CAA Consultation on the Scope and Management of an RNAV 1 Mandate for Operations in the London Terminal Manoeuvring Area

Future Airspace Strategy Deployment CAA Consultation on the Scope and Management of an RNAV 1 Mandate for Operations in the London Terminal Manoeuvring Area Status: Published Version Owner: Phil Roberts Head of Airspace, Air Traffic Management and Aerodromes Authors: Geoff Burtenshaw and Chris Barnes Document Filename: LTMA RNAV 1 Mandate Consultation Doc Final Date: 14 April 2014 Page 1 of 23

Contents 1. Purpose... 3 2. Background... 5 2.1 Introduction...5 2.2 The Rationale for an RNAV 1 Mandate in the LTMA...6 2.3 An overview of the options considered by the CAA Board...6 2.4 An overview of CAA s engagement with industry...7 2.5 A description of the alignment with the European PBN Implementing Rule and the SESAR Pilot Common Project (PCP)...8 3. Scope... 9 3.1 Technical and Operational Scope...9 3.2 Geographical Scope LTMA... 10 3.3 Organisational Scope... 10 4. Timelines and Implementation Approach... 12 4.1 Timelines... 12 4.2 Implementation Approach... 14 4.2.1 Exemption Policy... 14 4.2.2 Enforcement Policy... 14 5. Anticipated Stakeholder Impacts... 15 5.1 Airspace Users... 15 5.2 Aircraft Retrofit and Operational Approval... 17 6. Risks and Issues... 18 7. Consultation Questions... 20 Annex A: Glossary of Terms... 21 Annex B: Relationship of RNAV and RNP within an Airspace Concept... 23 Page 2 of 23

1. Purpose This document supports the CAA consultation with UK Aviation Stakeholders on the scope and management of an RNAV 1 Performance-based Navigation (PBN) Mandate for the London Terminal Area (LTMA). The consultation is coordinated through the National Air Traffic Management Advisory Committee (NATMAC) and the Future Airspace Strategy Industry Implementation Group (FASIIG) to ensure a broad range of operational stakeholders are engaged. The objectives of this consultation are as follows: - To refine the technical, geographical and organizational scope of the mandate, ensuring it is proportionate and effective; - To ensure the terms of the final mandate are clearly articulated to industry stakeholders; - To refine and strengthen the proposed implementation, exemption and enforcement approach; - To identify and quantify outstanding risks and issues; and - To validate the timetable for introduction of the mandate. The structure of consultation is as follows: # Section Description 2 Background This section of the consultation document provides the background to the Mandate approach, including: - The rationale for an RNAV1 Mandate in the LTMA; - An overview of the options considered by the CAA Board; - An overview of CAA s engagement with industry, regarding the mandate approach and impact assessment activity; and - A description of the alignment with the European PBN Implementing Rule and SESAR PCP. 3 Scope This section of the document consults stakeholders on the proposed scope of the mandate and identification of gaps, conflicts and ambiguities. It considers: - The proposed technical and operational scope including the ICAO navigation specification to be applied, additional aircraft requirements and operational approvals; - The proposed geographical scope including arrival and departure procedures and sectors of airspace covered by the mandate; and - The proposed organisational scope including the specific airports, operators and ANSPs that are expected to be affected by the mandate and their respective areas of responsibility. Page 3 of 23

4 Timetable and Implementation approach This section of the document consults stakeholders on the feasibility of the timetable and implementation approach to introduce the mandate. It considers: - The timetable for publishing the terms of the mandate and the dates it should come into effect for aircraft operators, airports and ANSPs; - The proposed approach for managing temporary exemptions and enforcement activity. 5 Anticipated Stakeholder Impacts 6 Risks and Issues This section of the document details the CAA s assessment of anticipated impacts, including: - On airspace users, including fleet capabilities across the London airports and how this affects access for operators; and - On aircraft retrofit and operational approval aspects including the impact on General Aviation aircraft operators flying under IFR inside the LTMA. This section of the document addresses Risks and Issues identified by the CAA associated with the mandate approach. 7 Consultation Questions This section contains the questions upon which the CAA is seeking the views of stakeholders. In particular, we are looking for feedback on: - Our defined scope of application; - The stakeholder impact; - The timeline for introduction of the mandate; and - Our exemption policy. Page 4 of 23

