VZCZCXYZ0003
RR RUEHWEB

DE RUEHLO #2943/01 2130802
ZNR UUUUU ZZH
R 010802Z AUG 07
FM AMEMBASSY LONDON
TO RUEHC/SECSTATE WASHDC 4710
INFO RUEHMT/AMCONSUL MONTREAL 0044
RUEWMFA/FAA NATIONAL HQ WASHINGTON DC

UNCLAS LONDON 002943 
 
SIPDIS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: EAIR ICAO UK
SUBJECT:  UK VIEWS ON US ICAO SAFETY PAPER 
 
REF:  STATE 77572 
 
¶1.  Post received the following comments in response to ref cable, 
from Adrian Sayce at the UK Mission in Montreal, via Glenn Cronin of 
the UK Dept for Transport: 
 
Agenda Item 13  Vision for the future of USOAP. 
 
This WP proposes the application of a system safety approach to the 
future USOAP.  This concept is not new and was the reason that the 
current USOAP was expanded in 2004 to apply 'a comprehensive systems 
approach'.  The systems part of this was to apply a risk assessment 
methodology - or so the Commission was told - but this does not seem 
to have happened.  The idea was that auditors would spend more time 
assessing the data before an audit and would then audit all 16 
Annexes using a targeted approach.  To my knowledge this has not 
happened. 
 
In view of this, I strongly support the US WP.  The only problem is 
getting some idea how ICAO would go about accomplishing the safety 
risk analysis.  At the moment the Secretariat has established an 
Audit Results Review Board which is supposed to serve as a link 
between USOAP, USAP and the Unified Strategy Programme (USP).  The 
ARRB is a new concept that has not been described in detail to the 
Commission.  It is supposed to review USOAP data and provide an 
early warning of problems.  This is nice in theory and will sound 
good at the Assembly, but how it will work in practice will be 
interesting to see. 
 
In summary, I support this WP. 
 
Agenda Item 23  Electronic sharing of AIP. 
 
I support this WP.  It is good that ICAO is doing at least something 
to help the environment!  However, I believe the WP does not 
emphasize the safety benefits from this. 
 
This subject has become very controversial as ICAO's role in all 
this has been questioned by Eurocontrol and FAA, as well as data 
originators, processors, publishers, regulators, system designers, 
service providers and end users.  There was a Eurocontrol AIS 
Congress in 2006 which ruffled ICAO feathers.  (Note AIS is the 
Aeronautical Information Service, as detailed in Annex 15 and AIPs 
are the most important Aeronautical Information Publications 
provided by States under AIS).  This WP may simply be used as part 
of a wider discussion on the future of AIS. 
 
Agenda Item 25  ICAO Safety Evaluations/Audits of International Air 
Operations. 
 
I believe that this presents a rather narrow view of the role of 
ICAO in evaluating/auditing a State.  We have known that there are 
States where the national authority is poor but national operators 
are excellent.  Although we can probably assume that there is some 
correlation between a State having appropriate oversight capability 
and operators being safe (this is the ICAO position), the strength 
of this correlation is open to question.  Often national operators 
have working-relations with operators in other States and this can 
improve their level of safety (for example KLM and Kenya Airways, 
but this may not be the best example!). 
 
I do not believe there is a very strong correlation.  For this 
reason, ICAO audits have included some assessment of a state's 
international air operators (during the UK Audit both easyJet and 
Air 2000 were visited).  Also, ICAO is supposed to be working more 
closely with IATA so that combined USOAP and IOSA results can give a 
better picture of a State's level of oversight.  I also believe the 
US position is slightly flawed because ICAO's objective to 'meet the 
needs of the peoples of the world for safe, regular, efficient and 
economical air transport'.  This implies that as airlines provide 
the service to 'the peoples of the world', ICAO must try to ensure 
the operations are safe either directly or indirectly through their 
State. 
 
In spite of all this, I understand the US is trying to keep USOAP 
focused and this is a good thing to aim for.  But some flexibility 
must be allowed.  If a State has an excellent airline, this may be 
because the airline has acted responsibly and does not need to be 
spoon-fed by a State regulator.  We could talk around the need for 
regulation and the value of self-regulation for a long time. 
 
Agenda Item 28  Analyzing Precursors of Accidents. 
 
It is hard to disagree with most of this.  It is very ambitious and 
many of the subjects have been seen before.  I agree with the 
Actions by the Assembly. 
 
My only reservation is that Annex 13 should really be examined to 
firm up the reporting requirements for Serious Incidents.  At the 
moment, para. 7.7 states 'If a State conducts an investigation into 
an incident' it shall send a report to ICAO 'as soon as 
practicable'.  This doesn't seem worth the paper it is written on. 
Even the new USOAP reports from States for Annex 13 will not reveal 
much. 
 
Perhaps we need another WP that highlights the weakness in Annex 13. 
 I was once told that only about 5% of world reportable aviation 
accidents are produced as a Final Report.  Needless to say, the UK 
does a terrific job.  As Peter Hunt is producing a UK Information 
Paper on the UK Airprox scheme, perhaps the CAA should do the same 
for its MOR Scheme. 
 
Agenda Item 31 - Transforming today's ATS to meet tomorrow's 
challenges. 
 
This seems more of an Info Paper.  Concerning the Action by the 
Assembly, para. 5.1 a), this seems to be asking the Assembly to 
promote the US systems.  I am not sure this is what the Assembly 
should be asked to do.  Perhaps it should instruct ICAO Council to 
examine such systems and recommend to States what they must do to 
harmonize with them. 
 
As for 5.1 b), I am a bit concerned about reference to 'development 
and acceleration of standards for required future systems'.  I would 
hope that ICAO will develop performance-based standards, or detailed 
specifications outside the Annexes 
 
TUTTLE