CPDLC Mandate - FokkerWho Is Ready In The Air? The true level of equipage is actually unknown. Requiring aircraft operators to insert J1 into item 10 of the ICAO flight plan form was

CPDLC Mandate

Where Does The Aviation Industry

Stand?

An article by Fokker Services

The benefits of Controller Pilot Data Link Communications (CPDLC) remain apparent: improved operational efficiencies and safety, simplified flight deck Air Traffic Control (ATC) communications for pilots, and a substantial 11% air traffic capacity increase for Air Navigation Service Providers (ANSPs) when CPDLC reaches 70% usage. To prepare for the mandate, comprehensive steps have already been taken. SITA/ARINC ground stations now cover most of Europe and the overwhelmingly high demand on the single CPDLC frequency has been recognized and responded to. As a result, automatic switching between five frequencies has been introduced and this figure is likely to increase further as demand continues to rise.

Despite this progress, the journey to implement the February 5, 2020 mandatory regulation has been far from straightforward. From infrastructure related delays to inconclusive debates about exemptions – setbacks have caused confusion and frustration within the aviation industry. The Data Link Support Group (DLSG) event organized by Eurocontrol in September 2019 was highly effective in bringing stakeholders together. However, its varied contributions and five year absence highlights the somewhat fragmented and incomplete path towards the date set by the European Commission.

Direct from the DLSG event in Brussels and the Data Link User Forum (DLUF) in Dublin, Fokker Services shares the latest updates associated with this complex and imminent mandate.

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Introduction

Courtesy of Eurocontrol: Data Link Performance Monitoring Function (DPMF) September 2019 Performance Report

Ground Infrastructure

Insufficient readiness on the ground was the main reason for delaying the mandate from the original compliance date in 2015. As seen in the diagram below, it is encouragingly clear that the Aeronautical Telecommunication Network (ATN) operational status is almost complete, with the reported capability to provide data link services to approximately 72% of flights in the European airspace.

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Who Is Ready In The Air?

The true level of equipage is actually unknown. Requiring aircraft operators to insert J1 into item 10 of the ICAO flight plan form was designed to give an early indication of progress towards CPDLC readiness. The consequent monitoring of flight plans appears to show that only 30% of all European traffic and 37% operating over FL285 are equipped (see figure below). However, it seems that in some cases operators have chosen not to file J1, even if equipped. This is because, in their view, they are not operationally ready.

The elements contributing to this viewpoint include incomplete proving tests, development of operating procedures, and completion of staff training. Anecdotally, Eurocontrol also describes a “chicken and egg” situation in which one third of pilots and one third of controllers are not using the system because they experienced, or believe that, the other party is not doing so. As a result, there is a need to encourage further data link usage in order for everyone to experience the full benefits.

Courtesy of Eurocontrol: J1 Flight Plan Sections, September 2019

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The Lists

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Courtesy of Eurocontrol: PA Rate Graph, August 2019

The latest reports from Eurocontrol show that the average Provider Abort (PA) rate is five per 100 flight hours, against a target of one per 100 flight hours, and with a slightly worsening trend over the last few months since the step improvement presented by the introduction of multi-frequency (see graph below). Additionally, unpredictable results with some data link users have been reported, including amongst more experienced users. This situation is currently under investigation and likely influenced by factors including:

» Aircraft type/avionic equipment combinations. » ATN network processing. » Operational practices.

In an effort to improve the PA rate, ANSPs MUAC, Skyguide, NAV Portugal and DSNA decided to initially focus on avionics, and collaborated to establish a “White List”. This list consists of aircraft types and equipment configurations to help distinguish between good and poor PA performance. If flying through the airspace controlled by one of these four ANSPs, it was decided that it is only permitted to log on to data link services to use CPDLC over ATN if the operator’s combination of aircraft type and avionics is on the White List.

For now, whether this sets the necessary standard for all European ANSPs, or whether it adds a controversial additional level of compliance beyond the regulatory requirements, remains an open question. It creates a situation in which an operator may be compliant with the regulation, but is unable to log on to data link services in skies controlled by the specified ANSPs. The ANSPs operating the White List are determined when they describe their commitment to the White List approach because of its positive contribution to the overall objective. The list is not applied across all European ANSPs but, in the opinion of Eurocontrol, it should be in order for the maximum benefits to be realized.

