RESPONSE to Safety Recommendation:
Hellenic Civil Aviation Authority (HCAA) response to AAIASB Safety Recommendation (SR) 2021-01 was received by email on 29/7/2021.
[HCAA response to AAIASB SR 2021-01]:
“Our Directorate [HCAA Airports Directorate - Department of Airports Fire Safety and Equipment] has issued the Regulation on the aircraft refuelling at airports (Government Gazette, Series B, No 1109/2011), which, in Chapter 19, refers to the refuelling of light and ultra-light aircraft at airports, where aeroclubs, air schools, etc. operate and the necessary type of fuel is not available by the airport fuel companies for this type of aircraft, for their self-handling only. This chapter regulates fuel handling (19.2), storage (19.3), measures to protect fuel storage areas (19.4), and the process of aircraft refuelling (19.5).
Item 19.5, which regulates the refuelling of these aircraft, includes details on the person who will refuel, as well as its training (19.5.1), the use of suitable anti-explosive pumps and special filters to ensure the quality of the transferred fuel, such as filters for water retention and microparticles, which may be contained in the transfused fuel (19.5.2 & 19.5.3). It is also envisaged that these aircraft will be refuelled with specially certified fuel tanks (19.5.3).
Regarding the type of fuel required for the aircraft engine(s) and the quantity required to perform the flight, the pilot or owner of the aircraft shall be solely responsible (19.5.5). As regards the quality of the fuel, if supplied by the pilot or the owner of the aircraft, he is responsible (19.6.3). Otherwise, it is the refueller who is responsible (19.6.1 & 19.6.2).
In Chapter 19, reference is also made to the use of MOGAS fuel specifications ASTM D 4814/EN 228, where in addition to the above, those referred in Decision No Δ2/Ν8337/2475/9-3-2005 of the Governor of HCAA apply. At this point, it should be clarified that, in practice, MOGAS has been identified with unleaded car petrol, which is sold by petrol stations [outside of airports] and is used by all light and ultra-light aircraft permitted by their engines, and its use has been consolidated in many aircraft and helicopters operating in LGMG airport [main general aviation airport near Athens]. It should be noted that the provisions of Chapter 19 allow refuelling of petrol from a fuel service station [outside of airports] only for ultra-light aircraft (19.10.1), which can be checked at airports, unlike in landing fields, where there is no control at all, i.e. not only on the type of fuel but also on its transport (e.g. type of container) and the refuelling process.
It must therefore be concluded that the current regulatory framework, at least regarding refuelling at airports, is capable, if accurately applied, of ensuring the quality of the transferred fuel on the aircraft in question. At the same time, there should be clarification in relation to MOGAS in order to address the practical problems arising from the use of unleaded petrol.
In view of the above and in the context of the safety recommendation 2021-01, the Directorate [HCAA Airports Directorate - Department of Airports Fire Safety and Equipment] will intensify the inspections to ensure that the provisions of the Regulation on the refuelling of aircraft (Government Gazette, Series B, No 1109/2011) are strictly complied with at airports and landing areas”
[AAIASB assessed this response as “Adequate” on 23/9/2021 (Board meeting) and changed the SR 2021-01 status to “Closed”]