Regulatory Development: Modernising Qatar's Aerodrome Regulations

In 2016, the State of Qatar commenced a program to align it’s aviation safety regulations with the European aviation regulatory framework. New EU-based aerodrome regulations were initially promulgated in 2017 but the application of parts of this model were not possible in the Qatari context. Over the next two years, I analysed the local environment and, with the help of my colleagues, developed some appropriate solutions which I formulated into the European model. These amended regulations were promulgated in March 2020.

State Providers

Like many jurisdictions, Qatar has transitioned its main airports from a state-run operating model to a privatised airport company model. However, not all aspects of airport operation were or have been moved to the airport company. Most notably being the aerodrome rescue and fire-fighting service (ARFFS).

The ARFFS has remained part of the Civil Aviation Authority (QCAA), albeit separate from the regulatory arm of the organisation.

Early versions of the regulations and most versions of international guidance, don’t make allowance for such organisations in their certification and oversight systems. Instead, the aerodrome operator is generally made accountable for the compliance of these organisations without little consideration for the power needed to effect change where safety issues are identified.

With the help of a colleague, we created the state provider concept. In a nutshell, state providers are those government entities the state has made responsible for some aspect of the scope of certification defined in the aerodrome regulations (typically the same as Annex 14 and associated ICAO guidance material).

In these instances, the regulation impose obligations on the state entity to be party to the certification process, contribute to and abide by the aerodrome manual and be subject to oversight in a manner similar to the aerodrome operator. These obligations replicate industry best practice for organisations working together and the general approach being undertaken by the relative organisations at the time.

Tiered Approach

One of the most powerful aspects of the EU-based aviation safety model is the tiered approach to regulatory compliance.

At the top are a relatively limited number of regulations. These requirements are generally high level in their nature and should be generally applicable to all aviation participants - in our case, aerodrome operators. In terms of page numbers the regulations are now just 52 pages (down from 270 pages).

Of course, this doesn’t mean that the other requirements were discarded completely. Most of these requirements, usually the more detailed aspects of Annex 14, are outlined in Acceptable Means of Compliance (AMCs). The relationship between the AMCs and the regulations is pretty simple - if you do what the AMCs say, you will automatically comply with the associated regulation.

In Qatar, the language of our legal system makes compliance with the AMCs mandatory by default but the Alternative Means of Compliance (AltMoC) avenue is also available. This means that if you have developed a different (hopefully, better) way of meeting the requirements of a regulation, you can apply for approval of your AltMoC. This application must be supported by a robust safety assessment including appropriate risk assessment and mitigation measures.

There is also a third tier with some regulations and AMCs supported by Guidance Material (GM). These provisions provide additional supporting information and guidance. They include things like training syllabi, explanations and industry best-practice.

On the physical characteristics side of things, a set of Certification Specifications were developed to form the foundation of what is called the Certification Basis. As part of this project, one of my colleagues reviewed the EU-based specifications against recent ICAO Annex 14 amendments as well as incorporated Annex 14 Volume 2’s heliport requirements.

Completing the Picture

For a sovereign state like Qatar, the EU-model model is incomplete. As a “super-state”, the EU regulations are limited to larger aerodromes involved in international civil aviation. Where a state has domestic operations, it needs to fill that gap.

Within the new regulatory suite, we developed two lower levels of aerodromes - domestic public-use and domestic private-use. Broadly speaking, the former go through a “declaration” process and the latter become “registered” aerodromes.

New provisions were developed along the model of the EU regulations with new Authority Requirements (AR) and Organisation Requirements (OR) for each new category of aerodrome. These lower lever aerodromes have fewer regulatory requirements in both areas but with appropriate, risk-based provisions allowing for increase regulatory oversight and action.

Making it Happen

The work of the last two years was not carried out in isolation. In the early stages, a great deal of formal and informal consultation was carried out with the primary aerodrome operator and other stakeholders, including state providers, at the airport. As the nature of the required work became clearer, I moved the project into the formal setting of a regulatory development project under the QCAA.

Once my proposal to the Technical Review Committee (TRC) had been approved, I developed the necessary notice of amendment documents for issuing to the industry and the public for comment. The regulation’s notice was issued in July 2019 and the AMC & GM notice in October 2019.

Both notices received good feedback which was taken into consideration before two industry seminar were held. I presented the feedback and responses at those forums with some discussions becoming quite passionate. Following the first seminar, we moved into focussed consultation with our key stakeholders and over a period of three months we held a number of meetings to discuss the proposed changes.

The final regulations and comment response documents were delivered to the President for his approval in early March 2020. They were signed and promulgated on the 8th March 2020.

