Aviation Safety Advisory A18Q0140-D1-A1

200 Promenade du Portage
Place du Centre , 4th floor
Gatineau, QC  K1A 1K8

05 August 2021

Director General, Civil Aviation
Transport Canada

Dear Sir:

The purpose of this Aviation Safety Advisory is to make your organization aware of the absence of standards, recommended practices and guidelines pertaining to the safety of operations at airports under construction, and to encourage the implementation of corrective measures as soon as possible.

During investigation A18Q0094 into an incident that took place in June 2018 on a runway under construction at the Baie-Comeau Airport in Quebec, the TSB determined that other similar incidents had taken place, which led to the issuance of Aviation Safety Advisory A18Q0094-D1-A1 ^{Footnote 1} to Transport Canada Civil Aviation (TCCA) on 12 July 2018. In this advisory, the TSB was alerting TCCA about the runway markings used during construction when the entire length of the runway is reduced in width, given that these markings had not enabled several flight crews to distinguish the usable portion of the runway from the closed portion. This resulted in some aircraft manoeuvring on the unserviceable portion of the runway during takeoff or landing. Any aircraft movements outside of the established limits of a runway have clear consequences that could involve not only significant damage to aircraft, but also serious injuries to the occupants.

The TSB’s concerns were reinforced when 2 new similar occurrences^{Footnote 2} took place in Quebec subsequent to the release of the Aviation Safety Advisory. Given the number of similar occurrences happening and their repetition at airports in Quebec and Nunavut where the runway had been reduced in width for construction work, the TSB decided to conduct Safety Issue Investigation A18Q0140 to highlight any systemic underlying causes or contributing factors. This investigation is ongoing.

An unavoidable necessity, construction work at airports presents significant risks to the safety of flight operations. Any airport operator planning to carry out construction work at the airport must prepare a plan of construction operations (PCO) and have it approved by TCCA. The purpose of a PCO is to describe measures that will be put in place during construction to comply with the aerodrome standards stated in Transport Canada’s publication TP 312 and to reduce operational risks. Investigation A18Q0140 highlighted that airport operators found it difficult to prepare a PCO due to the absence of standards, recommended practices, guidelines and any other information on the subject. Some of the airport operators examined during investigation A18Q0140 decided not to use closed markings, given that the 5th edition of TP 312 allows them to use other means to notify aircraft pilots and vehicle operators of the short-term closure of a runway.^{Footnote 3} Therefore, the PCOs examined for the purposes of this investigation did not contain all of the elements needed to ensure effective risk control measures were put in place.

PCO evaluation by TCCA staff is vital to ensure the safety of operations at airports under construction and to ensure regulatory compliance. However, during the investigation, an analysis of the PCO approval process revealed that TCCA inspectors do not have a national standard evaluation guide at their disposal. As a result, TCCA inspectors in the Quebec and Prairie and Northern regions wrote their own guides. However, given that these manuals have not been approved by TCCA’s Headquarters and are not up to date, they do not guarantee an effective evaluation of PCOs or consistency at the national level. Consequently, PCOs are being approved using informal, random procedures and may be approved even though they do not comply with all regulatory provisions or they do not include all (reasonable) risk control measures or construction monitoring and follow-up measures.

In the United States, to assist airport operators in planning construction, the Federal Aviation Administration published a document on the subject, Advisory Circular AC 150/5370-2G, entitled Operational Safety on Airports During Construction. This circular enables airport operators to plan their construction and prepare their plans in accordance with specific guidelines. It also enables the persons responsible for approving these plans to evaluate them using these criteria. American airport operators know that if they comply with the circular, they will meet aerodrome standards, including those applicable to airport construction. 

Airport operators must state in their PCO how they will communicate airport construction information to pilots. The investigation revealed that most airport operators had chosen to publish a NOTAM. The number of occurrences that took place before and after publication of Aviation Safety Advisory A18Q0094-D1-A1 seems to indicate that pilots were unable to distinguish the usable portion of the runway from the closed portion. This risk was not assessed during preparation and approval of the PCOs, and was not identified despite the repeated occurrences.

Therefore, it would be desirable for TCCA to take safety actions addressing the absence of standards, recommended practices and guidelines pertaining to airport construction planning in order to mitigate the risks associated with the safety of operations at airports under construction.

The TSB would appreciate being advised of any action that is taken in this regard, as those actions could be included in our report. Upon completion of investigation A18Q0140, the Board will release its investigation report into this safety issue.

Yours sincerely,

Original signed by

Natacha Van Themsche
Director of Investigations – Air
Transportation Safety Board of Canada

Cc.

• Director, Aviation Safety Policy and Intelligence, Transport Canada
• President & CEO, NAV CANADA
• Vice President, Chief Safety and Quality Officer, NAV CANADA
• Director General, Réseau québécois des aéroports
• President, Canadian Airports Council
• Chairman, Regional Community Airports of Canada