2. Background 2.1 Introduction PBN is ICAO s number one priority and offers potential benefits in terms of minimising environmental impact, improving safety, flight efficiency and airport resilience resulting in savings for the industry. The implementation of PBN in complex terminal airspace is a core strand of the UK s Future Airspace Strategy (FAS) Deployment Plan. UK airspace was developed over 40 years ago around ground-based navigation infrastructure. Improvements in aircraft performance and the shift to satellite-based navigation creates an opportunity to redesign the airspace and generate significant benefits for the industry, passengers and local communities. PBN is significantly under-utilised in today s airspace system, especially in the London Terminal Manoeuvring Area (LTMA) where the benefits are potentially greatest. The route structure in the LTMA has evolved incrementally around terrestrial navigation infrastructure and it is inefficient and reaching capacity. Frequent route interactions create high levels of workload for pilots and air traffic controllers. Holding stacks are used by air traffic control to pool inbound traffic as it bunches on arrival. Outbound traffic on standard departure routes from airports are kept lower for longer to avoid the standard arrival routes and stacks. PBN is a critical enabler for the systemisation of the LTMA. In a systemised environment the routes are de-conflicted and optimised by design. The implementation of RNAV 1 also supports the rationalisation of the ageing terrestrial navigation infrastructure, leading to cost savings and a more efficient use of the radio spectrum. The London Airspace Management Programme (LAMP) is a very significant opportunity to redesign the LTMA and greatly enhance safety, capacity, fuel efficiency and environmental performance. It is the largest and most ambitious airspace change to introduce PBN routes on a large scale in complex airspace. The programme is long-term, complex and requires significant investment from a number of stakeholders. The route structure for the first phase of implementation, covering the airspace around Gatwick and London City, is being designed to an RNAV 1 standard. The CAA s engagement with Industry stakeholders has demonstrated broad support for expediting RNAV 1 implementation in the LTMA as part of LAMP, but highlighted the need for a proportionate regulatory intervention to address mixed capability levels and guide the transition to a full PBN environment. Within Europe, the regulatory scene related to PBN is not clear. There are two regulatory initiatives currently sponsored by the European Commission targeting a mandate of PBN in approach and terminal airspace operations. The SES Interoperability Implementing Rule and the SESAR Deployment Pilot Common Projects Implementing Rule both envisage mandating PBN at defined airports/terminal airspace. The UK mandate of RNAV 1 in the LTMA is seen as a precursor to these emerging European regulations with an earlier set of timescales and enforcement to a lower technical standard that will deliver the changes necessary for LAMP. FASIIG a group of 60 plus aircraft operators, airports, NATS and other aviation stakeholders tasked with deploying FAS strongly advocate the mandate approach so they can plan their investments against a common timetable for the implementation of a minimum navigational standard in the LTMA. This will ensure that the airspace and the operators will be appropriately prepared in a co-ordinated manner. Page 5 of 23

The CAA has engaged with CAA Netherlands and their Ministry of Transport to learn lessons from the implementation of a RNAV 1 mandate in the Schiphol TMA which became effective from 15 November 2013. The Dutch experience has strengthened the CAA s focus on the temporary exemptions and enforcement of the mandate, described in section 4. The Airports Commission Interim Report of December 2013 (Chapter 5) talks about making best use of existing capacity and recommends an Optimisation Strategy to improve the operational efficiency of UK airports and airspace, including airspace changes supporting PBN. The LTMA mandate and the introduction of LAMP is therefore key to delivering the short and medium term measures recommended by the Airports Commission. The work being undertaken under FAS to trial a range of different departure procedures based on RNAV principles is in support of concepts planned for LAMP. The availability of enhanced route spacing criteria allowing optimally spaced routes and the assessment of split departures to improve runway resilience and offer environmental respite are essential enablers. The LTMA mandate effectively provides the vehicle for implementation of those enablers. The requirement for RNAV 1 in the LTMA is seen as a first step to UK wide implementation of PBN in Controlled Airspace (CAS) in an appropriate timetable and the mandate is seen as a model for other potential UK deployments where an impact assessment indicates the need for regulatory intervention. This consultation is therefore an exercise in seeking feedback from stakeholders on the implementation planning and as a means to de-risk the exercise ensuring that the regulatory model the CAA applies is targeted, necessary and proportionate and that the regulator has not overlooked any potential issues. 2.2 The Rationale for an RNAV 1 Mandate in the LTMA RNAV 1 is a PBN standard that assures aircraft consistently achieve a minimum level of track keeping conformance. The PBN concept includes more advanced standards than RNAV 1. For example the RNP 1 standard provides a higher level of assurance of track keeping, especially for aircraft in the turn. Approximately 90% of all the aircraft operating in the LTMA are RNAV 1 capable today. About 60% are capable of RNP 1. A general description of both RNAV 1 and RNP 1 is in included in a Glossary of terms contained in Annex A. The acceptable means of compliance for RNAV 1 is detailed in Section 3. The range of aircraft operating in the LTMA is highly diverse and capability levels vary across the fleet. Although many aircraft are equipped and certified to fly to the RNAV 1 standard, industry has been slow to either reach a critical mass or redesign the airspace to realise the benefits. By setting a minimum standard the CAA will establish a platform from which the operation can be systemised and more advanced navigational capabilities such as RNP 1, can be introduced based on operator and local airport needs. 2.3 An overview of the options considered by the CAA Board In developing the LTMA mandate, the CAA is following Better Regulation principles for which the first step was to seek approval from the CAA Board for an RNAV 1 mandate in the LTMA affecting aircraft operators from November 2017 and airports and NATS up to November 2019. In reaching this conclusion the Board considered the following options: Page 6 of 23

