Stakeholder Consultation Workshop on the draft implementing rule forAir-Ground Voice Channel Spacing II (below FL 195) 6th May 2011, Brussels, EUROCONTROL
Agenda Item 1: Welcome and Introduction Workshop Objectives Eivan CERASI Acting Head of SES Unit EUROCONTROL
Setting the scene… (1/4) Stakeholders : States, Service Providers, Airspace Users, Industry, etc. ENPRM Formal Consultation Draft Implementing Rules SES Mandates SES Implementing Rules Enforcement by EU States European Commission <=> Single Sky Committee Single Sky Committee, Industry Consultation Body European Commission
Preliminary Impact Assessment Regulatory Approach Full Impact Assessment Development of draft Rule Drafting Phase Public consultation (2-6 months) Formal Consultation Summary of Responses Amendment of draft Rule Review of Comments Adoption/Approval Publication Setting the scene… (2/4)
8.33 Setting the scene… (3/4) • VCS Mandate issued in 2005 • “first step” mentioned in Recital 5 of 1265/2007 • 11 March 2009: ICB IoP Sub Group recommended extension below FL195 • October 2010: Acceptance by the EC of the Regulatory Approach • Draft IR developed and submitted to a formal consultation 2.02. – 8.04.2011 • Network Management Functions IR voted by the SSC - 15.02.2011 – includes coordination of radio frequencies
Setting the scene… (4/4) • Several rounds of consultations on the subject involving wide range of stakeholders (Regulators, ANSPs, Airspace Users, Military, General Aviation, etc): • Regulatory approach – written consultation with the Program Steering Group (PSG), Stakeholder Consultation Group (SCG) and Civil-Military Interface Standing Committee (CMIC) • Draft IR – Dedicated session and written consultation with the PSG, in the period preceding the formal consultation
Objective of the workshop • Present the results of the consultation • Present the major comments received and the proposed EUROCONTROL responses • Indicate the way EUROCONTROL intends to update the IR text (and associated material) • However: • No new comments • No “real-time” drafting session
Agenda Item 2: SES Interoperability Eduardo MORERE-MOLINERO European Commission
The interoperability Regulation Eurocontrol, 6 May 2011 Eduardo MORERE MOLINERO European Commission
The interoperability Regulation (EC) N° 552/2004 as amended by Regulation (EC) N° 1070/2009 1 – Main provisions 2 – Implementing rules 3 – Community specifications
OBJECTIVES: • Interoperability between the different systems and associated procedures of the European ATM network • Coordinated introduction of new concepts of operation or technologies in ATM
SCOPE:Systems and procedures for • Airspace management • Air traffic flow management • Air traffic services • Communication, navigation and surveillance • Aeronautical information services • Use of meteorological information
REQUIREMENTS:Mandatory essential requirements • Seamless operations • Support for new concepts of operation • Safety • Civil-military coordination • Environmental constraints • Principles governing the logical architecture of systems • Principles governing the construction of systems
CONFORMITY ASSESSMENT:Verification of systems • EC declaration of verification of systems issued by the air navigation service provider • Supervision of compliance by the national supervisory authority • Alternative verification procedures can be developed by the European Aviation Safety Agency (EASA) in accordance with Regulation (EC) N° 216/2008 as amended
2- IMPLEMENTING RULES (I) • Complement or refine the mandatory essential requirements • Describe the specific conformity assessment procedures • Mandatory Commission regulations
2- IMPLEMENTING RULES (II) • 7 interoperability implementing rules drafted by Eurocontrol have already been adopted • Commission Regulation (EC) N° 1265/2007 on air-ground voice channel spacing (above FL 195) • Draft Commission Regulation on air-ground voice channel spacing (below FL 195)
3- COMMUNITY SPECIFICATIONS (CS) • Formal means of compliance (publication of the reference in the Official Journal of the EU) • European standards developed in cooperation with EUROCAE • Eurocontrol specifications • 8 references of CS already published in the Official Journal
Conclusions: • Mandatory essential requirements may be complemented or refined by implementing rules • Key role of implementing rules (Commission regulations) and Community specifications • Draft Commission Regulation on air-ground voice channel spacing (below FL 195)
Agenda Item 3: Results of the consultation on the draft VCS II IR Octavian CIOARA SES Unit EUROCONTROL
Initial feedback • 45 responses • 13 acceptable without amendment • 19 acceptable but could be improved • 12 not acceptable but could be accepted if amended • 1 not acceptable under any circumstances • ≈130 detailed comments • Main comments • Impact on General Aviation • Financial support • Role of the Member States • Type of conversions for the interim phase • Exemptions for the radios operated by ANSPs
Initial feedback Legend: A = Acceptable without amendment B = Acceptable but would be improved with amendments C = Not acceptable but would be acceptable with amendments D = Not acceptable under any circumstances
Comments C - It was felt that the proposed draft has a major impact on General Aviation with no benefits for these users therefore any other alternatives reducing the impact should be considered. R - Several alternatives have been considered and only the deployment of 8.33 kHz will provide enough frequencies on medium and longer term at a reasonable overall cost. - It is acknowledged that the deployment of 8.33 kHz in the airspace below FL 195 (notably the widespread deployment expected in 2018) will have a significant impact on General Aviation with very limited benefits. - it is proposed to allow the Member States to take local measures and to grant exemptions having limited impact on the network. Appropriate information to be provided to the EC and to the NM. - the applicability of Article 1.6 extended to the entire draft IR.
