APPENDIX 27
Memorandum submitted by Mott MacDonald
Ltd
INTRODUCTION
1. Mott MacDonald is a UK-based multi-disciplinary
consultancy employing over 8,000 staff worldwide. Included in
our skill base are professionals specialising in airport planning,
the design of airport facilities, aviation forecasting, economic
regulation and other aspects of the industry. Most of these staff
are based in the UK, North America and Australasia and have experience
of working on aviation projects in many countries and every Continent.
Such projects are usually governed by the International Civil
Aviation Organisation (ICAO) standards and recommended practices
(SARPS), and by local civil aviation regulators—including
the UK CAA, and in the USA, the FAA as appropriate. We therefore
not only have first hand experience of how the UK CAA regulates
the aspects of the industry that we are involved with, but can
also compare this with regulation in other countries and, in particular,
the over-riding role of ICAO SARPS. As a leader in the aviation
consultancy field, we feel we have a duty to respond to the invitation
to provide a memorandum in order to assist the committee in producing
its recommendations to Government in deciding the best way forward
to identify a future role and position for the CAA.
CONFLICTING ROLES
2. It is clear from our work that some aspects
of CAA policy constraining the optimum development of UK civil
aviation growth, in great part due to a clear conflict between
two of its most important roles, namely those of safety regulation
and of economic regulation of the UK air transport sector. We
consider that in trying to balance these two roles, the CAA may
in some cases be failing to provide the clear leadership and guidance
that should be expected. In some instances this is hindering the
growth and prosperity of the civil aviation market, a situation
which may worsen should the status quo be maintained.
3. For example the CAA is the airport economic
regulator and policy adviser and encourages the maximum use be
made of existing runways in accordance with government policy.
At the same time it is also the industry safety regulator with
an overview on declared ATM rates from a safety perspective. We
are left with a situation in the UK where we can allow 18 seconds
separation between aircraft on a single runway (Annex 1). The
margin for error is very tight and the pressure on the air safety
regulators within the CAA will grow, from its own economic regulators.
REGIONAL ACCESS
CONCERNS
4. In terms of Regional Access there does
not appear to be any cohesion between aviation and transport policy
on the one hand and UK and EU regional economic policy on the
other. As the government's aviation advisor the CAA should support
the development of accessibility between the UK regions and the
rest of the world. The current Future of Air Transport White Paper
emphasises the recognition of the importance of air travel to
national and regional economy and prosperity. Yet the CAA appears
to be abdicating its responsibilities and deferring to market
forces when it comes to the importance of connections between
the UK's primary international gateway and the rest of the country.
5. The CAA's viewpoint on Public Service
Obligation routes is ambivalent and suggests these should only
be operated where there are compelling reasons to do so. It is
against ring-fencing slots for vital routes from Heathrow to the
regions, arguing in part that the new wave of low cost carriers
are operating many services into other London airports from domestic
points, ignoring the fact that these have no connectivity with
long haul services out of Heathrow (Annex 2). It also seems to
take the view that in the event of a third runway being built
at Heathrow, this would enhance the opportunities for flights
between the UK regions and the airport, while not even mentioning
that without any sort of ring-fencing or control, there is absolutely
no guarantee that this would happen under internationally agreed
slot allocation rules. New slots created at Heathrow from either
a new runway or mixed-mode use of the existing ones of themselves
do not provide guarantees of domestic usage. It may simply provide
more long haul slots on the main runways, with existing short
haul European services moved to any new runway at the expense
of domestic services.
6. In CAP 754—the UK Regional Air
Services study (February 2005)—the CAA suggests that the
answer could be to create a transparent and efficient secondary
slot market. It believes this could be an opportunity for UK-based
airlines, and goes further to suggest some form of trading where
non-airline concerns such as regional bodies, other public bodies,
or business consortia could buy slots. Airlines have recently
been seen to buy slot pairs at Heathrow for figures as high as
£20 million (Qantas January 2004). Few non-airline bodies
would be prepared to pay such sums for any slots at Heathrow not
already governed by historical precedents (grandfather rights).
Furthermore, there is absolutely no guarantee that UK based airlines
buying slots would use them for domestic services. There is also
the possibility under existing rules concerning new slot allocation
rules giving priority to new entrants that smaller UK airlines
could take advantage of these new entrant rules to buy slots in
order then to sell them on at a premium to a larger international
carrier already operating at the airport. Many smaller carriers
have already sold their existing slots at Heathrow and moved services
to Gatwick to realise short term financial gains, rather than
for any compelling route profitability reasons.