Do Nothing Doing nothing is not considered a viable option. The UK is expected to comply with an extant ICAO General Assembly Resolution (A37-11) to implement PBN as part of all new major airspace designs. LAMP is the cornerstone of the FAS Deployment Plan and aims to generate over 130m in annual fuel savings and reduce aircraft CO 2 emissions by over 600,000 tonnes per year from 2020 onwards. Whilst plans for a European wide mandate strongly align with the UK s ambitions, the broader scope and uncertain timescale are not sufficient to support LAMP implementation plans. UK Wide PBN Mandate Addressing the issue as part of a comprehensive UK-wide mandate is considered disproportionate and unlikely to strike the right balance between costs and benefits given the variability in navigational capability and operational requirements across the Network. In some cases the cost of aircraft upgrades would be prohibitively expensive. Preferred Option: RNAV 1 PBN Mandate for the full LTMA An RNAV 1 mandate for the LTMA implemented on a consistent basis across aircraft operators, airports and NATS, is considered a necessary and proportionate intervention to coordinate the shift to a systemised operation, enable the significant benefits expected from the LAMP airspace redesign and remain aligned with European developments. Articles 124 and 125 in the Air Navigation: The Order and Regulations permit this approach and no change to legislation is required. Evidence of RNAV 1 capability levels by airport (see Figure 2 in section 5) and the performance improvements expected from airspace redesign in the areas under consideration are being used to assess the impact of the mandate. The outcome of the CAA Board meeting on 18 December 2013 was endorsement for the Preferred Option, namely: An RNAV 1 equipment mandate applicable to aircraft operators from 09 November 2017, with a commensurate mandate on airports and NATS to establish an RNAV 1 route network in the LTMA by 07 November 2019. Note: the difference in dates applicable to operators and airspace change is to ensure that a homogeneous fleet equipage exists before introducing major airspace change. In complex airspace such as the LTMA for reasons of safety and efficiency, it is not possible to manage a mixed fleet capability. 2.4 An overview of CAA s engagement with industry The principal engagement mechanism used by the CAA thus far has been the FAS Industry Implementation Group (FASIIG) a group of 60 plus Aircraft Operators, Airports, NATS and other aviation stakeholders tasked with deploying FAS. Feedback from this group has indicated a strong desire for a mandate so that they can plan their investments against a common timetable for the implementation of a minimum navigational standard in the LTMA. The membership of the National Air Traffic Management Advisory Committee (NATMAC) has also been kept informed throughout the development of this mandate. Page 7 of 23

The mandate has been briefed in European forums, notably the joint ICAO-EUR PBN Task Force and EUROCONTROL RNAV Approach implementation Support Group (RAiSG). Further representation has been made through the EUROCONTROL Navigation Steering Group (NSG). Apart from the action already taken by the Netherlands, it is of interest that similar action is also being planned by Paris and one other major European TMA. 2.5 A description of the alignment with the European PBN Implementing Rule and the SESAR Pilot Common Project (PCP) In April 2011 the European Commission (EC) issued a mandate to EUROCONTROL to prepare a draft Interoperability Implementing Rule on PBN. Following inter-agency discussions between EUROCONTROL and EASA, the EC at the end of March 2014 agreed that the task should be transferred to EASA and the IR prepared under the EASA Basic Regulation framework. The Regulatory Approach prepared by EUROCONTROL still forms the basis of the Implementing Rule thereby retaining the technical standards previously proposed. An EASA Notice of Proposed Amendment (NPA) is anticipated by summer 2014 and the Opinion by end of 2014. In parallel, the EC has also identified Extended Arrival Management and PBN in high density Terminal Manoeuvring Areas Arrival Management as one of the ATM Functionalities within the initial deployment of SESAR enablers captured within the Pilot Common Project (PCP). Finalisation of the PCP Implementing Rule and announcement of the Deployment Manager is anticipated in summer 2014. The PCP overlaps with the PBN IR in so far as it identifies requirements for approach operations and terminal airspace. The technical standards are common between the two regulations i.e., RNP APCH in approach and RNP 1 in terminal airspace. Where the two regulations are not aligned is in the applicability of PBN i.e., at which airports and within which terminal airspace should the standards be applied. Under the PCP, the requirements would apply to a smaller subset of aerodromes. The respective timings are also different in certain aspects. Against this backdrop, the UK plan for an RNAV 1 mandate might be seen by some as not going far enough. However, the approach being taken creates a homogeneous PBN environment for which systemised route interactions can be designed. Furthermore, the European regulations start from a more demanding technical standard in a later timeframe and at more selected airports and terminal airspace. The LTMA mandate is targeted at the complex and dense London environment affecting nine airports and in order to achieve a uniform fleet equipage with no provision for conventional arrival and departure routes, a lower technical standard is seen as having least impact. Note: the LTMA mandate still provides a platform for airspace enhancements where fleet equipage for RNP 1 can be demonstrated. Page 8 of 23

