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PBN RAD Consultation Workshop Brussels, 05 February 2013 PAVLICEVIC Franca Head of Navigation & CNS Research Unit NESHEVSKI Sasho Mandate Activity Manager

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Page 1: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop

Brussels, 05 February 2013

PAVLICEVIC FrancaHead of Navigation & CNS

Research UnitNESHEVSKI Sasho

Mandate Activity Manager

Page 2: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

Agenda Item 1

Welcome, Introduction

Workshop Objectives

Agenda

PAVLICEVIC FrancaHead of Navigation & CNS

Research Unit

Page 3: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 3

Introduction

Comments Early SoR

Stakeholder Workshop

Updated SoRUpdate

European CommissionDeliverable

Formal Stakeholder Consultation

RAD

SSC informed

Page 4: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 4

Introduction

Thank you for the comprehensive comments

RAD must develop issues to identify options for a regulatory approach

RAD selects the most appropriate option based on readily available information

We are in the Initiation Phase of the mandate - significant development is ahead of us

Full impact analysis may influence specific provisions

Page 5: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 5

Workshop Objectives

Discuss the main outcomes of the Formal Consultation for ENPRM/12-004

Present and discuss issues

Based on the discussions, present the most appropriate basis for the development of the draft Implementing Rule

Page 6: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 6

AgendaItem Start Subject Actor(s)

1 10h00 Welcome, Introduction and Workshop Objectives Franca PAVLICEVIC

2 10h15 The Mandate:- Why is this Mandate required?- Subjects raised during consultation

Franca PAVLICEVICSasho NESHEVSKI

3 10h30 Results of the consultation on the draft RAD for PBN:- Overview- Comments received and draft responses- Discussions

Franca PAVLICEVICSasho NESHEVSKIAnd all

11h15 Coffee break -11h30 Continuation on the results of the consultation Sasho NESHEVSKI

and all13h00 Lunch -14h00 Continuation on the results of the consultation Sasho NESHEVSKI

and all15h30 Coffee break -

4 16h00 Closing:- Summary- Next steps

Franca PAVLICEVIC and all

17h00 End of Stakeholder Consultation Workshop -

Page 7: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

Agenda Item 2: The Mandate

Overview

Why is the PBN Mandate required ?

Subject raised during consultation

NESHEVSKI SashoMandate Activity Manager

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PBN RAD Consultation Workshop – 05 Feb 2013 8

Overview The PBN Mandate

Subject

’’Mandate to Eurocontrol to assist the European Commission in the development of an interoperability implementing rule on Performance Based Navigation (PBN).’’

Purpose

Define navigation performance requirements

Identify the functionalities required in en-route and terminal airspace, including arrival and departure, and also approach

Address the implementation of ICAO Resolution A37-11

Developed in coordination with EASA

Page 9: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 9

Overview The Mandate development process

A-ENPRM(31 July – 16 Nov 2012)

ENPRM (Dec - Feb 2014)

30 Jun 2011

March 2013

Dec 2013

Initial plan

Regulatory Approach

Draft Final Report

Final Report

EC and SSC proceedings

EC and SSC proceedings

Jun 2014

Page 10: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 10

Overview Mandate Current Status

Phase I - Regulatory Approach

Draft Regulatory Approach Document (RAD) submitted to formal stakeholder consultation from 31 July 2012 to 16 November 2012

Review of comments

Early draft Summary of Responses (SoR) document

Page 11: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 11

Overview Mandate Phase 1 - Next Steps

Finalisation of the draft RAD

Coordination with the Single Sky Committee (SSC)

Delivery of RAD to the European Commission – March 2013

Page 12: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 12

Overview Mandate Phase 2 - Implementing Rule Development

Draft Final Report

Based on the option selected following the Regulatory Approach consultation

Includes:

Proposed Draft Implementing Rule

Draft Justification Material

Detailed impact assessment (safety summary, civil/military organisation, efficiency and economic aspects)

Draft IR submitted to formal consultation (ENPRM)

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PBN RAD Consultation Workshop – 05 Feb 2013 13

Why is a PBN IR required ?

