Instrumental Flight Procedures (GNSS Based) To Non .
Instrumental Flight Procedures (GNSS based) toNon Instrument RunwaysCarmen Aguilera, European GNSS Agency (GSA)Jose Maria Lorenzo, European Satellite Services Provider (ESSP)Chris Neville, European GNSS Agency (GSA)
Instrumental Flight Procedures for General Aviation(GNSS-based)The following document provides an assessment of the current operational requirements to perform RNPAPCH operations down to Localizer Performance with Vertical guidance (LPV) on small Aerodromes,without the need to upgrade runway infrastructure.This document provides a view on the current implementation solutions in different EU countries and basedon EASA RMT developments, identifies the gaps on the implementation process that would need to bemodify in order to set a proportionate scenario for General Aviation IFP implementation. It has beenprepared by European Satellite Services Provider S.A.S. (ESSP SAS) under its EGNOS Service Provisioncontract with the European Global Navigation Satellite Systems Agency (GSA).This document is published for information purposes and does not commit ESSP and/or the GSA. It may becopied in whole or in part for non-commercial purposes only (not for sale), provided that the sourcesinvolved in the preparation of the document are acknowledged. The information in this document shall notbe modified without prior written permission from GSA.Released: October 20172
Instrumental Flight Procedures for General Aviation(GNSS-based)Table of Contents1Introduction. 42Concept View. GNSS-Based instrumental operations for general aviation . 53Regulatory analysis of IAP implementation process for general aviation. . 64Summary . 14Appendix AIFP for GA in EU countries . 18Appendix BReference Documents and Acronyms . 273
Instrumental Flight Procedures for General Aviation(GNSS-based)1INTRODUCTIONGeneral Aviation market conducts millions ofoperations with a fleet equipped with GNSSreceivers demanding to benefit from the newaviation technologies. EU regulation has opened thedoor to enhance safety of small VFR AD with a lowcost implementation process for instrumental flightoperations. This document addresses theimplementation process, analysing the existingregulatory scenario and best practices in EUcountries.EASA Approach to General AviationEASA efforts are intended to enhance the safety ofGeneral Aviation operations with one of the focusset on the introduction of IFR operations. Adoptionof new ICAO classification is the main enabler forGNSS-based approach implementation, but otherEASA RMT, deeply analysed and conclusionsextracted during the document, are also part of thischanging process. These regulatory initiatives aredriven to have more proportionate requirementstailored to GA needs and covering all EASAdomains,from licensing to ATS or ADinfrastructure.EASA efforts have produced major progress onairworthiness and pilot licensing in GeneralAviation, with a proposal for a light Part-M, CS-STANin airworthiness, Single Engine Turbines for IMC inOPS and Basic Instrument Rating and DeclaredTraining Organizations in Pilot licensing. This willease IFR implementations for sure, butnevertheless, ATM and Aerodrome frames are notfully afforded to also set proportionaterequirements to enable GA instrumentaloperations.But this is still missing. This initiative contributes tomeet this objective, highlighting those RMTs whichcan be relevant for the implementation of IFR forGeneral Aviation tackling the missing points andproposing solutions. The solutions proposed are tobe further discussed and defined wherever feasibleby the GA community (ideally within EASA remits)shall conclude on the development of a ‘PracticalGuide’ to enable the use of GNSS-based operationsfor GA at VFR locations.The most representative EASA RMTs involved in theimplementation process which can be relevant forthe purpose of this document are as follows, alongwith the implementation roadmap: RMT.0591 Maintaining ADR rules. Introducesnew ICAO RWY classification.RMT.0719: Regular update of ATM/ANS rules.RMT.0464: Requirements for Air Trafficservices (introduces UNICOM services).RMT.0477: Technical requirements andoperational procedures for AIS and AIM (newAIS certificate).RMT.0455 Technical requirements andoperational procedures for airspace designincluding flight procedure design.RMT.0657 Easier access of General Aviation(GA) pilots to instrument flight rules (IFR).Introduces BIR and DTO.RMT.0677 ToR Easier access of General Aviation(GA) pilots to instrument flight rules (IFR) flyingquotes:“In this context, it is expected that ns for changes of the aircrew,airworthiness, ATM, and aerodrome, etc.requirements”.4