7. For the airports themselves, the allocation
of new slots to an international wide-body service will always
be more attractive than to a short domestic route, not only from
the increased revenues it will obtain from landing fees and passenger
charges from the use of larger aircraft, but also from additional
revenue from commercial sources such as retail and duty-free sales.
Although regional services may be strategically important for
the remote regions of the UK, the reality for these airlines and
airports is that in order to maximise shareholder revenues at
highly constrained airports, economic pragmatism will prevail.
The CAA believes that the best means of securing continued access
to Heathrow from regional airports goes with the grain of commercial
decisions and the dynamics of the airline market".[2]
Mott MacDonald disagrees, and believes that the CAA should advise
Government that positive action is needed to counter the natural
inclinations of airlines and airports.
8. The BAA in its official Investor Relations
presentation of its own half year 2005-06 financial results states
At Heathrow, it is anticipated that traffic growth will continue
to be limited, over the next few years, by capacity constraints
and the slow transition of slots from short-haul operations to
more attractive long-haul. The pace of slot usage change to long-haul
at Heathrow is slowed by the highly regulated nature of international
aviation." Furthermore, in answering a question raised at
the Brabazon lecture given by BAA's Chief Executive Mike Clasper
at the Royal Aeronautical Society on 10 November 2005 he stated
We currently have an aircraft mix of one third wide bodied, two
thirds narrow bodied at Heathrow. We want to change this mix to
two thirds wide bodied and one third narrow bodied." The
implication is clear: the BAA is more interested in long haul
use of its Heathrow slots, and the CAA is not ensuring that vital
connections are retained between the UK regions and the rest of
the world.
9. In fact the CAA goes further in its conclusions
to suggest Access to Heathrow remains an important issue for regional
airports and regional economic development, and in particular
for passengers wishing to connect to other services. There has
been some reduction in services between UK regional airports and
Heathrow over the past decade. However, overall, London is better
served from the regions than in the past, with more services at
Gatwick, Stansted, Luton and London City that numerically much
more than offset the loss of Heathrow services. In addition, links
to other European hubs from regional airports can provide an alternative
means of making connections." [3]As
the body tasked with advising the government on the UK air transport
sector, the suggestion that passengers from the UK regions can
fly with (invariably) non-UK carriers to connect to their long
haul services out of Amsterdam, Frankfurt or Paris, cannot possibly
be a view that is in the best interests of this country's aviation
industry. CAA general policy objectives laid out in the Civil
Aviation Act 1982 state that it shall be the duty of the CAA to
perform its functions in a manner which it considers is best calculated:
to ensure that British airlines provide air transport services
which satisfy all substantial categories of public demand (so
far as British airlines may reasonably be expected to provide
such services) at the lowest charges consistent with a high standard
of safety in operating the services and an economic return to
efficient operators on the sums invested in providing the services
and with the securing the sound development of the civil air transport
industry of the United Kingdom; and to further the reasonable
interests of users of air transport services".
10. In fact some UK regions have links to
other European hubs but not Heathrow at all. Travellers from South
Wales may find it more attractive to fly with KLM from Cardiff
to Amsterdam for onward connections than make a long train or
road journey to Heathrow, with the added costs and hassle factor
involved. Passengers in Yorkshire for example have the choice
of more flights daily to mainland European hubs out of Leeds-Bradford
than to Heathrow (Annex 3).
11. It is true that many regional airports
have seen major growth in passenger numbers and new destinations,
but this has largely come as a result of the massive growth of
the low cost sector serving predominantly leisure destinations.
Where some regional airports have been successful in attracting
long haul international services, this has in many cases come
from Route Development Funds. Scotland in particular has benefited
from such a scheme, both for long haul and short haul international
services. These developments have come about from private and
governmental/local authority initiatives—not from any work
done by the CAA.
12. The CAA seems to be content to let the
market get on with it" but as the economic policy advisor
to the government it is necessary that it should be more proactive
in ensuring that regional interests are addressed, and that accessibility
is secured.
FAILURE TO
MEET OBJECTIVES
13. As part of the 1985 government White
Paper on aviation, two key areas in particular were highlighted.
The first was to establish Heathrow and Gatwick as global airports.
The second was to ensure airport capacity is built as and when
required, to meet demand where it is greatest. This has manifestly
not happened over the last 20 years—and the CAA's own stated
approach to this is to let the private sector/commercial developers
decide if and when they should meet demand.
