It was suspended July 1 but now faces revocation
There is a risk that PIA’s authorization to operate into European airspace may be revoked if it does not implement a Safety Management System to the satisfaction of the regulator by the end of March 2021.
Six months ago PIA and all airlines regulated by the Civil Aviation Authority were banned by the European Aviation Safety Agency from its airports.
There had been ample warning for nine months prior to the ban. The regulator had warned PIA it was not satisfied with its safety record. The airline had said it would work on fixing the problem and meeting standards.
On May 22, PK-8303 crashed in Karachi and EASA expressed grave concerns after initial findings. It said it showed “successive breaches of multiple layers of safety defences in the safety management system” and said it had concerns that the Safety Management System “is not achieving its primary objective”. It took note of Pakistan’s aviation minister informing Parliament that 260 out of 860 pilot licenses issued by the CAA are “fraudulent” and therefore, “Pakistan, as the State of Operator, is currently not capable to certify and oversee its operators and aircraft in accordance with applicable international standards”.
By July 1, EASA had suspended PIA’s authorization for six months. It said the third country operator permission would be reinstated once it was satisfied that PIA had fixed the problem.
When suspension period comes to an end EASA can extend it for another three months (in accordance with ART235(b) of Part-ART). If the regulator is not convinced the airline has taken corrective action, it can even revoke the authorization when the suspension time period ends (under ART 235(c)(1)of PART.ART).
By December 2, 2020, the European Union Aviation Safety Agency wrote to inform PIA that the documents it submitted on November 16 were “satisfactory and sufficient as a first important step towards the closure of the above-mentioned finding,” but considering the recent suspension for safety concerns the agency would still put PIA through an audit when deciding on ending the suspension.
If only the CAA and PIA had filed for review within two months of their initial suspension starting July 1, 2020, they would have been advised on the steps to be undertaken for putting in place a Safety Management System as per the ICAO and Chicago Convention. Unfortunately those at the helm of both the CAA and PIA had worked in a command and control military environment with minimal significance of any role for a regulator. Unlike other state owned enterprises, PIA and other airlines regulated by the CAA are subject to regulatory supervision of every country whose airspace they fly over or land they cross.
EASA said that concerns mentioned in ART205©️(2) had not been met. Furthermore, the investigation conducted by the European Commission on the way professional licenses were issues was still going on, which indicates that there is “a possibility that the audit will not have the expected positive results”.
If PIA’s authorization to enter Europe’s airspace is taken back, there will be chain reaction. The International Civil Aviation Organization (of the UN) would in all probability advise all countries to impose similar restrictions. This would sound a death knell for all Pakistan Civil Aviation Authority-regulated airlines, who would not be allowed to fly on international routes. Needless to say, this would have a drastic financial impact on all airlines and insurance coverage would escalate astronomically.
With PIA no longer allowed to operate on major international routes, passenger and cargo traffic would be carried by foreign airlines. Almost $1.5 billion in revenue earned from sale of tickets to Pakistan-based passengers heading to foreign destinations would be pocketed by these airlines, who would transfer this amount to their countries of registration. This would drain our already scarce Forex reserves.
Neither PIA nor the CAA have appealed for a review for reasons best known to them. EASA had given PIA the right of appeal to be filed in writing within two months from the date it had told it of the suspension and how to move forward.
Five Corrective Action Plans were implemented but there had been no progress on the sixth which related to the Safety Management System.
It was PIA’s failure to implement the Corrective Action Plan within the timeframe which resulted in the sixth item being raised to Level 1. Level 1 means immediate implementation, failing which a ban follows.
In a letter (titled Suspension of Third Country Authorization No.EASA.TCO.PAK-0001.01) EASA talked about two technical consultation meetings with PIA held in 2019.
After analysis, the EASA raised a total of six Level 2 findings and accepted PIA’s plan. However, after review, five Corrective Action Plans were accepted by EASA, but PIA could not show it effectively implemented all elements of a Safety Management System.
EASA referred to the statement by Minister Aviation on June 24, 2020 revealing that “260 out of 860 pilot licenses issued by Pakistan CAA and used by pilots operating for air operators certified in Pakistan are fraudulent” and therefore “Pakistan as the State of operator, is currently not capable to certify, and oversee its operators and aircraft in accordance with applicable international standards”.