Combining Mixed-Use Flight Operations Safely at Airports (2016)

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104 This study found that although a number of airport and community leaders believe there are significant issues and risks associated with combining various aeronautical activities at any one airport, anecdotal and interview information indicated a less significant problem. For the majority of airports in the United States, especially the small general aviation airports, the infrequent or low volume of opera- tions do not result in major conflicts or challenges. Issues become a concern primarily where there are high volumes of traffic, a wide mix of activity, or frequent use of an airport by one particular type of aeronautical user. With communication and coordination, several airports in the study have been able to resolve those issues to a large extent. Important points to learn from the study are: • A basic premise asserted by both the FAA and courts is, if a pilot is conducting the activity in accordance with FAA regulations, then the operator and the operation are presumed to be operat- ing in a safe manner. • Stakeholder communication and coordination are keys to safely combining mixed-use operations. • Prohibiting uses at an airport requires extensive documentation and approval by FAA. • Minimum standards, operating rules, and standard operating procedures (SOPs) are effective practices that airport managers use to assure safe operations in mixed-use aeronautical environ- ments. These practices must be policed and kept current to remain effective. Issues involving mixed-use aeronautical activities appear to stem primarily from the difference in operating speeds, lack of user knowledge or understanding of competing operational user needs, user’s failure to follow existing standard and accepted practices, lack of airport land area to accom- modate a user, and conflicts with competing economic entities. Airport design criteria are tailored toward traditional aeronautical uses, such as fixed-wing and rotary-wing operations. Other mixed-use aeronautical activities, such as gliders, skydiving, balloons, and ultralight operations are expected to integrate with existing facilities. Airports have only recently started to benefit from additional plan- ning and guidance that helps ensure safety. FAA has provided a number of handbooks and advisory circulars to address those activities, as have aeronautical user trade associations. The most evident means of accommodating different aeronautical users is through separation of their activities to the extent possible at individual airports. A prohibition of all aeronautical activity of one type, such as ultralights, gliders, parachute jumping, balloon and airship operations, acrobatic flying, or banner towing is allowable if the FAA concludes that such operations cannot be mixed with other traffic without an unacceptable impact on safety or the efficiency and utility of the airport. If the FAA determines there are less restrictive ways or alternative methods for accommodating the activity while maintaining safety and efficiency, then an airport is expected to accommodate the activity to some extent. A review of FAA determinations and discussions with study participants indicates the need to not arbitrarily reject or delay a user request, but to make a diligent effort to find alternatives for accommodation. Upon request, the FAA will perform a safety review of any aeronautical activity at an airport. In light of recent industry efforts to enhance safety through the implementation of safety management systems, an airport’s diligent effort could include an independent safety risk analysis. The synthesis study reaffirmed the airport’s responsibility to manage the affairs of the airport in a reasonable, and not unjustly discriminatory, manner. The development of minimum standards or rules chapter sixteen CONCLUSIONS

105 and regulations can lay a strong foundation for meeting the airport operator’s obligations. SOPs, rules and regulations, and minimum standards are all means to enhance safety at an airport. The literature review for this study discovered news articles, standards, and court cases that tend to group into two general formats for establishing minimum standards: (1) those developed by airports that seek to encourage and support various aeronautical uses and (2) those that tended to discourage them. Concern has been expressed in the literature that skydiving, ultralights, and other mixed-use aeronautical activity may result in traditional fixed-wing flight operators avoiding operation at an airport, especially jet activity. Airport operators project that there can be a subsequent decrease in fuel sales and other economic business activity. This study did not find quantifiable data related to the various claims. As the study further discovered, the development of SOPs and rules and regulations have little value if they are not well communicated and consistently upheld. A common finding from minimum standards at airports is that they often use a boilerplate approach to the more common commercial aeronautical activities, rather than including the possibility of a different aeronautical user. It is not until a little-anticipated aeronautical operator appears at the airport manager’s door and requests access to the airfield that many managers first think of the possibility or consequences. While much of this study focuses on the responsibility of the airport operator, the data collected also describe users’ actions having an impact on airport operations. As the study progressed, it became apparent the various aeronautical users are passionate about their activity. That passion can bring solutions to the table or can create obstacles. The majority of users displayed efforts to bring solutions to the table. This is evident in the efforts of the aeronautical trade associations to provide leadership and guidance to their members. Their development of organizational structure, operating manuals and best practices, education and training resources, safety documents and reviews, and a host of social and competitive opportunities, all are indicative of efforts to provide solutions. However, the trade association handbooks tend to have little information on how to integrate with other aircraft, or information on how to work with airport management. Simple courtesy and common sense go a long way when different aeronautical users share the same airspace and airport. Users of an airport have a responsibility to completely and thoroughly understand the operating rules of the airport and airspace, and combine that with good decision- making. Many of the accidents reviewed for this study reflect shortfalls in those responsibilities. A number of airport operators emphasized the need to better train and educate users, but the study found smaller airports are less likely to have the resources or to make efforts to do so beyond normal issuance of a Notice to Airmen. However, the review discovered a gap in information listed in the remarks section of the Airport/Facility Directory. Often the information does not reflect current practice at an airport, if information is lists at all. The various aeronautical handbooks that have been developed invariably focus on enhancing the knowledge of pilots. Pilot education could be enhanced with addi- tional emphasis on integrating some of the practices presented in this report. The guidance material in the literature and lessons from study participants suggest the following basic elements will help airports safely combine mixed-use aeronautical activities: • Develop useful minimum standards and operating rules and procedures that consider the possibility of future aeronautical users and that are reasonable and not unjustly discriminatory. • Mixed-use operations require an understanding of accepted procedures and needs of the other categories of operations. Promote public outreach to meet that goal. • Accepted procedures and standards need to be enforced quickly, equitably, and consistently. • The absence of an operating airport control tower creates a need for increased vigilance and situational awareness on the part of all users operating at an airport. • Efforts that promote communication and understanding among the users can improve safety. • Regular safety and user meetings improve communication and understanding. • A safety review and risk analysis can help achieve a number of goals. • Be open to the benefits that a particular aeronautical user group can bring to the airport.

106 Owing to the limited breadth of this study, there are airports and examples of practices that were not captured. Each of the aeronautical activities studied in this report could warrant a separate synthesis study to elaborate on airport practices. A singular study on each aeronautical activity could provide more in-depth analysis. In particular, a review of minimum standards focusing on each activity would be beneficial. None of the airports participating in the study had helicopter tour operators. Further study on tour operators could be beneficial to the industry because they have unique commercial operating needs and practices that would be valuable to present.