SAFETY
14. We recognise the CAA's work in ensuring
that the UK has a safety record second to none, and the respect
that it has earned across the globe in this field. However, we
do have some areas of concern and in this submission we have decided
to concentrate the following comments on the specific aspects
of the role of the Safety Regulation Group (SRG) that have given
us the greatest concern and which have industry-wide implications.
15. These cover the following areas:
I. consultation with Consultants; and
II. CAP 168 (Licensing of Aerodromes), including
unpublished requirements and differences between CAP 168 and ICAO
Annex 14 (Aerodrome Design and Operations) and other related ICAO
documents.
CONSULTATION WITH
CONSULTANTS
16. Airport owners frequently choose to
appoint Consultants to plan and/or design airport development
projects for them. There are many potential reasons for this,
but in general, owners do not routinely employ sufficient numbers
of professional staff to undertake such work. That applies to
both small and large airports, where the scale of projects may
also vary, but can still be a major development if viewed in relative
size.
17. Aspects of any such development may
be regulated by CAP 168 or other CAA requirements and so, as designers,
Consultants require:
I. a clear statement of the regulatory requirements;
II. a clear procedure for handling issues
where those stated requirements cannot be fully achieved; and
III. a process to obtain a formal approval
(or at least a no objection") in advance of the Airport proceeding
with, or relying upon, such an intended course of development.
18. In general CAP 168 is a complicated document,
but no more so than ICAO Annex 14 that it is primarily intended
to replicate. The subject of differences between these is discussed
next in this submission. There are however a number of elements
where:
I. the CAA reserves a decision to itself;
II. the CAA has unpublished rules or guidelines
as to the application of CAP 168 or ICAO SARPS; and
III. the CAA takes a particular view on a
particular issue, but one which cannot be predicted from published
documents or from past decisions taken in similar circumstances
at airports elsewhere.
19. We have also encountered a situation
where a development that was in full compliance with CAP 168 was
still not approved and another situation where operations from
an extended runway were not subsequently permitted as intended
by the designer and airport operator. [The references are to:
Scatsta apron flood lights and apron marking; and to Scatsta declared
runway distances]
20. In most of these instances, designers
would benefit from consultation with the SRG.
21. However, we have been informed in the
past that the CAA SRG will only liaise with airport Licensees
and will not discuss a project with Consultants. This has certainly
been our experience in recent years. This makes it difficult to
give accurate or complete advice; it generates a risk of abortive
design work—incurring additional cost; and it can delay
the project, placing an additional burden on airport Licensees.
22. We therefore ask that the CAA respect
the fact that Consultants form an integral part of the development
process and that the CAA takes a more open, constructive and helpful
approach in ensuring that Airport developments are achieved in
both a safe and cost effective manner. This would be to the benefit
of all airport owners.
CAP 168 LICENSING
OF AERODROMES
23. The CAA is responsible for the application
of the UK's obligations that stem from it being an ICAO Contracting
State. CAP 168 is the CAA's document that describes its regulatory
requirements in respect of aerodromes and airport operations.
It does so in terms of Licensing requirements. Many of the provisions
of CAP 168 are identical to those SARPS stated in ICAO Annex 14.
However, CAP 168 departs from Annex 14 in numerous places. We
are going to concentrate on one aspect in this submission, which
is the classification of runways and their declared lengths. It
is a technical matter and we will describe the issue as succinctly
as possible, but we raise it as it has potentially very serious
implications that could threaten the future of public transport
operations at numerous regional UK airports.
24. The background to this is as follows.
Both Annex 14 and CAP 168 classify the design of runways by two
measures. A runway has a Code Letter, which relates to the largest
aircraft wingspan and undercarriage width that can be accommodated.
Safe clearances are determined from this classification. A runway
also has a Code Number, which is the pertinent issue here. Together
these produce the Aerodrome Reference Code".
25. ICAO Annex 14 and (prior to February
2001) CAP 168 classified the Runway Number in terms of the runway
performance of aircraft it is intended to serve. This is determined
by the aeroplane reference field length, which is the take-off
distance required under specified standard conditions. These are
reproduced in Annex 5.
26. Both documents said that this Code is
a simple method of interrelating the numerous specifications of
the aerodrome's characteristics, but also stated that it is not
intended to be used for determining" or influencing"
the actual length of runway provided.
27. However, in their February 2001 amendment,
the UK CAA fundamentally, and as far as we are aware unilaterally,
redefined the Code Number and its application at UK airports.