Operations Management: The "Pain-o-Meter" & Personnel Resourcing

Effectively planning for your personnel requirements at an airport can be a real challenge. First and foremost, we have to "take them as they come" with flight schedules dictated by airlines* and this means peaks and troughs in demand that are difficult to match with people.

In mid-2016, the Queenstown Airport was moving to extended hours operations. Previously, the airport had been limited to daylight operations and could be covered with a single shift of people each day. With after-dark flights being approved, the airport was moving to a 18-hour-plus day but it wasn't as simple as doubling the size of the team.

For the first season, scheduled after-dark flights were minimal but daylight flights were also continuing to grow. The challenge for me was to identify my personnel needs using some foundation that would not only support my request for additional people but also support future requests as the airport continued to grow.

Not Quite Starting from Scratch

While it seemed like I was starting with nothing, it became clear to me quite quickly that the organisation had already thought a lot about its needs but had never put it into a coherent model. When speaking to floor staff and duty managers, they used words like heaving, stretched, tight, blocked, etc. They knew what was going wrong as well as where and when they needed help.

What struck me was the organic qualities of the comments and it conjured up an image of the airport as a living creature that would suffer pain as passengers passed through it. I was inspired to develop a model that would predict when and where the airport would feel that pain.

Pinch Points

Queenstown Airport has all the standard airport pinch points - check-in, security, customs. It also has a couple of rather novel ones such as on the apron where flights of different categories can't mix and require "traffic" management.

Again, the team knew where these issues were and helped me to understand what impact each area had and how they could assist in making it better.

Charting Passenger Flow

Not all passengers behave the same way and not all flights have the same requirements on their passengers. Only international passengers have to be processed by customs and biosecurity officers and only departing passengers pass through security, etc.

So, in order to calculate the impact of an individual flight, I had to vary the model depending on whether in was domestic-v-international and arriving-v-departing. Within these four categories I then needed to establish the timings for passengers at each stage of their journey and make estimates of how many would reach each stage at approximately the same time.

My model was quite basic and but it was modelled down to five minute intervals across seven pinch points.

Number Crunching

I wish I could say that this number crunching was done using some sophisticated, high-tech software platform. I can't. It was all done in Excel using filters, look ups and a host of other formula to produce what I called the "Pain-o-meter" (Trademark pending**).

The result was an extremely noisy look at when the airport would be under pressure. At five minute intervals, it was too much information to use so I smoothed it out using mean and moving average calculations over days, weeks, days of the week and months.

From here, I created an algorithm to calculate who many people I would need on each day. I had to apply some managerial discretion here because the basic model would have had people standing around on the chance of something going wrong and this wouldn't be sustainable. After a couple of iterations, I settled on an acceptable ratio of pain to people.

Structure

With a greater understanding of the flow of passengers that came from the model, it also became apparent that the team needed slightly more depth in its structure. With the data available from the "pain-o-meter", I was able to show that two new positions could be created within our steady-state requirements and that these positions would support the supervision of the overall team when the airport was busy.

The Operations team was a combination of steady local people supported by a large, traditionally itinerant, group of working tourists. The model showed that we could expand our steady workforce within the new resourcing requirements.

In addition to a small cost saving, this change also allowed me to employ some of our more senior and talented temporary workers. Their addition to the team shifted the culture with an injection of enthusiasm and spirit. They also became our lead on-the-job trainers having been through their training in the previous year and having a great deal of empathy with our itinerant workforce.

Rostering Made Slightly Less Hard

The "pain-o-meter" was the base for rostering which could, theoretically, be completed six months ahead. I say theoretically because I still have a predominately itinerant workforce which couldn't be rostered effectively beyond two months.

But even this timeframe allowed the whole team to enjoy flexibility in their work schedule and comfort in scheduling leave in the future. While the model gave me a way of planning and rostering, it also gave the team some confidence in the roster and the rest of the team.

* albeit within capacity and slot constraints

** not really

Project Lead: Queenstown Airport Park & Ride

The Queenstown Airport is one of the fastest growing airports in Australasia. It has been experiencing a double digit average growth for over two years. While this type of growth is exciting and good for business, it can be extremely challenging for operations. One area of pain, from both the operational and customer points of view, was the car park.

Queenstown Airport was very much as tourist destination airport and the car park reflected that with a large and increasing emphasis on rental car parking and grooming spaces. But the increasing population of the resort town was also putting pressure on the private car parking areas.

