Report of the Provincial Airports Safety Working Group
Table of Contents
1. Introduction
2. Background
3.1 Members
3.2 Meetings
4. Findings
5. Analysis
5.1 Risk Management
5.3 Policy Approach
5.3.2 Setting Priorities
5.3.3 Funding
5.4 Airport Improvement Projects
7. Conclusions
Attachments
1. Introduction
The Minister of Transportation Government Services struck a Working Group in December 1997 to review safety at the twenty-two provincially operated airports. The Working Group was composed of representatives of First Nations, air carriers, Transport Canada, Northern Affairs and Transportation & Government Services. The Working Group Report (Released in Oct. 1998) documented safety-related issues and prioritize improvements that could be considered to enhance the safe operation of provincial airports in northern Manitoba.
2. Background
Manitoba owns and operates twenty-two airports located throughout northern Manitoba (Refer to Attachments 1 & 2). These airports primarily serve First Nations communities and are often the only means of year round transport. As well as supporting economic development, these airports are the vital lifelines for the communities for medical and social services. During the last fifteen years, $15.0 million worth of capital has been expended for facility and equipment maintenance, replacements and upgrades.
Construction and upgrading of the provincial airports over the years has been undertaken through a number of programs. In the late 1960’s and early 1970’s the Province undertook the construction of small airports at many remote communities. These were constructed to accommodate aircraft such as the Twin Otter and Aztec. With the exception of Island Lake and Norway House, the Province provided the funding for these initial capital projects. At these two sites, Transport Canada provided capital funding on a 50:50 basis. Through the Northlands Agreement (1976-1982) and the Northern Development Agreement (1982-1989), the Federal Government contributed 60% for upgrading and construction of new airports. Airports upgraded under these programs included Brochet, Lac Brochet and St. Theresa Point. The last major project under this program was the construction of the Tadoule Lake airport in 1987. In 1990, the Province acquired the God's River airport from the local lodge owner. Manitoba Transportation & Government Services continues to upgrade airports, as funds are available. In fact, the Department has identified over $50.0 million of capital projects to improve both the safety and operation of the provincial airports (see Attachment 3.).
Today the airports serve larger turbo-prop and jet aircraft that offer communities superior air services. These aircraft are now the basis of air carrier fleets; examples include the HS748, the Metro II, the Beech 1900 and the Citation II.
The upgrading of the northern airports is beyond provincial resources. The Province pays the full costs for the operation of these airports with only marginal direct cost recovery. The Province currently spends almost $6 million annually to operate, maintain and improve the twenty-two community airports. The availability of capital funds is limited to major maintenance. The Province of Manitoba simply cannot afford the $50.0 million required to bring the airports up to a higher standard. Federal financial involvement is required. Federal funding is justified by:
- the federal obligations to First Nations peoples;
- the history of federal/provincial involvement in northern airport development; and
- the air mode falls within the federal government’s jurisdiction.
3. Working Group
3.1 Working Group Members
Membership on the Working Group consists of the following:
- John R. Hosang (Chairman) Manitoba Transportation & Government Services
- Chief Raymond Keeper Little Grand Rapids First Nation
- Chief Jerry Knott Wasagamack First Nation
- Chief Gladys Powderhorn Sayisi Dene
- Chief Ken Wood St. Theresa Point First Nation
- Allan Nimmo Perimeter Aviation
- Lynn Peters Skyward Aviation
- Ron Lapp Transport Canada
- Yvan Bineau Transport Canada
- Rick Kosmick Manitoba Northern Affairs
- Roland Savoie Manitoba Transportation & Government Services
- David O. Selby Manitoba Transportation & Government Services
3.2 Working Group Meetings
The Working Group has had four meetings. These took place on February 17, March 16, May 26 & 27, as well as August 20,1998. The May meeting was held in Thompson to facilitate attendance by northern representatives. In response to a request by the SouthEast Resource Development Corporation, the Working Group traveled to Little Grand Rapids in August to discuss their concerns. The Working Group also used the opportunity to review the draft report.
The Working Group reviewed submissions (Appendix A) that were given during the December 17, 1997 meeting with the Minister of Transportation & Government Services. At the meeting in Thompson on May 26 and 27, 1998, the Working Group also received submissions to identify needs and issues. Grand Chief Francis Flett presented on behalf of the 26 First Nations making up the Manitoba Keewatinowi Okimakanak (MKO). As well, eight additional presentations were made. The letters and briefs are included at Appendix B. At the Little Grand Rapids meeting on August 20, 1998, a submission (Appendix C) was presented to the Working Group by South East Resource Development Corporation.
