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EASA Note: Subject: Adherence to Filed Flight Plans in European Airspace

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EASA Note: Subject: Adherence to Filed Flight Plans in European Airspace

Old 29th Jun 2019, 07:39
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EASA Note: Subject: Adherence to Filed Flight Plans in European Airspace

EASA has issued a ‘Note’ on ‘Adherence to Filed Flight Plans in European Airspace’.

EASA Note

Its key point is ‘It is important that aircraft operators and ATS adhere to filed flight plans unless there are safety reasons’. I interpret the message to be ‘don’t ask for directs or higher levels than planned’.

This has caused some confusion amongst colleagues, especially at one operator which does all flight planning at max weights, but often operates with much lower payload - so we may be planned at FL300 but able to go much higher, for example.

Meanwhile, it seems to be business as usual when airborne, with controllers still offering directs and better levels, leaving me unclear whether to follow management instructions to obey the EASA instruction and insist on staying on the plan, or save time, money (and in a tiny way, the environment), and accept the better option.

I have, for now, stopped asking for directs or better levels.

May I ask Area ATCOs in Europe to comment?
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Old 29th Jun 2019, 18:09
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A place where pilots may enter the 'lions den' that is Air Traffic Control in complete safety and find out the answers to all those obscure topics which you always wanted to know the answer to but were afraid to ask.
Or not, as the case would seem to be. I'd really appreciate some answers (and I'll admit to being a yellow licence holder myself, with an area radar rating, albeit now expired for many years, so you can imagine you're amongst friends!).
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Old 29th Jun 2019, 21:19
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Originally Posted by TheiC View Post
EASA has issued a ‘Note’ on ‘Adherence to Filed Flight Plans in European Airspace’.

EASA Note

Its key point is ‘It is important that aircraft operators and ATS adhere to filed flight plans unless there are safety reasons’. I interpret the message to be ‘don’t ask for directs or higher levels than planned’.

This has caused some confusion amongst colleagues, especially at one operator which does all flight planning at max weights, but often operates with much lower payload - so we may be planned at FL300 but able to go much higher, for example.

Meanwhile, it seems to be business as usual when airborne, with controllers still offering directs and better levels, leaving me unclear whether to follow management instructions to obey the EASA instruction and insist on staying on the plan, or save time, money (and in a tiny way, the environment), and accept the better option.

I have, for now, stopped asking for directs or better levels.

May I ask Area ATCOs in Europe to comment?
I have been retired for a while, now, but it would seem to me that this is the tail wagging the dog. If the controllers providing the service offer, or are willing to accept requests which are not included in the flight plan, what is the problem ? I do know that people sitting in ivory towers ( not ATC towers) sometimes have no actual understanding of real ATC & issue their directives in ignorance of reality ( thinking that they are, in some way, helping the overall situation), so I would say - not actually knowing what lies behind this - that you should not be afraid of departing from the flight plan if it is offered to you, or if you make a request to do so which is approved. The whole ethos of ATC, as I know it, is to assist the pilots in moving the traffic safely, expeditiously & efficiently.
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Old 30th Jun 2019, 05:51
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Certainly at London, there's a "file it, fly it" directive that's come from somewhere above us. Essentially, there's a lot of traffic routing around slot delays and then asking for more direct routes once they get airborne, either just across our FIR or to go direct through Brest when they've filed oceanic down the Tango routes for example. It also says we have to leave you at your flight planned level as well to avoid overloading sectors down route that we may not know about. So if you file FL310 in our airspace, that's all we're supposed to give you until you leave the London FIR. The example we were given was that last summer we climbed two aircraft above their filed level and then further down the line a sector at Marseille was overloaded with two extra aircraft being the tipping point.

The mockery of this comes when we have three aircraft all planned at FL370 through the same point within a couple of minutes of each other, at least one of them will end up at FL350 instead and going South through BHD that will put you into a different Brest sector that you weren't flight planned into which is what we're supposed to be avoiding Also, we cap you at a certain level for 200 miles and then watch you climb the moment we hand you over to the French as well.

