Stakeholder Consultation Workshop on the draft Implementing Rule on Standardised European Rules of the Air (SERA Part B)

Transcription

1 Stakeholder Consultation Workshop on the draft Implementing Rule on Standardised European Rules of the Air (SERA Part B) 19th September 2011 Brussels, EUROCONTROL The European Organisation for the Safety of Air Navigation

2 Agenda Item 2: Welcome and Introduction, Workshop Objectives Luc TYTGAT - Director Single Sky Olivier MROWICKI - SES Mandate Manager for SERA EUROCONTROL The European Organisation for the Safety of Air Navigation

3 SERA: welcome and introduction SERA: a SES II mandate for a long standing project to standardize ICAO implementation within the European environment An initiative which will support the establishment of FABs but also achieve wider objectives by consolidating common European practices An innovative rulemaking process taking account of a new legal context SERA Consultation workshop 3

4 Workshop Objectives Discussion on the MAIN OUTCOMES of the Formal Consultation Reach a COMMON UNDERSTANDING on the way forward SERA Consultation workshop 4

5 Agenda - Morning Item Time Subject Presented by 1. 09h30 Registration 2. 10h00 Welcome and Introduction Presentation of the Workshop Objectives Luc TYTGAT (ECTL/DSS) Olivier MROWICKI (ECTL/DSS/CM) 3. 10h15 SES II and the objectives of the IR Jyrki PAAJANEN (EC-DG MOVE) h30 10H45 The SERA Mandate Context & Requirements RIA & safety assessment Olivier MROWICKI (ECTL/DSS/CM) Maria ALGAR RUIZ (EASA) 11h00 Coffee Break 6. 11h30 Main Outcome of the Formal Consultation Olivier MROWICKI (ECTL/DSS/CM) 7. 11h45 Discussion on Main Outcome of the Consultation Olivier MROWICKI (ECTL/DSS/CM) All 12h30 Lunch SERA Consultation workshop 5

6 Agenda - Afternoon Item Time Subject Presented by 7. 13h30 Discussion on Main Outcome of the Consultation (Cont d) Olivier MROWICKI (ECTL/DSS/CM) All 15h00 Coffee Break 7. 15h15 Discussion on Main Outcome of the Consultation (Cont d) Olivier MROWICKI (ECTL/DSS/CM) All 8. 16h15 The Way Forward Next Steps Olivier MROWICKI (ECTL/DSS/CM) Jyrki PAAYANEN (EC-DG MOVE) Maria ALGAR RUIZ (EASA) 9. 16h45 Conclusions Olivier MROWICKI (ECTL/DSS/CM) 17h00 End of Workshop SERA Consultation workshop 6

7 Agenda Item 3: The SES II and the objectives of SERA Jyrki PAAJANEN DG MOVE European Commission The European Organisation for the Safety of Air Navigation

8 Single European Sky (SES) First SES package approved in 2004 Introduced Community competence Capacity Cost Interoperability Harmonisation of airspace to improve services European UIR Functional Airspace Blocks (FAB s) Airspace classifications Route and Sector design Flexible Use of Airspace SERA Consultation workshop 8

9 Single European Sky second package Second SES package published 10/2009 Built on lessons learned Focus on performance & continuing SES1 Four pillars Performance main issue in SES rules (targets, network management, etc) Safety extend EASA to ATM & Aerodromes Technology SESAR Master Plan endorsed Airport capacity Airport observatory, linking AD s to airborne issues SERA Consultation workshop 9

10 Rules of Air SERA objectives Rules of the Air the most basic cornerstone of aviation regulation Objectives link to several SES initiatives Safety avoid misunderstandings, ensure it is possible to know the rules Functional Airspace Blocks not possible to have integrated air navigation services without harmonised rules Free movement across borders same rules, same concepts means less hassle & easier planning Support ICAO reduce national differences SERA Consultation workshop 10

11 SERA scope Work started with a study of national differences 2007 Annexes 2, 6, 10, 11 & Docs 4444, 7030 & 8168 Over 1700 official differences found (363 for Annex 2) Up to 760 in one country + untold unofficial differences Rules of Air material spread over many ICAO annexes / Docs Various Parts to make work manageable Part A (ICAO Annex 2) agreed in Single Sky Committee February 2011 Annex 6 / Doc 8168 since covered by EASA (=OPS) Part B today (ICAO Annex 11) now in workshop Approval of Part B winter 2011/12 Part C to come next SERA Consultation workshop 11