4. Findings
In general, the projects the Department had previously identified (see attachment 3)addressed many of the needs noted by the northern communities and air carriers during this review.
The areas of consensus about needs included:
- the addition of lighted beacons (or strobes) and approach slope indicators;
- the extension of runways to both improve safety and to minimize operating restrictions for the aircraft now using these airports
- the need for the new airport between Wasagamack and St. Theresa Point
- new airport locations for Poplar River and Little Grand Rapids and the reconstruction of Gods River, together with runway lights and Non Directional Beacons (NDBs) for Gods River and Poplar River. There are additional remote communities that have no airport at all such as Granville Lake and Pauingassi.
The one exception is at York Landing where the Chief felt that the current airstrip is too close to the settlement. The balance of the Working Group did not see the location as a safety issue.
The issue of runway surface type received conflicting views. Several community presentations called for paved runways while some air carriers indicated that gravel surfaced runways, when well maintained, provide better traction in wet or icy conditions.
Several non-airside facility issues were identified to the Working Group. While some of these have a safety component, they are not primarily for air safety. Such projects included terminals, fire halls, fencing, fuel tanks, water and sewer and electric heating. These projects are important and should be factored into an overall airport improvement program.
The Working Group considered the following issues related to operating concerns:
- Instrument Approaches - Global Positioning System (GPS) technology now makes it feasible to develop instrument approaches. The Department will follow-up with NAV Canada as a result of this Working Group’s Report to identify the priorities for the Provincial airports. Depending on the eventual acceptance of GPS, this may improve existing instrument approach capabilities
- Radar Coverage – discussions will take place with NAV Canada regarding radar with a view to improving advisory services
- Weather Information – feasibility of enhancing weather services should be investigated
- Co-ordinated Emergency Response Services - these are already provided but may not be fully understood or appreciated
The Department is continuing work with the appropriate agencies such as NAV Canada, Atmospheric Environment Services (AES), Manitoba Emergency Management Organization (MEMO) and Air Carriers to improve services in these areas.
5. Analysis
5.1 Risk Management
There is no such thing as a guarantee of safety. In aviation, as well as other modes of transport and indeed, all fields of endeavour, the objective is to recognize the risk, assess its impacts, and take all reasonable actions to minimize the risk. Transport Canada determines whether an airport is safe or not by inspecting it to see if it meets standards associated with becoming certified, such as depicted in attachment 4. However, certification is also relative to use. One airport may be certified for "air taxi" operation under daytime and visual flight rules weather conditions. Such an airport is considered "safe" as long as those conditions are respected. It may not be certified as "safe" for night-time operation for use by commuter carriers, unless it can meet the additional standards required for night-time operations. Safety is closely related to the idea of reliability. Under marginal weather conditions, the cancelled flight, is the safest, but the availability of an instrument approach improves reliability and accessibility while respecting the higher safety standards for such operations. Risk is also cumulative. An airport with the same risk factors but with a greater volume of traffic has a greater overall risk that needs to be reflected in setting priorities.
The risk assessment and minimization approach is widely recognized. It is the approach underlying NAV CANADA’s Aeronautical Studies in reviewing Air Navigation facilities and services. It may not be possible to guarantee safety, but risk can be calculated. Prudent investments can then be made to reduce risk as much as possible given the technological and fiscal constraints.
5.2 Technical Standards
A.) Under the Canadian Air Regulations (CARs), Transport Canada sets the standards for the certification of airports. When designing an airport, the "critical aeroplane" for that airport, must be identified. The critical aeroplane, is the aeroplane identified from all those serving, or to serve the airport in question, that has the most demanding operational requirements. Based on the critical aeroplane, the runway length is identified. Finally, the standard requirements (runway width, markings, lighting etc.) are applied to the runway.
Runway length is not necessarily a safety-related issue, but rather a level of service issue. For instance, with the disappearance of the older aircraft for which airports were designed, higher performance aeroplanes can still use the present airports. Because some of these runways are relatively short, the operations are often with penalties. An air carrier may have to operate with less freight and/or passengers, or with less fuel. Each of these options penalizes all involved, by higher costs or shorter routes, therefore, reduced service. So the runway length does not impact safety, but rather the level of service that can be provided by the air carriers. To mitigate this situation, the extension of some runways should be considered.
