Ghana National Air Carrier and the International Aviation Safety Assessment (IASA) Challenge

The global commercial aviation industry is doing very well, and more than four billion people traveled by air in 2017. According to data from the International Air Transport Association, global passenger traffic grew by 8.1% during 2017. During the first half of 2018, air travel grew 7%. (Zhang & Lee, 2018). There has been a remarkable improvement in the aviation industry in Ghana with projects geared towards an enhanced air travel experience. Some of the projects include: commissioning of Terminal 3 at Kotoka International Airport (K.I.A), designed to accommodate five (5) million passengers in the next 5 years; construction of Modern Air Navigation Services Centre at K.I.A, to ensure safety and security of aircraft and passengers in our air space; and construction of Phase II of both Kumasi and Tamale Airports (GACL, 2017). The need for these investments in infrastructure and air navigation systems is to respond to anticipated traffic growth, and to keep up with the dynamism in technology that the aviation industry demands.

Economic Potential of Aviation in Ghana
In Ghana, aviation has the potential to create about 95,500 new jobs and an additional GDP of 46.8 million USD by 2035 (IATA, 2017). Presently there are about 30 aviation operators with Air Carrier License (ACL) issued by the Ghana Civil Aviation Authority (GCAA) and some have acquired their Air Operators Certificate (AOC) which means that they can fully operate as fully- fledged businesses entities and employ qualified personnel (GCAA, 2017).

Strategic Rationale for A National Air Carrier
Ghana has the strategic goal of becoming the destination of choice and the preferred aviation hub in the West African sub-region. There has been a strategic national desire to establish a new home-based carrier after the demise of Ghana Airways (fully state-owned entity) and the subsequent collapse of Ghana International Airlines, established with private sector participation. The desire stems from afore-mentioned growth in the sector experienced on the continent and the industry’s future potential.

Subsequently, the government of Ghana recently signed a memorandum of understanding (MOU) with Ethiopian Airlines (ET) as strategic partners in a public-private -partnership (PPP) for the establishment of a national air carrier. The MOU which will be finalized before the end of 2018, will see the Ethiopian Airlines contributing funding, equity, aircrafts and management services which are critical areas the airlines have expertise in. The government will receive 10 per cent of shares in the home-based carrier while the majority shares will be for Ghanaian investors. (Graphic.com.gh, 2018).

Current Challenges to Ghana-US Air Route Network Optimization

However, as interconnected as global air travel may be, countries around the world still have differing standards in term s of their safety, technical, and regulatory frameworks. the EU publishes a list of airlines banned from its airspace due to their failure to satisfy regulators. The US, one the other hand, does not evaluate individual airlines, but rather a country's ability to follow international standards set by the United Nations' International Civil Aviation Organization or ICAO.

The Ghana-US routes has a great potential for both passenger and freight services. In the opinion of this author, this potential is due to the minimal number of operators on the Accra- direct -US route (currently Delta Airlines and South Africa Airways which enjoys 5th freedom flights operate on that route). Analysis done by the writer using data from the US Department of Transportation’s ( Transporatation.gov, 2019) suggests that within the period 2016 -2018, passenger throughput were Delta Airlines (182,830) on the New York-Accra route; South Africa Airway ( 227,013) on the Washington-Dulles –Accra route; United Airline (149); Charters (357) and Delta (1708) on the Atlanta-Accra route. The analysis suggest a potential for increased throughput and robust competition on the US cities-Accra routes. It behooves on Ghanaian registered air carriers to make in-roads on that route to regain a competitive posture and strive for good break-even load factor (percentage of seats that have to be filled for the airline to recover the cost of operation) that can ensure profitability and business sustainability.

However, a current challenge to direct services from Accra to US cities by Ghanaian registered aircraft (9-G) and crew is the current designation of Ghana as a category 2 status by the United States Federal Aviation Administration (FAA) as part of their International Aviation Safety Assessment (IASA) program. Under IASA, the FAA determines whether another country’s oversight of its air carriers that operate, or seek to operate, into the U.S., or codeshare with a U.S. air carrier, complies with safety standards established by the International Civil Aviation Organization (ICAO). Countries are listed as either Category 1 - the FAA has found that the country meets ICAO standards for safety oversight of civil aviation, or Category 2 - the FAA has found that the country does not meet those standards.

Considering the challenges enumerated, how will Ethiopia Airlines manage operations under an air operator certificate (AOC) issued by GCAA for the national carrier while presumably utilizing ET registered resources for such Ghana-US routings? Will there be re-registration to 9-G or use of ET-registered aircraft and crew for such operations? What happens when the new carrier has to re-register aircraft to 9-G while Ghana is IASA category 2? What will be the effects on our global reach in terms of route network to the US and access to that potentially viable market?

Scope of International Aviation Safety Assessment (IASA)

The IASA program focuses on a country's ability, not the ability of individual air carriers, to adhere to international aviation safety standards and recommended practices contained in Annex 1 (Personnel Licensing), Annex 6 (Operation of Aircraft), and Annex 8 (Airworthiness of Aircraft) to the International Convention on Civil Aviation “Chicago Convention” (ICAO Document 7300). Carriers from Category 1 countries are permitted to operate into the U.S. and/or codeshare with U.S. air carriers in accordance with Department of Transportation (DOT) authorizations.