12 Agenda Item 4: The SERA Mandate - Context & Requirements Olivier MROWICKI SES Mandate Manager for SERA EUROCONTROL The European Organisation for the Safety of Air Navigation

13 SERA IR Mandate Mandate by EUROPEAN COMMISSION (August 2009) EUROCONTROL to support the European Commission and EASA in the development of Standardised European Rules of the Air EASA basic regulation amended in 2009 Mandate amended by EC in October 2010: -EASA NPA to be used for consultation -Delivery via ATM001 RM Group of EASA SERA Consultation workshop 13

14 Mandate Requirements Deliver a draft IR which «should prioritise ICAO compliant solutions» Envisage that: «in cases, where the ICAO solution is deemed to be insufficient, or leading to non-optimal results in particular in cases where a large number of Member States have filed similar differences consideration should be given to solutions, that allow for common EU differences to be developed.» «in cases, where full harmonisation is not required» complement the draft IR with non-binding regulatory material SERA Consultation workshop 14

15 Mandate Development Take account of the regulatory framework of EASA which defines the nature and content of the regulations according to specific target regulated bodies Utilization of the Rule of the Air criteria to extract relevant provisions from the considered ICAO documents For these reasons, SERA Part B deliverable, which is the subject of the workshop today, is containing provisions of ICAO Annex 11 (and 3) but not the Annexe s entirety Only the binding part is presented today, additional non binding material to be introduced later this year SERA Consultation workshop 15

16 Mandate Specificities Dual legal basis (SES and EASA BR) Mandate amended to take account of the new EASA basic regulation extended to ATM in 2009 (consultation by EASA/NPA and delivery via ATM001 RM Group) EUROCONTROL not drafting alone but in a joint group comprising EC, EASA, stakeholders and ICAO, with agreed drafting principles published in the NPA. Not a new regulation but a «transposition» of already existing obligations for standardisation of implementation Very short time available (SESII) Regulatory approach indicated by the mandate (IR ensuring ICAO compliant solutions, complemented, if justified or if deemed more efficient, by common European differences, and by additional non-binding regulatory material) Deliverables in sequence Phase 1 frozen, Phase 2 ongoing Phase 3: information later today SERA Consultation workshop 16

17 Development SERA Part B Draft IR SERA Consultation workshop 17

18 Agenda Item 5: Notice of Proposed Amendment NPA Maria ALGAR-RUIZ EASA The European Organisation for the Safety of Air Navigation

19 Notice of Proposed Amendment (NPA)(I) NPA : Published in EASA website from 10/02/ /05/2011 Content of the NPA: Explanatory Note Regulatory Impact Assessment (RIA) + safety assessment in appendix to the explanatory note Further appendices to the explanatory note (e.g SERA Part A) Draft rule text for SERA Part B including the amendment to the Article 2 of SERA IR on definitions

20 Explanatory material (I) Background: EC Mandate to ECTL on SERA, EASA extension to ATM, The outcome of the work on SERA Part A including the last draft available at the time The new approach: Change the EC mandate and use of EASA RM process The arrangement for the drafting group The drafting principles Content of the draft rule: The outcome of the ECTL informal consultation The explanation of the major changes with regards to ICAO material SERA Consultation workshop 20

21 Regulatory Impact Assessment (I) Aim of the RIA determine the best option to achieve the objective of the rulemaking activity while minimising potential negative impacts Options were limited because of the framework established in the EC mandate to EUROCONTROL and because of the SERA Part A Assessment of impacts (safety, environment, economic, social, regulatory harmonisation impact and other impacts outside the scope of SES and EASA) was carried in general terms Full RIA needs to consider the entire EU regulatory framework for civil aviation (incl. ops, FCL, AIR, ATM and ADR) Safety impact assessment complemented by Appendix III (Summary of the safety assessment on the draft SERA Part B) SERA Consultation workshop 21

22 Regulatory impact assessment (II) safety impact assessment Safety assessment on Part B is only a part of the overall safety impact assessment SERA Part B complement SERA Part A but the complete transposition of ICAO material has not been done yet (e.g. PANS-ATM) However the overall safety impact will be positive: Uniform implementation of rules of the air with a high level of safety But could be shown only once all measures are in place SERA Part B safety impact assessment follows the same methodology than SERA Part A

23 Agenda Item 6: Comments Response Document (CRD) Olivier MROWICKI SES Mandate Manager for SERA EUROCONTROL The European Organisation for the Safety of Air Navigation

