When “All the Lights Are On” Isn’t Enough: Why Photometric Testing Is a Governance Issue for Airport Executives
Guest Feature written by Bulent Ulas, Airport Services Manager at Arc & Spark Electric
Airfield lighting is a fundamental safety system at airports. Runway, taxiway, approach lights, and PAPIs are relied upon by pilots precisely when margins are lowest, at night, and in reduced visibility.
Yet in many Canadian airports, lighting performance is still judged largely by visual checks. If lights appear illuminated during inspections, they are often assumed to be compliant. That assumption creates a hidden and unnecessary risk.
Photometric testing, which objectively measures light intensity, beam alignment, and colour, is the only way to confirm that airfield lights meet TP312 standards. Whether or not Transport Canada has recently requested a test does not change the airport’s responsibility, or its liability, if those lights are later found to be non-compliant.
This is not an operational nuance. It is a governance issue.
Executive Accountability Does Not Stop at Delegation
Day-to-day responsibility for airfield lighting is usually assigned to operations or maintenance teams. However, under Canada’s regulatory and legal framework, accountability for compliance ultimately rests with the airport’s executive leadership.
TP312 defines when a light is considered unserviceable based on photometric performance, not on whether it appears illuminated. Advisory Circulars further identify photometric measurement as the practical way to verify that performance.
From a governance perspective, the critical question is not “Has Transport Canada asked us to do photometric testing?”
The real question is “Can we prove our lights were compliant if something happens?”
If the answer is no, or uncertain, the organization is exposed.
The Liability Gap
When lighting performance is assumed rather than measured, a liability gap forms quietly in the background. It only becomes visible after an incident.
If a runway excursion, unstable approach, or visibility-related event occurs, investigators and insurers will examine the condition of the visual aids. In that moment, visual inspections and good intentions carry little weight. What matters is evidence.
Without photometric test data, an airport may be unable to demonstrate that:
Light intensity met TP312 thresholds
Beam alignment was correct
Colour performance was within limits
That gap exposes the airport on multiple fronts:
Regulatory risk. Difficulty demonstrating compliance during post-incident scrutiny or surveillance.
Insurance risk. Increased exposure during claims, potential coverage challenges, or higher premiums.
Legal risk. A weaker defensive position if litigation follows.
Reputational risk. Public and stakeholder confidence erodes quickly when safety systems are questioned.
None of these risks depends on whether Transport Canada explicitly requested a test in advance. Liability exists regardless.
Photometric Testing Is Not a Capital Project
One of the most common misconceptions at the executive level is that photometric testing requires significant capital investment. It does not.
Airports do not need to purchase C$100,000+ testing equipment to meet their obligations. Photometric testing can be procured as a service, just like pavement inspections, wildlife studies, or electrical testing.
This removes cost as a barrier and reframes photometric testing as a risk-management tool rather than a budget burden.
Better Data Leads to Better Financial Decisions
Beyond compliance and liability, photometric testing provides a highly valued benefit: clarity.
Objective lighting data allows leadership to:
Understand the true condition of their lighting systems
Separate minor degradation from systemic failure
Avoid premature capital replacement based on assumptions
In one recent Canadian airport assessment, photometric testing revealed that while a few fixtures required attention, overall system performance was strong. As a result, the airport deferred a planned lighting system replacement and redirected capital to higher-priority needs.
Without data, that decision would have been guesswork. With data, it became defensible.
Photometric testing turns lighting from an unknown risk into a managed asset.
Questions Every Airport Executive Should Be Able to Answer
Executive oversight does not require technical expertise, but it does require visibility. Leaders should be able to answer:
When was our last photometric test?
Can we demonstrate compliance with TP312 today?
Do we have objective data, or are we relying on visual inspections?
If an incident occurred tomorrow, could we defend our lighting performance?
If any of these questions raises uncertainty, that uncertainty itself is the signal to act.
The Executive Imperative
Photometric testing is not about anticipating enforcement. It is about managing regulatory, financial, and legal exposure before an incident forces the issue.
Airport executives are accountable not only for what their organizations do, but for what they can prove. In airfield lighting, proof comes from measurement.
The cost of testing is modest.
The cost of assumption is not.
Leadership that treats photometric testing as a governance responsibility, not just a maintenance task, signals maturity, diligence, and commitment to safety from the top down.
How We Can Help
Managing airfield lighting compliance requires both strong governance and reliable technical execution. Acclivix works with airport executives and leadership teams to strengthen regulatory programs, clarify accountabilities, and ensure safety management systems, QA processes, and documented evidence stand up to scrutiny when it matters most. If you require support reviewing your compliance framework, integrating objective testing into your SMS or QA program, or strengthening executive-level oversight of safety-critical systems, Acclivix can help.
For the technical delivery, Arc & Spark Electric provides specialized airfield electrical expertise, including photometric testing, airfield lighting maintenance, LED upgrades, and power distribution services, helping airports meet TP312 requirements with confidence. Together, Acclivix and Arc & Spark offer a practical, end-to-end approach that turns lighting compliance from an assumed condition into a defensible, well-governed system.