Luchtverkeersleiding Nederland
LVNL
LVNL – Air Traffic Control The Netherlands provides air navigation services for Amsterdam Airport Schiphol, Rotterdam The Hague Airport, Groningen Airport Eelde and Maastricht Aachen Airport and en-route services up until FL 245 (± 8 km).
ID: 943962512957-38
Lobbying Activity
Meeting with Henrik Hololei (Director-General Mobility and Transport) and DFS Deutsche Flugsicherung GmbH and skeyes
21 Apr 2021 · SES2+
Response to SESAR Common Project 1: Concluding the pilot phase of the SESAR deployment framework
31 Aug 2020
LVNL would like to thank you for the opportunity to provide comments. We want to share the following remarks on the draft implementing regulation.
AF1: The PCP Performance Based Navigation (PBN) part of AF1 and the sub-functionality "Enhanced Terminal Airspace using RNP-Based Operations” are no longer included in the CP1 regulation. However, no explanation has been included in the draft regulation under “Whereas” for this. Previous information given at workshops and in SSC meetings has shown that this has been removed because a PBN regulation (2018/1048) already exists, fully understandable, because double regulation is undesirable. However, this PBN regulation does not cover the full scope as described in the PCP regulation. More specifically, the PCP regulation also mentions "transitions" in addition to SIDs and STARs, while transitions are not part of the PBN regulation. The SESAR Deployment Programme (Edition 2018, page 51) clearly states what is intended by the PCP regulation, namely: “… arrival procedures including transition to final approach procedures”. Is the Commission aware of the consequences of this removal by the CP1 proposal and is it the intention of the commission to amend the PBN regulation so that it will have the same scope as described in the PCP regulation?
AF1: In the description of AMAN / DMAN integration, under 1.1.2 system requirements it is stated that this applies to runways operated in mixed mode. However, under 1.2.2. it says, "applies to airports that have single runway or dependent runways, which may operate in mixed-mode or have departure runway linked with dependency to an arrival runway", that is inconsistent with each other.
AF2: It says that Airport safety nets consist of “the detection and alerting of conflicting ATC clearances to aircraft and deviation of vehicles and aircraft from their instructions, procedures or routing”. The system requirements state that “Airport conformance monitoring must integrate A-SMGCS surveillance data and when available surface movement routing and air traffic controller routing clearances. It is strange that a route is required for the safety nets, but that the sub-functionality “Automated Assistance to Controller for Surface Movement Planning and Routing” has been dropped. This should be consistent and, for the optimal functioning of the safety nets, including the A-SMGCS routing and planning function.
AF3: In the PCP regulation, under the geographical scope, it is stated that “Flexible Airspace Management and Free Route shall be provided and operated in the airspace for which the Member States are responsible at and above flight level 310”. In CP1 the flight level 305 is stated only for “Free route airspace”, with the consequence that Airspace Management and A-FUA must be provided and operated on all flight levels. It is not reasonable to set this new requirement at such a short notice, namely a deadline of December 31, 2022. Is this an error and does the minimum flight level 305 also concern Airspace Management and A-FUA?
AF4: It is stated that FF-ICE flight plan data must be used for automated support for traffic complexity assessment. However, an FF-ICE flight plan is not mandatory (according to ICAO) and is still at the beginning of its introduction. Wouldn't it be better to say that the FF-ICE flight plan data should be used if available?
AF6: Point 6.2 contains an incorrect text that apparently belongs to AF3 and the correct geographical scope should be included.
AF6: In the implementation target date (6.3.1), it says that “Point 6.1.1 applies to all flights operating as general air traffic in accordance with instrument flight rules within the airspace above flight level 285”. This minimum flight level should be stated under geographical scope and it should made clear if this minimum flight level also relates to system requirements for ATS units providing air traffic services below FL 285.
Read full response19 Mar 2019
In the original regulation article 3 was dedicated to the status of responses and article 4 was dedicated for the use of data base information. We miss these articles in the new proposal and want to see them taken onboard again.
Origineel was er nog een artikel 3 dat apart over die responses ging:
Article 3
Status of responses to safety recommendations
1. The access to safety recommendations responses shall be limited to addressees of safety recommendations.
2. Any addressee of a safety recommendation may request access to the responses contained in the database mentioned in Article 1, in particular the Member States Civil Aviation Authorities and the European Aviation Safety Agency. Safety Investigation Authorities outside the European Union may also request access to the responses contained in the database mentioned in Article 1.
3. Addressees of safety recommendations shall address their request to the European Commission. L 342/46 Official Journal of the European Union 14.12.2012 EN ( 1) OJ L 295, 12.11.2010, p. 35.
4. The European Commission shall assess the request and decide on a case-by-case basis whether the request is justified and practicable.
Article 4
Use of database information
Safety recommendations and their responses shall not be used to apportion blame or liability.
Read full response