Safety Regulation of PBN Operations Filippo Tomasello Rulemaking officer 25 May 2011

Safety Regulation of PBN Operations

Filippo TomaselloRulemaking officer25 May 2011

ICAO EUR – PBN Workshop 225 May 2011

“Specific” approval is not the “normal” solution

Instrument Rated (IR) pilots normally authorized (by law):

FCL.605 IR – Privilegesref. EASA Opinion 04/2010; 27 Aug 2010:

(a) fly aircraft in IFR with minimum DH of 200 ft(b) In case of multi-engine IR, even lower when the applicant has undergone specific training(c) ….

Rule FCL.605 (and all other EASA rules for FCL) is expected to be adopted by the European Commission during 2011… but national rules in the EU, based on JAR-FCL are similar

Underlying assumptions: operations well established in the community; suitable training programmes for IR; airworthiness certification; safe radio-navigation signal; etc….


8 requirements behind privileges

1. Aircraft (and avionics) has airworthiness approval covering the envisaged IFR operations

2. OPS of not challenging complexity3. Concept/systems “mature” (= operationally used

since a sufficient number of years = not “new”)4. Associated risk is tolerable, including

5. Accuracy, integrity, availability and continuity of radio-navigation signals

6. Safety oversight of procedure designers7. Accuracy and integrity of NAV data base

8. Suitable training standards and (periodic) checking procedures for pilots established


MNPS operations were “new” in 1977

FAA AC 91-49 (23 Aug 1977)d. Lateral separation in NAT-MNPS airspace is reduced (1978) from 120 NM to 60 NM = more complexitye. decided by ICAO that all operators desiring to use MNPS must show that equipment and procedures are capable of continuously complying with specificationsU.S. operators to FAA (= to competent authority)

Operators who have long-range navigation equipment installed (and certified) may be issued

Letters of Authorization to operate in NAT-MNPS airspace

Specific Approval (SPA)

The 8 requirements were not satisfied


Authorization, Approval or SPA?

Is the semantics sufficiently standardised?No definitions in Annex 6 for authorization, acceptance, approval or specific approval

a “normal” case seems to exist:Par. 2.2.4.7 of Part II (Intl GA) .. aeroplanes in IFR shall comply with instrument approach procedures approved by the State

“specific” is used in particular cases:Par. 2.2.2.2 of Part II to … fly below aerodrome minima


General authorization through rules

Par 2.3.1.1 Annex 6 Part IIAn aeroplane shall be operated:

a) In compliance with the terms of its airworthiness certificate or equivalent

b) Within the operating limitations prescribed by the certifying authority of the State of Registry

c) …. And of course by a pilot enjoying sufficient privileges

Par 2.4.11 Annex 6 Part II

All turbine-engined …authorised to carry more than nine passengers….

No SPA known for No of pax

The word “authorization” in Annex 6

does NOT necessarily mean SPA


Is “approval” always “specific”?

Par. 3, Attach 3.B to Annex 6 Part IIThe State should indicate through approval of a Minimum Equipment List (MEL) ….

Is the approval of the MEL “specific”?


Authorization for PBN

Par 2.5.2.2 Annex 6 Part IIFor PBN operations, in addition:

a) Equipment compliant with the PBN specification

b) Authorized by State of Registry

Authorization can be issued:Through general rulesThrough OPS spec attached to AOC for CAT operators (of course not for G.A.)As privilege to IR pilots (when all the other requirements are fulfilled), including for aerial work and general aviationThrough a Specific Approval (e.g. letter of authorisation)…..etc.

States have several choices


General rules in EU OPS

Regulation 859/2008 (applies only to operators of CAT by aeroplanes):

1.175 General for air operator certification(c) 3. satisfy Authority that can conduct safe operations(g) 2. procedures for the supervision of operations(l) ensure that every flight is conducted in accordance with the provisions of the Operations Manual(n) ensure that aeroplanes are equipped and crews are qualified for the area and type of operation(o) comply with the maintenance requirements

Many possibilities for approvals/oversight


Appendix 1 to EU OPS 1.175

Contents of the Air Operator Certificate:

(c) Description of the type of operations authorised(f) Authorised areas of operation(g) Special limitations

(h) Special authorisations/approvals e.g.:CAT II/CAT III (including approved minima)(MNPS) Minimum navigation performance specifications(ETOPS) Extended range operation twin engined aeroplanes(RNAV) Area navigation(RVSM) Reduced vertical separation minimaTransportation of dangerous goodsAuthorisation to provide cabin crew safety training

Normal authorization or special approval are almost the same x CAT?


PBN in EU OPS 1.243

Operation in areas with specified navigation performance requirements

(a) Operator shall ensure that an aeroplane operated where navigation performance requirements have been specified, is certified according to these requirements, and

if required, that the Authority has granted the relevant operational approval(b) Operator shall ensure that all contingency procedures, specified by the authority, have been included in the Operations Manual

Possible non-uniformity


EASA OPS Rules

Apply to:CAT (by aeroplane or helicopter)SPO (= aerial work)NCC = Non-Commercial Operators of “Complex” aircraft (e.g. business or corporate aviation)NCO= Non-Commercial Operators of “non-complex” aircraft (e.g. light and sport private aviation)

NPA 2009-02b proposed SPA (of unlimited validity) for certain types of operations, including:

PBNB-RNAV (RNAV 5)

Much larger scope than EU OPS (= JAR OPS 1)


NPA 2009-02b (January 2009)

OPS.SPA.001.SPN Operations in areas with specified performance based navigation (SPN)