3. Scope 3.1 Technical and Operational Scope The minimum aircraft standard to be applied through this mandate is RNAV 1, as defined in the ICAO PBN Manual Doc 9613 Edition 4 2013. Recognising that there are currently no EASA certification criteria reflecting this ICAO navigation specification, the following acceptable means of compliance is defined: An aircraft certification baseline of JAA TGL No. 10 Rev 1 for European Precision RNAV plus the following features: Aircraft that do not have GNSS installed and providing navigation position updates and therefore comply with TGL No. 10 Rev 1 through DME/DME radio position updating should also have an underlying Inertial Reference System (IRS) comprising multiple Inertial Reference Units (IRU) i.e., DME/DME/IRU position updating. The IRS should have automatic runway updating function thereby providing the ability to automatically null the drift error at the runway threshold/displaced threshold. In line with the UK and Ireland PBN Policy Statement No. 4, it is assumed that all aircraft, as a minimum, will be able to conduct the simplest form of RNAV holding i.e., capable of flying Holds manually using a RNAV fix 1 as the holding waypoint. All operators shall hold an operational approval for RNAV 1 as a minimum. Although the LTMA mandate applies the RNAV 1 navigation specification as minimum standard, where more advanced terminal airspace procedures using the RNP 1 navigation specification are implemented at specific locations in the LTMA, a separate approval (aircraft and flight operations) will be required. Those operators required to modify aircraft in order to comply with the minimum RNAV 1 standard should consider emerging European regulations and the requirements linked to either the PBN Implementing Rule or the Pilot Common Project (PCP) Implementing Rule. Both of these Implementing Rules plan to introduce a requirement to move all high density terminal airspace to RNP 1 with use of the Radius to Fix (RF) ARINC 424 path terminator on SIDs and STARs. The precise timescale for this change is not, as yet, clear. Within the timeframe of the LTMA mandate, airports, having consulted with their operators and where practicable, may wish to introduce RNP 1 Arrival or Departure procedures ahead of the anticipated action from Europe. Note 1: EASA is currently transposing JAA TGL No. 10 Rev 1 and other ICAO PBN navigation specifications into a Certification Specification for Airborne Communication, Navigation and Surveillance (CS-ACNS). A Notice of Proposed Amendment (NPA) is anticipated later in 2014. Note 2: Whilst RNAV 1 differs from the European Precision RNAV standard, the CAA accepts prior P-RNAV certification subject to the additional requirements as referenced above. Note 3: In the 2017 timeframe the CAA envisages the introduction of changes for operational approval as detailed in EASA NPA 2013-25, Revision of Operational Approval Criteria for 1 An RNAV fix is the generic name given for a geographical position; used by the RNAV system when defining the desired path to be flown. Page 9 of 23

