Ops Approval
Regulatory Oversight
PBN Operational Approval
Workshop
Anthony Houston
ICAO/IATA PBN GO - Team Visit
Russia
Sep, 2012
Objectives
•  Snapshot of the current status and future
requirements in Russia
•  Discuss best practices for Ops Approval
•  Understanding of operational and
airworthiness requirements
•  Established processes for approval
•  Discuss oversight requirements
•  Review best practices
•  Identify steps to “Move Forward”
Performance Based Navigation
depends on:
•  A defined airspace concept
•  An available navigation aid infrastructure
•  Functional requirements of the Navigation Specification prescribed
for PBN operations
•  Approved RNAV/RNP equipment installed that meets performance
requirements
•  Air crew satisfying the operating requirements set out by State
regulations
Global
PBN Task Force Go-Team
TAKEOFF
RNAV 2
RNP 4
ENROUTE
OCEANIC
RNP APCH
APPROACH
Slide 3
LANDING
PBN Operational Approval
Why we need operational approvals?
•  Determine that the proposed operation meets
the minimum requirements; AND
•  Assess the operator’s capability to meet the
operational intent of the particular navigation
specification
Note: For the purpose of this discussion, the
term Operational Approval refers to
Airworthiness and Operational Approval.
Slide 4
Lessons Learned
•  Many Operators struggle to understand the requirements
–  Equipment eligibility issues / training requirements / data
management
–  Can cause reluctance to apply for approval
•  Common regulator responses to PBN approvals
–  Lack of oversight – ”Rubber Stamp”
–  Unreasonable oversight – Require more than the minimum req’d
–  Impeding oversight – Refuse approval due to lack of confidence
Bottom Line:
Operational approval >>>>>>> aircraft movements
Without it NOTHING HAPPENS!
Slide 5
Part 1 Agenda
•  Group discussion on current situation in Russia
•  Ops Approval Guidance Materials
•  CAA/Regulator Requirements
•  Operator Requirements
•  Identify gaps that are hindering approvals
Part 2 Agenda
•
•
•
•
Regulatory Oversight Process
Other issues
Ops Approval Exercise
Questions and Recommendations to move
forward
Current PBN Situation
Group discussion
•  General understanding of PBN at the working level
(Regulator, ANSP and aircraft operators)?
•  Russia’s PBN existing regulatory framework and
approvals process
•  Current Nav applications in play
•  Current challenges/impediments to implementation
•  Future PBN applications to be implemented
•  Near-term / Long-term
•  Regulator and Operator future requirements
Ops Approval Workshop
Questionnaire
PBN Authorizations in Russia
Navigation Specification ICAO Standards
Other International
Standards
Implementation of GPS
receivers
Regulatory
Framework Nav Specs in play
Standards Rules and
Procedures RNAV 10 RNAV 5 RNAV 2 RNAV 1 RNP 4 RNP 2 Advanced RNP Basic RNP 1 RNP 0.3 RNP APCH Instruction 25.01.2002 №
НА-36-р (non-precision
approach with area nav)
RNP AR APCH P-­‐RNAV Instruction 4.02.2003 №
НА-21-р B-­‐RNAV Letter 10.10.98 NO 3.10-41 Order 4.03.1998 No 61 DGCA
Advisory
Material Qualification Requirements?
•  KT 34-01 «Airborne equipment of satellite navigation», 4th
revision;
•  KT-253 «Airborne equipment of GNSS/GBAS»;
•  KT-229 «Airborne equipment of GNSS/SBAS».
Slide 11
Ops Approval Guidance Materials
•  ICAO DOC 9613 - PBN Manual, Vol. 1, Attch C
•  ICAO DOC 8335 – w/ regard to acceptance of
foreign approvals
•  ICAO Ops Approval Manual (Draft)
•  Certification Documentation
•  EASA AMCs / FAA ACs
•  ICAO SAM ACs (1st attempt to harmonize)
•  Ops Approval Process / Requirements
ICAO DOC 9613 – Attachment C
Operational Approval
•
•
This attachment provides high level
guidance on the processes the regulatory
bodies should follow when applying the
navigation specifications in the approval
process.
Further detailed guidance can be found in
the PBN Operational Approval manual.
ICAO DOC 9613 – Attachment C
Operational Approval
•  Section 1 – Overview
•
A PBN operational approval authorises an operator to carry out
defined PBN operations with specific aircraft in designated
airspace.
•
The operational approval for an operator may be issued when the
operator has demonstrated compliance with the relevant
airworthiness, continued airworthiness, and flight operations
requirements to the State of Registry / Operator regulatory
authority.