Comments C - In was considered that in order to alleviate the financial burden on the General Aviation financial support was desirable. R - The content of the draft IR is limited by its legal basis: the SES interoperability Regulation. - The requirements allowing the Member States to take local measures and to grant exemptions from the carriage of 8.33 kHz radio will alleviate some of the financial pressure on the GA. C - Clarification was demanded with regard the scope of the draft IR and on the assignments exempted from conversions. R - Article 1 sets the subject matter and the scope of each implementing rule and all the subsequent articles shall be read and interpreted in the context of that scope defined in Article 1. - The assignments identified in Article 1.5 are outside the scope of the draft rule and the Article 3 will not apply to them. Not necessary to repeat across Article 3 the exemptions defines in Article 1.5.
Comments C - Explanations were required on the role of the Member States vis-à-vis the role of the Air Navigation Service Providers. R - A definition for “conversion” is proposed in the draft IR. It includes the coordination and publication in the ICAO-COM2 table, which is a State responsibility. Therefore the States will have the responsibility for conversions. - some of the requirements which in 1265/2007 were on ANSPs now are on Member States. C - Several comments asked for clarifications with regard the types of assignments to be converted in the interim phase. R - The ACC assignments are only used to derive a target figure. The target figure may be fulfilled by converting any assignment.
Comments C - Several questions were asked with regard the applicability dates of the regulatory provisions. R - The proposed dates were consulted with the Program Steering Group (PSG) , Stakeholder Consultation Group (SCG) and Civil-Military Interface Standing Committee (CMIC). They were selected so as to avoid a too serious frequency congestion and the entire business case is based on them. C - Clarifications were required on the exemptions applicable to the radios operated by the ANSPs. R - The success of the 8.33 kHz implementation is measured through the number of conversions. - in order to make a conversion, the radios operated by ANSPs need to be 8.33 kHz capable but the capability of the radio is not an objective in itself.
Comments C - The identification of the exemption indicator to be used for flight planning after 15.11.2012 is considered premature as its format has not been agreed yet. R - The requirement will be made more generic and will refer to an “appropriate indicator”. C - Enquiries were made on the applicability of the EUROCAE 23C R - No technical documents/solutions are referenced in the draft regulatory provisions as they will be left at the level of Means of Compliance. - the new EASA ETSO-2C169a already requires ED23C for new radios and the Certification Specification currently under development by EASA will be based on the provisions of the EUROCAE 23C.
Comments C - It is considered necessary to exclude air-to-air and the Search and Rescue frequencies from the scope of the draft IR. R - The proposed frequencies (123.45 MHz and 123.1 MHz) will be excluded from the scope of the draft IR. C - Questions were asked on the availability of new technologies making the deployment of 8.33 kHz unnecessary R - All proposed future technologies were analysed and none would be able to timely and cost-efficiently deliver the required future frequencies. - The current SESAR position is that the initial operation of a new voice communication system is expected circa 2030. Up to this time, voice communications will be supported by VHF
Comments C - It was felt that the proposed text creates confusion with regard the extent of the “user of voice communication system” and the associated responsibilities. R - to improve clarity by replacing “user of voice communication system” with the “user of radio” associated with an update of the definition for “radio” and the introduction of a new definition for “aircraft radio”. C - Several comments were made on the requirements extracted from the existing Regulation (EC) 1265/2007. R - As Regulation (EC) 1265/2007 will be repealed by the proposed text some of its provisions were transposed in the new draft IR amended where necessary to remove dates occurring in the past. - in principle the text originating from (EC) 1265/2007 was not changed as the provisions of this Regulation are already applicable.
Agenda Item 4: Way forward – the next steps Eivan CERASI Acting Head of SES Unit EUROCONTROL
Way forward • Update of the draft IR to reflect accepted comments • Update and completion of Final Report (draft IR, Justification Material, Summary of Responses) • Delivery of the Final Report to the EC and availability on the EUROCONTROL Web-Site – June 2011 Not … of the EC approval process but …