Performance-based Navigation (PBN). Both AOC and non-aoc holders should refer to the changes being proposed to the EASA Air OPS Implementing Rule as a consequence of this NPA. 3.2 Geographical Scope LTMA The geographical scope of this mandate affects published Standard Arrival Routes (STARs) and Standard Departure routes (SIDs) in to and out London airports with connectivity to the en-route network. Rationale: As previously explained the purpose of the LTMA mandate is to ensure the highest level of interoperability of aircraft and procedures in the London area with the introduction of the London Airspace Management Programme (LAMP) Phase 2 in the 2018-2019 timeframe. In order to gain the maximum Network level efficiencies, the airspace design will not retain extant conventional Arrival and Departure routes. Consequently, all routes creating connectivity with the UK En-route system (already RNAV 5 at all levels since 07 April 2011) must have an RNAV designation consistent with that required for terminal airspace procedures. Where an airport does not have extant IFR route connectivity today, there will be no requirement to change that system and the airport can continue to receive aircraft and depart aircraft under their current arrangements, subject to NATS being able to meet air traffic demand and provide the required service. Note: Post 2019 and subject to negotiation, ATC may be able to offer a tactical service to those aircraft not on established Arrival or Departure routes to/from a London Area Airport. However, those aircraft should expect to experience non-optimum routings and operating levels and restrictions as to what times they may access from/to the Network. Where an airport wishes to introduce new Arrival and Departure Routes, they should apply the appropriate ICAO PBN navigation performance standards i.e., RNAV 1 as a minimum or a higher standard such as RNP 1 where fleet mix and airspace demands are established. The LTMA mandate does not apply to aircraft transiting sectors across the London area. The LTMA mandate does not apply to VFR operations or helicopter operations in the London area. 3.3 Organisational Scope The following organisations are envisaged to be affected by this proposed mandate: NATS En-route (NERL): Responsible for management of ATS in the en-route phase down to 4,000 feet above the airport in accordance with their licence arrangements. NERL are also responsible for infrastructure, route design and production, environmental consultation and ATS safety for this region. Affected airports: From the runway to 4,000 feet on departure routes and from 4,000 feet to the runway on arrival routes and instrument approach procedures. The airports are responsible for the approach infrastructure including ground facilities, route design and production, environmental consultation and ATS safety for this region. Page 10 of 23

It is envisaged the following airports will be impacted by the mandate in 2017: London Heathrow Airport London Gatwick Airport London Stansted Airport London Luton Airport London / City Airport Southend Airport Biggin Hill Farnborough Northolt Operators: Both commercial (AOC) and non-commercial (non-aoc) operators are responsible for ensuring that their aircraft are suitably equipped and approved to the applicable airworthiness standards and that they have obtained the required operational approval to conduct operations in the airspace for which a PBN application (e.g., RNAV 1 or RNP 1) has been promulgated. Note: With the introduction of LAMP Phase 2 (see timelines in Section 4), it is envisaged that all conventional (non-pbn) Arrival and Departure routes will be removed. Operators who wish to gain access to the airports affected by this mandate and who are not proposing to avail themselves of the new RNAV 1 Arrival and Departure routes will have to seek alternative arrangements from NATS and the airport ATS, subject to them being able to meet the demand and provide a service. Page 11 of 23

4. Timelines and Implementation Approach 4.1 Timelines The key milestones and timelines associated with the introduction of the RNAV 1 mandate in the LTMA is indicated in Figure 1. The milestones are detailed as follows: 14 April 2014: This consultation launched to confirm the impact from this regulatory intervention and ensure that no aspect of the technical, geographical or organisational scope has been overlooked. The consultation with aviation stakeholders will be conducted over an 8 week period, ending 9 June 2014. 07 August 2014: Publication of an Aeronautical Information Circular (AIC) in order to notify the RNAV 1 LTMA mandate as determined by this consultation. The AIC will also highlight the strategy for the wider application of PBN across the UK, including the optional use of RNP 1. End of 2015: End of 2017: Planned introduction of LAMP Phase 1a affecting mainly London Gatwick and London City airports. Planned introduction of a raised of the Transition Altitude (TA) across the UK/Ireland Functional Airspace Block. A raised TA is seen as key to facilitating the re-design and re-structuring of UK airspace and the introduction of LAMP Phase 2. 09 November 2017: All operators using Arrival and Departure Routes into or out of the London airports listed in the scope of the LTMA mandate to have aircraft equipped and approved for RNAV 1 operations subject to the conditions of a Temporary and General Exemption Policy detailed below. Operators should also have obtained the necessary operational approval for RNAV 1 operations by this date. 2018 to 2019: Planned implementation of LAMP Phase 2. 07 November 2019: All Arrival and Departure Routes in the scope of the LTMA mandate to have been re-designed in accordance with RNAV 1 principles. Optionally, procedures may be introduced within this timeline in accordance with RNP 1 principles. Page 12 of 23

Timelines S S A W = Spring, Summer, Autumn, Winter Figure 1 Key Milestones and Timelines associated with the Introduction of an RNAV 1 Mandate in the LTMA Page 13 of 23