B.) The CARs also govern air carrier operations. New restrictions that are presently being implemented will, by the year 2010, restrict operations of certain aeroplanes utilizing present day airports. Aeroplanes are classified by the number of passengers they carry: an "air taxi" has nine or less passengers, a "commuter" has between 10 and 19, while an "airline" has 20 or more. By the year 2010, the new CARs will require some aeroplanes to be operated using performance criteria not used today. For many of the smaller category of aircraft, the runway length at most airports may be insufficient to operate these aircraft at full capacity, even if that is not the case today. Air carriers will either have to modify their operations, or some runways will have to be lengthened.
Planning the physical characteristics of these airports is becoming an increasingly difficult challenge because of the nature of the standards and the regulatory changes. These issues are often not necessarily working together. To this problem can be added the uncertainty of the next generation aircraft.
Determining the runway length is a demanding challenge for an airport operator. But, also equally affected, is the airline operator who has to select the appropriate aeroplane that will be capable of, not only servicing his customers effectively, but also be efficient using the airports that will be available.
5.3 Policy Approach
Provincial policy can be developed as the framework for setting development objectives for community airports. Facility deficiencies can then be identified and projects can be defined to overcome these deficiencies. There are three aspects to be considered in developing a Provincial Airports Policy. The first is the Level of Service that is to be provided, in other words, what is the service objective to be achieved. This aspect of the policy can be used to identify potential airport improvement projects. Secondly, the policy should provide guidance in how priorities are to be established amongst the identified projects. Finally, the policy sets out the funding responsibilities amongst the stakeholders.
5.3.1 Level of Service
The Working Group proposes to use a level of service policy approach to identify potential projects.
The proposed levels of service policy objectives are:
- all airports should be certified for both day and night conditions and for both Visual Flight Rules (VFR) and Instrument Flight Rules (IFR) operations in support of emergency medical evacuations
- all airports should serve the aircraft currently being operated on a regular basis with minimum practical operating restrictions
- non-airside airport development will be undertaken to meet safety, environmental, efficiency and economic objectives
- airports should be planned and developed to accommodate more demanding aircraft requirements as they become justified
These policy objective guidelines were combined with the CARs standards to identify potential airport improvement projects.
There is one additional level of service objective that is not dealt with by these guidelines, because they only deal with the development of the current airports system. That is the case of determining when an airport should be provided for a community when no airport currently exists. The new Wasagamack/St. Theresa Point airport is being located to better serve the two communities. The Granville Lake and Pauingassi communities have no airport and receive only float and ski equipped aircraft. It may be necessary to include a population criterion as a factor in our deliberation when examining the requirements for the provision of new airports or for other airport requirements.
5.3.2 Setting Priorities
Competing projects serving the same level of service policy objective can be prioritized by cost-benefit analysis. Attachment 5 includes an estimate of annual economic impact benefit from the 1997 traffic volumes. As an illustration of the approach, the final column considers the benefit-cost ratio for objective one projects. The runway extension and lights at Berens River has a ratio of 3.75:1 versus a ratio of 10.01:1 for the NDB at Bloodvein. Another example in Attachment 5 shows that, after the installation of the airport rotating beacon lights which have a benefit-cost ratio of 86.21:1, the Precision Approach Path Indicators (PAPIs) and emergency power units for all sites would have the highest priority with benefits exceeding costs by a ratio of 16.73:1. More detailed analysis will include data on community population, use of Medevacs, site weather records etc, to establish the priority of the potential projects within the funding available each year. The Economic Impact Benefits as listed in Attachment 5, is calculated by establishing a relative value for each site. In this case, it is equal to dividing the total of 100 multiplied by the passenger traffic, plus 1000 multiplied by the freight traffic, by 1000. This value is then utilized to establish a relative Cost-Benefit Ratio. It is equal to the estimated cost of Policy Objective One, divided by the Economic Impact Benefit.