We are not aware of any event or substantive safety issue that
gave rise to this change and note that ICAO and other Contracting
States has continued with the former definition.
28. CAP 168 now states that the Number is
determined by selecting the higher value of declared TODA or ASDA"
(Annex 6). This, in effect, reverses the earlier intention that
the Code Number does not even influence" the runway length
provided, in that the length provided now determines the Code
Number.
29. The implications of this change can
be substantial, particularly in the case of Code 2 runways. The
clearances and obstruction surfaces associated with Code 2 and
Code 3 runways are substantially different. For example, a runway
sits inside an obstruction-free surface area termed a runway strip.
The required width of an instrument approach runway strip doubles
from 150m to 300m. There are also much more onerous obstruction
surfaces associated with these two classes of runway. Again for
example, the take-off climb surface increase from a 4% gradient
surface 2,500m long, to a 2% gradient surface 15,000m long. As
a result, many existing aerodromes with Code 2 runways cannot
comply with Code 3 requirements due to existing developments and
natural features on and off their site.
30. This change also makes the declaration
of clearway and stopway pointless.
31. In a direct response to a written query
from us, the SRG stated that they would not be expecting existing
runways to be brought up to the new standard, nor would they reduce
declared distances of existing Code 2 runways to no more than
1,199m. However they would expect new developments to comply with
this new definition and the related requirements.
32. The CAA also said that if a newly developed
runway is not able to comply with the provisions for a Code 3
runway, then its declared take-off distances will be reduced to
those applicable for a Code 2 runway. This could cause the cessation
of public transport operations at these airports as only very
few aircraft types can reliably operate with a commercial payload
off of a 1,199m long runway.
33. In a related matter, as a general principle
a longer runway is a safer runway and it is usual to provide a
length greater than the minimum requirement. In addition, the
length provided will also be increased, if applicable, to reflect
runway gradient, airport altitude or reference temperature. These
are standard industry practices that are included in ICAO runway
design documents. CAP 168 (and the SRG) do not allow a runway
length to be increased for such reasons. They do have an unpublished
allowance that will permit declared runway distances to be increased
by up to 10% to allow for the variation in air temperatures, but
that is all and remains contrary to the stated definition in CAP
168.
34. As a consequence of this, we have had
to advise one airport not to undertake runway end safety improvement
measures as these may be considered as development" and result
in the reclassification from Code 2 to Code 3. A change which
could not be provided for, due to physical constraints and the
prohibitively high cost of compliance.
35. It has also become apparent that many
existing regional airport Code 2 runways cannot be improved as
they then become subject to the unacceptable commercial risk of
having reduced declared runway distances. We also detect a reluctance
on the part of such airport operators to openly challenge the
CAA over this change, in case it highlights their inability to
comply with the much more onerous clearances and obstruction surfaces
required for Code 3 runways.
36. In making these points, we repeat that
we are not arguing in favour of any unsafe practice or the perpetuation
of any unsafe practices. Indeed, we would accept that there is
an argument for reviewing all the runway classifications and related
clearances to reflect the changed levels of risk associated with
modern aircraft operations. However, that should at least be done
after a proper study and after full consultation with all sides
of the industry. It should also be done through ICAO, if at all
possible, to ensure international uniformity in standards, practices
and operations.
37. By its simple act of amending CAP 168
in 2001, the CAA has put the majority of UK regional airports
outside of regulatory compliance and virtually prevented their
future development. It is also now unable to enforce the provision
of its own regulations, which undermines the value of these important
documents and has departed from the UK's obligations to apply
ICAO SARPS. Such a move displayed the underlying attitude of the
SRG of the CAA, which quite rightly causes concern to consultants
and aerodrome operators alike.
THE FUTURE
OF THE
CAA
38. Clearly the European Commission is evaluating
proposed further central regulation of the civil aviation sector.
The Commission has recently launched a public consultation on
airport capacity, efficiency and safety in Europe, the future
outcome of which could lead to significant changes in the role
and remit of the United Kingdom's CAA.
39. In particular the Commission is proposing
to extend the functions of the European Aviation Safety Agency
(EASA) into the airport environment, a policy which will be outlined
in an official communication published at the end of 2005.
40. An enhanced EASA, given greater powers
could potentially become a safety authority operating at the same
level as the United States' Federal Aviation Administration (FAA).
From the discussions that led to its creation, the intentions
were that an organisation would be set up:
— to draw-up common standards to ensure
the highest level of safety;
— to oversee their uniform application
across Europe; and
— to promote them at world level.