4.2 Implementation Approach 4.2.1 Exemption Policy Employing a similar approach undertaken by our colleagues in The Netherlands for the mandate of RNAV 1 into and out of Schiphol airport with effect from 15 November 2012 2, the CAA is proposing to operate the following exemptions policy: Where an operator has failed to complete their RNAV 1 approval process before 09 November 2017 due to circumstances beyond their control, the CAA may grant a Temporary Exemption to an operator until 08 November 2018 subject to one of the following conditions being satisfied: 1. Aircraft modification is planned; 2. An aircraft modification approval, either an amended Type Certificate (TC) or Supplemental Type C Certificate (STC) is pending; or 3. The aircraft is suitably equipped but an operational approval for RNAV 1 is pending. Note: an aircraft modification has to be scheduled with an approved maintenance organisation and a pending regulatory approval has to be lodged with the respective authority, prior to application for a temporary exemption. State and military aircraft using Northolt and other airports in the LTMA will be granted a general exemption from the mandate, although in-line with the UK/Ireland PBN Policy document published in October 2011, aircraft that routinely use the civil ATS structure as GAT, should be certified to equivalent standards of performance such as accuracy, integrity, continuity and most importantly, are interoperable with respect to aircraft functionality and the ability to conduct required operations. An exemption from the LTMA mandate issued at the discretion of the CAA and coordinated with NATS will be available for certain operations e.g., humanitarian disaster relief. 4.2.2 Enforcement Policy It is the intention of the CAA to enforce the mandate of RNAV 1 in the LTMA from 09 November 2017 through the following mechanisms: Identification of non-compliant operators from flight plan data Routine audit and oversight of UK AOC holders Routine airport ramp checks as part of EASA s Safety Assessment Of Foreign Aircraft (EC SAFA Programme) Operators who fail to comply with the requirements of the RNAV 1 LTMA mandate can expect enforcement action being taken by the CAA. The CAA is exploring a number of enforcement options including denial of access to the airspace and fines. 2 The Schiphol RNAV 1 mandate came into effect on 15 November 2012. Those operators who were granted temporary exemption were given until 14 November 2013 in which to comply. Page 14 of 23

5. Anticipated Stakeholder Impacts 5.1 Airspace Users The CAA has recently conducted an assessment of the PBN fleet capability at LTMA airports against annual Air Traffic Movements (ATMs) based on data drawn from CAA statistics and aircraft flight plans. The data is presented in Figure 2, but what it indicates is that at the larger London airports, the fleet is already in excess of 90% RNAV 1 capable and in the case of Heathrow and Gatwick; almost 100%. Within the timelines considered for the RNAV 1 LTMA mandate i.e., November 2017, NATS plans to introduce LAMP Phase 1a which will require IFR arrivals to both Gatwick and London City to be RNAV 1 compliant. The expectation is therefore that the current shortfall in compliance at London City will be addressed before the implementation of LAMP Phase 1a. Both Farnborough and Southend airports have recently launched consultation exercises with a view to airspace changes introducing RNAV 1 SIDs and STARs. Again, within the timelines of the RNAV 1 LTMA mandate there is an expectation that IFR arrivals and departures will be RNAV 1 compliant. Northolt is a Military aerodrome that handles civil and military aircraft, but due to its proximity to Heathrow is heavily dependent on network services. The extant Northolt departures and arrivals (both SIDs and STARs and non-airways arrivals and departures) will be factored into the LAMP Phase 2 design. With a capability across the user fleet at 65% in 2012/2013 there is an expectation that this will improve over the next few years. In certain cases the lower civil fleet capability may be an indication of aircraft being equipped to the necessary standards but operational approval for use of the systems either pending or not requested to date. For the Military/State aircraft, the General Exemption policy highlighted in Section 4 will be applied with possible consequences on arrivals and departures depending on the availability of a tactical ATC service from NATS. Biggin Hill does not have published SIDs or STARs today, although it does support Instrument Approaches to Runway 21. Connectivity to the Network therefore will remain as it does today based on a tactical service for those affected IFR ATMs. Should the airport request Network connectivity as part of a future airspace change development, those new routes will come under the RNAV 1 LTMA mandate and be required to conform to the RNAV 1 standard as a minimum. This is a general point and also applies to any other airport in the LTMA geographical scope wishing to introduce new arrival and departure procedures outside of the LAMP Phase 2 programme. Page 15 of 23