ICAO DOC 9613 – Attachment C
Operational Approval
•  Section 2 – State Regulatory Responsibilities
•  Individual States must develop national regulatory material which addresses
the PBN applications relevant to their airspace or relevant to operations
conducted in another State by the operators and aircraft registered in that
State. In line with current practice, small or less capable States may elect to
adopt or even adapt the national regulatory material of the major certification
States as an acceptable means of compliance.
ICAO DOC 9613 – Attachment C
Operational Approval
•  Section 3 – Operational Approval
The operational approval assessment must take account of the
following:
a) Aircraft eligibility and airworthiness compliance;
b) Operating procedures for the navigation systems used;
c) Control of operating procedures;
d) Flight crew initial training and continuing competency
requirements;
e) Dispatch training requirements;
f) Control of navigation database procedures;
g) Continued Airworthiness.
ICAO DOC 9613 – Attachment C
Operational Approval
•
•
•
•
Section 1 - Overview
Section 2 – State Regulatory Responsibilities
Section 3 – Operational Approval Assessment
Section 4 – Documentation of Operational
Approval
•  Section 5 – State Regulatory Material
•  Section 6 – Approval Process
•  Section 7 – Foreign Operations
.
PBN Operational Approval
Manual (Draft)
Doc 99xx
AN/yyy
PBN Operational Approval Manual/Circular/Leaflet
Notice to Users
This document is an unedited advance version of an ICAO publication as
approved, in principle, by the Secretary General, which is rendered
available to the public for convenience. The final edited version may still
undergo alterations in the process of editing. Consequently, ICAO accepts
no responsibility or liability of any kind should the final text of this
publication be at variance from that appearing here.
Advance edition (unedited)
PBN Ops Approval Manual
DRAFT
•  Status: Advanced unedited edition in circulation.
•  Scope: Operational approval against a PBN navigation specification
–  Intended to supplement existing guidance in the Manual of Procedures for
Operations Inspection, Certification and Continued Surveillance, DOC 8335
•  Table of Contents:
–  CH 1. PBN (high-level description)
–  CH 2. Certification and Operational Approval
–  CH 3. Operational Approval Guidelines
–  CH 4. Navigation Specifications:
–  Job Aid for each
–  Annexes: RNAV systems; Example regulatory text; and Example
application form
Slide 19
PBN Ops Approval Manual
DRAFT
Ops Approval Guidance on Certification Standards
•  Recommended to be referenced in the legislation as the
certifying document
•  Covers the following nav specs:
–
–
–
–
RNAV-5, -10, -2, and -1
Basic RNP
RNP APCH [LNAV], RNP APCH [LNAV/(Baro)VNAV]
RNP APCH AR
•  Each Nav Spec has 2 AC: general requirements and Job-Aid
(=checklist)
CAA/Regulator Requirements
Establish regulatory framework / guidance material
•  PBN operational approval (requirements for an approval)
•  Privileges of an operator holding a specific approval
•  Continued validity of a specific approval
•  Changes to operations: subject to a specific approval
•  PBN operations - define implemented nav specs and the
related certifying documentation (AC or AMC)
CAA/Regulator Requirements
PBN Regulations should at least include:
•  Basic PBN Concept Definitions
•  General requirements for authorization / approval
•  Requirements for electronic navigation data
management
•  General training requirements
Example Regulatory Text is in the
PBN Operational Approval Manual
Global PBN Task(ANNEX
Force Go-Team C) (Draft)
Slide 22
CAA/Regulator Requirements
National Regulatory material / certifying documentation
•  The AC, AMC or Order is the certifying document;
compliance cannot be approved against the PBN Manual
nor any Navigation Specification
•  States may develop national regulatory material using
the PBN NS and/or relevant ACs / Orders or AMC / TGLs
as guidance material
Navigation Specification
RNP 10 (RNAV 10)
Relevant Airworthiness/Approval
Document
FAA Order 8400.12A
RNP 4
FAA Order 8400.33
RNAV 1 and 2
AC 90-100A or AMC 20-16
RNP AR APCH
AC 90-101 or AMC 20-26
23
Slide 23
Ops Approval Guidance on
Certification Standards
(EASA / FAA)
Ops Approval Guidance on
Certification Standards
(ICAO SAM)
Flight Phase
Ops Approval
Guidance on
Certification
Standards
En-route
Oceanic/Remote Continental
