Mr. Declan Fitzpatrick:

I thank the committee for extending an invitation to the Irish Aviation Authority to this meeting to discuss the standard instrument departures in use at Dublin Airport. I am accompanied today by my colleagues Mr. Jim Gavin and Mr. Adrian Corcoran, who I may call on to assist in providing answers to queries as they arise. I will set out the background to standard instrument departures, SIDs, what they are, what safety regulations apply, who is responsible for supplying them, and the role of IAA as regulator when approving an SID. First, I should explain the overall role of the IAA as it has recently changed with the enactment of the Air Navigation Transport Act 2022.

The Irish Aviation Authority is a commercial semi-State company and is the single civil aviation regulator for Ireland. The IAA is the responsible authority in Ireland for the regulation of safety, security, economic and consumer interests in civil aviation. The company's responsibilities are set out in a framework of applicable global, European and national legislation and regulations. Since 1 May, the IAA no longer provides air traffic control services in Irish airspace and at the airports of Dublin, Cork and Shannon. These services are now provided by a separate commercial semi-State company, AirNav Ireland, which is responsible for the management of Irish sovereign airspace on behalf of the State as set out in the Air Navigation Transport Act 2022.

The regulatory functions of the IAA cover all aspects of civil aviation, including the certification and registering of aircraft; the continued airworthiness of aircraft; and the licensing of pilots, maintenance engineers, air traffic controllers, aviation security personnel and unmanned aircraft system, UAS, operators. It is also responsible for the certification and oversight of commercial airlines and aircraft operators; aerodromes; design and production organisations; continued airworthiness maintenance organisations; air navigation service providers; UAS-specific operations; training schools; and cargo consignors and shippers.

Since 1 May, the functions and personnel of the Commission of Aviation Regulation have merged with the IAA. These new functions include the setting of en-route charges for aircraft in Irish airspace; the setting of passenger charges at Dublin Airport; schedule co-ordination and slot allocation at Irish airports; the licensing of the travel trade in Ireland; commercial licensing of airlines and approval of ground-handling service providers; the oversight of air passenger rights regulations; and the provision of assistance to passengers with reduced mobility.

The IAA operates to the highest international safety standards developed over decades by the International Civil Aviation Organisation, ICAO, a UN specialist agency established by the Chicago Convention in 1944 to set global standards and recommended practices, SARPs, for aviation and uniform global procedures for air navigation services, PANS. The SARPs are contained in 19 annexes to the convention and run to approximately 13,000 individual requirements while the PANS are contained in six volumes approved by the ICAO’s air navigation commission.

In Europe, the ICAO SARPs are codified into law by the European Union, which has primacy in aviation transport, with some minor exceptions. The primary regulation in Europe, issued in 2018, is Regulation (EU) 2018/1139. The regulation covers all key areas of aviation, including airworthiness, aircrews, aerodromes, air operations and air navigation services. The aim of the revised regulation is to establish a high and uniform level of civil aviation safety while ensuring environmental protection. It includes a revised mandate for the European Union Aviation Safety Agency, EASA, and new rules designed to allow the European Union aviation sector to grow, make it more competitive and encourage innovation. It is further expanded by specific implementing regulations and delegated acts which lay out the specific obligations in each domain for the entities and for the IAA as the competent authority in Ireland. All these regulations are readily available through the EASA website.

As part of the ICAO and EU safety regulation frameworks, the IAA is subject to external independent auditing by both the ICAO and EASA. The ICAO operates the universal safety oversight audit programme while EASA operates a standardisation programme as per EU regulation (EU) 628/2013. Both programmes consist of a continuing monitoring assessment of the IAA as well as on-site audits of the IAA and entities the IAA regulates. For example, last year EASA conducted four such audits on specific areas and will conduct another two this year. The IAA consistently performs excellently in these audit programmes and ICAO ranks Ireland in the top ten states globally and second in Europe. Similarly, the EASA auditing continually places the IAA at the top end of EU states and well ahead of the EU average.

It is important that the IAA continues to perform well in these audits as it provides assurance to other states that Ireland’s aviation industry is effectively regulated and can continue to get the full access and benefits of the global aviation market. The IAA performs well because it is staffed by highly experienced aviation safety and security experts in all aviation disciplines including air transport pilots, airworthiness design and maintenance engineers, aviation security, ground handling, aeromedical and licensing experts, pilot training, aerodrome engineers, air traffic controllers, air navigation equipment engineers, unmanned aircraft systems and aviation safety management experts. The IAA always seeks to be a leader among aviation regulators and is highly respected by the ICAO, EASA and its regulatory peers in other states.

Regarding SIDs, each certified aerodrome must provide instrument flight procedures to assist aircraft to operate safely and efficiently at its aerodrome. These include standard instrument approach procedures and SIDs. Both depict the profile of an instrument departure or arrival route and consist of information such as direction to fly, minimum climb or descent gradients for the aircraft, minimum or maximum speeds to fly and relevant navigational points. These are all published and freely available in the aeronautical information publication, AIP, for Ireland, which is available on the AirNav Ireland website. In Ireland, the airports covered are Cork, Dublin, Shannon, Donegal, Ireland West, Kerry, Sligo, Waterford and Weston. Essentially these SIDs are roads in the sky which the air traffic controller can tell the pilot to follow, removing the need for the controller to continuously give detailed instructions.

