Status of EASA RNAV Approach AMC Development and SDF Discussion

1. Status of EASA RNAV Approach AMC DevelopmentandSDF Discussion B. RABILLER / DGAC-DCS

2. Overview • NPA 2008-14 • AMC 20-26 (RNP AR Operations) • AMC 20-27 (RNP APCH) • AMC 20-28 (LPV) • Step Down Fixes (SDF) Coding

3. Background • As part of rulemaking programme, EASA published NPA 2008-14 at the end of May • 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

4. 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

5. Disposition of Comments • Next step is preparation of a Comment Response Document (CRD) and updated AMC • Meeting 17-19 September started the process • Another meeting planned before end of 2008 • AMC 20-27 the easier document to disposition • Unfortunately we can not split the CRD • Target for completion by end of 2008 • EASA Decision 1Q2009

6. AMC 20-26 (RNP AR Operations) • Main comments: • Clarification of applicability to departure operations i.e., not just Approach and Missed Approach • RNP System performance demonstration • Display requirements for low RNP • Applicability to rotorcraft and GA • Deviations from existing FAA and PBN text • Differences between EASA and FAA systems of approval • Existing fleet qualification

7. AMC 20-27 (RNP APCH) • Main comments: • Some OPS requirements have been considered as airworthiness requirements in particular in Appendix 4 • Reinvestigation of existing installation should be clarified • Concerns have been expressed regarding the Vertical Total System error concept and in particular the Vertical FTE budget • To confirm the necessity of having two separate altimeters for APV Baro VNAV operation

8. AMC 20-28LPV OPERATION

9. AMC 20-28 Status(formerly AMC 20-LPV) • End of July 08, EASA indicated the possibility to expedite the issuance of the AMC relative to LPV provided : • It exists a mature document • A final draft is available end of September 2008 • The EASA objective was to amend the TOR for task 20.006 (various CNS AMC’s update) to include the LPV AMC (AMC 20-28). • In order to reach this objective: • A new AMC draft was issued end of July 08 (Draft 1.3) • This Draft circulated for a short period of time (6 weeks) at the EASA working group level • AMC draft (Draft 1.4) should be issued soon to include these comments • But EASA work programme 2009 is still under discussion??? • Anyway from a technical point of view, we have to continue the work • At the last meeting AMC 20-LPV draft 1.2 was discussed

10. AMC 20-LPV Draft 1.3 content versus Draft 1.2 (1/2) • AMC 20-LPV Draft 1.3 takes into account, when applicable, editorial comments and document format modification which have been applied to the AMC 20-27 (RNP APCH) published in the NPA 2008-14 • In particular section 10 regarding operational criteria is now divided in several sections (a new para 10 plus two annexes, one for the ops procedures (annex 3) and one for the flight crew training (annex 4) . • Withdrawal of the lateral and vertical accuracy table including APV I and II performance. The AMC accuracy section is only referring to the ICAO Annex 10

11. AMC 20-LPV Draft 1.3 content versus Draft 1.2 (2/2) • Withdrawal of text and figures extracted from DO 229 ( ) in order to prevent duplication of requirements in the AMC. Only cross reference to the RTCA document is provided. • New required function added (Item 2) regarding the necessity to indicate to the crew the « GNSS approach mode » : e.g. LNAV, LNAV/VNAV or LPV • New required function added (Item 3) regarding the necessity to indicated to the crew the distance to the LTP/FTP ( Landing Threshold Point/Fictitious Threshold Point).

12. AMC 20-28 draft 1.4 (1/2) • Comments on AMC 20 –LPV Draft 1.3 received in August and September 08. • Reference of this AMC is now AMC 20-28 • Title is changed and proposed to be: • « Airworthiness approval and operational criteria for RNAV GNSS approach operation to LPV minima using SBAS ” instead of « Airworthiness approval and operational criteria for LPV approach operation” • In order to better reflect the AMC content • This title change impacts the whole document from an editorial point of view

13. AMC 20-28 draft 1.4 (2/2) • Concern associated to the “Low altitude alert” function was expressed by an equipment manufacturer • Nuisance alert rate (e.g. when aircraft is ATC vectored to the FAP at a different level than the promulgated one) • FAA confirmed this “low altitude alert function” issue • It is proposed to suppress this required function • Pre flight planning (Appendix 3 paragraph 1.1.c) • Operator procedure asking to check that a non-GNSS approach is available at the destination or at the alternate is relaxed under certain circumstances • No more required if the relevant ANSP or airspace authority doesn’t require it (e.g. in US NAS with WAAS) • Alleviation necessary to address European operator flying in US • ETSO C 146a and C 145a should be issued • Reference to (at least) DO 229C is essential

14. Step Down Fix Discussion

15. 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 • JAA CNS/ATM Steering Group undertook to prepare a Position Paper (PP049) outlining the standards and practices and making recommendations • Intended that EASA should transmit the paper to ICAO IFPP for action within their Integration Working Group

16. PP 49 Status • Draft version 5 of PP049 prepared after July CNS/ATM Steering Group meeting • Sent to interested industry parties for comments • Responses from Universal Avionics and Garmin • Critical of certain illustrations, but no adverse comments on recommendations • Final version in preparation

17. Status of IFPP discussion • Not to miss the opportunity of ICAO IFPP meeting in Seattle three weeks ago, EUROCONTROL have submitted a WP for discussion within the Integration Working Group • Based on PP 49 recommendation • Make proposal to amend PANS OPS Vol I and II • IFPP Conclusion “This WP identifies some charting issues related to a stepdown fix in a final segment and makes proposals for amendment of PANS OPS, Volume I and II to clarify the charting requirements. The proposals included in this WP will contribute to safety of air navigation through consistency in the operational information included in the profile view of instrument approach charts with reference to the information presented in airborne systems. They also support the CDFA concept. The group agreed with the proposals in principle but felt that the WP should be considered in conjunction with specific charting proposals and that the IWG should prepare a complete mature proposal for IFPP/4 that includes the specific charting proposals.”

18. SDF next step …. • To close PP 49 • To wait IFPP/4 conclusion next year (March?) in order to have a coordinated position at international level • However it doesn’t mean that unilateral decision at state level will not be taken before • E.G. Germany or UK position

19. Questions