STAR
Approach
Initial
Intermediate
Final
SID
Applicable
Complementary
Documents
guidance material
AC 91-001
EASA AMC 20-12
Missed
RNAV 10
FAA 8400.12
AC 91-002
EASA AMC 20-4
RNAV 5
FAA 90-96()
RNP 4
AC 91-004
FAA 8400.33
RNP 2
tbd
tba
AC 91-003
EASA TGL 10
RNAV 2
FAA AC 90-100()
AC 91-006
EASA TGL 10
B-RNP 1
FAA AC 90-105
AC91-003
EASA TGL 10
RNAV 1
FAA AC 90-100()
A-RNP
tbd
RNP APCH
AC 91-008
(LNAV)
RNP APCH
tba
EASA AMC 20-27
AC 91-010
FAA AC 90-105
tbd
EASA AMC 20-28
(LNAV/VNAV)
RNP APCH
(LP/LPV)
FAA AC 90-107
AC 91-009
EASA AMC 20-26
RNP AR
FAA AC 90-101
RF
Electronic Data
Management
tbd
FAA AC 90-105
tbd
EASA IR 21 subpart G
FAA AC 20-153
CAA/Regulator Requirements
Establish the Approval Process for Air Operators/
ANSP’s
•  Should be a 5 Step Process:
–  1) Phase one:
Pre-application
–  2) Phase two:
Formal application
–  3) Phase three:
Analysis of the documentation
–  4) Phase four:
Demonstration and inspection
–  5) Phase five:
DGCA Approval
•  Process can be simplified in certain cases (e.g. RNAV 5)
5 Step Approval Process
•  Step 1 – Pre-Application Phase: The operator initiates the
approval process by reviewing the requirements,
establishing that the aircraft, the operating procedures, the
maintenance procedures and the training meet the
requirements; and developing a written proposal to the
regulator. A meeting with the CAA and using the Job-Aids is
recommended.
•  Step 2 – Formal Application Phase: The operator
submits the formal, written application for approval to the
CAA, which appoints a project manager. Example form in
App C.
Slide 28
5 Step Approval Process
•  Step 3 – Document Evaluation Phase: The CAA project
manager evaluates the formal, written application for
approval to determine if all the requirements are being met.
•  Step 4 – Demonstration and Inspection Phase: During a
formal inspection by the project manager (assisted as
necessary by a CAA team), the operator demonstrates how
the requirements are being met.
•  Step 5 – Approval Phase: issue of the approval (approval
of Ops manual amendment + Ops specs or Letter of
acceptance)
Slide 29
CAA/Regulator Requirements
Issue Approvals
•  An amendment to the Operations Manual if applicable, and
•  A Letter of Authorization (LOA) or
•  An Operations Specification of the AOC (Ops Spec)
Foreign Operations:
•  Not necessary to issue foreign Ops Specs
•  Approval of the State of the Operator should be
accepted for foreign operator PBN operations in Russia
(State of Registry for GA)
Issuance of Approval
Examples of PBN Operations Specifications
Y N
x Navigation
Specifications
for
PBN
Operations
RNAV 10
RNAV 5
RNAV 2
RNAV 1
RNP 4
Basic RNP 1
RNP APCH […]
RNP AR APCH
Also valid for airspace /routes
designated as RNP 10
Also valid for B-RNAV routes
Also valid for
routes/procedures
P-RNAV
Valid for approach procedures
designated as RNAV (GNSS)
Valid for approach procedures
designated as RNAV (RNP)
and RNP SAAAR Apch
•  RNP APCH should be precisely defined by LNAV, LP, LNAV/
VNAV, LPV as appropriate in the […]
CAA Inspector Requirements
Responsibility: Must ensure the PBN operation is safe
•  Training and qualification of inspectors for PBN approval:
–  Must be appropriately experienced and trained
–  Must be trained and competent in all ops elements:
•  Aircraft capability, functionality
•  Operating procedures, dispatch, planning
•  Crew procedures
•  Flight, dispatch and controller training
–  Must have an understanding of:
•  Procedure design and implementation
•  ATC procedures
Operator Requirements
•  Submit Application for authorization (Ops Spec/
Letter of Approval)
•  Determine aircraft/equipment eligibility
•  Establish operating procedures
•  Control operating procedures through review/entry in
Ops Manual
•  Incorporate flight crew training requirements
•  Control of the navigation data-base process
Slide 33
Operator Requirements
Common Air Carrier Concerns
•  Harmonization & Access
•  Aircraft Equipage Eligibility
•  Pilot/Dispatcher Training
•  Operator’s Documentation
•  Nav Database Validation & Maint
•  Issues regarding RAIM and RAIM monitoring
•  Maintenance & Continual Operational Monitoring
•  Regulator position on ‘Acceptable Means of Compliance’
34
Aircraft Eligibility
Scenarios
Scenario
Aircraft Certification Status
Actions by Operator/Owner
1
Aircraft designed and type certificated for
PBN application. Documented in AFM, TC
or the STC.
