5.2.3. Primary/direct regulatory requirements affecting a visual surveillance system

• ED Decision 2023/005/R found in: GM Remote Aerodrome Air Traffic Services (Jan 2026)

##### 5.2.3. Primary/direct regulatory requirements affecting a visual surveillance system *ED Decision 2023/005/R* Point (b) of AMC1 ATS.TR.205(c) to Regulation (EU) 2017/373 [4] states that: ‘(b) Control of all flight operations on and in the vicinity of an aerodrome, as well as of vehicles and personnel on the manoeuvring area, should be continuously maintained by: (1) visual observation, which can be achieved directly by out-of-the-window observation or through the use of a visual surveillance system; and (2) an ATS surveillance system where available, in accordance with ATS.TR.245.’ In addition, Part III, Section 2, Chapter 2.1.1 a) of ICAO Doc 9426 (ATS Planning Manual) [15] states that ‘the tower must permit the controller to survey those portions of the aerodrome and its vicinity over which he exercises control’*.* At the same time, Chapter 2.1.2 of ICAO Doc 9426 (ATS Planning Manual) [15] states: ‘The most significant factors contributing to adequate visual surveillance are the siting of the tower and the height of the control tower cab. The optimum tower site will normally be as close as possible to the centre of the manoeuvring part of the aerodrome, provided that at the intended height, the tower structure itself does not become an obstruction or hazard to flight.’ and Chapter 2.1.3 states that ‘The height of the tower should be such that the controller is provided with the visual surveillance previously described. The higher the tower, the more easily this optimum surveillance is attained, but at greater financial cost and with a greater likelihood of penetrating the obstacle limitation surfaces.’As these guidelines provided by ICAO Doc 9426 may be valid in the case of a single centrally located camera tower installation at an aerodrome, they may on the other hand not be relevant in the case of a visual surveillance system comprising several camera installations on various locations around the aerodrome. This promotes understanding of the overarching regulatory requirements directly affecting the visual surveillance system and can be formulated as follows: **The** **visual** **surveillance system** — subject to the visibility conditions at the aerodrome and its vicinity as well as the topography of the surrounding terrain and tailored to the ATCO/AFISO roles — **should enable the ATCO/AFISO to survey those portions of the aerodrome and its vicinity over which they exercise ATS and should enable them within their area of responsibility, to see:** — **flight operations (aircraft****[[20]](#_ftn20)****) in the vicinity of the aerodrome****[[21]](#_ftn21)****;** — **flight operations (aircraft****[[22]](#_ftn22)****) on the aerodrome;** — **vehicles and personnel on the manoeuvring area****[[23]](#_ftn23)****.** ***Note:*** *Different tasks performed by ATCO/AFISO (e.g. ground, air, apron management (if applicable)) may affect the area of interest; therefore thorough consideration should be given to the tailoring of the visual presentation in support of each specific task.* The above should be seen as applicable in both daylight and darkness conditions (subject to the hours of operation of the ATS unit); however, during darkness it is acknowledged that it may be difficult to see objects without their own light source. --- [[20]](#_ftnref20) ‘Aircraft’ is defined in Annex I to Regulation (EU) 2017/373 as ‘Any machine that can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the earth’s surface’. [[21]](#_ftnref21) A description of the term ‘aircraft operating in the vicinity of an aerodrome’ is provided with the definition of ‘aerodrome traffic’ included in Regulation (EU) No 923/2012 [4] as ‘includes but is not limited to aircraft entering or leaving an aerodrome traffic circuit’. [[22]](#_ftnref22) ‘Aircraft’ is defined in Annex I to Regulation (EU) 2017/373 as ‘Any machine that can derive support in the atmosphere from the reactions of the air other than the reactions of the air against the earth’s surface’. [[23]](#_ftnref23) The manoeuvring area is defined in Regulation (EU) 923/2012 [6] as ‘that part of an aerodrome to be used for the take-off, landing and taxiing of aircraft, excluding aprons’.