5.3.3 Funding
Provision of airports involves operating costs and capital costs. The Province already covers operating costs and minor maintenance capital projects such as stock piling gravel. Federal funding is required for the major capital projects. The federal Airports Capital Assistance Program (ACAP) provides funding for airport improvement projects which meet specific criteria. ACAP funds 100% of airside facility and equipment capital projects for airports with less than 50,000 passenger movements per year. This would relate to the level of service objectives to meet the needs for air ambulance service and for the safe operation of aircraft now using the airport. ACAP also funds 50% of projects for asset protection or operating improvement, for air terminal buildings and groundside access. Many of the "level of service objective three" projects would fall in this category.
ACAP is only intended for existing airports that currently receive passenger service. It has not been determined whether relocating airports would qualify within the ACAP framework. ACAP would not apply to communities where there is no existing airport. The current Provincial Government/Indian and Northern Affairs Canada cost sharing agreement in place for the roads and airport to serve Wasagamack and St. Theresa, may serve as a model in these cases.
Another issue could be with the ACAP funding envelope, which is currently limited to $35.0 million a year for all of Canada. ACAP was intended as a fund for major capital projects at existing airports. It did not contemplate a major upgrading program of a whole system of airports, such as has been identified by the Working Group on Safety. While ACAP could provide a framework for administration of federal contributions, it may be necessary to negotiate a federal-provincial upgrading program that would provide additional funding over and above the regular ACAP funding envelope.
5.4 Airport Improvement Projects
Level of Service Objective One
The first policy objective includes several dimensions: certification, night operation, IFR operation, and runway requirements for the critical aircraft that provides medical evacuation service.
Certification: Fundamentally, safety requires that an airport must meet the standards of the regulator, Transport Canada, to be certified. Three of the provincial airports are not yet certified because they do not meet dimension standards. Pukatawagan is in the process of being certified; Gods River requires strip widening and the possible relocation of the MTS communications tower; Poplar River cannot be certified in its current location because it cannot meet Transport Canada Standards.
Night Operation: An airport certified for day VFR operations must meet additional standards to be certified for night operation. A lighted beacon (rotating or strobe type) is one of the requirements for night certification. The Province is working with Transport Canada to prepare an omnibus ACAP application for the provision of beacons at all eligible airports. Transport Canada TP312 (Standards and Recommended Practices), Clause 5.3.6 states that a visual approach slope indicator (such as a PAPI) should be provided if the pilot of any type of aircraft may have difficulty in judging the approach due to:
- inadequate visual guidance such as is experienced during an approach over water or featureless terrain by day or in the absence of sufficient extraneous lights in the approach area by night ….
Since power outages tend to coincide with other emergencies, Emergency power is required at all sites to support this objective.
IFR Operation: Only three airports have published approaches for IFR operations; Island Lake, Norway House and St. Theresa Point. A further fourteen airports have NDBs. Air carriers regularly using these airports have "company approved" approaches for IFR operation. Five airports do not have an electronic navigational aid on which to develop an instrument approach. Airport instrument approaches are now being developed based on GPS instead of ground based aids. Depending on the eventual acceptance of GPS, the priority for development of GPS approaches would be: those without an IFR approach, those with non-published approaches, then those with a current published approach. Current NDBs would be maintained to the end of their useful lives to provide back-up and redundancy to GPS approaches.
Runway Length: Sufficient runway length is needed to accommodate the type of aircraft used as the air ambulance. The critical aircraft would usually be the Manitoba Air Services Citation II which requires 3000 ft. Several airports are less than 3000 ft. They include Berens River, Little Grand Rapids, Pikwitonei, Poplar River, Pukatawagan, South Indian Lake, Thicket Portage and York Landing.
Attachment 5 details the airport deficiencies to meet the first level of service objective and other needs to provide a good surface of sufficient length equipped for night and IFR operation. For preliminary costing purposes, the subsequent analysis assumes that most airports will be extended to at least 3000 ft and assumes an average unit cost of $1000 per lineal foot to extend runways. More detailed analysis will be required to determine the precise runway length to be provided at each site to meet the air ambulance policy objective.
Objective One Conclusion:
The estimated cost to meet the first level of service policy objective, to provide each community a certified airport for the operation of air ambulance, is $25.2 million. This includes four new airports (Little Grand Rapids, Poplar River, Pauingassi and Granville Lake), at an estimated cost of $5 million each.
