work will aim to bring a full scope of impacted stakeholders together, including the TSB, to ensure all views and possible approaches are considered to address this important aviation safety risk. The complete report and recommendations advanced by the working group will be finalized by fall 2020. This report will be provided to the TSB once finalized.

In recognition of the urgent action that is required to address the safety risks posed by icing, the actions outlined above have begun or will begin before the beginning of the 2019-20 winter season. The intent of these actions will be to further build on the Canadian regulatory requirements in place to reduce the likelihood of aircraft taking off with contaminated crucial surfaces. CAR subsection 602.11(2) establishes that the responsibility to ensure an ice-free surface is with the operator and flight crew. These regulations are similar to the operational requirements that are found within the Federal Aviation Regulations (FAR) 121.629 in the United States, the European Air Regulations (Air OPS regulation (EU) 965/2012), CAT.OP.MPA.250 as mandated by EASA and other National Aviation Authorities.

At the April 2019 Northern Air Transport Association (NATA) Annual General Meeting, Transport Canada officials used their regulatory presentation session to highlight the TSB recommendations, plans for addressing them and called on attendees to provide comments and suggestions on how to improve conditions at Northern and Remote Airports. While the session did not produce a great deal of feedback from those in attendance, TC officials had additional conversations following the session with attendees including airport, air operator and ground support organizations to discuss possible options and considerations regarding improved anti-icing /de-icing operations. As a follow-up, TC is set to discuss options and considerations at the upcoming NATA Board of Directors meeting in June 2019. Part of this discussion will be to formalize how additional input could be generated from aviation stakeholders operating in northern and remote communities.

In its response, Transport Canada (TC) indicated that it agrees with Recommendation A18-02.

To address the safety deficiency identified in Recommendation A18-02, regarding the identification of locations where there is inadequate de-icing and anti‑icing equipment and the requirement for urgent action to ensure that the proper equipment is available to reduce the likelihood of aircraft taking off with contaminated critical surfaces, TC has taken the following short-term actions:

• In early 2019, TC commenced collaborative action with air operators, airport authorities, as well as the Northern Air Transport Association (NATA) and its members, to mitigate the risks identified in Recommendation A18-02.
• In January 2019, TC requested that its regional offices reach out to air operators and airport authorities in order to consolidate information on the de-icing and anti-icing services available at airports, with specific emphasis placed on remote and northern airports. This initiative confirmed that de‑icing and anti-icing capability is only available at very few remote and northern airports.
• In April 2019, TC highlighted TSB’s recommendations A18-02 and A18-03 and the plans for addressing these two recommendations during its regulatory presentation at the NATA Annual General Meeting.
• In May 2019, TC sent a letter to all air operators reiterating the requirement to comply with Canadian Aviation Regulations (CARs) subsection 602.11(2), as well as Commercial Air Services Standards (CASS) 622.11. Additionally, the letter called on all air operators to work with their flight crews and airport authorities to better address the risks highlighted by recommendations A18-02 and A18-03. Air operators were also asked to confirm by June 30, 2019, what actions they will be taking ahead of winter 2019-2020 to reduce the likelihood of aircraft taking off with contaminated critical surfaces and ensure that the proper equipment is available to comply with CARs subsection 602.11 (2). To date, responses were received from most operators.
• In June 2019, TC’s Director General Civil Aviation attended the NATA Board of Directors meeting, where icing was discussed.
• In July 2019, TC sent a letter to airport authorities asking them to actively engage and collaborate with air operators to find solutions to address the safety deficiency identified in Recommendation A18-02.

As a mid-term action, TC is also planning to establish, in fiscal year 2019-20, a working group comprised of various stakeholders to examine the safety risks and identify measures, including additional education and awareness campaigns, policy, standards and/or regulation, to further reduce the likelihood of aircraft taking off with contaminated critical surfaces. TC indicated that the results of this effort will be available by fall 2020.

The Board is encouraged that TC has completed some actions and that it is planning additional actions in the near future, including the creation of a stakeholder working group. These actions, when implemented, have the potential to substantially mitigate the risk associated with the safety deficiency identified in Recommendation A18-02, by identifying locations where there is inadequate de-icing and anti‑icing equipment, and by increasing the provision of such equipment to reduce the likelihood of aircraft taking off with contaminated critical surfaces.

Therefore, the response to Recommendation A18-02 is assessed as Satisfactory Intent.

Transport Canada (TC) agrees with the recommendation.