Figure 2 PBN Fleet Capability at LTMA Airports against annual ATMs Page 16 of 23

5.2 Aircraft Retrofit and Operational Approval The technical standard linked to European Precision RNAV (P-RNAV), on which the RNAV 1 standard is based, was first published in November 2000. RNAV 1 is therefore considered to be a mature standard and one found on all current production IFR certified aircraft models. The question of aircraft produced pre-2000 which do not have the capability and therefore will require retrofit has to be balanced against the benefits available to the majority of airspace users and the desire set out in the Future Airspace Strategy (FAS) and supported by NATS to move to a totally systemised Network operation in the London area before the end of this decade. By announcing the RNAV 1 LTMA mandate over 3 years ahead of its introduction, the CAA believes that adequate advanced notice is being given to those operators affected. Operators should also have regard to the wider European regulatory playing field and be provisioning aircraft capability to meet the potentially higher standards that may emanate from either the PBN or PCP Implementing Rules. RNAV 1 compliance will undoubtedly be a complementary step along the PBN route. The RNAV 1 LTMA mandate has also considered access to non-aoc operated aircraft and especially those types linked to General Aviation. Over the last 20 years the avionics market has seen the introduction of equipment that provides en-route, terminal and approach capability based on GNSS sensors. EASA has eased the introduction of some of the more common equipment types through their validation of FAA STCs and publication of an Approved Model List (AML). From an operational approval perspective, the majority of UK commercial operators are already (P- RNAV) RNAV 1 approved. The difficulty with which non-commercial operators might obtain an approval is currently being addressed by EASA who recognise the administrative burden associated with obtaining PBN operational approvals. The Agency has recently concluded consultation on a Notice of Proposed Amendment (NPA) 2013-25, Revision of Operational Approval Criteria for Performance-based Navigation (PBN), which proposes to remove RNAV 1 and RNP 1 from Part SPA (operations requiring specific approvals) of Commission Regulation (EU) No. 965/2012 (AIR- OPS). In doing so, the individual pilot becomes approved through the training and testing undertaken as part of the issue of the Instrument Rating linked to Flight Crew Licensing. In the timelines of the RNAV 1 LTMA mandate, these new EASA provisions should be in place and thereby overcome the difficulties in granting operational approval to a non-commercial operator. A general exemption for smaller aircraft is impractical and for reasons of safety and interoperability a homogeneous aircraft fleet has to be maintained. IFR access for aircraft covered by the exemption policy will still be possible, subject to agreement with NATS. Again, where arrival or departure routes currently do not exist to those airports in the LTMA, there is no obligation to introduce them. Only if Network connectivity is required does the RNAV 1 LTMA mandate apply. Page 17 of 23

6. Risks and Issues The mandate is required to support the London Airspace Management Programme (LAMP) a NATS led initiative to fully redesign of the airspace structure and route network in the LTMA, which is an essential component of the Future Airspace Strategy. LAMP is considered a very significant opportunity to redesign the LTMA and greatly enhance safety, capacity, fuel efficiency and environmental performance. The programme is the largest and most ambitious airspace change undertaken in the UK and plans to introduce RNAV 1 routes on a large scale for the first time. The initial core implementation phase of LAMP will start in 2018 and complete by November 2019. A fully capable RNAV 1 fleet must be in place by 2017 for the implementation to be successful. The CAA, NATS and FAS Industry Stakeholders agree it is too expensive, risky and inefficient to implement a systemised RNAV 1 route network while retaining a large number of conventional procedures to accommodate aircraft that do not meet the minimum navigational standard. Some operators with non-compliant aircraft have stated in focus group meetings with the CAA that they cannot justify the investment to upgrade their fleet to an RNAV 1 standard until a mandate is in force that covers both aircraft capability and airspace redesign. In support of the deployment of functionalities identified in the European ATM Master Plan, the Commission is developing an Implementing Rule that is likely to mandate the use of Performancebased Navigation linked to Extended Arrival Managers (AMAN) in high density terminal airspace. The mandate is not expected to take effect until 1 January 2024. The objectives of LAMP and the LTMA mandate are strongly aligned to the European goals. The LTMA mandate will ensure the UK is in line with European developments and takes advantage of the benefits of PBN in an earlier timeframe. The LTMA mandate aims to set a common timetable for aircraft operators to meet the minimum standard, and for the implementation of airspace changes introduced by NATS and the airports that will generate benefits from the investment in RNAV 1. The mandate proposal intentionally affects aircraft operators first, allowing a 1 year period for issue of temporary exemptions where an agreed upgrade programme is in place. State aircraft including Military platforms will be exempt from these proposals in accordance with ICAO conventions. The airspace elements of the mandate will then ensure the necessary action by Air Navigation Service Providers (ANSPs). By mandating RNAV 1, the platform is established from which more advanced standards, such as RNP 1 can be introduced where the aircraft fleet is equipped and an airport and Network business case exists. It could be argued that the London area should be mandating the ICAO RNP 1 navigation specification as the LAMP timescales are closer to those of the European regulations. However, the scope of those regulations are only likely to apply to Heathrow, Gatwick and Stansted due their high number of ATMs and it would be surprising if within the LAMP Phase 2 design there was not a number of RNP arrival and departure routes. However, the European regulations will not address the wider LTMA efficiency and the necessity to have a systemised environment at all London airports where Network connectivity is required. The advantage for NATS and the user community comes from taking that step towards a PBN environment upon which airspace can be migrated from RNAV 1 to RNP 1 as the fleet capability develops and the demand for more advanced navigation specifications becomes established. The LTMA includes smaller airports such as Southend, Biggin Hill, Farnborough and Northolt and the consultation will help eliminate the full impact on those operations. The mandate specifically Page 18 of 23

targets network performance in controlled airspace, especially the modernisation of extant arrival and departure routes and to the introduction of new routes. The mandate will not impact on sports and recreational flying outside of controlled airspace. Page 19 of 23