Another interesting fact is that an operator initially becomes eligible for White List status as a result of not being

on the “Black List” (or “Gray List”). Therefore, it is possible for operators with White List status, due to their combination of aircraft type and avionics configurations, to only be there temporarily.

This is because these operators, in some cases, have not demonstrated that they really belong on the Black List, and not because their PA performance is satisfactory. Should an operator find itself on the Black List with some or all of its aircraft, then serious consideration should be given to rectifying that status, up to and including a change to or modification of installed equipment. Operators may temporarily be given Gray List status when performance is judged to fall below the target threshold, but the dataset is inconsistent or too small for a final decision.

The benefits of improved operational efficiency and safety will be gained even if an exemption decision is made in favor of the operators’ aircraft type.

White List & Black List

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» 60% of ATC/flight crew related incidents are related to problems with voice communications content, which CPDLC would largely address.

» VHF for communications is old technology with fragility issues; either it is not always available, or suffers interference when it is available. Examples include simplex transmission, weather static, solar, and line of sight. Whilst CPDLC still uses VHF, there is a robustness improvement due to a combination of short message transmission time and the inherent verification feature of connection to ATN.

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Also, interesting conversations continue to take place within the affected community about the “Best Equipped, Best Served” concept. The concept may be controversial for those with exempt aircraft in that it could be seen as introducing a bias in favor of equipped aircraft, when exempt aircraft are simply that; exempt. However, it could only really be considered controversial if the ANSPs were to take a conscious action or decision to impose an unfavorable operational environment. In fact, the introduction of CPDLC itself naturally creates a favorable situation for those equipped, in the same way that any technological advancement brings with

it certain advantageous benefits. For this reason, some at Eurocontrol are less publicly vocal about the “Best Equipped, Best Served” aspect of CPDLC. At its extreme, this perceived bias may also be contributing to the delays at the European Commission in finalizing the exemption list.

What is clear is that operators with equipped aircraft (that are on the White List) will “naturally” receive a better service, with all of the featured benefits, than those relying on voice communication alone. For example, with:

» When ATC is busy, continuous climb clearances may not be possible using voice communications, but will continue to be available using CPDLC. » When ATC is busy, it is unlikely the flight crew will receive “Direct To” routings, whereas they will still be able to receive such routings with CPDLC.

Improved Safety Improved Operational Efficiency

The European Commission will decide on the applicability of CPDLC, and whether certain aircraft types may be exempt. It published its draft implementing decision with draft exemption annexes in July 2019, and opened a period of feedback which ended August 9, 2019. Within the range of feedback, a number of operators commented on the logic of CPDLC applicability to older Airbus A320 aircraft.

The European Commission has not made its final decision on exemptions, but a representative stated this was likely to be end 2019 or early 2020. This leaves relatively little time for operators hoping for exemption, but

suddenly finding themselves needing to comply by February 5, 2020. In the opinion of Eurocontrol, and others, the lack of Exemption List finalization is a contributory factor to the current level of equipage.

Operators waiting to see if they are on the exemption list is understandable from one viewpoint. However, this could be risky as there is a strong drive from Eurocontrol to realize the targeted benefits and consequences for non-compliance, which are also not yet determined. Those tempted to wait for the Exemption List to be published should know that standalone and economical solutions are available. The benefits of improved operational efficiency and safety will be gained even if an exemption decision is made in favor of the operators’ aircraft type. At the moment, it is considered unlikely that changes will be made to the current draft European Commission implementing decision and its exemption annexes.

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Operators waiting to see if they are on the exemption list is understandable from one viewpoint. However, this could be risky.

Exemption List

MAN

DATE

Viewpoints: The Three CPDLC Lists

The White List will enable an overall PA rate of less than five to be achieved. Currently operated by MUAC, Skyguide, DSNA and NAV Portugal, Eurocontrol believe it would be beneficial if all ANSPs adopted the same standard.