(a), (b) only if the operator has been approved by the competent authority

(c) To obtain approval operator shall:(1) demonstrate navigation equipment functionality … (2) training programme for the flight crew(3) establish operating procedures specifying:

(i) equipment to be carried, including MEL(ii) crew composition and experience(iii), (iv) normal and contingency procedures(v) incident reporting(vi) specific regional procedures, in case of MNPS(vii) navigation database integrity, in case of PBN

Uniform common rules


CRD 2009-02b.4 (November 2010)

Part SPASPA.PBN.100 PBN operations

Aircraft shall only be operated where performance-based navigation (PBN) is established, if the operator has been granted an approval by the competent authority

No specific approval is required for RNAV5 (basic area navigation, B-RNAV)

Opinion to be delivered during 2011Adoption expected in 2012


SPA for PBN in EASA OPS (CRD)

Operation AMC Specific Op. Approval

CAT SPO NCC NCO

RNAV 10 20-12 Y Y Y Y

RNAV 5 (B) 20-4 No No No No

RNAV 2 // Y Y Y Y

RNAV 1 (P) 20-16 Y Y Y Y

RNP 4 // Y Y Y Y

Basic RNP 1 20-XX Y Y Y Y

APCH/LNAV 20-27 Y Y Y Y

APCH/L/VNAV 20-27 Y Y Y Y

APCH/LPV 20-28 Y Y Y Y

RNP AR 20-26 Y Y Y Y


Regional/National safety rules

ICAO SARPs

National competent authority

Air Operator

Contracted NAV Data Provider

Safetyoversight

Safetyoversight

Safetyoversight

Safetyoversight

Data providers contracted

Air Operator


Evolution RNP APCH in Europe (excluding AR)

Requirement Year

No Topic 2009 2011 2013

1 Airworthiness No AMC AMC 20-27 +AMC 20-28

2 Complexity No more complex than ILS Cat I

3 Maturity PBN not explicit in EU OPS

PBN in draft EASA SPA

EASA OPS in force

4 Risks RNP also includes on board monitoring

5 GNSS Signal in Space

No clear legal responsibilities

EGNOS SSP certified

EASA oversight

6 Procedure designers

No common EU provisions

Art 2.2(c)(ii) Reg. 73/2010

7 Data bases Responsibility of operator EASA rules

8 Competence of pilots

No common EU provisions EASA FCL amended

+ OSD


The will of the EU legislator

Whereas:In its Communication of 15 November 2005 entitled “Extending the tasks of the European Aviation Safety Agency – an agenda for 2010”, the Commission announced its intention to progressively extend the tasks of the European Aviation Safety Agency ("the Agency"), with a

view towards a "total system approach", to aerodrome/airport safety and interoperability, Air Navigation Services ("ANS") and Air Traffic Management ("ATM") Recital 1 EASA BR


Segment Constituents/Elements Responsibility of

AirspaceClassification and borders

of airspace volumesState aviation authority

ATS routes (including instrument procedures)

Airspace designers**

Published AIS AIS Providers*

AirborneNavigation Data Data providers**

Integrated Nav. (avionics) Manufacturers & Air OperatorsNavigation receiver(s)

Space Nav. Signal in Space (SIS) NAV SP*

GroundGround segment

Information to ATCOs ATS provider*

Airport Lights Aerodrome operators**

Certification of avionics not sufficient


Navigation Service in SES

Regulations 549 and 550/2004

Facilities and services that provide aircraft with positioning and timing (Art. 2.30; 549)

GNSS clearly fells into this definitionNAV providers (= NSP) can be individually

certified (Art. 7.3; 550)

No identical requirement exist for other transport modes

EGNOS initiated before (…. unfortunately!!!!) Planning for certification of Galileo NSP

should initiate as soon as possible …. EASA available to advise


Regional/National safety rules

SATNAV SP

ICAO SARPs

Regional/National competent authority

Air OperatorCertified Data

Provider

Safetyoversight

Safetyoversight

Safetyoversight

Certified NAV data providers


Operational Suitability Data (OSD)

GNSS has changed NAVNAV has a tradition for “specific approval” (SPA)SPA has unlimited validityEven COM is evolving (e.g. data link)But for COM no SPA is requiredOSD allows to define (and mandate) specific training requirements:

Whenever there is a relevant change“key elements” under responsibility of the (S)TC holderImplementation of said requirements is checked through regular oversight of pilots/operatorshttp://www.easa.europa.eu/rulemaking/docs/crd/2009/CRD%202009-01%20(EN,%20comment%20response%20summary%20and%20resulting%20text).pdf Rules for OSD in force in 2012

http://www.easa.europa.eu/rulemaking/docs/crd/2009/CRD%202009-01%20(EN,%20comment%20response%20summary%20and%20resulting%20text).pdf




Conclusion

All aviation operations require approval/authorization (“normal” or “specific”)For CAT operators several ways (AOC, OPS Spec, Manual, etc…)For G.A. the easiest way is through pilot’s privilegesWhen the 8 safety requirements … …. are not satisfied SPAOpinion for EASA OPS will follow CRD (= only BRNAV exempted from SPA)…but EASA is drafting Pre-RIA for new task MDM.062 in order to replace the SPA for some PBN OPS (e.g. straight in RNP APCH)OSD is an emerging concept, possibly safer than SPA

Questions?

Thanks for the attention

Documents

Safety Regulation of PBN Operations Filippo Tomasello Rulemaking officer 25 May 2011