Initially, the car park would reach capacity on holiday long-weekends and during special events in Auckland (don’t talk to the Operations team about Adele). The situation soon became on where overflow arrangements were a regular requirement with the team even working with nearby parking providers (ie competitors) to ensure a reasonable customer experience.

The geography of the landslide area in the vicinity of the terminal meant that options for expansion within the terminal precinct were virtually non-existent. Any development in this area would need to be studied carefully, key in with the Master Plan under development at the time and require substantial capital investment.

So, to alleviate the pressure on our car park system, I was handed the task of developing and conducting a remote park and ride service trial. I actually volunteered for a project that would stretch my capabilities a couple of weeks prior - in a way, I asked for it!  

Team Leadership & Development

To help me make this happen, the CEO assembled for me a cross-functional team drawn from all parts of the business. Coincidently, they nearly all volunteered for a “stretch project” as well. As with most projects within a largely operational business, I had become the leader of a team who already had full-time jobs and managers to whom they reported. 

The first step was to get to know what each of the team members wanted to get out of this project. From here, I began to assign work according to both individual and project goals. And to avoid siloed work, we also came together to tackle larger project issues as a group in a series of workshops. The combination of individual and group work helped to cultivate a strong team connection and to capitalise on the team member’s strengths while exposing them to other tasks,

Options Analysis & Board Engagement

The park and ride service trial began with a near blank sheet. Previous work had looked at specific options but the team was given the opportunity to explore other options. The team relished this task and workshopped numerous ideas. We explored numerous options including constructing a low specification car park on airport land on the other side of the runway (medium capital expenditure (capex) option) and entering into an agreement with a nearby shopping centre to utilise a portion of their infrastructure from which to base the service (low capex option).

The only way we felt we could make a recommendation to the Board was through a robust modelling and options analysis. Using data from existing car park patronage, observations from nearby public parking areas and future flight schedules, the team produced Net Present Values (NPVs) for each option covering three patronage scenarios. 

While no options provided a clearly viable business opportunity (this was a trial project for a reason), The comparative NPVs did provide us with a direction forward. And then a new option was presented to us from the local council.

A nearby roading project was going to need to provide off-street parking for displaced car owners and airport landing in the vicinity provided a good opportunity for the council and the airport to work together. As majority shareholder in the airport and a key stakeholder generally, the council was aware of our park and ride project and proposed that we pool our resources to construct a car park that would service both our needs.

Thanks to the previous options analysis, we were able to model this new option and show clearly to the Board that by sharing costs with council and taking advantage of economies of scale off the nearby roading project, the now clear preferred option would be “joint-venture” car park proposed to us. Without our previous analysis modelling, we would not have been able to take advantage of this last minute suggestion from the council. 

Customer-Centric View

From the initial stages of the project, the team was very much focussed on the Voice of the Customer. As a trial project, we knew that it would live or die by the experiences of those who would use the service. This project was more than building a car park. It was about building a new product that we wanted people to buy. Would our market take to a park and ride service? 

Historically, residents of Queenstown have been from the higher end of the social-economic scale and they had been used to convenience and budget rates. Car parking prices had not changed at the airport for over four years and this new product would require a review in that pricing to be viable. Would our customers be willing to pay the same amount or more for parking with less convenience?

We didn’t know but we wanted to give ourselves the best chance by making sure that the customer experience was as intuitive, efficient and valuable as it could be. In workshop after workshop, we would challenge each other on the best way to service our customers within the scope and budget we had. We supported our approach with focus group data sourced through another car parking project and social media feedback from early engagement on the park and ride offering.

Performance

The Queenstown Airport Park & Ride Service began operation on the same day as the opening of Stage I of the new airport access road, Hawthorne Drive. While we had planned to celebrate with any customers on the first day, we were generally sceptical of whether we would actually see any that day. As it was, our first customer interrupted our own celebrations and took the very first schedule shuttle service to the terminal.

First month revenues exceeded expectations and, prior to my departure from the airport, the trend for the rest of the trial was extremely positive. In addition to this, the new park and ride service relieved the pressure in the existing car parks and helped to usher in a new pricing regime thanks to a level of reliability that had not existing in the terminal precinct for some time. The Operations team we glad to dis-establish its overflow procedures.​

Leading this project was one of the highlights of my time at Queenstown Airport but it was not at all possible without the help of Rowan, Kylie, Shikha, Chris, Sophie, ​Naomi & Colin.

Contract Management: Shifting Models & Saving Money

I joined the Moranbah Airport team not long after it opened its new terminal and introduced two major operational contracts - one for airport management and the other for airport security.  

