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Status of EASA AMC Development Geoff Burtenshaw Directorate of Airspace Policy UK CAA
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10 February 2009CNS/ATM Steering Group2 Overview NPA 2008-14 AMC 20-26 (RNP AR operations) AMC 20-27 (RNP APCH operations) AMC 20-28 (LPV operations) Step Down Fixes (SDF) Coding
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10 February 2009CNS/ATM Steering Group3 Background As part of rulemaking programme, EASA published NPA 2008-14 at the end of May 2008 Comprised 2 draft AMC documents –AMC 20-26, RNP AR Operations –AMC 20-27, RNP APCH including APV Baro VNAV 3 month public consultation period
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10 February 2009CNS/ATM Steering Group4 NPA 2008-14 Consultation 342 comments received –29 general comments –183 comments against AMC 20-26 –130 comments against AMC 20-27 In fact multiple comments against each entry Commentors included: –FAA, DGAC, CAA, TCA, Boeing, Airbus, Cessna, Embraer, Honeywell, Thales, Garmin, KLM, BA, AEA, ECA, AOPA-Sweden, Eurocopter, EUROCONTROL, ECOGAS, Skyguide, IFATCA, Walter Gessky
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10 February 2009CNS/ATM Steering Group5 Disposition of Comments Since RATF#5 –EASA Rulemaking Task 20.003 RNP/RNAV Review Group Meeting held 2 nd meeting on 10th - 11th December 2008 –Comment disposition of comments against AMC 20-27 handled off-line –Meeting therefore concentrated on review of comments against AMC 20-26 Some contentious issues
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10 February 2009CNS/ATM Steering Group6 AMC 20-26 (RNP AR Operations) All comments now reviewed Disposition agreed except for comments in the following areas: –Paragraph 7.1 Minimum Required Functions for RNP AR operations, Table 1 Item 1 - Continuous Display of Deviation Item 12 – Numeric Display of Deviation –Clarification of the role of lateral and vertical deviation indication in the pilots primary field of view, Navigation MAP display and numeric display of deviation –Scaling, requirements for RNP 0.3 NM and RNP < 0.3 NM –Differences between acceptable means of compliance applied in US approvals and consistency with EASA position expressed in previous certification projects
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10 February 2009CNS/ATM Steering Group7 AMC 20-26 (RNP AR Operations) –Paragraph 7.2 Additional Required Functions Supporting Complex RNP AR Operations, Table 2 Item 1(4) - Upon initiating go-around (through activation of TOGA), the flight guidance mode should remain in LNAV to enable continuous track guidance during an RF leg –Acceptance of other means and/or mitigations Item 2(3) – TOGA to LNAV requirement applied to RNP < 0.3 NM –Where other means acceptable, should only be allowed for RNP 0.3 NM and RNP > 0.3 NM –Consistency with EASA position expressed in previous certification projects
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10 February 2009CNS/ATM Steering Group8 Outcome Review group could not reach agreement on disposition of contentious issues Decision taken to refer Items to EASA Panel of Experts for consideration and resolution
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10 February 2009CNS/ATM Steering Group9 AMC 20-27 (RNP APCH Operations) As mentioned, disposition of comments to AMC 20-27 completed off-line Seven remaining comments not addressed Mainly associated with the operational characteristics of the procedure and the need for operator evaluation under EU-OPS 1.975 (Appendix 2) –Considered a burden on the operators and unjustified Action for EASA Rulemaking to discuss internally with Flight Standards specialists
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10 February 2009CNS/ATM Steering Group10 Status EASA updating the CRD and AMC 20-26 as a result of the December Review Group meeting Position paper with two contentious issues still need to be presented to the EASA Panel of Experts AMC 20-27 outstanding issues need to be resolved internally by EASA Finalised CRD and updated AMCs will be published for review and any dissenting comments Final Decision 2Q2009?
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10 February 2009CNS/ATM Steering Group11 AMC 20-28 (LPV Operations) At previous meeting: –Final draft of AMC nearing completion –Indication that EASA Rulemaking Programme would be amended to include the AMC 20-28 for LPV within the ToR for Task 20.006 (Miscellaneous AMC) –However, the NPA was not planned to be available until 4Q2009, with a Final Decision not before 1Q2011 Comments provided to EASA at November AGNA meeting
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10 February 2009CNS/ATM Steering Group12 AMC 20-28 (LPV Operations) At same meeting a Working Paper was presented by the Agency under priorities for ATM related matters in the rulemaking programme Reported that an NPA will shortly be available for AMC 20-28 and that it is proposed to issue it a soon as possible to meet the deadlines envisaged by the mandate (2009) The mandate referenced is Commission mandate (M 408) to support the Single European Sky regulations to develop Community Specifications on APV (Approach with Vertical Guidance) A new Agency task should therefore be included in the rulemaking programme
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10 February 2009CNS/ATM Steering Group13 Status Draft 1.4 of AMC 20-28 provided to EASA Additional comments being provided by FAA and Honeywell Awaiting preparation of an NPA prior to publication Even if NPA appears in this quarter, Final Decision not before 1Q2010 But an improvement on before
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10 February 2009CNS/ATM Steering Group14 Step Down Fixes (SDF) Recall that States had expressed concern with practice of Data Service Providers coding SDF Could potentially lead to hazardously misleading information i.e., only showing depiction of distance to SDF
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10 February 2009CNS/ATM Steering Group15 Step Down Fixes (SDF) EUROCONTROL submitted a WP to ICAO IFPP Integration Working Group just prior to RATF#5 Comprised a shortened version of EASA CNS/ATM Steering Group Position Paper (PP049-5) Also included a copy of CAA Letter taking unilateral action to request Data Service Providers not to code step-down fixes as waypoints in the final approach for UK published non-precision instrument approach procedures
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10 February 2009CNS/ATM Steering Group16 Status EUROCONTROL WP has largely taken over events Text being developed for inclusion in ICAO Doc 8168, Vol II, Part I, Section 4, Chapter 9 To be reviewed next month within the Integration Working Group and then presented to the IFPP Working Group of the Whole meeting It would be interesting to know what action is being taken by other European States Survey?
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