No action required, aircraft eligible for PBN
application.
2
Aircraft equipped for PBN application but not
Obtain SB (and associated amendment pages to the
certified. No statement in AFM. SB
AFM) from the aircraft manufacturer.
available from the aircraft manufacturer.
3
Aircraft equipped for PBN application. No
Establish if the statement of compliance is
statement in AFM. SB not available.
acceptable to the regulatory authority of the State of
Statement of compliance available from the
Registry of the aircraft.
aircraft manufacturer.
4
Aircraft equipped for PBN application. No
statement in AFM. SB not available.
Statement of compliance from the aircraft
manufacturer not available.
Develop detailed submission to State of Registry
showing how the existing aircraft equipment meets
the PBN application requirements.
Aircraft not equipped for PBN application
Modify aircraft in accordance with the aircraft
manufacturer SB or develop a major modification
in conjunction with an approved design
organization in order to obtain an approval from the
Slide 35
State of Registry (STC).
5
Ques%ons ? Part 2 Agenda
•  Other issues
•  Flight Validation / Nav Database Validation
•  Regulatory Oversight Process
•  Ops Approval Exercise
•  Questions and Recommendations to move
forward
Regulatory Oversight
Key Concepts to Ensure Adequate Oversight
•  Line observation is essential – real world issues drive
real solutions
•  Continuing education – keep up with changes in
technology and international regulation
•  Robust reporting allows data analysis and trending
•  Safety over-rides efficiency
Regulatory Oversight
Regulatory Oversight Process (After Carrier’s
Implementation of PBN operations)
•
Regulator’s key goals through oversight:
1.  Ensure safety of domestic PBN operations
2.  Ensure safety of foreign operators PBN ops in domestic
airspace
3.  Ensure compliance with regulation/advisory materials
•
Other regulatory responsibilities:
1.  Review and approve AMOC’s (alternate means of
compliance)
2.  Review and approve additional PBN carrier approvals
and airport specific approaches/departures
3.  Withdraw approvals as required by violation/incident
history
Regulatory Oversight
Regulatory Oversight Process – Regulator’s Tools
•
Compliance tools:
1.
2.
3.
4.
5.
•
Anonymous reporting programs (ASAP)
Simulator spot checks
Line checks to PBN specific airports
Data review (data provided by carrier via DFDR analysis)
Spot checks on maintenance of nav accuracy and nav
database loading procedures
Continuing surveillance tools:
1.  Approved SMS programme should specifically break-out PBN
incidents
2.  Coordination with other regulators and ICAO to stay current on
revisions to international guidance materials
3.  Understand foreign operator’s regulatory requirements to
ensure interoperability with Russia’s regulatory guidance
4.  Keeping inspectors educated on changes and new technology
Regulatory Oversight
Regulatory Oversight Process – Data Capture & Analysis
•  Importance of Data Capture on carrier’s PBN operations:
1.  Allows comparison to level of carrier reporting – can
determine if carrier accurately reporting all issues
2.  Permits “trend analysis” and surveillance on specific
problem areas
3.  Identifies aircraft nav maintenance or database
anomalies
4.  When combined with SMS data, improves overall
analysis of carrier compliance
5.  Can be used to cross-check line check and sim check
reports to determine if inspectors accurately reporting
airman performance
Regulatory Oversight
Regulatory Oversight Process – Aircraft Maintenance
•  Aircraft maintenance oversight challenges:
1.  Ensure mechanics loading databases as soon as
practical after database cycle release
2.  MEL’s related to Nav accuracy and navigation avionics
must be tracked and cleared in logbooks and
maintenance system
3.  Proper coordination and communication to dispatch and
pilots of nav system MEL’s/downgrades
4.  Proper data-loader maintenance (prevention of database
corruption via data-loader)
5.  Can be used to cross-check line check and sim check
reports to determine if inspectors accurately reporting
airman performance
•  Ops Approval Exercise
(RNAV 1 / RNAV 2 / RNP APCH)
Exercise: RNAV-1 & RNAV-2
RNP APCH
•  Two exercises to illustrate the approval process of PBN
ops
•  Review with the attendance the Job-Aids page by page.
•  Illustrate the Job-Aid usage (either AC or Ops Approval
Manual Job-Aids) for 2 PBN nav specs with:
–  Airline personnel provides operator’s input
–  Ops Inspectors provide the requested CAA inputs
–  Other participants provide comments/inputs
•  Complete exercise for RNAV-1 & 2 and RNP APCH
Questions and Conclusions