Without being too critical of the work that preceded me, let’s just say that the scopes of these contracts were a mixture of complex-consultant-drafted, techno-speak and standardised mining services requirements that had little applicability under civil aviation legislation or in airport operations, generally. These contracts also missed out on cleaning and grounds-keeping requirements and clashed with standard asset maintenance processes mandated elsewhere in the organisation.

Probably the biggest issue with the contracts were that they were set up for growth but by the end of the first year of their three-year term, the mining sector in Queensland had stopped growing and was about to enter into a very tough period. 

Contract Management as a Discipline

Managing an airport requires a certain set of skills and knowledge but managing a contract that includes managing an airport requires quite a different approach. While I took the personal angle of being a hands-on airport superintendent, when it came to making things happen and discussing issues, I had to use the language and the processes found in the contracts.  

Issues surrounding performance and compliance were uncovered in a relatively standard way under the airport’s Safety Management System but corrective actions had to be translated into contract performance and breach language to effect change. While going through these motions seemed overly officious and impersonal at times, it did establish a clearer understand of the reality of the relationship between the airport owner and the contractor. 

The Downturn

In the second half of 2013, mining was definitely on a downward trajectory and my organisation’s business model had to change. Operationally, the airport went from nearly 300,000 passengers per year to as low as 140,000 pax per year. Flying operations moved towards peaks and we lost a great deal of the efficiency that came through the previously significant and consistent flow of passengers.

The effect on the airport was threefold:

• obviously, our passenger revenue and other traffic dependent revenues decreased

• as part of a larger mining business, there was pressure to reduce to costs and an airport is not a mining revenue centre

• as mentioned above, the existing contracts were designed for growth and based on ill-defined scopes of work and a high-price tag

My organisation commenced a significant program to reduce costs. Every part of the business was examined with ambitious targets set and an appropriate culture of urgency introduced. This wasn’t a program of slash and burn but rather, a persistent environment of asking why on everything we did with a clear cost-per-tonne goal in everyone’s mind.

Shifting Gears

Airport Management Capability

I’ve blogged on outsourcing airport operations before and in that article, I identify that some contracting companies simply hire their aerodrome capability to suit the contract. This was the case here. The airport management team were capable but beyond them, there was little support in the technical knowledge and skill required to run an airport. I saw this as an opportunity to save money through direct employment.

By increasing the in-house airport management team, I could not only save money on the corporate overhead that existed, I could also increase the resilience of my organisation’s airport capability, give the team a higher level of security, pay them better and increase loyalty to a greater depth at the airport.

Contractor Workforce

The bulk of the workforce would remain contractors. The market was much too volatile and we still needed flexibility should the airport operations continue to change.

I did, however, take the opportunity to fundamentally amend the contract scopes. The existing scopes were somewhat outcome focussed, which would normally be good, but not in the same way that the business was used to. Unfortunately, moving people through an airport is not the same as moving dirt or coal.

Using the previous three years, I had a very good understanding of what work was being carried out on site. In the previous year, I had introduced work menus and this provided a great source of data on the work activities and work times. It also gave me an opportunity to look for synergies in particular work activities, especially around grounds-keeping and habitat management.

As such, I decided to shift to a personnel-based contract. The contractor would provide my organisation with a set number of people, holding set qualifications, ready to work set hours and provided with basic requirements (clothes, etc.) and we would provide the rest. The plant, tools, equipment, vehicles, procedures and facilities were provided by my organisation as it had established procurement and maintenance arrangements in the area.

Getting Approval

While saving money was a significant objective, changes such as this had to be vetted and analysed and approved. Thanks again to the operational modelling I had completed using real-world airport experience, the financial modelling required to satisfy my management was relatively easy to develop. The introduction of additional employees at the airport increase the level of scrutiny. Such an experience can be frustrating and exhausting but the benefit is a high-level of confidence in the approach when the contracts finally go to tender.

Tenders & Negotiations

Using the organisation’s standard tendering process, multiple parties engaged in the process. Being the person who drafted the contract scopes allowed me to assist these parties in understanding what we were looking to get on award of the contract. I quickly saw how the previous contract situation had developed. If there is a distance between the contract scope development and the tender process, confusion and misunderstanding can be introduced easily.

Once proposals had been received and the tender closed, we set about the two step process of assessing each proposal. The first step was to assess the capability of the contractor to provide the service. This was carried out against pre-arranged criteria and without reference to the price schedule. After all organisations had been assessed, only the pricing for those contractors that met the minimum standard were reviewed.

After this, we entered into negotiations with all phase two contractors and eventually with the front-runners before settling on a preferred contractor. Final contractual negotiations were then finalised before announcing the award.