As the European Commission has not yet finalised its exemptions decision, Eurocontrol believe that this is contributing to a lower than targeted level of equipage and will delay the air traffic capacity improvement timetable.

Eurocontrol strongly recommend that operators with aircraft/equipment on the Black List should stop using their equipment due to its unreliability, and upgrade before the mandatory compliance date.

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WHITE LIST

BLACK LIST

EXEMPTION LIST

Read through our quick guide below to discover the features of these three lists, as well as the different operator benefits and viewpoints:

Aircraft and avionics equipment updated monthly that are proven to deliver a good PA rate performance, or are not on the Black List (or Gray List). For example, the Spectralux Dlink+ at software mod revision 5 offered by Fokker Services is on the White List.

The White List is the best place to be from a regulatory compliance and operational performance perspective. Operators want to see return on their CPDLC investment, and enjoy the Eurocontrol “Best Equipped, Best Served” status.

Aircraft and avionics equipment that are proven to exhibit a PA rate performance of 50% worse than comparable aircraft over a four month period, and where there is at least 250 hours of usage data from which to judge performance.

Note: Temporary Gray List status is given when performance is judged to fall below the target threshold, but where the dataset may be inconsistent or too small.

Operators with Black List equipment will be regarded as compliant with the CPDLC regulation, but will not be able to use their equipment in areas covered by ANSPs using the White List. There may be justification to challenge this, but Eurocontrol remains determined to deliver targeted results that are only achieved through inherently good quality, data link communications. The Eurocontrol position is logical, reasonable and likely to be maintained. Therefore, the decision to upgrade to White List avionics is highly recommended.

Operator Options & Viewpoints

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WHI

TE L

IST

From July 12 - August 9, 2019, operators could provide feedback to the European Commission on its intended implementation decision (including exemptions). This period has now ended, and the final decision is expected by the end of 2019 or early 2020.

It may be tempting to await the final decision on aircraft exemptions, particularly for older A320 aircraft operators. However, delaying the decision to equip may result in insufficient time to do so if aircraft are not exempted. These operators would be exposed to the risk of a non-compliance penalty. Also, there are significant operational and safety benefits to be gained from equipping, regardless of whether an operator’s aircraft are on the exemption list.

BLAC

K LI

STEX

EMPT

ION

LIST

List Eligibility/Requirements

Though the White List and Black List names may change, their purpose will be preserved. Operators equipped and on the White List can relax. They are compliant with the forthcoming regulation, and can enjoy the full operational and safety benefits from being “Best Equipped, Best Served”. Operators of aircraft/avionic equipment on the Black List will be unable to log on to ATN with the four ANSPs, even if compliant with the regulation. There is no need to tolerate this. Talk to an organisation like Fokker Services to discuss how to get on the

White List. When it comes to the Exemption List, operators should not wait for this to be finalized. Act now to start benefitting from CPDLC and avoid unknown non-compliance penalties.

Now is the time to equip aircraft fleets with an effective solution to ensure White List status for the fast-approaching February 5, 2020 deadline. Regardless of which list an operator may find itself on, CPDLC benefits can bring a competitive edge in the crowded European airspace environment.

The Bottom Line

Now is the time to equip aircraft fleets with an effective solution to ensure White List status for the fast-approaching February 5, 2020 deadline.

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For more information on Fokker Services’ CPDLC solution, please contact Iris van den Nieuwenhof, Regional Sales Director, EMEA, Fokker Services: [email protected]

Watch the Fokker Services CPDLC video here to find out more about the upcoming mandate as well as Fokker Services’ solution.

For more information on the subjects tackled in this article, please refer to Eurocontrol’s website and WikiLink main page.

Disclaimer: The material and information contained in this paper are for general information purposes only. You should not rely upon the material or information in this paper as a basis for making any business, legal or any other decisions. Whilst we endeavor to keep the information accurate and topical, Fokker Services makes no representations or warranties of any kind, expressed or implied, about the completeness, accuracy, reliability or suitability with respect to the paper or the information contained therein for any purpose.

CPDLC Mandate: Where Does The Aviation Industry Stand? Document publication date: November 28, 2019.