COPA responds to Comprehensive Environmental Study of the Decommissioning of the Banff and Jasper Airstrips

On February 28 the public comment period will end for letting the Canadian Environment Agency know our views on the results of a study regarding the decommissioning of Banff and Jasper Airstrips. Judging by the number of responses copied to COPA, there was a significant response. Thank you to everyone who took the time at this critical juncture.

COPA’s response raised some issues to demonstrate how the study process was flawed and we made a strong recommendation for a way to reconsider Parks decision to decommission. We emphasized that first and foremost, it is our position that the Proponent of the project and the Responsible Authority for the study should not be the same body. This has removed objectivity from the process which is evident in the study.

The Air Safety Risk Assessment report by Kootenay International Associates clearly indicates there will be an increase in risk to pilots and passengers as a result of the proposed project.

In its Consolidation of Findings report Parks Canada suggests the following as a risk mitigation: “The two main undertakings now proposed in the modified project are to remove all features indicative of an operational aerodrome and to restore the natural montane environment. However, as a safety mitigation the former airstrip lands will be maintained in natural grassland condition free of trees and shrubs.”

During the Air Safety Risk Assessment workshop, COPA, and most of the other participants, explained in detail why this option would not mitigate the risks. The result would be the removal of all information from the Air Navigational Charts, the Canada Flight Supplement (aerodrome directory) and the GPS aerodrome databases in addition to the removal of all surface indications of an aerodrome. It is important to understand that from the air there are many areas in the mountain valleys that look like fields. However, pilots will not choose them for an emergency or diversionary landing area when the need arises because they are most often bogs or swamps, clear-cut areas filled with tree stumps, or overgrown gravel areas riddled with boulders rather than smooth fields. From the air it is very difficult to discern the difference between a suitable and unsuitable landing area without positive markings on the ground and on the navigational charts. Pilots are typically instructed in this manner at mountain flying training courses.

Pilots are highly trained to minimize risks to their passengers. When unforeseen circumstances arise necessitating an emergency or diversionary landing, a pilot will choose the lowest risk option. In the case of such a landing in the mountain areas where there are no known or marked airstrips, the lowest risk option may be the nearest highway.

The bottom line is this. With positive markings on the ground (such as exist now), and the maintenance of the two strips in the Canada Flight Supplement, the grass strips are a viable option to pilot safety. Without them, there is no option provided to pilots. The proposed risk mitigation is not a mitigation at all.

We believe that it is not necessary to decommission the airstrips in order to achieve Parks Canada’s goal of limiting access to the two airstrips (emergency/diversionary flights for example). During the Air Safety Risk Assessment workshop, COPA proposed a viable, alternate means of compliance with Parks Canada’s goal and the need for risk mitigation. This was supported in Kootenay International Associates’ final report. In October, 2003 COPA made a written offer to provide its considerable expertise in the matter of aerodrome regulations and practices to Parks Canada to help formulate a mutually acceptable mitigation option. This offer was not accepted.

In our letter to Agency, we reiterated the alternate proposal presented during the ASRA workshop. When the National Parks Aircraft Access Regulation (NPAAR) was first proposed in Canada Gazette Part I, Vol. 129, No 34, August 26, 1995, Banff and Jasper were included in the list of eight national parks where aircraft access would be permitted at specified locations (the Banff and Jasper airstrips), with specific restrictions. Subsequently, in Canada Gazette Part II, Vol. 131, No 7, March 19, 1997, Banff and Jasper were removed from this list. This is the version that became law on January 29, 1998, bringing litigation in the Federal Court of Canada, the Provincial Court of Alberta, and the Court of Queen’s Bench of Alberta. All were decided in favor of pilot safety concerns.

In order to avoid further litigation, Parks Canada can easily request a change to the NPAAR to have Banff and Jasper placed back on the Schedule of aerodromes to the NPAAR with specific restrictions to limit usage of the airstrips to emergency and diversionary purposes. Re-listing them is the only way to ensure the airstrips continue to be marked on charts, in the CFS and in the GPS databases. There are already adequate provisions within the CARs to designate the airstrips as restricted (R) on the navigational charts and in the GPS databases (Private). In the Canada Flight Supplement they can not only be designated as restricted (Prior Permission Required) but additional instructions, to be determined by Parks Canada, can be added to make the status very clear to pilots.

With these provisions in place we maintain that Parks Canada will be able to successfully control access under the NPAAR, while still maintaining pilot safety.

There is precedent for this in the case of Wood Buffalo National Park’s airstrip, Garden River, located at Garden Creek, Alberta. This is listed in the NPAAR list of acceptable landing locations in national parks (No 7). It is listed as restricted (R) on the Lake Athabasca VFR Navigational Chart, is listed in the Canada Flight Supplement as a Prior Permission Required airstrip, and listed in the GPS databases for ease of pilot identification. Open, yet restricted.

Although investigation of this option was recommended by Kootenay International Associates, it was not pursued by Parks Canada.

The Canadian Environmental Assessment Act provides for the study to be referred to a mediator or a review panel should public concerns warrant. Due to the lack of proper consideration of the above mentioned mitigation option, and the following statement from the Strategy Plus Analysis of Public Input report: “Safety and having airstrips available for emergency and diversionary purposes was of concern to almost three quarters of all respondents, and the most frequently noted comment”, COPA requested that the study be referred immediately to a mediator for resolution.