Harmonisation of navigation performance and functionalities within EATMN to avoid potential fragmentation

Commitment to coordinated and harmonised introduction of navigation capabilities and deployment of PBN routes and procedures

Operational benefits

Improved flight efficiency

Increased capacity

Enabling new concepts of operation

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PBN RAD Consultation Workshop – 05 Feb 2013 14

Subjects raised during consultation (No prioritisation)

A. Global Harmonisation and ConsistencyB. Navigation Performance Requirements and Stakeholder ActionsC. Implementation ConditionsD. Means of ComplianceE. Economic Impact AssessmentF. Safety Impact AssessmentG. Civil-Military CoordinationH. Impact on General Aviation StakeholdersI. Reversionary Mode of OperationJ. Applicability of the SES Legislation to Providers outside EUK. Availability of Harmonised High Quality Aeronautical Data

Page 15: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

Agenda Item 3: Results of the consultation

Overview

Main comments received / draft responses

Discussions

PAVLICEVIC FrancaHead of Navigation & CNS

Research UnitNESHEVSKI Sasho

Mandate Activity Manager

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PBN RAD Consultation Workshop – 05 Feb 2013 16

Overview Stakeholders Groups

Responses Received by Stakeholders

Civil Aviation Authority (CAA)28%

EUROCONTROL Body (ECTL)

0%

General Aviation (GA)4%

Industry (IND)8%

International Organisation (INT)0%

Military Authority (MOD)8%

National Supervisory Authority (NSA)

11%

Other0%

Service Provider (ANSP)28%Airport Operator (AO)

2%

Airspace User (AU)11%

Airport Operator (AO)

Airspace User (AU)Civil Aviation Authority (CAA)

EUROCONTROL Body (ECTL)

General Aviation (GA)

Industry (IND)International Organisation (INT)

Military Authority (MOD)

National Supervisory Authority (NSA)

OtherService Provider (ANSP)

53 Responses – 320 Individual Comments

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Overview Categories of Responses

Total Received Responses by Category

Prefer Option 16%

Prefer Option 32%

Propose another alternative

15%

None11%

Agree w ith Option 2 as recommended in the Draft

Regulatory Approach

66%

Prefer Option 1

Agree w ith Option 2 as recommended inthe Draft Regulatory Approach

Prefer Option 3

Propose another alternative

None

Page 18: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

PBN RAD Consultation Workshop – 05 Feb 2013 18

Overview Summary of Responses document

Comments summarised into ‘Key’ issues in the draft RAD.

‘Editorial’ type comments will be reflected in the updated RAD.

All preferences and comments recorded verbatim in the annexes to the SOR.

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Issue A – Global Harmonisation and Consistency (1)

Comments

Interoperability requirements should be developed in a global perspective.

Global interoperability of each option is not sufficiently addressed.

Traceability and compliance with global standards should be established.

ICAO standards terminology shall be kept.

Emphasise should be put on global coordination on PBN implementation.

Need for coordination with ICAO and FAA.

Responses

Global harmonisation and consistency is required.

Global standards are being defined in RTCA SC-227 / EUROCAE WG-85.

Regulatory drafting will rely on the existing global industry standards as far as practicable.

The aim of a draft PBN IR ensure that relevant industry standards are used.

Coordination with ICAO, FAA and EUROCAE will be ensured.

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PBN RAD Consultation Workshop – 05 Feb 2013 20

Issue A – Global Harmonisation and Consistency (2)

Comments

Consistency between the SES implementing rules and the EASA implementing rules need to be established.

Synchronisation between airborne equipage mandate and related certification material publication shall be effective.

The RAD should present the plans for the EASA publications to enable PBN operations.

Responses

Need for consistency between the SES interoperability regulation and the EASA regulatory framework is fully recognised.

Close coordination and cooperation with EASA is maintained during the development of the implementing rule, necessary PBN implementation guidance material & means of compliance.

Timely availability of appropriate certification and operational standards should be ensured.