Instrumental Flight Procedures for General Aviation(GNSS-based)2CONCEPT VIEW. GNSS-BASEDINSTRUMENTAL OPERATIONSFOR GENERAL AVIATIONBased on the best practices used on USA and otherEU countries jointly with EASA rulemakingdevelopments, the following concept gives atheorical example of how to perform instrumentalapproaches at non-controlled Aerodromes.The main difference between operating at anaerodrome with ATC or non-controlled is thedifference about instructions or advisories. ATCissue clearance, taxi or arrival instructions onspecific ATC frequencies, meanwhile at nontowered AD, advisories are transmitted through adedicated frequency (UNICOM, not ATS), but theresponsibility for traffic separation, sequencing orknowing the local procedures falls on the pilot onboard.The objective of this section is to show a full GAscenario mixing all the elements, to provide anexample of an operation that tackles all relevantpoints and can be used as a starting point to definethe missing gaps.most part of the flight, reducing the non-controlledoperation to 3NM of the final approach segment.The AD has a non-instrument RWY available, withan instrumental approach procedure (RNP APCH)publishedonitsnational AIP jointlywith the info aboutthe services availableon its location, namelyan APP and UNICOMfrequency or thesourceofMETinformation. MET info needed for the approach canbe obtained from automated MET systems(AWOS/ASOS), or by a near MET station, properlypublished on AIP info.Following the principle ‘one in, one out’ only oneaircraft is cleared to enter on the vicinity of the AD,determined by a RMZ Class G. This ensures that theairspace is free of IFR flights, but no separation fromIFR/VFR aircraft is provided, so pilots shall separateOur scenario is composed by an aircraft equippedwith a certified GNSS-receiver (ETSO-145/146, i.e.Garmin GTN750) and a pilot holding a BasicInstrument Rating (BIR), which enables the use ofinstrumental approaches with a limit on theoperating minima of the approach down to 500ft.The aircraft enters in the airport vicinity airspaceClass E (until 1000ft AGL), and asks for an ATCclearance to perform an instrumental RNP APCH(with SBAS-based vertical guidance, down to LPVminima) from the designated APP unit. This airspacelimit Class E allows the aircraft to be controlled thethemselves. To contact other airspace users, pilotuses the UNICOM frequency, self-announcing to thesurrounding traffic their position and its landingintentions, even with blind messages. To end theapproach, the pilot finishes the procedure in VMC,5
Instrumental Flight Procedures for General Aviation(GNSS-based)integrating the aircraft into the visual approachcircling circuit.Once safely on the ground, the aircraft is requiredto contact ATC or AFIS via the phone or radio toclose the IFR flight plan, leaving the airspace free forother users to conduct a new IFR approach.3REGULATORY ANALYSIS OF IAPIMPLEMENTATION PROCESSFOR GENERAL AVIATION.After the analysis of the results of EASArulemaking tasks there are relevant aspectsregarding the implementation of GNSS-basedoperations at small AD involving almost everyarea. Some of them are already clear, but otheraspects may need further clarifications. Thissection summarizes the most representativeones, to identify the gaps or potential barriers ofIFR operations implementation for GA including aview of how to solve them when feasible, beingaware that further EASA developments couldchange the presented understanding.After each subsection the implementationsolution available (in blue) and the activitiesarisen to solve the existing barriers or improvethe implementation frame (in orange) are alsohighlighted.3.1 AerodromesESSP has performed a high-level market assessmentto value the number of potential aerodromes acrossEurope that features the AD scenario for GA. Mainconclusions drawn from the analysis are:-There are around 5300 non-instrumentalrunway ends at EU28 scope (2673 airports).-Most of these airports are serving private traffic(note that the BA/GA segment is the segmentbest fitted for SBAS nowadays).-Most non-instrumental runways are located inGermany, France, UK and Italy, representingalmost 75% of the airports.EASA each year also provides a list of AD under thescope of CR 139/2014 [RD-3], following thestatement in Article 4: Information to the EuropeanAviation Safety List%20of%20EASA%20ADRsArt%204%20%26%205.pdfThis list compiles also the AD expected to ask foran exemption due to traffic expected providinginfo about the Aerodrome operator.Basic Regulation application to AerodromesThe Aerodromes to which EASA Regulation appliesare defined in Article 4.3a (Basic Regulation (EC)216/2008 [RD-2]) as follows: Aerodromes, including equipment, located in theterritory subject to the provisions of the Treaty, opento public use and which serve commercial airtransport and where operations using instrumentapproach or departure procedures are provided,and:(a) have a paved runway of 800 metres or above; or(b) exclusively serve helicopters; Nevertheless, in Article 4.3b of the same Regulationsome derogation may be applied: subject to localarrangements. By way