7. Consultation Questions The consultation questions are designed to solicit views of stakeholders on the key aspects of the LTMA mandate, including the impact assessment. An open question is included for stakeholders to offer any further thoughts on any aspect of the LTMA mandate that the CAA may have overlooked. Q1. Technical Scope a. Do you agree with the CAA s defined technical scope for the LTMA mandate? b. Are there any additional impacts the CAA should consider? Q2 Geographical Scope a. Do you agree with the CAA s defined geographical scope for the LTMA mandate? b. Are there any additional impacts the CAA should consider? Q3. Organisational Scope a. Do you agree with the organisational scope for the LTMA mandate? b. Are there any additional organisations impacted by these measures? Q4. Timelines a. Do you agree with the planned timeline for the introduction of the LTMA mandate? b. If not, please explain why not. Q5. Exemption Policy a. Do you agree with the proposed Exemption Policy for the LTMA mandate? b. If not, please explain why not. Q6. Any other issues a. Any other comments you would like to offer the CAA concerning implementation of the LTMA mandate effective on operators by 09 November 2017 and on NATS and airports by 07 November 2019. Page 20 of 23

Annex A: ANSP AOC ATM ATMs CAS FAS FASIIG ICAO IFR IR LAMP LTMA NATMAC Glossary of Terms Air Navigation Service Provider Air Operators Certificate Air Traffic Management Air Traffic Movements Controlled Airspace Future Airspace Strategy Future Airspace Strategy Industry Implementation Group International Civil Aviation Organisation Instrument Flight Rules European Commission Implementing Rule NATS London Airspace Management Programme London Terminal Manoeuvring Area including the airports of Heathrow, Gatwick, Stansted, Luton, London City, Southend, Farnborough, Biggin Hill and Northolt. National Air Traffic Management Advisory Committee Part SPA Operations requiring specific approvals of Commission Regulation (EU) No. 965/2012 (AIR-OPS) PCP PBN P-RNAV RNAV 1 RNP 1 SES SESAR Pilot Common Project linked to deployment of SESAR enablers Performance-based Navigation is an ICAO concept utilising on-board navigation equipment capability including accuracy, integrity and continuity coupled with functionality in a given airspace environment, delivering area navigation procedures in all flight phases. European Precision RNAV. Applicable as a terminal airspace specification with criteria first published in November 2000. P-RNAV was later superseded by the ICAO specification RNAV 1. A terminal airspace standard applicable for SIDs/STARs and Runway Transitions with a navigation accuracy of +/- 1 NM for 95% of the flight time. RNAV 1 is the basis for all procedures currently under development at UK airports, including LAMP. A terminal airspace standard similar in both performance and functionality as RNAV 1, except it provides greater assurance of navigation position and therefore allows greater reliance to be placed on the aircraft capability rather than on the ground monitoring system provided through Air Traffic Control). Single European Sky Single European Sky Air Traffic Management Research Page 21 of 23

SID STAR STC TA TMA Standard Instrument Departure route Standard Arrival route Supplemental Type Certificate Transition Altitude Terminal Manoeuvring Area Page 22 of 23

Annex B: Relationship of RNAV and RNP within an Airspace Concept RNAV 5 is a continental enroute specification with a navigation accuracy of +/- 5 NM for 95% of the flight time and is applied today on all UK ATS routes. Airspace Concept Com Nav Surv ATM Nav Applications Nav Specifications RNAV Specifications Nav Infrastructure RNP Specifications RNAV10 (RNP 10) RNAV 5 RNAV 2 RNAV 1 RNAV 1 is a terminal airspace specification applicable for SIDs/STARs and Runway Transitions with a navigation accuracy of +/- 1 NM for 95% of the flight time. In Europe it was formerly called Precision or P-RNAV. RNAV 1 is the basis for all procedures currently under development at UK airports, including LAMP and NTCA programmes. RNP 4 RNP 2 RNP 1 Advanced RNP RNP 0.3 RNP APCH RNP AR APCH RNP with Added Requirements e.g. 3D, 4D RNP APCH (approach) highlighted in the ICAO Assembly Resolution. RNP specifications offer similar performance to RNAV specifications e.g., 1 NM but greater assurance of that performance through monitoring and alerting onboard the aircraft. RNP potentially offers reduced ATC controller workload and closer spaced routes. Advanced RNP is the basis of the proposed EC PBN Implementing Rule and has no single performance designation e.g., 1 NM, as it has the capability to meet multiple flight phase performance requirements from 2 NM to 0.3 NM. Page 23 of 23