In response to TC’s May 2019 letters to 803 air operators holding Canadian Aviation Regulations (CARs)604, 703, 704 and 705 certificates and to airport operators holding CARs 302 certificates, 39% replied:

• Most of the responding air operators reported they do not allow aircraft to take off if ice, snow or frost is adhering to any of the aircraft’s critical surfaces. The operators confirmed compliance with CAR 602.11(2) and described measures they undertake to fulfill this requirement.
• Only 12 airport operators replied; the responses varied from having 24/7 availability of de-icing/anti-icing equipment/materials to closing runways during freezing season.

In late 2019, the department established a De-icing in Remote Locations Working Group, comprised of 10 industry partners, including both airport and air operators, along with TC personnel from across the country. The working group objectives are to examine the safety risks and recommend solutions to improve the consistent use and availability of de-icing and anti-icing equipment. This includes additional education and awareness campaigns, a review of equipment use and availability and a review of TC’s policy, standards and regulations in an effort to further reduce the likelihood of aircraft taking off with contaminated critical surfaces.

In January, TC facilitated a breakout session on de-icing at the Canadian Aviation Safety Collaboration Forum (CASCF) on January 15, 2020. Stakeholders were encouraged to participate in this working group. The goal of the breakout session was to:

• Raise awareness to the concerns and recommendations brought forward by the TSB in A18-02 and A18-03 and the letter from [TSB Chair] Kathleen Fox to the Minister of Transport dated December 14, 2018, emphasizing the apparent normalizing of many pilots taking off with contamination on critical surfaces.
• Motivate and inspire leaders in the aviation industry appealing to our moral compasses and professional ethics to work together in reducing this risk by using our combined experience and influence.
• Get commitment from enough leaders to have a cross section of the industry who are motivated to move forward on this initiative.

There were some excellent discussions during the breakout session, and a lot of commitment from industry seeking to participate in this working group. TC will now begin following-up with these individuals to discuss formalizing this initiative, with the first priority being to develop/approve a Terms of Reference, which will outline the group’s mutually agreed upon goals and responsibilities. Its review and approval was on the agenda for the first meeting which was scheduled to take place in March 2020; however, in light of COVID-19 this has been delayed to allow industry time to deal with the many challenges they are facing during the pandemic.

TC remains committed in engaging our industry stakeholders and has reached out to the working group members in August 2020 to re-engage in discussions and reschedule this initial meeting for late September, prior to the 2020 winter season.

On October 1, 2020, the first De-icing in Northern and Remote Communities working group (DNRC) meeting was held via MS Teams, producing the first results on the examination of this issue. The working group consists of 32 participants from a diverse group of external industry stakeholders spanning across the country, including various air operators, airports, associations such as National Air Transportation Association (NATA), Air Transport Association of Canada (ATAC), Airline Pilots Association (ALPA) and Réseau Québécois des Aéroports. As well, internal TC participation included Subject Matter Experts (SME’s) from various regions, TC Headquarters Aviation Safety Regulatory Affairs, Aviation Policy and Programs Branch (Airport Capital Assistance Program, ACAP).

The agenda included three main topics, the first being a review of the draft Terms of Reference, including a discussion to determine the frequency of meetings. Secondly, TC provided an overview of the existing TC/industry Standing Committee Under Icing Conditions (SCUIC). This provided an opportunity for the DNRC working group members to understand the parallels and differences between the two groups in an effort to avoid duplication and ensure outcomes and recommendations are complimentary. Lastly, the working group members were divided into four sub-groups, each chaired by an industry member to discuss a set of questions which were provided to participants two weeks prior to the meeting. The objective was to gather input and different perspectives focusing on several questions, as an example, “the magnitude or level of risk is for pilots taking off with surface contamination at Northern or remote airports?; what are the high-risk locations?; examining the existing infrastructure and reviewing present use of available facilities; and where are the operational or occupational safety hazards?” To provide sufficient time to thoroughly answer all the questions, the sub-group meetings continued throughout the months of October and November. The results of these discussions have been documented and by early December 2020 they will be summarized into themes and used as a tool to guide future working group discussions and recommendations.

The next DNRC meeting is scheduled for the week of December 7, 2020. TC has compiled a list of all airports in Canada that are located in northern/remote communities (this criteria is based on airports located north of the 51st parallel). The objectives of the next meeting will be to discuss an approach on what information needs to be obtained for existing de-icing/anti-icing equipment and storage facilities currently available at each site and divide up the collection of information by sub-group.

Subsequent meetings will focus on the results of information collected regarding existing de-icing/anti-icing equipment and facilities and make recommendations on future safety improvements (i.e., equipment, funding, storage facilities, and upgrades to infrastructure, regulatory /policy changes).

