The civil aviation industry in India has witnessed tremendous growth over the years. With the growing air traffic in the passenger, freight, and air movements segments, India is touted to become one of the largest domestic civil aviation markets in the world in the coming years. In a bid to increase regional connectivity as well as Indian citizens’ access to aviation services, the government of India launched the UDAN (Ude Desh ka Aam Naagrik) Scheme in 2016.
Under the aegis of the UDAN Scheme, Chitrakoot, a city located in one of India’s most backward regions, is all set to inaugurate the very first airport in the region. This airport aims to promote accessibility and religious tourism in the region. The airport at Chitrakoot is going to be a tabletop airport. While this is a huge and impressive feat for the government at the State and the Centre, tabletop airports have often been in the spotlight for the wrong reasons. This write-up aims to shed light on multiple issues surrounding tabletop airports in the country and suggest measures to improve safety at such airports. Part I of this blog post aims to give a background on tabletop airports and the dangers associated therewith. Part II assesses concerns regarding their legality and infrastructure, and Part III enumerates and suggests measures to mitigate the risks involved in operating airplanes to and from such airports.
Part I – An Introduction to Tabletop Airports
What are Tabletop Airports?
Atabletop airport, much like its name suggests, is an airport wherein the runway is shaped like a flat, table-like surface. At both ends of the runway, there is a drop that can extend to hundreds of feet. A tabletop runway is often constructed by excavating peaks of hills to create a tabletop-like structure. Since such runways have deep slopes at both or either ends, the probability of injury and fatality is increased manifold.
Not all tabletop airports, however, are built on mountains or plateaus; some are also built on islands.
Examples of such airports in India are – the Calicut International Airport in Kerala (also known as the Kozhikode Airport); the Lengpui Airport in Mizoram; the Mangalore International Airport in Bangalore; the Pakyong Airport in Sikkim, and the Shimla Airport in Himachal Pradesh.
For a country like India, which has a diverse terrain, such tabletop airports play a vital role in increasing connectivity and accessibility. However, over the years, these airports have made the headlines for being associated with some of the deadliest aviation accidents in India involving commercial flights.
Dangers associated with Tabletop Airports
One of the flaws associated with tabletop airports is the design of the runway, the starting and ending, which is extremely dangerous and often fatal. Due to the way the runway lines up with the horizon and the edge of the mountain peak or plateau, an optical illusion hiding the drop is created, making it extremely difficult for the pilot to navigate the landing or take-off of the aircraft. This situation is even more alarming during low-visibility conditions created by fog, heavy rainfall, or low-lying clouds, making it difficult for the pilot to gauge the depth perception.
The margin for error is very small, making it immensely tough for even the most skilled pilots to land or take off flights to and from such airports.
A Series of Unfortunate Accidents
Most plane crashes are said to be caused by human error or technical glitches; however, tabletop airports, due to the very nature of their design, add an extra layer of complication. Such airports have been surrounded with reports of several mishaps, some attributed to the inherently dangerous design of the runway, while others are attributed to the negligence of the pilots. On August 07, 2020, a Boeing 737-800 airplane operated by Air India Expressmet with an accident due to a runway overrun. The Air India Express flight crashed after overshooting the runway at the Kozhikode airport, killing 18 and severely injuring numerous (hereinafter “the Kozhikode Accident”).
This Kozhikode Accident is not an isolated incident; back in2010, a Boeing 737 aircraft of Air India Express in Mangalore overshot the runway, hit the airport boundary fence, fell into the deep valley, and exploded. Owing to the impact of the crash and the fire caused thereafter, 152 passengers and 6 crew members lost their lives. Only 8 survived the tragic accident (hereinafter the “Mangalore Accident”). The Lengpui Airport in Mizoram also experienced a non-fatal runaway overrun accident in2011.
Tabletop Airports around the World
Nepal has some tabletop airports such as the Manmaya Rai Airport, the Tenzing Hillary Airport, and Kathmandu’s Bagmati Pradesh Tribhuvan International Airport. In the United States of America, there are three tabletop airports, namely the Catalina Airport in California, the Sedona Airport in Arizona, and Charleston’s Yeager Airport in West Virginia. Of these, the Catalina Airport does not allow commercial operation flights since it is privately owned, while the Sedona Airport in Arizona is only used for general aviation purposes by private jets. Tabletop airports located in Nepal and the United States of America have also witnessed numerous accidents owing to the nature of the runways.