of derogation from paragraph 3a,Member States may decide to exempt from theprovisions of this Regulation an aerodrome which:handles no more than 10 000 passengers per year,and handles no more than 850 movements relatedto cargo operations per year. Aerodromes operating under VFR typically do notserve commercial air transport, so most of smallaerodromes are out of EASA Regulatory scope. Thissituation leads to local solutions which will probablynot be homogenous.With the introduction of ICAO new RWYclassification and definitions, instrumentalprocedures are considered to be implemented inany runways type, and therefore this could lead toa potential increase on the number of aerodromesunder the scope of EASA basic regulation.This document based on EASA RMT developmentstries to be a supportive documentation for thehomogenous application of LPV procedures in EASAand non-EASA aerodromes. The aim is to build acommon proportionate approach aligned with EASA6
Instrumental Flight Procedures for General Aviation(GNSS-based)criteria useful also to comply with EU national levelregulation.Runway requirements“non-instrument runway” - a runway intended forthe operation of aircraft using visual approachprocedures or an instrument approach procedureto a point beyond which the approach may continuein visual meteorological conditions.According to new ICAO RWY classification referredin ICAO Annex 14 [RD-4], IFP can be implemented atnon-instrument RWY, so there is no additionalrequirement in terms of RWY infrastructure isneeded to implement RNP APCH. This definition isexpected to be adopted at EU level by CR. 139/2004(ADR) [RD-3] in 2016 Q21To reinforce this understanding EASA Opinion 032016 [RD-16] quotes in its Executive Summary:“The specific objective of this Opinion is to maintainand, for specific types of runways (non-instrumentand non-precision), enhance the high level of safety.It facilitates performance-based navigationapproach operations with vertical guidance to beapplied at non-precision approach runways, andinstrument approach operations to be associatedwith non-instrument runways without the need inboth cases to upgrade runway infrastructure”Lighting requirementsRunway lights are not mandatory for a runwayintended for use during day-time2 (unless it is aprecision approach runway). The class of lightingfacilities available at the RWY does not have impacton the minima DH achievable, it has an impact onthe RVR needed to operate at the AD.RVR values range from 600m to 1300m for aDH 250ft (AMC5 CAT.OP.MPA.110, Aerodromeoperating minima, Table 5, [RD-11]).Obstacle Limitation Surfaces1At the time of the present document the provisions have notbeen implemented.2Lighting systems for night operation are not alwaysmandatory: CS ADR-DSN.M.625 Approach lighting systems:Implementing RNP APCH procedures down to LPVminima at non-instrument RWY does not introduceadditional requirements. The ICAO Annex 14 OLS(included in EU Reg 139/2004 Part ADR [RD-4]) aredifferent depending on the runway classification(non-instrument, non-precision and precision) andrunway code number, but it not depends whetherthere are Instrumental procedures implemented.Implementation solution: No upgrade on runway infrastructure is neededThere is no additional lighting system requirements.There is no additional OLS requirements.All RWY types (instrument or non-instrument) canimplement IFR operationsPBN based solutions with vertical guidance are highlyrecommended (3D approach type A)ADR certificateGM1.ADR.AR.C.035 includes EASA form for ADRcertificate (EASA Form 157 Service ProviderCertificate, [RD-12]).With the adoption of new ICAO RWY classification,IFP are allowed at non-instrument RWYs, so theterms of an existing certificate shall be modified toinclude IFR flights:-Note 3, conditions to operate: IFR.Note 5, type of approaches.Users experience shows that the process to modifythe conditions of an existing certificate is usuallydifficult, constituting a barrier to IFRimplementation (feedback provided by EuropeanRegional Aerodromes Community).Practical guide to CAA and AD operators on safetyimplications of the change from VFR to IFR in orderto upgrade the ADR certificate and any mitigationmean needed could help to make the processeasier.ADR-DSN.M.626 should be provided to serve a non-instrumentrunway where the code number is 3 or 4, and intended for useat night, except when the runway is used only in conditions ofgood visibility, and sufficient guidance is provided by othervisual aids.Non-instrument runway Applicability: Where physicallypracticable, a simple approach lighting system as specified in CS7
