The steps to obtaining an Air Operator Certificate

In this interview, the ‘Guernsey Aircraft Register’ or ‘2-REG’ answers questions about the legal requirements and processes needed to obtain an Air Operator Certificate.

The steps to obtaining an Air Operator Certificate

In this interview, the ‘Guernsey Aircraft Register’ or ‘2-REG’ answers questions about the legal requirements and processes needed to obtain an Air Operator Certificate.

Q: What is the Guernsey Aircraft Register?

The Guernsey Aircraft Register is the aircraft register of Guernsey, a UK Crown Dependency situated in the English Channel. It is operated under a public-private partnership with the Guernsey Director of Civil Aviation (DCA) being the public partner and SGI Guernsey Ltd, trading as 2-REG, as the private partner. More than 360 aircraft have been registered since its start in December 2013, of which about half are current.

Q: What are the key elements and can 2-REG give any guidance for obtaining an AOC?

In March 2016, Guernsey legislation was introduced authorising the DCA to issue Air Operator Certificates (AOC). In aviation, an AOC is the ultimate safety authorisation for operators as it allows the holder to offer air transport to the general public. Internationally, ICAO has set standards and guidance for both the requirements for an AOC and the application process.

The requirements are set out in Annex 6, Part I to the Chicago Convention. These pertain to various aspects, some of which are technical, while others are of a more-organisational nature. It is now commonly accepted that aviation safety starts with a sound organisation with clear management commitment and accountabilities and with safety-risk management, assurance and promotion procedures in place. In addition to that comes a host of more detailed requirements in the areas of flight operations, aircraft instruments and equipment, maintenance, manuals, records and personnel competencies.

A key concept for an air operator is that of operational control. The organisation must have control over each flight, from the moment it starts being prepared through the actual commencement to final landing. Whenever a situation which may jeopardise safety develops during any of these phases, the organisation must have in place procedures that allow staff to act properly to mitigate the hazard. In the vast majority of cases, these procedures will have been prepared well in advance (such as abnormal and emergency checklists for flight crew or an emergency response manual), but operational control is also about the organisation acting responsibly in case of less-common or even unpredictable situations ranging from sudden atmospheric conditions (e.g. hurricanes, volcanic ash) to political unrest (e.g. conflict zones) or aircraft defects that fall outside the normal envelope of what the manuals address.

Another key element for an AOC holder is Principal Place of Business (PPB). An AOC must be applied with the civil aviation authority of the country in which the operator has its PPB. Whereas ICAO has only loosely defined PPB, Guernsey has adopted two alternative definitions from which an applicant may choose. One definition is similar to that of the EU/EASA, whereas the other definition is taken from the UK Overseas Territories Air Navigation Order. Both definitions aim at ensuring that operational control is exercised in Guernsey, but there are some subtle differences.  

Q: What is the application process for an AOC?

The 2-REG AOC application process is designed so that it complies with ICAO guidance . The process consists of five phases, which are as follows.

Phase 1: Pre-application phase

If a future applicant is interested in a 2-REG Air Operator Certificate, he may indicate his interest via email, telephone call, visiting the 2-REG office or completing an application form.

Prior to the actual start of the process, 2-REG will invite the candidate applicant for an informal meeting to discuss expectations from either side. This practice is in addition to the ICAO guidance but has proved to be very helpful as it serves as a reality check for some of the over-ambitious applicants.

Following this informal meeting, the process will formally start when 2-REG sends a standard information package (SIP) with information on the process, the requirements and a pre-assessment statement form for completion by the applicant.

On receipt of the pre-assessment statement, 2-REG will appoint a project manager and a certification team. A pre-application meeting will then be scheduled with key management personnel of the operator. That meeting serves as a check on whether the applicant is indeed ready to formally apply for the 2-REG AOC. If the outcome is positive, the project manager will hand over a formal application package (FAP), which includes information regarding how to proceed.

Phase 2: Formal application phase

The formal application phase starts at the moment the applicant decides to formally apply for the AOC. The FAP which has been handed over during the pre-application consists of 21 different kinds of documents for the applicant to submit. These range from which PPB definition has been chosen to information on the proposed key staff to a description of, and a business plan for, the intended operations, plus drafts of the various operational manuals and the safety management system. An important document which some applicants find quite demanding to complete is a compliance checklist proving that all the requirements can indeed be met. Not only will this document help the applicant in ensuring that he or she meets all of the regulatory requirements, but it also serves as a good reference document during the subsequent phases.

As some of the requirements ask for approval or acceptance by the Director of Civil Aviation, the applicant needs to complete a separate document in which a detailed justification is given for each of the approvals or acceptances that are requested. A special kind of approval form the specific approvals, such as RVSM, NAT HLA, EDTO, EFB, LVO and DG . These approvals are the subject of a separate process in which typically the following elements are verified:

  • Aircraft capability (i.e. proof of certification for the specific approval)
  • Continuing airworthiness arrangements (does the maintenance programme include tasks related to the specific approval)
  • Operational procedures
  • Proof of training of personnel.

Upon receipt of the completed package, a formal application meeting is held to establish communication and working relationships between the 2-REG certification team and applicant personnel. The applicant can explain the submission and a schedule for the next steps will be agreed upon. At the same time, interviews are held with proposed key staff such as the accountable manager and postholders to verify that they satisfy the regulatory requirements.

Phase 3: Document evaluation phase

The next step is for the certification team to commence the evaluation of all the documents that were submitted as per the FAP. Typically, this evaluation will raise comments that then have to be resolved by the applicant. All comments and their response are documented using checklists.

Phase 4: Demonstration and inspection phase

During this phase, operations are witnessed by the certification team that imitate as closely as possible the proposed operation. The operation’s demonstration and inspection will consist of the following:

  • Organisation and administration. Through discussions with the key management personnel and through observation the certification team will evaluate whether the operator is properly structured and can ensure operational control
  • Ground-based operations inspection. The purpose of this part is to ascertain, through on-site inspections, the adequacy and suitability of the applicant's staffing, training programmes, ground equipment, facilities and procedures to conduct the operations specified in the application
  • Flight operations inspection. The part is to demonstrate the ability of the intended flight operations, as well as compliance with the regulatory requirements. Proving flights need to be conducted as per the procedures described in the operator’s manuals submitted as part of the formal application
  • Maintenance control. The maintenance-control demonstration and inspection phase is for the operator to demonstrate to the certification team that the operator has sufficient resources and knowledge and adequate procedures to ensure an airworthy condition of its aircraft during the entire duration of their operational life.

All deficiencies will be discussed with the applicant, in order for the applicant to resolve these to successfully pass this phase.

Phase 5: Certification phase

When all phases have been passed successfully, 2-REG will issue a recommendation to the Guernsey Director of Civil Aviation for issuing the AOC and its operations specifications.

Q: Is there any continuing surveillance?

An AOC is issued for an unlimited period. However, the AOC holder will be subjected to a continuing surveillance programme to verify that he or she continues to meet all the requirements so that safe operations are ensured and that the AOC is not endangered. Typically, the first audit will take place three months after issuing the AOC and will focus on elements that could not be verified during the demonstration and inspection phase, such as the proper functioning of the safety management system. Another audit will be held later in the first year. The frequency and depth of subsequent audits will be determined by the safety performance of the AOC holder.

Q: Where can readers find more information?

Readers may consult the website (www.2-reg.com) or contact 2-REG by emailing info@2-reg.com