Level of Service Objective Two
The second level of service policy objective provides facilities to safely accommodate the aircraft currently using the airport with minimal restrictions on passengers and freight. This objective will require detailed site by site analyses. Attachment 5 shows the type of aircraft currently associated with the type of operation (air taxi, commuter, and airline) at each airport. To provide the basis for cost estimates, the following dimensions are assumed as being required to provide airports to serve these aircraft on a regular basis with minimum practical operating restrictions:
- for airports certified for air taxi operations, a runway of 3000 ft x 75 ft
- for airports certified for commuter operations, a runway of 3500 ft x 75 ft
- for airports certified for airline operations, a runway of 4000 ft x 100 ft
Objective 2 Conclusion
Attachment 5 indicates that, after providing runway extensions or new runways to meet the first objective, there will be a further 11 airports requiring extensions to bring them to 3500 ft., and three to 4000 ft. This is in addition to the new airport for Wasagamack/St. Theresa Point. The incremental cost to satisfy the second level of service objective is estimated at $6.1 million.
Level of Service Objective Three
The third level of service policy objective covers the non-airside projects. The projects identified to date (as listed in Attachment 6), include $1.7 million for five terminal developments and $2.6 million for other projects (fencing, fire halls, water & sewer, fuel tanks and electric heating conversions), a total of $4.4 million for objective three projects.
Level of Service Objective Four
After substantial completion of Level of Service Objectives One and Two, consideration should be given to enhancing runway lengths to accommodate aircraft without operating restrictions. Increased requirements will also be necessary in part, to meet the more restrictive Canadian Air Regulations requirements at the Year 2010. The following dimensions are assumed as being required to provide airports to serve the aircraft currently being operated on a regular basis without operating restrictions:
- for airports certified for air taxi operations, a runway of 3000 ft x 75 ft
- for airports certified for commuter operations, a runway of 4000 ft x 100 ft
- for airports crtified for airline operations, a runway of 4500 ft x 100 ft
An airport that is currently accommodating commuter operations and has a project identified to extend its runway to 3500 ft, should have the project planned so that, if it is justified, the runway could be extended to 4000 ft without major modifications. Longer and possibly wider runways may be justified by unique needs, such as developing an operating base for the CL 215 water bombers. It is noted that because of the extension of some runways beyond the 4000-foot limit available for Code 2 runways, side and/or end zoning may become an issue for review at some sites such as Oxford House and God's Lake Narrows. At Oxford House for example, because of the more stringent zoning requirements, if it becomes a Code 3 runway, it may be necessary to move the terminal and equipment shop further away from the runway.
Factors to be considered in defining project requirements within this objective include:
- Community/Population projections
- Aircraft requirements
- Canadian Air Regulation implications. The estimated cost of meeting the portion of this objective for providing unrestricted aircraft operations is $8.2 million
5.5 Airport Operations
Several submissions made suggestions concerning operations which included improved weather information, airport traffic advisory service and co-ordination of emergency response plans. With suitable training, (similar to the Community Aerodrome Radio Station observer-communicator training program given at Fort Smith, in addition to the existing airport maintenance and equipment operation), airport staff may be able to provide additional weather reporting and airport advisory service; many of the more experienced airport staff already do some of this on an unofficial basis.
Emergency plans are already established for all sites as part of the airport certification. Aircraft fire fighting equipment is also provided at all certified sites and emergency drills are held each year. They planned so as to incorporate all the community resources. Further co-ordination will be undertaken to ensure the local communities are aware of, and involved in, airport emergency planning.