41. Furthermore, the adoption of a European
Parliament and Council Regulation (EC) No 1592/2002 of 15/07/2002,
put in place a Community system of air safety and environmental
regulation and led to the creation of EASA. The objectives of
that regulation can be found in Annex 7.
42. These will impact the role of the CAA.
It is also the intention of the Commission that EASA would develop
its know-how in all the fields of aviation safety in order to
assist Community legislators in the development of common rules
for:
— the certification of aeronautical
products, parts and appliances;
— the approval of organisations and
personnel engaged in the maintenance of these products;
— the approval of air operations;
— the licensing of air crew; and
— the safety oversight of airports
and air traffic services operators.
43. As a first step however, the Regulation
established only the basis of Community action in the first two
domains listed above. The Commission, assisted by the Agency,
plan to progressively propose the necessary amendments of the
Regulation to extend its scope to the other domains.
44. So where would this leave the CAA in
the future? How much authority would it have in the area of safety?
Already EASA states that European aviation authorities perform
a critical role in assisting EASA with the performance of its
core rulemaking, certification and standardisation functions."
This suggests more of a support function for the CAA, where it
ensures implementation of EASA Europe-wide standards and legislation
in the UK, rather than creating them in its own right. Furthermore,
when one looks at the Management Board of EASA, the UK member
is currently Mr Michael Smethers of the Department of Transport,
with the UK CAA only providing an advisor to the board. For the
majority of other European countries, it is their Civil Aviation
Authority who provides the board member. As safety regulation
is arguably the most important function of the CAA today, any
large-scale removal of its powers to a central European body in
this area, would bring in to question just what sort of organisation
it should be in the future.
45. According to its own literature, the
CAA's key responsibilities are in the areas of Air Safety, Economic
Regulation, Airspace Regulation, Consumer Protection and Environmental
Research and Consultancy. Safety is becoming increasingly led
by EASA, and regulation of it in the UK is also arguably undermined
by economic pressures in other areas. Economic regulation may
get increasingly constrained by decisions made in Brussels as
part of wider international agreements and treaties signed between
the EU and other countries, although it could be argued that this
would ensure no change in the CAA's sit back and let the market
get on with it" approach it seems to have increasingly taken
in this area. Airspace regulation is led by Brussels (through
Eurocontrol) and NATS in the UK.
46. Consumer protection has long been an
area of great importance to Brussels, with EU-wide legislation
recently introduced to protect passengers' interests regarding
delays and cancellation of flights, surely only the start of further
central regulation in this area in the future. Indeed the CAA
itself actually states that one of its responsibilities is to
license UK airlines and enforce European Council requirements
in relation to their finances, nationality, liability to passengers
for death or injury and insurance." When the CAA recommended
the bonding of scheduled air services the UK government rejected
its proposal, further undermining the CAA's role as a policy-making
body in this area.
47. Research and consultancy in the environmental
field is something the CAA is keen to highlight. The environment
is high on the European Commission's aviation agenda, with suitable
funding in place for such research to be undertaken. While this
is an area of great importance, and one that will become greater
still in the future, research in environmental issues is a function
that could be carried out by a myriad of respected institutions
across Europe, many of which will not be hindered in this research
by potential conflicts of interest in other areas of their work.
It is not ideal for a body which is charged with getting the maximum
possible use out of its country's runways to also be charged with
research into environmental issues, which could include economic
areas such as emissions charging. Furthermore, the CAA is investing
a great deal of time and energy in an area when it doesn't even
have a mandate from the government to do so. None of its original
mandates set out by the government or its own stated objectives
cover the environment.
48. We believe that with many of its key
roles becoming increasingly Brussels-led and with its record of
sitting back in the area of Economic Regulation, an area where
it can still potentially lead rather than be directed from Brussels,
the future position of the CAA is uncertain. Its future seems
increasingly to be a somewhat smaller rubber-stamping institution,
no longer charged with policy initiatives or legislation creation,
merely ensuring European Union legislation is implemented within
the United Kingdom; a role of mere oversight but no duty.