The exception to this is traffic going to places that have an agreed level out of UK airspace to nearby destinations like Paris/Brussels/Amsterdam etc so you can request what you want in those cases and we'll try and accommodate you
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Old 30th Jun 2019, 06:52
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It's just as frustrating for us as it is for you. File it fly it is fine as long as you can actually get to the filed level. Being stopped lower for traffic reasons or aircraft load issues can and does push you into different sectors that can get overloaded. Happens very regularly from CLN/NOR London sectors into Maastricht.

I'm presuming that this EASA directive (which I haven't seen) is the root cause of London not being able to offer cross border directs this summer into Europe. Thus causing more frustration on the parts of pilots expecting them and the ATCOs that want to use them to help the sectors run more effectively.
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Old 30th Jun 2019, 08:08
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Some informative, & fair, points made in response from ATCOS at the “coal face”.Just shows that you soon lose touch with operational realities once you retire !
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Old 1st Jul 2019, 05:45
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Very grateful for those replies.

So, a cynic might say that this is a weak reaction to the problem of under-capacity, by introducing rules rather than fixing fundamental problems. I’d find it hard to argue with that.

Someone more forward-thinking might ask why the system can’t flex more and what the economic and environmental costs are of this move.

So my next question is, what inhabits the space between flow control and coordination? Why can there not be some form of medium-term flow control/coordination which tries to optimise, for both controllers and pilots, rather than restricting? Which looks for genuine overloads, not hypothetical ones, and also spots opportunities to exploit airspace optimally?

As I say, apart from a few TRUCE and STAC events, and some other liaison which has never focused on this issue, I’ve been out of the ACC world for a long time, so it may be someone can cast a more positive light on this?
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Old 1st Jul 2019, 06:36
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A lot of what you ask for is already going on. Certainly at LHR we will be looking at the rest of the day and the next day for route bias and working with airlines to swap, say Frankfurt and Cologne flights from going out through Dover to Clacton (and vice versa), or on a southabout transatlantic day, requesting the Dublin flights go north rather than out through Compton.

The problem is that everything in terms of capacity planning has to be based on the planned 4D trajectory, and if that route isn’t followed (regardless of the fact it was given a short cut for the best of intentions), all that planning goes out the window.

We are moving from ‘first come, first served’ to ‘best planned, best served’.

If you you wait until an overload situation is developing to do something, it’s far too late.
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Old 1st Jul 2019, 07:45
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Thanks Gonzo, but what do you mean by 'best planned'? Best for ATC or for the operator?
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Old 1st Jul 2019, 09:11
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As in sticking as closely as possible to the flight plan you’ve said you’d fly.

For example, at A-CDM airports, you have to call ready for push/start within 5mins of TOBT. the idea being that if you think you’re not going to make it, you have to update TOBT.

if you had a TOBT of 1000, it would be very tempting to, at 1004, change TOBT to 1001, in an effort to keep at the ‘front of the queue’ (this moving all those with TOBTs at 1005 back by one minute, and so on, updating your TOBT by 1 minute every minute.

To avoid this, most A-CDM systems at busy airports will be running a ‘late updater’ penalty, and a fairness algorithm, so that now you cannot update to a TOBT in the past, and if you update inside TOBT-10, you will effectively get placed in the next position in the start queue that’s available that won’t delay others. However, if you update early, then you are treated more favourably and won’t pick up so much of a delay.