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PBN RAD Consultation Workshop – 05 Feb 2013 21

Issue A – Global Harmonisation and Consistency (3)

Actions

Close coordination with EASA, ICAO, FAA and EUROCAE will continue to be maintained during the development of the draft IR.

The draft RAD will be revised to further emphasise the importance of global harmonisation, coordination and consistency and to provide details on how these will be achieved.

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PBN RAD Consultation Workshop – 05 Feb 2013 22

Issue B – Navigation Performance Requirements and Stakeholder Actions (1)

Comments

Performance requirements and functionalities not clearly specified.

Need for more details and precision in the description of the foreseen stakeholder actions.

Targeting should be applied when defining the requirements.

Concept of operations not fully defined (e.g. RTA, FRT & TPO).

Clear guidance, specific required functionality, and approval processes should be available for identified equipment standards.

Need for clarification on the identified navigation performance requirements and functionalities, and their use in the various phases of flight.

Need for clarification on availability of regulatory material for aircraft certification and operational approval.

Recommendation to adapt requirements proportionally to the appropriate capabilities of aircraft for which limitations exist (i.e. GA aircraft).

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PBN RAD Consultation Workshop – 05 Feb 2013 23

Issue B – Navigation Performance Requirements and Stakeholder Actions (2)

Comments

Need for synchronisation of actions of all stakeholders involved.

Not enough obligations foreseen for the ANSPs and need for clearly defined obligations in the IR.

Option 3 not a real option; poorly specified.

Responses

ICAO PBN Manual - including the Advanced RNP specification - provides detailed descriptions of the identified navigation performance requirements and functionalities.

All stakeholders requirements will be clearly defined in the IR.

Concepts of operation for some functions need further redevelopment. Availability of regulatory material for aircraft certification and operational approval needs to be ensured.

Further analysis and assessment required for a number of technical issues.

Page 24: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

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Issue B – Navigation Performance Requirements and Stakeholder Actions (3)

Responses

All potential stakeholder actions identified in the RAD will be further developed and complemented as necessary before being translated into obligations in the draft IR.

Option 3 is aimed at enabling the introduction of the SESAR target concept - Steps 1 through 3.

RTA functionality is required to be considered by EC Mandate and ICB recommendation.

Foreseen navigation specification is Advanced RNP.

Foreseen industry standard is EUROCAE ED-75B/RTCA DO-236B (work is currently ongoing on revision/update).

Unlikely that ANSPs will be able to put in place all necessary facilities to take advantage of some of the Option 3 functionalities by 2025.

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Issue B – Navigation Performance Requirements and Stakeholder Actions (4)

Actions

Necessary clarifications will be provided and the description of the foreseen requirements will be revised.

The Advanced RNP specification will be made available to stakeholders as reference.

The limitations for some categories of aircraft are recognised and the requirements will be adapted proportionally to the appropriate capabilities of those aircraft.

Synchronisation of stakeholder actions is one of the main goals of the IR and will be pursued during the development of the draft IR.

Further analysis will be undertaken during the drafting of the IR and the extended regulatory impact assessment in order to address a number of technical issues.

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Issue C – Implementation Conditions 1. Implementation Timescales for Airborne Equipage and Deployment of ATS Routes and Procedures

Comments

Preference for delayed implementation timescales by 4 to 5 years, e.g. to the beginning of 2025.

Commercial airspace users deployment of PBN ATS routes, procedures & associated tools and systems to take place 2 years before retrofit.

Deployment of RNP approaches should be done by 2016, in conformity with ICAO resolution A37-11.

Responses

Sufficient time needs to be allowed to stakeholders to achieve compliance

Amended Option 2.

A 2016 target date for deployment of RNP approaches is not achievable for all instrument runway ends in Europe.

Action

Implementation timescales will be subject to further analysis and consideration during the drafting of the IR and the extended regulatory impact assessment.

