EASA NPA on SERA Part ENAV Response sheet. GENERAL COMMENTS ON NPA PACKAGE Note: Specific comments are provided after the General Comments

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1 EASA NPA on SERA Part ENAV Response sheet GENERAL COMMENTS ON NPA PACKAGE te: Specific comments are provided after the General Comments 1 SERA Parts C and D ENAV still misses clarity on the whole scope of the SERA IR and on what SERA Parts C and D will be SPECIFIC COMMENTS ON REQUIREMENTS ON SERA Part B Objectives of the Air Traffic services Time in air traffic services Classification of airspaces- Class A Classification of airspaces- Class C ENAV agrees that these are objectives of ATS ENAV supports any place which will ensure the continuation of the ICAO spirit and the predominance of these objectives This should appropriately fit into the final future rule-structure ENAV confirms that the current practice is to deliver time checks to the nearest minute only and therefore proposes the SERA Part B IR be amended to reflect this common difference from ICAO The use of the classification of airspaces describing Class A is a major issue for some ANSPs which put some portions of their airspace in Class A where specific VFR flights are permitted under restricted conditions/ where ANSPs can refuse ATC clearance to VFR flights ENAV proposes to define the Class A as follows: IFR only are permitted unless specific VFR flights (namely exempted VFR flights) are permitted by the competent authority ENAV agrees with the definition of Class C It is important to recall that the regulation 730/2006 of 11 May 2006 on airspace classification and access of flights operated VFR above FL195 currently applies to the upper airspace of all European Member States

2 6 121 Classification of airspaces Class C to G Implementation of Class F shall be considered as a temporary measure 8 13 Requirements for communication s and SSR transponder Radio Mandatory Zone Transponder Mandatory Zone ENAV recommends to repeat here the 2 nd footnote of Appendix I Part B When the height of the transition altitude is lower than 3050 m (10000 ft) AMSL, FL 100 should be used in lieu of ft ENAV proposes to delete this provision and to stick to the spirit of the ICAO note: te Where air traffic advisory service is implemented, this is considered normally as a temporary measure only until such time as it can be replaced by air traffic control This provision should be placed in Guidance Material not an Implementing Rule These provisions added in SERA Part B which are not part of ICAO SARPS are of great added value even if it leads to some adaptations at national level For better clarity, this provision should be re-worded as follows: shall maintain continuous voice air-ground communication watch and establish two way air-ground communication, as necessary, Paragraph 1321 should be reworded in consistency with paragraph 1311 ENAV proposes the following rewording: 1321 For aall flights operating in the airspace designated by the competent authority as a transponder mandatory zone (TMZ) in accordance with relevant Union and national rules, the mandatory carriage and operation of shall carry and operate SSR transponders capable of operating on Modes A and C or on Mode S shall be required

3 Clearances issued by the ATC units ENAV has the following comments: ENAV recommends to repeat here the 2 nd footnote of Appendix I Part B When the height of the transition altitude is lower than 3050 m (10000 ft) AMSL, FL 100 should be used in lieu of ft ENAV wonders why it is not possible to separate the IFR flights visually in Class C while there is no difference between classes D-E and C The requirement in this paragraph represents an extension of the original requirement of Annex 11 by adding provisions from PANS-ATM However, the critical notion of 'maintaining own separation', as stated in PANS-ATM, 5211, 59 and is missing Mention of wake turbulence separation obligations and essential traffic information is also missing It appears that part of the conditions from the P-ATM paragraph 5211 and 59 have been simply swapped leading to the increased complexity to reader and lack of clarity Similarly to Annex 11, this possibility should be referred to in limited, general terms only, with the application details being provided (like PANS-ATM) in the section dealing with separation criteria/minima ENAV proposes the following wording: 222 Clearances issued by air traffic control units shall provide separation: a) between all flights in airspace Classes A and B; b) between IFR flights in airspace Classes C, D and E; c) between IFR flights and VFR flights in airspace Class C; d) between IFR flights and special VFR flights; e) between special VFR flights when so unless otherwise prescribed by the appropriate ATS competent authority; except, for the cases under b) above in airspace Classes D and E, when flights have been cleared to climb or descend subject to maintaining own separation and remaining in visual meteorological conditions Conditions applicable to the use of this procedure are contained in 222 bis 222 bis When so proposed by ATC unit or requested by an aircraft, and provided it is agreed by the pilot of the other aircraft and so authorized by the appropriate ATS competent authority, an ATC unit may clear a controlled flight, including departing and arriving flights, operating in airspace Classes D and E in visual meteorological conditions during the hours of daylight to fly subject to maintaining own separation to one other aircraft and remaining in visual meteorological conditions When a controlled flight is so cleared, the following shall apply:

4 Clearances issued by ATC units a) the clearance shall be for a specified portion of the flight at or below m ( ft) AMSL, during climb or descent and subject to further restrictions as and when prescribed on the basis of regional air navigation agreements; b) if there is a possibility that flight under visual meteorological conditions may become impracticable, an IFR flight shall be provided with alternative instructions to be complied with in the event that flight in visual meteorological conditions (VMC) cannot be maintained for the term of the clearance; and subject to further c) the pilot of an IFR flight, on observing that conditions are deteriorating and considering that operation in VMC will become impossible, shall inform ATC before entering instrument meteorological conditions (IMC) and shall proceed in accordance with the alternative instructions given NOTE: See also XXX XXX Essential traffic information shall be given to controlled flights concerned whenever they constitute essential traffic to each other Information related to controlled flights cleared subject to maintaining own separation and remaining in visual meteorological conditions shall be considered as essential traffic information (colour code for 222 bis :the yellow colour is what is added text in order to capture ENAV requirements, the grey is proposed new text to IR, however it is 100% ICAO P-ATM 59)

5 13 23 Separation minima b) Flight Information Service The term provisions adopted under the Chicago Convention is significantly broadening the scope, as it may now also include Manuals, Guidance Material and even Circulars as issued by ICAO; The selection of separation minima should continue to be covered according to the PANS-ATM and regional supplement Doc 7030 as long as these documents are not transposed as such in the SERA provisions It is not clear what responsibility and what actions the Commission will take so as to propose measures with regards to the selection of separation minima ENAV favours that the ANSP proposes the separation minima and that the Competent Authority adopts it To reflect the traffic information limitations brought by the ICAO Annex 11 paragraph 422 note 1, ENAV proposes to re-word the provision as follows: b) collision hazards, to aircraft operating in airspace Classes C, D, E, F and G, as far as practicable;

6 15 Chapter 5 Services related to Meteorology ENAV would like to raise the following comments: What is the justification for the quantity and frequency of data required? ENAV sees potential adverse implications for the Radio/Frequency spectrum Some data may not be available from many aircraft For instance, ENAV questions the physical capability of on board equipment to accommodate the quantity of data required in such a short time as required in the provision 522 Also, ENAV questions the availability of data link equipment on board helicopters as required in the provision MHz is for surveillance International agreements are in place to restrict the use of certain frequency bands for certain applications Current EU activities in this area (eg Datalink IR) do not include the requirement to downlink MET data ENAV wonders if safety assessments have been performed for any of the possible data-link technologies to show they can handle this extra data with the European traffic levels The new requirements, when properly scoped, should be fed into the definition work for future data-link We disagree with the modified version of the ICAO Annex 3 Chapter 5 provisions which have been proposed in SERA Part B Chapter 5 as we believe it does not fully implement the spirit of the ICAO requirements We are particularly concerned about the specific upgrading of the Recommendations to mandatory provisions given the resulting data burden, especially since the ICAO provisions which would limit this burden have not been transposed We also stress that, regardless of the particular technical concerns raised above, as a general principle it is not possible for ANSPs or Airspace Users to accomodate unplanned infrastructure requirements within a few months The nature of the provisions of Chapter 5 are therefore inappropriate for consideration within the general SERA entry into force date (anticipated as 4 December 2012)

7 16 Appendix 1 of Part B 17 Appendix 1 of Part B Second footnote ENAV welcomes the additional elements in the right columns on the communication requirements It permits to clarify some ambiguities ENAV recommends including specifications on the special VFR flights - as quoted in the paragraph 221 c) -when appropriate For better clarity, this footnote should be re-worded as follows: shall maintain continuous voice air-ground communication watch and establish two way air-ground communication, as necessary, - end of comments -