The whole point of it is to encourage predictability and to remove the human behaviours that we have all seen (file through low level sector and request high level cruise en-route, or file multiple flight plans and fly the least restricted).
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Old 1st Jul 2019, 21:12
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Part of problem lies in air carriers and their HR politics. Saving money for people T&C, training and education is very effective but you can't attract those who knows how to make bussines more effective.
I have never heard that someone who knows how system ( ATM, NM etc) works, has left ANSP ( especially those paid by CRCO) and join air carrier.
​​​​​​​It is just too big difference in T&C and less social security.
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Old 2nd Jul 2019, 17:30
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Speaking of A-CDM and predictability, at LEBL we have been told by ATC that no runway crossing will be available this summer because Eurocontrol wants more predictable taxi times. A crossing normally saves about 5 minutes (50 kg of fuel at least, or equivalent to running the APU for 1 hour), and even if we’d wait at the holding point to keep the takeoff time “predictable” we could save a lot of fuel by the occasional crossing, when traffic permits of course! But now we are looking at taxiing around the whole airport even if we’re the only aircraft around, in order to be “predictable”.
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Old 2nd Jul 2019, 22:10
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I can only see this getting tighter too and the "we're running late, any directs please?" being met with a stern "no". Why? Say 20 aircraft get airborne from various Spanish airfields and are expected to arrive exactly 1 minute in trail when they get to the UK entry fix. The first couple have filed a TAS of T460, but are actually only going along at M0.76 as the company have told them to only fly at IAS245 at all times. The next few all fly at M0.77/78 along their standard route and get their optimal requested flight levels. The last few are stuck underneath the ones already airborne and only get FL310/FL330, but they do get some great directs saving up to 30nm (Spanish boundary direct to the UK entry point). On top of this they are also a little late so they go full pelt at M0.78/M0.79. Now you are faced with a situation at that UK entry point where the 20 aircraft 1 minute in trail are now 20 aircraft crammed into 20nms from first to last, all wanting to get into the same airport, and the sector in question suddenly gets an unexpected overload that flow control could never protect.

There is a route through the airspace I control that the "usual direct" can save an average of 6 minutes on the flight time in UK airspace alone, that can be enough to overload a sector 1000nm away.

TheiC you ask why can there not be more flex in the system - simple, compatible & dynamic systems. For us to climb an aircraft to a level other than that filed means we would need to assess the impact of doing so, and making sure if that pushes a sector such as one of the Marseilles ones over the edge, that everyone in the line from me to Marseilles know that this aircraft needs to be level changed to go through the original planned sector. Systems just do not have that capability and flow control at this time isn't that dynamic.

I wish it all could be far more predictable because the consequences aren't that great.
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Old 3rd Jul 2019, 17:30
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Well, I'm grateful for all the replies.

In summary, it seems to me that the system has reached the point at which its managers believe that it cannot cope with flexing, and therefore the many beneficial direct routings and better levels which we have enjoyed until now are at an end.

Their justification is that flexibility delivers unpredictable overloads. However, I don't believe that assertion necessarily stands up to scrutiny. For example, the kinds of variability which zonoma describes will produce those overloads even in this brave new world of 'file it, fly it', and not all directs and level improvements will deliver overload - in fact, many of them may prevent overload by avoiding clumps in traffic (remember, randomness comes in those clumps).

I must ask, will we now get speed-trapped? If we've filed .76, and fly .78, what will the fines be?

I'm charmed that zonoma mentions Spanish en-route control as an example. For decades, many Spanish ATCOs (and experience tells me that they are lovely people with whom I'd be delighted to share a cold one) have been unable or unwilling to apply speed control effectively - I have flown almost the whole length of the country 2,000 ft above another AGP inbound, only to be given drastic speed control at ToD and a stepped arrival leaving us high and needing extra track miles, when a simple mach restriction on first contact by Madrid would have streamed us beautifully. (I now apply my own if I gather that we're running with other traffic for the same destination; it seems to work but I guess it might give me speeding 'points' in the future!).

If all of zonoma's traffic gets that 6-minute-saving direct, there'll be no overload - it'll all just fly through subsequent sectors 6 minutes earlier than it would have done (assuming a more-or-less uniform pattern of traffic).

In the nicest way, I'm afraid I don't buy the 'we can't climb you because we don't know the impact downstream' argument either. Climb me, and then ask me to descend again if necessary. That's where coordination should work, in the way it didn't work for that Marseille controller.

In the heirarchy of responses to challenging situations in complex technical environments, introducing new rules lacks credibility; the 2019 world should be better than that. This whole area needs to be re-thought, properly, and across State boundaries.