Page 27: PBN RAD Consultation Workshop - Eurocontrol RAD Consultation Workshop Brussels, ... H. Impact on General Aviation Stakeholders ... J. Applicability of the SES Legislation to Providers

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Issue C – Implementation Conditions 2. Airspace of Applicability

Comment

Explain the meaning of the statement that "The draft IR may apply to more limited areas of airspace in the case of a phased deployment" and to indicate which areas of airspace were envisaged in this context.

Response

Statement reflects the principle of targeting of the requirements.

Although the IR will be effective in all states where EU law is applicable, some requirements can be limited in their applicability further analysis, EIA.

Action

Implementation timescales, applicability criteria for aircraft equipage and airspace of applicability will be subject to further analysis and consideration during the drafting of the IR and the extended regulatory impact assessment.

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Issue C – Implementation Conditions 3. Applicability Criteria for Aircraft EquipageComment

Based on the applicability criteria for airborne equipage various levels of equipage could be achieved (e.g. 70%, 80%, 90%).ANSPs 90%.Airspace users Best Equipped Best Served (BEBS) concept to be implemented IATA and AEA Alternative proposal (different criteria for aircraft equipage).

EUROCONTROL to specifically define the applicability to helicopters in the draft IR and invite comments from the aviation community.

Response

Further work is required to detail the way the BEBS concept can be implemented in the EATMN.

Targeting of requirements on the basis of detailed fleet analysis is seen as a means to facilitate the introduction of changes and to achieve the required benefits.

It is intended that the IR will not be applicable to helicopters.Action

The applicability criteria for aircraft equipage will be subject to further analysis and consideration during the drafting of the IR and the extended regulatory impact assessment.

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Issue C – Implementation Conditions 4. Airborne Exemption Policy Principles

Comment

Mandate exemption processes to be clearly defined.

GA stakeholders for some models produced after 2000 (including models still in production), the requirement for the retrofit of certain capabilities, such as "Advanced RNP (1 NM TSE)", may be impractical.

Regulatory options should include the requirement for a marginal level of exemptions to the full implementation of the whole set of functionalities required.

Response

Exemptions need to be as limited as possible.

Exemptions only to be granted where they have a minor effect on the volume of flights by equipped aircraft and where the effect can be expected to reduce over time.

Action

The airborne exemption policy will be further addressed during the drafting of the IR and the necessary clarity will be provided.

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Issue D – Means of Compliance (1)Comments

The existence of relevant EASA and FAA compliance material should be the driver for determining the implementation dates.

Carriage of new avionics must only become mandatory after EASA has implemented a streamlined process for

a) Approval / documentation / certification of all new onboard navigation equipment required for PBN (e.g. FAA approvals to be valid in EASA member states)

b) Training requirements for pilots

c) Administrative / Organisational / maintenance cost burden for the aircraft operator.

Advanced RNP navigation specification, should be the one reflected in the EASA CS- ACNS and AMC material.

PBN IR should not specify new requirements, but facilitate application of existing modern aircraft capability by formalising a functional and performance framework.

SES rules should establish which PBN type of operation would be deployed in which airspace volumes and by when.

EASA rules should establish the "how”.

Synchronisation between airborne equipage mandate and related certification material publication should be ensured.

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Issue D – Means of Compliance (2)

Response

EASA’s intent is to ensure that the certification and approval material will be available within a timely manner before the effective date of the IR, in accordance with their Rulemaking Programme.

EASA’s intent is to transpose all of the navigation specification published in the PBN Manual into appropriate certification and operational approval standards to enable global PBN application.

Due account should be taken to minimise the impact on OEM and operators with respect to existing approvals in the draft IR requirements and the EASA airworthiness and operational standards.

Consistency between the SES interoperability regulation and the EASA regulatory framework is fully recognised and timely availability of the appropriate certification and operational standards should be achieved.

Action

The draft RAD will be revised according to the above the comments.

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Issue E – Economic Impact Assessment (1)

Comments

ANSP the assumption that aircraft older than 20 years in 2020 would be exempted led to a projection of 20% non-equipage which would cause the service provider significant problems for airspace design and mixed operations.