6. Recommendations
The Working Group recommends that:
- the four levels of service policy objectives be adopted as the framework for developing the Provincial airports system; (the preliminary list of projects, by priority, is given in Attachment: Preliminary List of Projects by Priority
- the Department should immediately undertake further analysis for the definition of projects and their priority to overcome the identified deficiencies in the airports system
- the ACAP application for Beacon Lights at all eligible sites should be fast-tracked (the application is currently in final draft at a total estimated cost of $363,000)
- Manitoba Transportation & Government Services prepare the supporting ACAP applications for the highest priority projects
- the Province should initiate a federal-provincial consultation for the negotiation of a cost-sharing agreement for the upgrading of the Provincial airports system as a multi-year program with funding over and above the ACAP envelope, particularly for the new airports
- an Advisory Committee of affected stakeholders should be established to support the Department in development and administration of the Provincial Airports Development Program on an on-going basis. The Advisory Committee work would include reviewing and advising the Department on the detailed project prioritization, within the framework of the four levels of service policy objectives
- the Department should initiate consultations with NAV Canada to set out the priorities and a schedule of development for GPS approaches at the airports
- the Department should look into the feasibility and means to further enhance the services provided in support of aviation, in particular, weather reporting and airport advisory service; a report should be provided to the Advisory Committee within six months
- the Advisory Committee will consult with Transport Canada, regarding regulatory changes that may impact on Airport and Airline operations
7. Conclusion
Manitoba Transportation & Government Services strives to operate the Provincial airports as safely as is possible. However, due to advances in aircraft technology, concurrent with public sector fiscal constraint, the facilities as they exist today at some of the provincial airports are less than desirable to support safe and efficient air transport services in the late 1990s. This Report has developed an approach to identify and prioritize the needs to develop a modern and capable airports system in support of the health and development of Manitoba’s remote communities. The upgrading of the airports system will require the participation and partnership of the federal and provincial governments, together with the communities and the aviation industry.
Attachment: Department Capital Program
The Department has identified more than $50.0 million of capital projects. These include:
- $40.0 million for new construction, including the funds already identified for the new airport and roads between Wasagamack and St. Theresa Point (replacing that airport), two runway relocations, (Little Grand Rapids and Poplar River), one airport reconstruction, (God's River) and two new airports (Pauingassi and Grandville Lake)
- $2.8 million for runway extensions at eight sites, ( Red Sucker Lake, Berens River, Oxford House, Cross Lake, South Indian Lake, God's Lake Narrows, Pikwitonei, and Thicket Portage);
- $800,000 for gravel crushing at four sites, (God's River, Oxford House, Pikwitonei and Thicket Portage)
- $165,000 for runway lights at four sites, (God’s River, Berens River, Cross Lake and Little Grand Rapids)
- $363,000 for rotating or strobe beacons at all 22 sites
- $1.1 million for abbreviated PAPIs (Precision Approach Path Indicators) at all 22 sites
- $770,000 for emergency power units at all 22 sites
- $1.7 million for terminals at five sites (Island Lake, Lac Brochet, God's River, Oxford House and Thicket Portage)
- and a further $2.5 million for fire halls, fencing, water and sewage, fuel tanks, electric heating conversion and other upgrades
Attachment: Preliminary List of Projects by Priority
Objective One: to provide a certified airport for day and night, and for VFR or IFR operations in support of medical evacuations.
- Beacon Lights: all airports ($363,000)
- Certification: Pukatawagan, Gods River
- Runway Edge Lights: Gods River ($45,000)
- IFR Approaches: consult with NAV Canada to develop GPS approaches for all airports (non-capital)
- Approach Lights and Emergency power: all airports ($770,000)
- Runway Extensions: six sites require extensions to meet 3000 ft length ($2.4 M)
- Construct four new airports: Poplar River, Little Grand Rapids, Pauingassi and Granville Lake ($20.0 M)
Objective Two: to provide an airport system to support aircraft currently being operated so as to minimize operating restrictions.
- Runway Extensions: 14 sites (in addition to the three new airports) may require further runway extensions to accommodate air commuter or airline operations standards, ($6.1 M).
Objective Three: non-airside development to meet safety, environmental, efficiency and economic objectives. This includes:
- Terminals at five sites: Island Lake, Lac Brochet, God's River, Oxford House and Thicket Portage, ($1.7 M)
- Fire halls at three sites: God's River, Pukatawagan and Red Sucker Lake, ($180,000)
- Water & Sewer at six sites: Island Lake, Lac Brochet, Pikwitonei, Red Sucker Lake, South Indian Lake and Thicket Portage, ($180,000)
- Fencing at 19 sites, ($1.46 M)
- Enviro Fuel Tanks at 16 sites, ($324,000)
- Electric Heating Conversions at six sites, ($155,000)
- Runway Lights Upgrade at three sites, Berens River, Cross Lake and Little Grand Rapids, ($120,000)
- Equipment Shop at God's Lake Narrows, ($85,000)
- Equipment Shop Upgrade at Island Lake, ($130,000).
Objective Four: to develop airports to meet higher-level certification standards as needs or regulatory changes require. The estimated cost of meeting the portion of this objective for providing unrestricted aircraft operations is $8.2 Million.