Part II – The Legality of Tabletop Airports
TheConvention on International Civil Aviation Organization, 1944, also known as the Chicago Convention (“Chicago Convention”), lays downstandards and procedures related to peaceful global air navigation, the development of international civil aviation in a safe and orderly fashion, the establishment of air transport services on the basis of equality of opportunity, as well as their operation in a sound and economic manner. India ratified the Chicago Convention on March 01, 1947.
Article 37 of the Chicago Convention lays down that the International Civil Aviation Organization (“ICAO”) must adopt and amend international standards and recommended practices and procedures dealing with several aspects to facilitate and improve services related to aircraft, airways, and personnel, including inter alia characteristics related to airports as well as landing areas. Article 44 of the Chicago Convention inter alia states that one of the primary objectives of the ICAO is the promotion of safe and systematic growth of international air navigation, as well as ensuring regular, efficient, and economical air transport. Further, one of the primary objectives of the ICAO, which is enhancing civil aviation safety globally and ensuring passenger safety, is a recurring theme found in the Chicago Convention.
The ICAO has laid down standards for runways inAnnexure 14, titled ‘Aerodrome Design and Operations’ of the Chicago Convention (“Annexure 14”). Arunway end safety area (“RESA”) is a clear graded area at the end of a runway intended to reduce the risk of damage to an aircraft that overruns the runway. An RESA reduces the risk of damage to an airplane undershooting or overrunning the runway. As per Annexure 14, the RESA required to be maintained for runways is at least 90 meters, and for runways having a length of 1200 meters and above, the RESA must be 240 meters. An airport may be compliant with the extant standards provided in Annexure 14 of the Chicago Convention, however, the standards laid therein are minimum standards, and airports located in different states may implement stricter measures to mitigate the numerous risks associated with the use of runways and airports. Similarly, keeping in mind the innately precarious infrastructure of table top airports, the RESA at such airports must be expanded over and above the minimum compliances as stated above.
The National Position
Some of the principal legislations related to regulatory laws in the aviation sector inter alia include:
- TheAircraft Act, 1934 (“Aircraft Act”) and Aircraft Rules, 1937 (“Aircraft Rules”) aim to regulate the manufacture, possession, use, operation, sale, import, and export of an aircraft, as well as provide parameters for determining the airworthiness, the maintenance of aircraft, and the general conditions related to flying and safety, along with registration of the aircraft and conducting investigations.
- TheAirports Authority Act, 1994 (“AAI Act”) establishes the Airports Authority of India (AAI) and lays down its powers.
- Section 4 of the Aircraft Act empowers the Central Government to make rules for implementing the Chicago Convention and any annexures thereto. Further, Rule 29C of the Aircraft Rules authorizes the Directorate General of Civil Aviation (“DGCA”) to prescribe standards and procedures not inconsistent with the Aircraft Act and Aircraft Rules in order to implement the provisions of the Chicago Convention and annexures thereto. Under Rule 133A of the Aircraft Rules, the DGCA may issue inter alia, theCivil Aviation Requirements (“CARs”). The CARs mandate minimum standards related to the operation, use, possession, maintenance, or navigation of an aircraft flying in or over India, or of airplanes registered in India. The CARs also specify procedures to meet the obligations of India as a signatory of the Chicago Convention.
- Aircraft Security Rules, 2011 (“Security Rules”) prescribe criteria related to aircraft and aerodromes in India.
TheMinistry of Civil Aviation (“MoCA”) is responsible for formulating policies and regulating civil aviation in the country. The functions of the MoCA include planning and implementing schemes for the growth and expansion of civil air transport, air traffic services, as well as carriage of goods and passengers by air. The regulatory authorities functioning under the MoCA are as follows:
- TheDirectorate General of Civil Aviation (“DGCA”) is the regulatory body in the field of civil aviation that deals with safety issues related therewith. It regulates air transport services to, from, and within, the territory of India and enforces civil air regulations, along with air safety and airworthiness standards. It also coordinates all regulatory functions with the ICAO.