Carriers from Category 2 countries that seek to initiate commercial service into the U.S. and/or seek to codeshare with any U.S. air carrier are prohibited from initiating such services. Currently, some of the African countries that enjoy direct routing of flight to the US (category 1 status) are Cape Verde, Kenya, Nigeria, Ethiopia, Egypt, South Africa and Morocco. Even though Ethiopia has category 1 status and as such Ethiopian registered aircraft and crew can operate any intended Ghana and US route from Accra, it will be a challenge when the new airline must use Ghanaian registered aircraft and crew whose oversight will be done by the Ghana Civil Aviation Authority (GCAA).

IASA Assessment and Requirements
The IASA assessments determine compliance with these international standards by focusing on each critical element (CE) of an effective aviation safety oversight authority specified in ICAO Document 9734, Safety Oversight Manual. These eight critical elements (CE) include:

Primary aviation legislation.
Specific operating regulations.
State civil aviation system and safety oversight functions.

Technical personnel qualification and training.
Technical guidance, tools and the provision of safety critical information

Licensing, certification. authorization, and approval obligations.

Surveillance obligations.
Resolution of safety concerns.
To achieve an IASA Category 1 rating, Ghana must demonstrate that it meets the ICAO standards for each of the eight critical areas during an in-country visit assessment by the FAA. After the assessment is done on these critical areas, the FAA provides the results of the assessment, through the report, to other U.S. Government officials and the GCAA. The report details the updated status of the IASA process, and requests appropriate follow on activities.

Final discussions on the report are allowed with the GCAA. The final discussions are also meant to provide an opportunity for the GCAA to present necessary actions to correct findings of non-compliance with ICAO requirements identified during the assessment activity. To achieve an IASA Category 1 rating, a country must demonstrate that it meets the ICAO standards for each of the eight CEs. When the initial results of the assessment of a CAA’s safety oversight indicate that a country does not meet ICAO standards, the FAA formally requests IASA final discussions.

Recommendations
An option available to airlines from countries like Ghana that have failed the FAA inspection is wet-lease aircraft from countries permitted to fly into the US as is currently being envisaged in the partnership with Ethiopia. In a wet lease, the lessor provides the aircraft complete with crew, maintenance, and insurance (ACMI). As a result, Ethiopia that complies with IASA category 1 standards maintains operational control of the flight to the US until Ghana can attain and sustain a FAA IASA category 1 status.

However, with the need for local-content and a Ghanaianization policy of our aviation sector, it is envisaged that every effort will be made by the government of Ghana through the Ministry of Aviation, Ghana Civil Aviation Authority as regulators and the Ministry of Foreign Affairs (Trade and Business Outfit) to formulate an immediate plan of action to regularize our IASA status. I am aware that in August 2018, Mr. Simon Allotey, Director-General of the Ghana Civil Aviation Authority (GCAA), in an interview with the Ghana News Agency at the Ministry of Aviation’s “Meet the Press” session said the Authority had scheduled for an ICAO Universal Safety Oversight Audit Programme (USOAP) to be conducted by 2019. That will be an opportunity to assess the effective implementation of the critical elements of a safety oversight system and the status of Ghana's implementation of safety-related ICAO Standards and Recommended Practices (SARPs), associated procedures, guidance material and safety-related practices. It will also be intuitive to use it for meeting the requirements of the FAA IASA category 1.

The IASA re-categorization to 1 for Ghana will provide choice for travelers on the Ghana-US route, enhance competition among the existing carriers while potentially improving services and reducing fares. It is also a national pride for Ghanaians to travel to and from the US in their own national carrier. Finally, it will enable full utilization of Ghanaian aviation human resources such as pilots, cabin crew and maintenance personnel to work on our own aviation assets while also benefitting from the economic gains of a national carrier that is not inhibited on any direct city-pair routes to the US or code-sharing with US carriers.

Okatakyie Kwasi Adjekum, Ph.D., CSP
Assistant Professor of Aviation and Aerospace Sciences

John D. Odegard School of Aerospace Sciences, University of North Dakota. USA

[email protected] (Views expressed are solely mine and does not represent UND)

Works Cited:
FAA (2018) - https://www.faa.gov/about/initiatives/iasa/media/FAA_Initiatives_IASA.pdf

Graphic.com.gh (2018)- https://www.graphic.com.gh/business/business-news/ghana-news-ghana-partners-ethiopian-airlines-to-fly-national-carrier.html

ICAO USOAP Link (Skybrary: Retrieved 09 January 2019) - https://www.skybrary.aero/index.php/ICAO_Universal_Safety_Oversight_Audit_ProgrammeUs

US Department of Transportation (Data retrieved on 9 January 2019) – Transprotation.gov https://data.transportation.gov/Aviation/International_Report_Passengers/xgub-n9bw

Zhang & Lee (2018) - https://www.businessinsider.com/countries-airlines-not-allowed-to-fly-into-the-us-faa-2018-11