Transition

Unfortunately for the incumbent contractor, they were not awarded the new contracts. As such, we entered a complex transition period. With the shift in airport management approach, a great deal of work had to be completed to ensure that my organisation was ready to assume the greater level of responsibility required. This meant developing procedures, hiring staff and purchasing equipment while onboarding two new contractors and ensure the existing contractor continued to fulfil their obligations.

The Result

To the bottom line, the new contracts saw a reduction in operating costs of approximately 40%. This included the costs that were shifted internally.

Above this, the airport moved into a new phase with an almost instantaneous shift in culture and teamwork. The clarity provided by the new contracts allowed people to get on with the jobs. We introduced traineeships to develop local residents and we increased the level of support for the frontline team in terms of equipment, guidance and training.

Industry Wide Analysis: The Authorisation Holder Performance Indicator

In 2011/2012, the Australian Civil Aviation Safety Authority (CASA) was redeveloping its surveillance procedures with the production of the CASA Surveillance Manual (CSM). There were a number of objectives attached to this project with taking a risk-based approach to surveillance chief among them.

The previous manual already had a method by which an authorisation holder (i.e. a certified air carrier, aerodrome, delegation or other civil aviation certificate holder) might be tagged as being of concern but there was little guidance provided to inspectors and managers as to how to appy these labels. The concept was known as Surveillance Posture and included three levels.

As a member of the Safety Systems Office (SSO), I was tasked with looking into this process and identifying a way of making it more risk-based, systematic and defensible. 

Building on the Work of Others

When I was assigned to this task, a questionnaire approach had already been developed but the questions were a little ad hoc, varied between industry sectors or hadn't yet been developed for some areas. Other states' Civil Aviation Authorities (CAAs) had also been working in this area with the New Zealand approach reviewed as part of our work. 

What I set out to do was to build on this work and, using the well-established Reason Model, develop a proforma set of questions that could be used for any authorisation holder type - airline, airport, maintenance organisation, manufacturer, etc.  I did this by building a large question bank from the existing questionnaires and started to identify common questions and underlying concepts. In was surprising to see the Reason Model fall out of this analysis so easily. There were a couple of gaps but they were easily filled in with targeted questions.

Assessment Algorithm

With a final set of sixteen questions spread over the four levels of the Reason Model, the next step of the process was to develop the assessment algorithm that would turn a completed questionnaire into a score that meant something in the real world.  This was done through trial and error with sense checking provided by colleagues in the SSO.

Using a set of archetypical operators, I manipulated variables across the question groups to arrive at indicative lists of surveillance postures for these hypothetical operators. Each operator through each variation of the algorithm was discussed to see if the result made any sense. 

As I was essentially systematising a process that used the knowledge and experience of inspectors to arrive a consistent conclusion, the algorithm needed to make logical sense to those same inspectors.

Validation

In order to deploy the new system, CASA needed to show that it did what we said it was going to do. We also needed to show inspectors what it was, how it did what it did and that those results supported their own assessments of operators. 

The validation program of the AHPI involved using a sample (approx 10%) of all operators across the Australian aviation industry and their assigned inspectors to test the system in small groups across all CASA regional offices and divisions.

These groups were first asked to assign a surveillance posture to the sample group. Thanks to CASA's policy of rotating inspectors periodically, each group usually consisted of more than one inspector familiar with the sample group operators. This allowed for moderation of the "analogue" approach to surveillance posture assessment. Then, inspectors were asked to assess their operators using the AHPI tool. 

Afterwards the results were calculated and compared to the traditional assessments of the operators. Where inconsistencies were noted, they were discussed with the assigned inspector to confirm their initial assessment. In these cases either the inspector revised their "analogue" assessment, altered answers to the individual questions or small tweaks were made to the algorithm.

Defence

The final hurdle of this project was to present and defend the new tool to the CSM Project Board. This group was overseeing the entire manual redevelopment project and, as senior leaders in CASA, were very demanding when it came to making changes and proposing new systems. 

At the next board meeting, I presented the development and validation of the AHPI.  The probing questions came thick and fast but I remember mostly ensuring that the power of the tool was not overstated. THe AHPI served a single purpose of providing inspectors with a way of categorising operators for surveillance intensity. The real work of any inspector remained and still remains auditing in the field to ensure that operators are complying with their regulatory obligations.

Epilogue 

Earlier this year, CASA revised the CSM and made changes to the Authroisation Holder Assessment process. It now appears that the AHPI is part of a larger assessment process and it is good to see the tool has lasted over five years so far.