The overall objective of the working group is to produce a report by March 30, 2021. The report will focus on the results of the working group discussions, including a national list of de-icing/anti-icing equipment and facilities available at each of the northern & remote airports. As well, observations and recommendations on future improvements that could lead to improved safety.

In its response, Transport Canada (TC) indicated that it agrees with Recommendation A18-02.

The TSB is encouraged that TC has reached out to stakeholders, that working groups have been created, and that discussions are occurring to address the safety issues identified in this recommendation. The COVID-19 pandemic has presented many challenges to the industry, which have delayed the development of concrete actions to ensure proper de-icing and anti-icing equipment is available to reduce the likelihood of aircraft taking off with contaminated critical surfaces.

Until steps are taken to ensure proper de-icing and anti-icing equipment is available, the risks associated with the safety deficiency identified in Recommendation A18-02 will continue to exist.

Therefore, the response to Recommendation A18-02 is assessed as Satisfactory Intent.

Transport Canada (TC) agrees with the recommendation.

Since the recommendation was issued in 2018, as immediate measures, TC mobilized airport authorities to engage and collaborate with air operators on solutions to address the safety issues. The Minister of Transport also reiterated that it is the responsibility of the air operator and their pilots to comply with all the requirements outlined in the Canadian Aviation Regulations (CARs) (602.1(2)) as well as Commercial Air Service Standards (CASS) 322.11. TC met with air operators and airport authorities at the April 2019 Northern Air Transport Association (NATA) AGM in Yellowknife (NT) and three other times with NATA in June and September 2019 and in January 2020 to identify initiatives in the short and medium-term to address this safety risk.

Following these measures and meetings with air operators and airport authorities, the Department committed in September 2020 to:

• Establish a De-Ice in Northern and Remote Communities (DNRC) working group to conduct a risk assessment, examine challenges and barriers associated with de-icing in remote locations and identify options and mitigation measures, including additional education and awareness campaigns, infrastructure, equipment and policy, to further reduce the likelihood of aircraft taking off with contaminated critical surfaces.

Since the previous update, a De-icing/Anti-icing Working Group was formed and first met virtually in October 2020, having been delayed due to the COVID-19 pandemic. The group discussed a number of questions put forward by different members associated with issues, challenges, and barriers arising from TSB Recommendations A18-02 and A18-03 in subsequent meetings.

In February 2021, following the review of the meetings summaries, more questions arose and the group concluded it was too early to start making recommendations and decided to move into identifying locations of concern as recommended in A18-02.

To this end, in March 2021, TC conducted a “Northern Blitz” inspection of 18 airports in the three territories, this also included interviewing air operators, pilots, CARs operators, airport personnel, and government transportation personnel on de-icing and anti-icing practices and noting relevant equipment and infrastructure at these airports. From the interviews and observations, there were no indications of high risk or breach of regulations in regard to aircraft taking off with surface contamination and it did not support TC taking any “urgent action”. This may be the positive results of actions already taken by TC and the aviation industry and the overall increased level of awareness.

The working group met in April 2021 and felt that “identifying locations where there is inadequate de-icing equipment” could be perceived as scrutinizing individual carriers as it can be very difficult to determine what is adequate or inadequate at any given airport as there are many variables such as size of airport and available space, airport operator/owner, number of operators using the airport, types of aircraft, etc.

In May 2021, the working group decided to “dig deeper” into the issues and drafted three sets of survey questions specifically for the operators, the pilots, and the airport operators. In June 2021, the first draft surveys were completed and were reviewed in August 2021 before going to the main working group for feedback. The surveys will then be dispersed accordingly with the help of industry associations.

It is the hope of the working group that careful analysis of the survey responses will provide needed guidance to identify locations where there is inadequate de-icing equipment and in making other recommendations to the Minister.

In its response, Transport Canada (TC) indicated that it agrees with Recommendation A18-02.

The Board is encouraged that TC has taken additional steps and has conducted inspections of 18 northern airports, including interviews and assessments of de-icing and anti-icing equipment availability at these locations. The Board notes that these inspections did not find indications of high risk or breach of regulations related to aircraft taking off with surface contamination. TC’s planned survey of stakeholders will help identify locations where there is inadequate de-icing equipment and in making other recommendations to the Minister of Transport.

While some action has been taken by TC to assess and gather information, until measures are taken to ensure proper de-icing and anti-icing equipment is available at remote and northern airports, the risks associated with the safety deficiency identified in Recommendation A18-02 remain.

Therefore, the response to Recommendation A18-02 is assessed as Satisfactory Intent.