24 CRD outcome of the consultation CRD was published in the EASA website on the 23 of August 2011 and is open for reactions until 23 of October CRD was developed taking into account the outcome of the EASA review group meeting on the 4 of August 2011 CRD provides answers to 415 comments received from 44 commenters SERA Consultation workshop 24

25 Comments by users SERA Consultation workshop 25

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28 Main Outcome of the CRD IR Points which were widely accepted List of main issues raised by formal consultation

29 Points widely accepted The need for a European standardisation is recognized The usage of ICAO material as a common basis is accepted There is a general high level of acceptance of the draft IR Part B by the majority of the stakeholders As an example, the introduction of RMZ and TMZ have been widely supported Necessity of a maintenance mechanism is emphasized Comments are in majority constructive and specific SERA Consultation workshop 29

30 CRD answers to the NPA questions The following questions were asked in NPA: Question 1: placement of the paragraph of SERA Part B (Objectives of ATS) Question 2: application and implications of SERA Part B ( due regard ) Question 3: time checks would be delivered to the nearest minute Question 4: Class F Question 5: placement of the provisions in paragraph 2.1 of SERA Part B (to whom ATS shall be provided) Question 6: entity responsible for selection of the separation minima Question 7: paragraph of SERA Part B (voice read-back CPDLC messages), whether this provision is more operational or regulatory task Question 8: suitable transposition of paragraphs of ICAO Annex 3 in SERA Part B SERA Consultation workshop 30

31 Main Issues Arising Overall rule structure The comments reflected a need for clarification of the general regulatory framework envisaged in the EU for aviation and especially ATM and how SERA will be integrated in this framework (see agenda item 8). Internal structure of SERA Some comments suggested that the rule should be built differently, grouping the provisions by the subjects to which they relate and not following the internal structure of ICAO Annexes. Drafting principles A few comments challenged the fact that ICAO recommended practices could be transposed into binding provisions in some cases. SERA Consultation workshop 31

32 Main Issues Arising Objectives of ATS The replies to the question asked in the NPA show that the legal specificity of the term «objectives» is understood. However, the importance of the subject has drawn comments which are in majority in favor of keeping the objectives of ATS in SERA. Having «due regard» for the requirement of aircraft operators The replies to the relative question asked in the NPA show that the legal specificity of the term «due regard» is understood. Like for the objectives of ATS, it is nevertheless considered a point of sufficient importance to be kept in the implementing rule. SERA Consultation workshop 32

33 Main Issues Arising Time checks A lot of comments challenged the relevance of the ICAO requirement to deliver time checks to the nearest half minute. This subject will be further developed this afternoon. Airspace classification A number of comments was related to the proposed conditions for the application of airspace classes A and F. Class A A significant number of comments related to Class A was requesting that Class A could still be open to VFR flights under certain conditions. Class F A significant number of comments related to Class F was requesting that Class F could still be implemented without limitation in time, and in the conditions as it is done nowadays in some EU States. SERA Consultation workshop 33

34 Main Issues Arising Provision of Air traffic Services A question of the NPA, related to the paragraph 2.1 of Part B, was asking whether the flights to whom air traffic services are to be provided should rather be described in SERA or in the future Part ATS. Most comments indicated that the preference was to keep this description in SERA. In-flight contingencies Some comments were seeking clarification on the requirements associated to situations where an interception may be expected. Selection of separation minima This point raised a significant number of comments linked to the «placeholder» sentence temporarily used in the draft for the consultation, but also on the question whether this selection should be done by the competent authority or by the ATS unit, or by a complementary action of both. SERA Consultation workshop 34

35 Main Issues Arising CPDLC voice readback A significant number of comments were underlining the operational nature of the decision related to the mandatory (or not) voice readback of CPDLC messages, therefore expressing a preference for a decison to be made by the ATS units. MET observations In many comments, the possibility and the conditions for automatic transmission of meteorological observation by data link have been challenged. Competent authority and ATS Unit This point raised a significant number of comments linked to the nature of the competent authority as opposed to the ATS unit and to the respective roles of each entity and the relation between them when replacing the ICAO terms «appropriate authority» or «appropriate ATS authority». SERA Consultation workshop 35

36 Main Issues Arising Separation NVFR with NVFR or IFR Some comments were received on the potential necessity of providing such separation, expressing various points of view, some supporting the separation and some not. SVFR at night Some comments did challenge the «daytime only» criteria retained for the special VFR clearance to be delivered. Some comments requested the possibility to fly «special VFR at night». SVFR (day) Some comments were expressed about the proposed conditions for SVFR, mainly related to the option of applying the minimum conditions to departing traffic only (to allow arriving flights without restrictions) or to the issue of SVFR transitting in a CTR without using the airfield. SERA Consultation workshop 36