15 November 2005
APPENDICES TO MOTT MACDONALD MEMORANDUM ON
THE TRANSPORT COMMITTEE'S INQUIRY INTO THE WORK OF THE CIVIL AVIATION
AUTHORITY (CAA)
Annex 1
RUNWAY SEPARATION
(Photograph not printed)
Annex 2
CONNECTIVITY OF LONDON AREA AIRPORTS
| London airport: |
Heathrow | Gatwick |
Stansted | Luton |
London City |
Total Destinations served
Full Fare-
Low Cost-
| 168
168
0 | 126
123
15
| 100
24
84 | 28
11
19
| 20
20
0 |
Total Weekly Departures
Full Fare-
Low Cost-
| 4,506
4,506
0 | 1,804
1,550
254
| 1,572
235
1,337 | 502
60
442
| 445
439
6 |
Long Haul Destinations—USA
| 14 | 16 | 0 |
0 | 0 |
Long Haul Destinations—Other
| 77 | 23 | 0 |
0 | 0 |
Terminal Passengers (Year 2003-mn)
| 63.2 | 29.9 |
18.7 | 6.8 | 1.5
|
ATMs—(Year 2003-000s)
| 458 | 236 |
172 | 61 | 50
|
Annex 3
TABLE REPRODUCED FROM CAA CAP 754 DOCUMENT (P 49)
HUB SHARE OF PASSENGERS FROM REGIONAL AIRPORTS WHO CONNECT
EN ROUTE
| Short-haul destinations |
| | Long-haul destinations
| | |
| | 1990
| 2001 | |
| 1990 | 2001 |
Edinburgh | Heathrow
| 73% | 24% | Edinburgh
| Heathrow | 70% | 57%
|
| Gatwick | 8%
| 11% | | Gatwick
| 23% | 6% |
| Other hubs | 19%
| 65% | | Other hubs
| 7% | 37% |
| | 100% |
100% | | | 100%
| 100% |
Glasgow | Heathrow
| 56% | 33% | Glasgow
| Heathrow | 40% | 48%
|
| Gatwick | 9%
| 9% | | Gatwick
| 13% | 9% |
| Other hubs | 35%
| 58% | | Other hubs
| 47% | 43% |
| | 100% |
100% | | | 100%
| 100% |
Aberdeen | Heathrow
| 58% | 36% | Aberdeen
| Heathrow | 58% | 41%
|
| Gatwick | 11%
| 14% | | Gatwick
| 29% | 20% |
| Other hubs | 31%
| 50% | | Other hubs
| 13% | 39% |
| | 100% |
100% | | | 100%
| 100% |
| | 1994-95
| 2001 | |
| 1994-95 | 2001
|
Newcastle | Heathrow
| 49% | 25% | Newcastle
| Heathrow | 60% | 55%
|
| Gatwick | 7%
| 11% | | Gatwick
| 12% | 14% |
| Other hubs | 44%
| 64% | | Other hubs
| 28% | 31% |
| | 100% |
100% | | | 100%
| 100% |
Notes: Figures for Scottish airports include only those
passengers whose surface origin is in Scotland.
Figures for Newcastle include only those passengers whose
surface origin is in the Northern planning region.
In both cases this captures the majority of users at these
airports.
Source: CAA O&D Surveys at regional airports.
Annex 4
CAA OBJECTIVES
— To foster a strong and competitive British airline
industry by providing enough airport capacity where it is needed."
— To support the leading position of Heathrow and
Gatwick among the world's major international airports and interlining
centres."
The 1985 Airports Policy White Paper; Department for Transport
Annex 5
RUNWAY CLASSIFICATION (ICAO ANNEX 14)
| Aeroplane Reference Field Length |
Aeroplane Reference Code Number |
|
| <800m
| 1 |
| 800m to <1,200m
| 2 |
| 1,200m to <1,800m
| 3 |
| >=1,800m
| 4 |
Annex 6
CAP 168 TODA AND ASDA DEFINITIONS
— Declared TODA is the declared Take Off Distance
Available, which is the surface take-off run available (TORA)
plus any declared clearway beyond that for aircraft to gain height.
— Declared ASDA is the declared Accelerate and Stop
Distance Available, which is the surface take-off run available
(TORA) plus any declared stopway provided for to stop in the event
of an abandoned take-off.
Annex 7
REGULATION (EC) NO 1592/2002 OBJECTIVES
— establish and maintain a high uniform level of
civil aviation safety and environmental protection in Europe;
— facilitate the free movement of goods, persons
and services;
— promote cost efficiency in the regulatory and
certification processes;
— assist Member States in fulfilling their ICAO
obligations on a common basis; and
— promote world wide Community views regarding civil
aviation safety standards.
2
(CAP 754 UK Regional Air Services P 94). Back
3
(CAP 754 UK Regional Air Services P 102). Back
| 