Airspace users aircraft exemption age of 17-15 years to be able to use investments for 8 -10 years. BEBS concept was suggested to enable airspace users to decide on the need and time of retrofit, based on their own business case.

GA stakeholders PEIA ignored the potential disbenefit of access to airspace being heavily reduced as a result of a PBN IR. Economic value of the operations under a variety of business models currently in operation should be taken into account for the impact assessment.

All costs should be taken into account in the assessment.

Need for a more detailed assessment of the costs and benefits, including confirmation of the assumptions applied.

Need for a presentation of a detailed breakdown of the estimated impact on the fleet per stakeholder group.

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Issue E – Economic Impact Assessment (2)

Comments

A financial incentive scheme could be useful for all stakeholder groups.

A review should be made of GA fleet and cost data, as well as GA equipage levels, capabilities and associated assumptions, and that additional detail be provided as part of the draft IR consultation.

It is doubtful that PBN IR could make a positive contribution to the achievement of all of the SES high-level objectives and network performance targets. Lack of hard data prevents from convincing airspace users to invest in airborne avionics at this moment in time. CBA should provide compelling argument to prove otherwise.

Cost saving expected from the optimisation of the NAVAID infrastructure has not been factored into the CBA. However, the importance of these benefits should not be underestimated, therefore text should be added to indicate that implementers should not dismiss NAVAID rationalisation as being of no consequence.

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Issue E – Economic Impact Assessment (3)

Response

A balance is to be obtained between the requirements of the ANSPs and those of the aircraft operators.

Procedures could be developed and implemented for a transition period during which a gradual increase of the proportion of equipped flights from a level of about 75-80% to a level of 90% could take place.

PBN IR should not result in some parts of the GA fleet being priced out of the market. Nor to block access to airspace to any category of airspace users. If evidence is available to show that this would be the effect, remedial measures could be proposed.

An estimate of all costs should be included in the assessment.

If benefits can be allocated to user groups on the basis of the proportion of flight hours, then commercial airlines would experience a large positive Net Present value (NPV), regional airlines would experience a small positive NPV, whilst GA would suffer a small net loss. The NPV values can be included in a revised annex.

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Issue E – Economic Impact Assessment (4)

Response

Financial incentives are presented as a possibility. At this stage, no decision has been made to implement incentives to support the IR.

Because the IR will represent a legal requirement, financial incentives are not offered as an incentive to comply with the IR but to go beyond its scope.

Financial incentives are seen as being appropriate to commercial organisations but not to state owned bodies.

The need to review the GA fleet and cost data, equipage levels, capabilities and associated assumptions, is recognised. Additional details will be provided as part of the draft IR consultation.

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Issue E – Economic Impact Assessment (5)

Response

Performance-based navigation is one of the key enablers to improve the performance of the EATMN, along with other enablers. PBN has the potential to enable benefits most notably in the areas of flight efficiency, capacity and safety.

The draft RAD provides an indication of the improvements that can be enabled by the IR.

Evidence should be provided to back up assertions.

It is normal for the assessment of a new technology to be supported by tests and simulations and the PBN assessment has made best use of what information is available.

NAVAID infrastructure rationalisation should be encouraged in whatever way possible.

Action

Detailed assessment of the costs and benefits, including as far as possible confirmation of the assumptions applied will be undertaken during the extended economic impact assessment.

Additional cost and benefit information will be sought in order to further detail the assessment.

The corresponding sections of the draft RAD will be reviewed and revised.

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Issue F – Safety Impact Assessment (1)

Comments

The detailed technical requirements should be expressed as acceptable means of compliance.

Safety requirements resulting from the end-to-end safety assessment should be covered by the EASA rules at CS level and only high level security requirements should be put at the level of the draft IR.

More detailed requirements should be identified at the level of the CS (Certification Specification or Community specification).

Safety assessment should be validated by EASA and the issues and/or assumptions identified during the safety assessment for each of the proposed options should be related with the necessary EASA regulatory material.

