Stakeholder Consultation Workshop
on the draft implementing rule for
Air-Ground Voice Channel Spacing II (below
FL 195)
6th May 2011,
Brussels,
EUROCONTROL
The European Organisation for the Safety of Air Navigation
Agenda Item 1:
Welcome and Introduction
Workshop Objectives
Eivan CERASI
Acting Head of SES Unit
EUROCONTROL
The European Organisation for the Safety of Air Navigation
AGENDA
09h00
Registration
09h30
Welcome and Introduction
Presentation of the Workshop Objectives
Eivan CERASI (Acting Head of SES Unit)
09h45
Presentation on the SES Interoperability
Eduardo MORERE-MOLINERO (European
Commission)
10h00
Results of the consultation on the draft IR for VCS II 8.33 kHz
Main comments and draft responses
Discussions
Octavian CIOARA (SES Unit)
10h30
Coffee Break
11h00
Results of the consultation on the draft IR for VCS II 8.33 kHz
Main comments and draft responses
Discussions
12h30
Lunch
13h30
Results of the consultation on draft IR for VCS II 8.33 kHz
Main comments and draft responses
Discussions
15h00
Coffee Break
15h30
End of Workshop
Way ahead
Next steps
Octavian CIOARA (SES Unit)
Octavian CIOARA (SES Unit)
Eivan CERASI (Acting Head of SES Unit)
3
Setting the scene… (1/4)
Stakeholders :
States, Service Providers,
Airspace Users, Industry, etc.
ENPRM Formal Consultation
SES Mandates
Single Sky
Committee,
Industry
Consultation
Body
Draft
Implementing
Rules
SES
Implementing
Rules
Enforcement
by EU States
European Commission <=> Single Sky Committee
European Commission
4
Setting the scene… (2/4)
Drafting Phase
Preliminary Impact Assessment
Regulatory Approach
Full Impact Assessment
Development of draft Rule
Formal Consultation
Public consultation
(2-6 months)
Review of Comments
Summary of Responses
Amendment of draft Rule
Adoption/Approval
Publication
5
Setting the scene… (3/4)
8.33
•
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
6
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
7
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
8
Agenda Item 2:
SES Interoperability
Eduardo MORERE-MOLINERO
European Commission
The European Organisation for the Safety of Air Navigation
The interoperability Regulation
Eurocontrol, 6 May 2011
Eduardo MORERE MOLINERO
European Commission
10

The interoperability Regulation (EC) N°
552/2004 as amended by Regulation (EC) N°
1070/2009
1 – Main provisions
2 – Implementing rules
3 – Community specifications
Eurocontrol
6 May 2010
11
|

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
Eurocontrol
6 May 2010
12
|

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
Eurocontrol
6 May 2010
13
|

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
Eurocontrol
6 May 2010
14
|

.
.
.
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
Eurocontrol
6 May 2010
15
|

.
.
.
2- IMPLEMENTING RULES (I)
Complement or refine the mandatory
essential requirements
Describe the specific conformity assessment
procedures
Mandatory Commission regulations
Eurocontrol
6 May 2010
16
|

.
.
.
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)
Eurocontrol
6 May 2010
17
|

.
.
.
.
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
Eurocontrol
6 May 2010
18
|

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)
Eurocontrol
6 May 2010
19
|
Agenda Item 3:
Results of the consultation on the draft VCS II
IR
Octavian CIOARA
SES Unit
EUROCONTROL
The European Organisation for the Safety of Air Navigation
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
21
Initial feedback
A
B
C
D
Total by
Stakeholder
Airport Operator (AO)
1
0
0
0
1
Civil Aviation Authority
(CAA)
3
4
2
0
9
General Aviation (GA)
0
3
3
1
7
Military Authority (MOD)
3
1
0
0
4
National Supervisory
Authority (NSA)
0
2
0
0
2
Other
0
2
4
0
6
Service Provider (ANSP)
6
7
3
0
16
Total Received
Responses by Category
13
19
12
1
45
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
22
Initial feedback
Responses received by Stakeholders
Airport Operator (AO)
Civil Aviation Authority (CAA)
General Aviation (GA)
Military Authority (MOD)
National Supervisory Authority (NSA)
Other
Service Provider (ANSP)
2%
20%
36%
16%
13%
4%
9%
23
Initial feedback
Responses by Category
2%
29%
27%
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
42%
24
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.
25
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.
26
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.
27
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.
28
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.
29
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
30
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.
31
Agenda Item 4:
Way forward – the next steps
Eivan CERASI
Acting Head of SES Unit
EUROCONTROL
The European Organisation for the Safety of Air Navigation
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
…
but …
of the EC approval process
33