I wonder when the required exemptions from Part 175 were/will be issued. Remember, the dilemma for Airservices was created by this:
175.140 AIS providers—aerodromes not covered by Part 139—removal of references in AIP
(1) This regulation applies if an AIS provider becomes aware of an aeronautical data originator:
(a) who is responsible for aeronautical data or aeronautical information about an aerodrome that is not:
(i) a certified aerodrome; or
(ii) a registered aerodrome; or
(iii) an aerodrome to which Subpart 139.D applies; and
(b) who has not complied with Subpart 175.D in relation to the aerodrome.
(2) The provider must remove any references to the aerodrome that the provider has published in the AIP from the AIP when the AIP is next amended.
Remember also that Part 175 still has these effects, absent exemptions:
An aerodrome operator must appoint a single senior manager within its organisation as the AIP responsible person for the organisation. If it does not, it commits a criminal offence carrying a penalty of 50 penalty units.
If the person the organisation appoints does not have knowledge and competence to carry out the responsibilities of an AIP responsible person, the organisation commits a criminal offence carrying a penalty of 50 penalty units.
Equivalent requirements and offences apply to the organisation’s NOTAM authorised person, if it has one.
The organisation must provide Airservices with the name of the AIP responsible person (and the organisation’s NOTAM authorised person, if it has one) and notify Airservices of any changes. If the organisation does not do so, it commits a strict liability criminal offence carrying a penalty of 50 penalty units.
The organisation commits a criminal offence carrying a penalty of 50 penalty units if it does not notify Airservices of the need to change aeronautical information, as soon as practicable after the organisation becomes aware of the need.
The data or information the organisation provides must be in accordance with specifications Airservices gives the organisation, or the organisation commits a strict liability criminal offence carrying a penalty of 50 penalty units.
Here are some other examples of ‘safety’ rules in action:
An organisation provides information and the information is published in the AIP. 367 days later the organisation has yet to do a review of that information. The organisation is a criminal, even if the published information remains complete and accurate in fact.
An organisation provides information and the information is published in the AIP. During the following year the organisation does a review of that information, but does not record the fact that the review happened, or its results. The organisation is a criminal, even if the published information remains complete and accurate in fact.
An organisation provides information and the information is published in the AIP. During the following year the organisation does a review of that information, and makes and keeps a record of the fact that the review happened and its results. During the second year the organisation does a second review and makes and keeps a record of the fact that the second review happened and its results, but throws the record of the first review in the bin. The organisation is a criminal, even if the published information remains complete and accurate in fact.
Neither Airservices nor aerodrome data originators have any choice in this, absent exemptions from Part 175.