37 Main Issues Arising Definitions Some comments were asking additional information on some definitions (operator-traffic avoidance advice-aircraft). RMZ-TMZ The RMZ and TMZ concepts described in SERA Part B were widely supported and however subject to suggestions for better wording and also some requests for clarification with regard to ICAO status. Read back of ATC instructions This subject led to some comments, mainly related to the readback of taxi instructions, transition levels, and also to the safety analysis of the proposed readback requirements. SERA Consultation workshop 37

38 Main Issues Arising Scope of FIS and MET An important number of comments expressed concens about the practicability of ATS providing information related to aerodromes of departure, destination or alternate aerodromes and also information related to surface vessels in the area. The question of the capability of ATS to inform about collision hazards was also raised. 250 Kts speed limitation This item received a number of comments showing interrogations on the rationale and origin of the speed limitation, as well as the conditions where it should be applied. ATIS The question of the content of the ATIS messages and also the conditions for the transmission of the ATIS message by the controller when requested by the pilot raised some comments. SERA Consultation workshop 38

39 Main Issues Arising Supplement to SERA Part B Comments were expressed with regard to the correctness of the supplement which describes the remaining differences to ICAO proposed to be commonly agreed by EU Member States when SERA Part B is adopted. Some comments are related to the analysis of provisions which may or may not be considered differences to ICAO according to the interpretation. Some comments are related to proposed changes to the draft IR, which, if accepted, should be reflected in the supplement. SERA Consultation workshop 39

40 Agenda Item 7: Discussion of Main Outcome of the Consultation Olivier MROWICKI SES Mandate Manager for SERA EUROCONTROL The European Organisation for the Safety of Air Navigation

41 Main issues for Discussion: Selection of separation minima Comments This item was the subject of a question asked in the NPA. The majority of the stakeholders who answered this question replied that the selection of separation minima was considered to be of an operational nature and therefore should be selected by the ATS unit and approved by the competent authority. Some comments were in favour of a placement in Part ATS. Response From the outcome of the replies, and taking into account the fact that the subject needs further clarification, it is being proposed for discussion, based on the following principles: The principle that the selection of separation minima must be conducted by the ANSP and approved by the competent authority will be described in Part ATS in replacement of SERA Part B b). The former text will remain in SERA after adaptation and will be followed by text indicating that any separation minima which would not belong to those available in the rules must be described in AIP. It is important to highlight that the NPA text of paragraph a) is a place-holder in the draft rule until further regulatory action is completed to cover the subject matter. This work is going to be carried out along with the transposition of PANS- ATM. SERA Consultation workshop 41

42 Comments Main issues for Discussion: Time check The majority of stakeholder s replies to this question indicates that time checks to the nearest 1 minute is normal practice nowadays, and it is considered to be sufficient for today s operations. Response From the outcome of the replies to the questions, it can be concluded that the majority of the stakeholders would find it sufficient to provide time checks to the nearest 1 minute. However, a safety impact assessment would need to be conducted because this would require filing a category C difference in the European rule to the ICAO standard. Until further safety assessment is conducted, it is considered necessary to leave the final conclusion open. SERA Consultation workshop 42

43 Main issues for Discussion: Airspace classification-class A Comments Some comments have requested to apply a deviation from the ICAO Class A airspace definition and to allow VFR flights under specific circumstances. Response After further analysis and discussions with some of the stakeholders, it has been concluded that this solution would require a category C difference between the SERA IR and the ICAO Standard and that other different solutions could be found in those circumstances such as a re-classification or establishment of a TSA/TRA (segregated airspace). It is considered necessary to retain the intended usage of Class A airspace to be exclusively for IFR flights. Other solutions should be sought for the acceptance of any VFR flights into a certain volume of airspace (e.g. for usual operations a reclassification, corridors or establishment of a TSA/TRA, for unusual operations the application of draft article 4 of SERA IR and for unexpected circumstances the application of draft Article 3 of SERA IR (Article of EASA Basic Regulation). SERA Consultation workshop 43