Instrumental Flight Procedures for General Aviation(GNSS-based)Implementation solution:Implementation solution:A change on ADR certificate (EASA Form 157 ServiceProvider Certificate) is needed to introduce IFRoperationsAFIS (with or without a limited certificate, subject toEASA/SES rules) and UNICOM (no ATS considered,national level) are tailored ATS solutions for GA. still work to do:ATS with limited certificateDevelop a practical guide with the steps and docs neededto change an ADR certificate including IFR operations.A limited certificate is a figure intended for smallservice providers, to allow having moreproportionate requirements to comply withATM/ATS requirements. It is not available for all SP,only for ANSP (ATS, MET, AIS, CNS).3.2 ATS level The nature and density of the traffic sampleexpected to operate at the AD. The metrological conditions and its influenceon the flow of air traffic. The geographical conditions of the ADsurroundings. The complexity of the airspace concerned.IR 373/2017 [RD-13] introduces a new approach toapply for a limited certificate from 1035/2011, withsome relevant differences. IR 1035/2011 [RD-14]set limited certificates (Art.5) as a derogationgranted by the competent authority of the existingrequirements, setting the responsibility ofmaintaining the safety level on Member States. IR2017/373 [RD-13] changes the point of view, now alimited certificate is a figure part of commonrequirements, ANSP do not obtain a limitedcertificate by the derogation of some articles, butcomplying with ATM/ANS.OR.A.010. This slightlydifference could enable the use of limitedcertificates for small ANSP through EU.For the purpose of implementing instrumentprocedures at an aerodrome, the following optionsare considered from more to less demanding:The scope of ANSP that could apply for a limitedcertificate does not change, small entities providingservices at locations with low traffic: Air Traffic Control service (ATC). Flight Information Service in an aerodrome(AFIS, certified or declared, when only aposition is open). ATS (ATC/AFIS) with a limited certificate. No ATC/AFIS.To determine the level of ATS to serve instrumentaloperations at an AD, an assessment considering thelocal conditions shall be issued. According to ICAOAnnex 11[RD-6] and the incoming Part-ATS [RD-13],this assessment shall consider:Implementing ATC or AFIS may result in a nonpositive business case in many small aerodromeswith low traffic. Therefore, the case that ispreferred at small aerodromes with low level oftraffic is no ATC nor AFIS but separation ensured bypilot communications reporting their positions andintentions (UNICOM). AFIS holding a limitedcertificate is also considered as a proportional ATSlevel for GA.ATSP planning to provide its services for: Aerial workGeneral AviationComercial Air transport MTOM 10tonnesor 20 paxANSP: With a gross annual turnover of less thanEUR 1 000 000Providing FIS with not more than oneposition at any ADANSP with a limited certificate are not required tocomply with the whole Annex IV, only the applicableprovisions listed on ATM/ANS.OR.010:(1) point ATM/ANS.OR.B.001 Technical and operationalcompetence and capability;8
Instrumental Flight Procedures for General Aviation(GNSS-based)(2) point ATM/ANS.OR.B.005 Management system;(3) point ATM/ANS.OR.B.020 Personnel requirements;(4) point ATM/ANS.OR.A.075 Open and transparentprovision of services;(5) Annexes IV, V, VI and VIII, where those requirementsare applicableThere are significant absences which require aneffort for small ANSP like change occurrencereporting(ATM.ANS.OR.A.065),contingency plans (ATM.ANS.OR.A.070), OperationsManual (ATM.ANS.OR.B.035) or liabilities andinsurance cover (ATM.ANS.OR.D.020).UNICOMNPA 2016-09 [RD-18] introduces UNICOM service.UNICOM is another feasible solution for nontowered aerodromes, designed to fill the gapbetween AFIS and no aerodrome service at all.This service comprises a frequency used by pilots toannounce their intentions at an aerodrome whereATS are not provided. It must be emphasised that aUNICOM service is not an air traffic service, meaningthat pilots must accept more responsibility for theiractions than when operating in a controlledaerodrome environment. As a reference, in somecountries such as USA or Australia, this service isprovided and a UNICOM frequency is clearly statedin the approach chart.UNICOM definition is out of EASA competences, andeach MS shall set the frame for its provision. Thelack of guidance to implement this new figure couldlead to a non-harmonized scenario and constitutesa barrier to its implementation.The needed formal agreements to ensure liabilitieswith other SPs in the case of UNICOM or ATS withlimited certificate could be ensured by the ADoperator. Aerodrome operators holding acertificate follow a similar scheme than ATSproviders, having similar provisions driven to ensuret
by the GA community (ideally within EASA remits) shall conclude on the development of a ‘Practical Guide’ to enable the use of GNSS-based operations for GA at VFR locations. The most representative EASA RMTs involved in the implementation process which can be releva
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