Assessment should be made to determine whether a generic ANS-wide GNSS safety assessment is needed to be performed at a European level. Such an activity would have to be led by EUROCONTROL.

Text should be amended to improve precision and readability.

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Issue F – Safety Impact Assessment (2)

Response

Safety requirements will be properly allocated within the available applicable regulatory frameworks. Full consistency and harmonisation will be ensured.

Validation by EASA is part of the process. Full consistency with EASA regulatory material will be ensured.

The potential need for a generic ANS-wide GNSS safety assessment to be performed at European level will be subject to assessment during the drafting of the IR and the extended impact assessment.

Action

The corresponding sections of the draft RAD will be reviewed and revised. The extended safety impact assessment will further address the specific relevant points raised in the comments.

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Issue G – Civil-Military Coordination (1)

Comments

Clarification was sought on the applicability of SES legislation to military stakeholders as well as on the categories of aircraft that would potentially be affected by the IR.

Need for transition arrangements related to both aircraft equipage to take account of the procurement and technical constraints incurred by military organisations when confronted with new ATM.

Need for accommodation of non-equipped flights by State aircraft by ATSPs.

Exemptions should only be granted for fighter aircraft, not for transport type state aircraft.

No indication of military costs was given (not even a baseline cost).

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Issue G – Civil-Military Coordination (2)

Response

Civil-military aspects are proposed to be covered in the draft IR because civil-military coordination is an essential requirement of SES, recognised in the Interoperability Regulation and in line with the declaration of member States on military matters included in the framework regulation.

For new production transport type state aircraft, forward fit actions are expected to be implemented by the military, in consequence of PBN regulatory provisions.

Forward fit must comprise not only new aircraft but also aircraft scheduled for major mid life upgrades. For other aircraft, compliance could be achieved on the basis of performance equivalence.

ATSPs will be requested to accommodate non equipped traffic as needed to enable unrestricted airspace access.

Exemptions are envisaged to be granted to transport type state aircraft only when out of service date is very close to the implementation date.

Applicability dates for transport type state aircraft could be later than those for civil aircraft.

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Issue G – Civil-Military Coordination (3)

Response

It is proposed to exempt military aircraft from retrofit requirements. For the purposes of the impact assessment, it is assumed that in the baseline case (no PBN IR) aircraft operators, including the military, would still equip new aircraft with suitable PBN avionics. Therefore the implementation of the IR would impose no incremental costs on the military. Military equipage will thus be on a voluntary basis and not as a consequence of the IR.

Action

The corresponding sections of the draft RAD will be reviewed and revised accordingly. The extended impact assessment will further address the specific relevant points raised in the comments.

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Issue H – Impact on General Aviation Stakeholders (1)

Comments

There is likely to be a lack of suitable equipment to meet the RNP1 requirements and all foreseen functionalities.

There would be, huge and unfeasible cost barriers.

There are large number of IFR aircraft with many different avionics fitments.

Text should be added to clarify that availability of solutions may be an issue for GA/AW due to certain segments of the market not yet being served with appropriate equipment.

The maturity and availability of the airborne functionalities were overstated.

Specific applicability of requirements to the GA fleet, in line with the characteristics and capabilities of this population of aircraft is recommended.

In the PEIA, cost of development, installation and certification of the proposed Option 2 functionalities were underestimated.

Annex E analysis was unclear as to the types of aircraft considered as "business/turboprop" and those considered as “general aviation”.

EUROCONTROL should revise the PEIA to clarify the aircraft classifications and update the costs associated with complying with the proposed Option 2 functionalities.

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Issue H – Impact on General Aviation Stakeholders (2)

Response

Availability of solutions for GA/AW is an issue.

The applicability criteria for aircraft equipage will be further detailed to determine to which classes of aircraft the IR will apply.

The types of aircraft included within the categories can be made available EUROCONTROL welcomes the opportunity to work with avionics manufacturers to improve the cost estimates.

It is intended that proportionality be applied when setting requirements on GA operators consistent with the capabilities compliant with E/TSO-C146 requirements.