Finally, there seems to be no answer to the freight operators (for whom I do some of my work), flying at night, and filing low because they may end up flying at MTOW. In freight operations, the load figures may not be available until STD minus 30, and frankly re-filing then is probably in no-ones interest. Surely there is a better answer than flogging around Europe in the dead-of-night empty airspace at inefficient levels, to satisfy a rule which addresses day-time incapacity?
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Old 3rd Jul 2019, 20:41
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To be fair I haven't seen one freight or mail flight not get its requested level when different from the filed level on a night shift. Or not get a big direct.
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Old 3rd Jul 2019, 22:53
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TheiC - you make many valid points and I hope to elaborate more on a few. Being early can be just as catastrophic as being late, it all depends on the segment you are now in compared to where the system predicted you to be. Some of my areas are affected by danger areas that when active high level, vastly reduces the flow rate as it takes 5 separated routes and forces all that traffic down just one single airway. You fly slow just before activation and then you turn up in the first period of activation and add to the restricted flow. Similarly, you get a slot in the first period after the activity finishes and turn up early, you then are in a more severe flowed segment and cannot fly the anticipated route as the danger areas are still active, the ATC workload can be huge.

Sadly there currently aren't any perfect answers. We cannot get the camera vans out to say "stop speeding/Oi fly quicker". I only use the Spanish/French directs as that is my experience and I have seen first hand the consequence. There are two airlines I regularly work who fly speeds vastly different to other operators of the same aircraft type, however the system processes the same speed for them all. The difference in flight time is significant. Sadly my 6 minute saving is about 4 aircraft an hour out of the 60-80 aircraft the sectors work. I'd love to be able to climb you to your optimum knowing where you need to descend again to conform with flow restrictions, however very few European systems inform the controllers where/when you need to be descended or which sectors you are flow restricted through. Having system compatibility means having systems that can talk to each other, which is currently very limited and unlikely to improve in the foreseeable future.

At night that simply depends on the controller, if you asked me, I'd make the calls and check the system, but it's not always simple or clear.
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Old 4th Jul 2019, 04:22
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Could be?

Could be a response to some operators policy of filing plans with non-realistic levels (let's say ryanair to london filed with fl240), and as soon as they exit approach, they request Fl360/380 and a direct??? That pretty much messes the entire nmoc / predictible flow idea.
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Old 4th Jul 2019, 07:50
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Gonzo & zonoma have made some very important points in their answers to the question. I thought, in my ignorance , that this was an issue where the planners were exercising their ideas without fully understanding the operational situation fully , & doing things because they could & pushing their own ideosynchratic ideas (& perhaps there might , occasionally, be an element of this) regardless of operational reality; but, the explanations from these two have been very enlightening & have provided a very good explanation of the operational facts & problems. I accept their answers fully. Well done.

Last edited by kcockayne; 4th Jul 2019 at 07:51. Reason: spelling mistake
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Old 4th Jul 2019, 12:57
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Once Target Time of Arrival (TTAs) are common, I'd imagine (hope) flight crews will end up refusing directs if offered and if it would take their projected ETA out of the TTA tolerance.
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Old 7th Jul 2019, 01:02
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Whilst computer flight planning systems are incredibly accurate nowadays thanks to very accurate upper wind and temperature forecast data, these systems never take into account the possible last minute loading changes, which may result in the flight planned levels not being achievable. There has to be some 'flex' in at least level allocation even if there will be none for lateral tracking.

Originally Posted by Gonzo View Post
Once Target Time of Arrival (TTAs) are common, I'd imagine (hope) flight crews will end up refusing directs if offered and if it would take their projected ETA out of the TTA tolerance.
One issue with TTA is that the shorter the distance remaining to the fix, in turn requires more aggressive changes to the speed to achieve the TTA. My lot did a trial a few years ago and it was soon shelved, as ACCs were complaining of 'unexpected' speed changes in the cruise and this was even more than a couple of hours before landing. Could such technology only exacerbate this problem of not flying what is filed initially?
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