44 Main issues for Discussion: Airspace classification-class F Comments The majority of the stakeholders who answered this question indicated that they would like to keep Class F in the airspace classes definition as in ICAO SARPs and that they would like to keep it without any limitation in time. Response It is considered that the proposed IR relating to advisory airspace reflects the intentions of ICAO when introducing this class of airspace into the ICAO provisions. By keeping the temporary nature, the spirit of ICAO is maintained. However, in order to make the IR legally clear, a time limit is needed. 3 years were found as a compromise between temporary and long term. In the area where Class F is implemented the most, it is not applied as described by ICAO, but a hybrid version of it is created by applying some additional provisions. At this stage it was decided to maintain the draft IR text and to use the opportunity of the workshop to exchange additional arguments and ideas on the subject. SERA Consultation workshop 44

45 Main issues for Discussion: Competent authority Comments Some comments highlighted that replacing ATS authority with the term competent authority or ATS units could lead to a destabilisation of the current systems and could create problems in the existing national framework. Response The terms ATS authority or MET authority do not exist in the current European regulatory framework based on the Single European Sky Regulations (which e.g. clarify the responsibilities based on the principle of separation between service provision and supervision). Therefore, the role of the National Supervisory Authority (NSA) or competent authority was separated from the role of the Air Navigation Service Provider and from the role of the Member States (Regulation (EC) No 550/2004 and Regulation (EC) No 216/2008). The terminology used in the high level regulations needs to be respected in the lower level regulations. Based on above, also the draft SERA IR needs to respect this principle of separation and therefore each reference in the ICAO Annex 11 and Annex 3 to ATS or MET authority must be reviewed with a purpose to indicate whether the task/function shall be performed by the supervisory authority or by the service provider (here ATS units). It should be highlighted that in some cases (e.g. selection of separation minima), the proposal by the ATS Units shall also be approved by the competent authority. SERA Consultation workshop 45

46 Main issues for Discussion: SVFR-1 Comments A number of comments are advocating that SVFR should also be authorised at night. Response It must be noted that the draft SERA Part B paragraph has been elaborated on the basis of tool No. 4 of the EUROCONTROL airspace classification toolbox and that, when this tool was developed, it was widely accepted that SVFR should be allowed during day only. At that time, the general aviation representatives were strongly opposing SVFR at night for safety reasons. There is currently no significant safety data available to justify a deviation from the toolbox dispositions. The subject is open for discussion and any robust safety assessment material provided by those stakeholders proposing such modification will be carefully considered. SERA Consultation workshop 46

47 Main issues for Discussion: SVFR-2 Comments Some comments are challenging the values selected in SERA for SVFR. The visibility values are extracted from the agreed toolbox and the intention for standardisation expressed in the EC mandate does not allow for State-specific values. Finally, comments were received with a suggestion to apply some of the SVFR criteria to departing traffic only. Response Changing the standard values would require a sound justification showing that they are not appropriate. This is not considered sufficiently justified to deviate from the agreed toolbox. Similarly to other situations in aviation, the necessary measures to continue a flight safely and in respect of the applicable regulations must be taken by the pilot in due time, otherwise leading to an emergency situation. Regulations must provide for a fair balance between safety and flexibility of operations, and should not be designed to cover cases where the necessary caution and good airmanship have not been applied. Nevertheless, when draft Part B is finalised, an additional safety assessment will be conducted on the elements which were added in complement to the provisions transposed from ICAO Annex 11, such as some elements coming from the airspace classification toolbox. The findings will be made available for potential refinements of the implementing rule. SERA Consultation workshop 47

48 Main issues for Discussion: Services related to MET (Chapter 5) Comments Expressed concerns on the proposed mandatory aspects of automatic aircraft observation and reporting requirements. Technology considerations (bandwidth) Implementation considerations (sufficient lead-time) Expressed concerns on the applicability of the proposed requirements for Helicopters. Response It is considered that all provisions related to automatic aircraft observations and reports should be removed from the Standardised European Rules of the Air (SERA) Part B Requirements regarding Services in Air Navigation. The relevant provisions on automatic aircraft observations and reports shall be included in the appropriate rules currently under development by the EASA. SERA Consultation workshop 48

49 Main issues for Discussion: Due regard Comments Most of the replies to this question of the NPA indicated that although it is not considered to be a very exhaustive requirement, it is general practice within the ANSPs and therefore it should be kept. Other comments indicated that more guidance or acceptable means of compliance should be developed. Response Based on the outcome of the replies to the question, it has been concluded to maintain the requirements as was proposed and to provide GM or AMC material to complement the IR provisions. In addition, the intention is to explain it with more details in the Opinion. SERA Consultation workshop 49