Action

The draft RAD will be amended accordingly to reflect the points that were raised.

Consideration will be given to the possibility to excluding GA aircraft from requirements outside of the approach phase of flight. A detailed description of requirements and breakdown of impact on GA will be provided taking into account the recommendations given.

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Issue I – Reversionary Mode of Operations

Comments

It should be within the scope of the PBN IR to regulate the reversionary navigation means in case of GNSS outages - both scheduled and unscheduled.

In the case of loss of the GNSS Signal in Space, ATC contingency procedures shall be established in a harmonised manner by the ANSPs.

Implementation of same procedures across the EATMN is of utmost importance.

Consider the use of RNAV 1 as the reversionary mode to RNP 1.Response

Further analysis of the possible contingency procedures needs to be undertaken, with a view to harmonise as much as possible the requirements for reversionary mode of operations in case of GNSS outage.

Guidance material would be needed in order to ensure that the contingency procedures are consistently applied across the EATMN to enable seamless operation to the maximum extent possible.

Action

Assessment of the possible application of the RNAV 1 specification as reversionary mode of operation to A-RNP/RNP1 will be made during the development of the draft IR and the extended regulatory impact assessment. Other possibilities will also be examined.

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Issue J – Applicability of the SES Legislation to Providers outside EU Comments

The draft RAD does not address the issue of the applicability of SES regulations provisions to the GPSSPS. This point was considered to be of utmost importance for NSAs as, according to the ICAO GNSS Manual, States shall approve GNSS.

Clarification is deemed necessary with regard to the extent that the SES regulations apply to GPS and the required steps a State should follow in order to approve operations based on GNSS.

Response

The point of the applicability of SES to GPS/GNSS is under consideration at present. The matter was discussed with the SSC in 2010 and is likely to be discussed further in early 2013.

EUROCONTROL is discussing with the EC and EASA how to introduce a waiver in the applicability of the SES to GNSS core-constellations. A paper addressing this subject could be presented to SSC in 2013.

Action

The matter should be clarified before PBN enters into force, i.e. before 2015.

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Issue K – Availability of Harmonised High Quality Aeronautical Data

Comments

The non-availability of high quality aeronautical data in support of PBN was not mentioned in the draft RAD.

High quality digital data is critical to the implementation of PBN and that this crucial dependency must be pointed out.

Appropriate information assurance and in particular information security policies would need to be applied to ensure safe information exchanges.

As onboard navigation databases would rely heavily on digital aeronautical information, this dependency should be expressed in the draft RAD.

Response

Availability of harmonised high quality aeronautical data and information and its secure exchange is of paramount importance for the implementation of PBN.

Action

The draft RAD will be amended accordingly.

This subject will be considered and analysed during the extended impact assessments and will be captured at least in the justification material attached to the draft IR.

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Amended Option 2

PHASE OF FLIGHT

En-Route Terminal Approach

Aircraft

Date of applicability of

certification and

operational approval for aircraft and

implementation for Service

Provider Above FL195 Below FL195

Service Provision Aircraft Service Provision Aircraft Service Provision

By end 2018

RNP APCH (APV where appropriate subject to

operational needs but LNAV as a minimum)

By end 2020

RNP1 +

RF leg +

RNAV Holding

Provide RNP SIDs and STARs

Use of altitude constraints

Optimise TMA flows to provide:

Capacity Efficiency Access CCO/CDAs based

on positive CBA

APV (either Baro

or SBAS)

By end 2023

A-RNP +

FRT

RNP1 +

RNAV Holding

Airspace designed to optimise flight

efficiency. Free routes

airspace enabling user preferred trajectories.

High density airspace re-designed for closer space routes and route conformance monitoring tools implemented to manage traffic

Use of altitude constraints

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Agenda Item 4: Closing

Summary

Next Steps

PAVLICEVIC FrancaHead of Navigation & CNS

Research Unit

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Summary

Comments Early SoR

Stakeholder Workshop

Updated SoRUpdate

European CommissionDeliverable

Formal Stakeholder Consultation

RAD

SSC informed