The applicable implementing regulation for certified aerodrome operations is Regulation (EU) 139/2014. It requires that the aerodrome operator shall ensure, either directly or through arrangements with accountable entities, the provision of air navigation services appropriate to the level of traffic and the operating conditions at the aerodrome, and the design and maintenance of the flight procedures, in accordance with the applicable requirements. In Dublin, the Dublin Airport Authority, DAA, is the aerodrome operator and has put in place arrangements with AirNav Ireland for the provision of air navigation services at the airport, including the provision of the instrument flight procedures.

Regarding the design of flight procedures such as SIDs, the applicable safety standards to which these procedures must be designed are contained in the standards and recommended practices and procedure for air navigation services produced by the ICAO, as I referenced earlier. The design of flight procedures including SIDs is a safety-critical and complex process which must take account of multiple factors such as the airport layout, the topography, the capabilities of aircraft, and the communication, navigation and surveillance equipment available at the airport among other things.

Before an organisation can design flight procedures for an aerodrome it must first obtain an organisation approval from EASA. This ensures the organisation has the appropriate competencies, procedures and quality assurance processes to perform the work. The list of organisations currently approved to design flight procedures in the EU is available from EASA. The certified aerodrome operators in Ireland, either directly or through their arrangement with their air navigation service provider, source the flight procedures from these specialist companies.

Before an individual instrument flight procedure can be used, it must be submitted to the IAA as the applicable competent authority. The IAA reviews these submissions and determines if they meet all safety requirements set out by the ICAO and EASA. Where an instrument flight procedure submission does not meet the safety requirements, it is rejected by the IAA and cannot be published. Where a procedure is approved by the IAA, it is sent to the aeronautical information service provider, AirNav Ireland, for publication in the AIP. As part of the AIP process, there is a lead time between publication and its becoming active. This is to allow airlines and aircraft operators across the world adequate time to promulgate the new procedures and ensure flight crews are advised, aircraft flight management systems are updated, etc. This publication process is also defined by ICAO standards and recommended practices, and works to common applicability dates globally, referred to as the aeronautical information regulation and control, AIRAC, cycle.

All published instrument flight procedures for Irish airports are compliant with the safety requirements, and monitoring processes are in place to ensure their safety is maintained. For the avoidance of any doubt, the IAA approval process only verifies that the procedures designed for a specific aerodrome, as presented to the IAA, meet all safety requirements set out by the ICAO and EASA. It is not in our remit to assess if the aerodrome is compliant with other obligations the aerodrome may have to meet, such as planning conditions and noise abatement obligations.

The opening of the new runway 10L/28R at Dublin Airport in August 2022 required the development of new SIDs and standard instrument arrivals, STARs, for the airport. The new flight procedures allow for simultaneous segregated operations on both parallel runways compliant with the applicable safety standards. Currently there are over 30 different approach and departure charts approved and published in the AIP for Dublin Airport to cover the different operational scenarios possible on all three runways.

A key safety requirement when operating the parallel runways in the same direction, as introduced in Dublin Airport, is to ensure that aircraft do not collide. Specifically, the ICAO specifies that the flight procedures for segregated operations must be designed to ensure, when it is intended to use an instrument departure procedure and an instrument approach procedure in the same direction on parallel runways simultaneously, the nominal tracks of the departure procedure and of the missed-approach procedure shall diverge by at least 30° as soon as practicable. This is best depicted in ICAO document 9643, a diagram of which appears in our submission.

The SIDs and STARs submitted to the IAA aviation regulator for the introduction of the new parallel runway and the current approved versions which became effective in February provide for missed-approach tracks to 28L to continue straight ahead, while the departure tracks for 28R require the operator to turn in a northerly direction above a specified altitude after the designated end of the runway thus ensuring the minimum 30° divergence criterion is met.

There are several factors in the airspace surrounding Dublin Airport that add complexity to designing an instrument flight procedure. For example, the Irish Air Corps operates from Casement Aerodrome, which is protected by a large volume of restricted airspace. Flights with civil instrument flight procedures cannot enter the restricted airspaces without there being arrangements in place, thus constraining the footprint of the procedures.

To reiterate, the IAA's approval process for the SIDS and STARs presented to the IAA for the introduction of the new parallel runway, 10L/28R, verifies that the flight procedures meet all safety requirements set out by ICAO and EASA. However, we have no role, when certifying these flight procedures, to ensure the aerodrome is compliant with other obligations it may have to meet, such as planning or noise-abatement obligations.

I hope this fully explains to members' satisfaction the background to standard instrument departures, what they are, what safety regulations apply, who is responsible for supplying them, and the IAA's role as regulator when approving a standard instrument departure. I am sure members will have additional questions, so we will be happy to give further clarification.