- TheAirports Authority of India (“AAI”) builds, upgrades, and maintains the infrastructure on the ground and the airspace in India.
- TheAirport Economic Regulatory Authority (“AERA”) aims at determining tariffs for aeronautical services as well as passenger service fees. It further monitors performance standards in relation to the quality, continuity, and reliability of aeronautical services.
- TheBureau of Civil Aviation Security (“BCAS”) ensures that the national and international standards of aviation security are observed in India. It further formulates and implements theNational Civil Aviation Security Programme (“NCASP”), as specified in annexure 17 of the Chicago Convention, in India.
The table below summarizes the functions and powers of the regulatory authorities under the MoCA:
Definitions of Airport and Aerodrome
The Aircraft Act defines an aerodrome as “any definite or limited ground or water area intended to be used, either wholly or in part, for the landing or departure of aircraft, and includes all buildings, sheds, vessels, piers and other structures thereon or appertaining thereto” and the AAI Act defines an airport as “means a landing and taking off area for aircrafts, usually with runways and aircraft maintenance and passenger facilities and includes aerodrome as defined in clause (2) of section 2 of the Aircraft Act, 1934.”
Although an airport and aerodrome are defined in the aforementioned acts, no statute defines a tabletop airport. From the above definition, however, it can be inferred that a tabletop airport, by virtue of being an airport, acts as a landing and takeoff area for flights, and includes runways and other facilities in addition to other relevant structures.
Provisions under the Security Rules
Part II of theSecurity Rules provides for the planning, designing, and layout of aerodromes in India, in accordance with the specifications of NCASP. The Rules inter alia state that aerodromes must comply with requisite architectural and infrastructure requirements provided in the NCASP and further stipulate compliances related to security clearances for aerodromes, security at aerodromes, the provision of lighting, a road for patrolling by security personnel, as well as observation posts for security personnel. Tabletop airports must compulsorily comply with the said mandates as well as introduce airport-specific mandates depending upon the location and weather of the airport. The Security Rules can be further amended to introduce rules for infrastructure at tabletop airports after relevant stakeholder consultation.
Provisions under the CARs
Section 4 of theCARs specifies the requirements for aerodrome infrastructure in India, including taxiways, aprons, markings, aeronautical lighting, emergency services, and maintenance standards in India. Aerodrome operators are required to include the said details of internal actions to ensure the maintenance of and compliance with the specified standards in their aerodromes. Under the said section, the CARs provide that the length of the RESA may be reduced if an ‘arresting system’ is installed as per the designs and specifications of the said arresting system. An arresting system refers to a system designed to decelerate an airplane overrunning the runway, thus reducing the probability of an accident.
It is pertinent to note that neither the Security Rules nor the CARs specify any compliances specific to tabletop airports. However, the appropriate infrastructure and engineering solutions should be implemented in accordance with the Security Rules and CARs. Moreover, ancillary modifications should be initiated at tabletop airports to ensure maximum safety at such airports.
Thus, it can be concluded that if tabletop airports adhere to the said specifications, they cannot be termed to be illegal. An important point that should always be taken into consideration as regards tabletop airports is that there is absolutely no room for error in taking off and landing the aircraft. Rather than relying on the mere skill of the pilot, it is pertinent for such airports to strictly comply with the said specifications and further introduce enhanced safety measures to reduce accidents in the future.
The next part of this write-up delves into some of the safety recommendations concerning the infrastructure at such airports and further provides some measures to reduce accidents and mishaps.
Part III – Mitigating Associated Risks
Aftermath of the Kozhikode and Mangalore Accidents
Following the Mangalore Accident, a court of inquiry was set up by MoCA which recommendeddetailed solutions and safety recommendations to avoid such accidents in the future. Some of the recommendations provided include:
- Avoidance of a downward slope in the overrun area by bringing it to the same level as the runway surface at all tabletop runways.