50 Main issues for Discussion: Scope of FIS Comments An important number of comments expressed concerns about the practicability of ATS providing information related to aerodromes of departure, destination or alternate aerodromes and also information related to surface vessels in the area. The question of the capability of ATS to inform about collision hazards was also raised. Response The conditions of application of these provisions will be further elaborated in AMC or GM in order to clarify how these requirements shall be understood. This clarification will make use of note 1 to paragraph of ICAO Annex 11. SERA Consultation workshop 50

51 Main issues for Discussion: Rule structure Comments Some comments indicated the need to clarify the relationship between the relevant parts of SERA (Part A, Part B and Part C) and the work on the relevant remaining ICAO material (PANS-ATM, PANS-OPS, Doc 7030). In addition, some of the comments indicated the need to group provisions in SERA Part B together with the provisions in SERA Part A. Response As indicated by the mandate issued by the European Commission to EUROCONTROL, the work needed to be carried out on a step-by-step approach and therefore in order to progress the different phases of the work, it was considered necessary to split the material between different parts. However, future work could be undertaken to group provisions together once SERA is adopted, if it is deemed to be the optimal solution. At this stage, it is important to highlight that the work on PANS-ATM will lead to draft SERA Part C and it will also complement SERA Part B, as applicable, as well as leading to the creation of AMCs and GMs. The review of PANS-ATM, PANS-OPS and ICAO Doc 7030 is being carried out in parallel. SERA Consultation workshop 51

52 Agenda Item 8: The Way Forward Next Steps Olivier MROWICKI EUROCONTROL Maria Algar Ruiz EASA Jyrki PAAJANEN DG MOVE European Commission The European Organisation for the Safety of Air Navigation

53 The way forward short term (2011) Amendments of IR articles to address received comments Finalisation of the Final Report/OPINION Issue of the Final Report/OPINION to the Commission at the end of October taking account of the outcome of the CRD, and taking into account the reactions to it and the outcome of this workshop AMC/GM on Parts A and B SERA Consultation workshop 53

54 The way forward medium term (2012) After Part A (Annex 2) and Part B (Annex 11) much is still missing: Doc 4444, (incl. phraseology) Bits of Annex 10, etc. Acceptable means of compliance and guidance material for the remaining parts Work continuing without interruption Same kind of joint Eurocontrol-EASA drafting group continues with participation of EC, ICAO and stakeholders SERA Part C to be developed under Phase 3 of SERA Initial Plan for Phase 3 before the end of 2011 SERA Consultation workshop 54

55 High level regulatory structure- EASA MB

56 To be considered for illustration purpose and as placeholder only!!!!

57 Agenda Item 9: First workshop conclusions Olivier MROWICKI SES Mandate Manager for SERA EUROCONTROL The European Organisation for the Safety of Air Navigation

58 Conclusions of the workshop Selection of separation minima: No need for exhaustive list of minima in the binding part of the rule Combination of binding/non binding material to describe the issue A certain level of flexibility is needed with regards to possible proposals by ANSPs of additional means of separation to be approved by the competent authority. Guidance should be developed as necessary Competent authority: prescribed by the competent authority - Skyguide will provide examples of instances where it is likely to disturb the current structure Approval/Acceptance by the competent authority in b) could be deleted pending final drafting of a) SERA Consultation workshop 58

59 Conclusions of the workshop Time check : Commonly shared view by participants that ½ minute was not appropriate Support needed to consider and develop justification for a Cat C difference to ICAO Views from IFALPA/ECA/IATA will be sought by EUROCONTROL to consolidate the case IFR in Class G - communication capability requirement: Airspace design solutions could be an option to cover the example given (gliders activities above 3000 ft), but the case will be further considered Class A +F: Airspace design solutions are a possible means to optimise the airspace organisation while accomodating IFR and VFR needs and respecting ICAO airspace classification Nevertheless, arguments that it is more complicated to establish and that some cases may be difficult to cover were recorded, issue to be further studied before final decision. SERA Consultation workshop 59

60 Conclusions of the workshop Services related to MET The proposed way forward was supported (to remove provisions related to automatic aircraft observations and reports) SVFR at night The strong request for keeping the possibility to allow special VFR at night is understood and the option for more flexible provisions offering the possibility to the competent authority to decide will be considered Scope of FIS The concern is understood, however, this is a complex drafting issue. Possible solutions will be considered in the final refinements of the draft implementing rule SERA Consultation workshop 60