- Improvement in the maintenance of the RESA at the Mangalore Airport and periodic maintenance of the same by filling it with sand.
- Installation of arresting systems like engineering material arresting system (“EMAS”), especially in tabletop airports. A soft ground arresting (“SGA”) system could be installed instead of EMAS in such airports since it is a cost-effective alternative.
Although the high-level committee investigating the Kozhikode Accident ascribed the accident to the negligence of the pilot, thereport recommended an additional layer of safety to prevent accidents in the future. The recommendations therein include the following:
- Efforts should be taken to extend the runway to a sufficient length to ensure safe operations. In furtherance of this, the State Government may be requested to provide filled-up and levelled land for the RESA within a suitable timeframe. In case the land is not provided within the time frame, the option of reducing the runway at both ends for providing the RESA should be implemented.
- The RESA at the Kozhikode Airport should be filled with 15 cm sand or soft soil for effective deceleration.
The questions revolving around the safety and functionality of such tabletop airports can be addressed in multiple ways. These measures include:
Firstly, the RESA provided in the Chicago Convention is a minimum compliance that must be adopted by airports. Tabletop airports must have a longer thanthe suggested RESA in order to reduce the slope from the end of the runway to the surrounding land.
A sophisticated engineering solution that can be implemented in airports having an inadequate RESA, is the Engineered Material Arresting System (“EMAS”). The EMAS is placed at the end of a runway in the form of a bed that crushes under the weight of an aircraft, thusdecelerating the aircraft and bringing it to a safe stop within the overrun area, causing minimal damage.
However, installing an EMAS is extremely costly and might not be a viable solution. Therefore, instead of the EMAS, an SGA system, which employs soft materials to absorb the kinetic energy of the runway of the aircraft, can be installed. This is a non-destructive and economical solution.
It must be kept in mind that the recommendations provided by the expert committee investigating the Mangalore Accident were not implemented or only implemented partially due tohigh cost involved. Although this solution is difficult to implement in tabletop airports that are currently in operation, new tabletop airports must be constructed with a longer RESA to reduce runway overrun risk. Airports can also adopt certain operational measures to deal with the problems specific to tabletop airports.
Secondly, considering the limitations related to the models of airplanes that can operate efficiently in an airport having such a design, certain restrictions can be placed on the type of airplanes that may be allowed to undertake operations on tabletop airports. For example, bigger airplanes have still not resumed operations from the Kozhikode Airport after theKozhikode crash. Stemming from the above, the number of passengers in the aircraft may also be limited and the flight can take off at a capacityless than the full capacity of the aircraft.
Tabletop airports are not a new phenomenon in a country like India, which has a diverse topography. As stated above, while such airports are not illegal, they must comply with all the requisite safety requirements as provided for in national and international obligations, as well as go a step further to install systems that will enhance the safety parameters. Moreover, it must be ensured that all pilots flying in and out of such airports have the requisite and specialized training to effectively deal with the challenges associated with them. In light of the vision of the government in promoting civil aviation, more resources should be deployed in increasing runway safety by using state-of-the-art technology.
While tabletop airports form a pivotal cog in the wheel in providing accessible infrastructure, they must be constructed with additional safety features, taking into account the inherent risks associated with their structure to make them safer and less accident-prone.
About the Authors
Mr. Avinash Kumar Khard is a Partner at the DSK Legal and has more than 13 years’ experience in representing various stakeholders such as private and public sector companies and undertakings, public sector banks, Governments, private banks, foreign lenders, non-banking finance companies, borrowers, Indian bidders, foreign bidders, financial and multilateral institutions, developers, funds etc. in relation to development, financing, construction, operation and acquisition of capital-intensive projects and facilities around Asia, Middle East and Africa. His experience in projects and project finance include, amongst other things, roads and highways, sea-links, ports, airports, roads, smart cities and other infrastructure assets.
Ms. Sanika Dalvi is a final year student at Government Law College, Mumbai.
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Preferred Method of Citation
Avinash Kumar Khard and Sanika Dalvi, “Assessing Tabletop Airports in India: Challenges and the Way Forward” (IJPIEL, 10 October 2022)