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End of ATSOCAS

Old 15th Aug 2019, 11:07
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End of ATSOCAS

I understand that EASA will be mandating as of January 2020 that no Air Traffic Control service can be provided outside of CAS - i.e. class G. (There are 5 years to implement it apparently.) This will obviously mean the death of Deconfliction, Traffic and Procedural services as we know them, unless a UK type fudge can be found. I am struggling to find the exact references for this change. EU 373 Part ATS does not seem to give me the nuts and bolts of it. Anyone out there able to help with the specific references? (Apologies for having to ask, which I take as a personal failing on my part....)
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Old 15th Aug 2019, 11:25
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The term ATSOCAS was changed some time ago in favour of FIS(s) in order to create the very fudge to which you refer - and we do not provide a control service outside CAS.

2 s
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Old 15th Aug 2019, 11:38
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2 Sheds,

Sorry - I'm not currently using them being in class D. So, does that mean that we will happily be able to still provide these services - which however you crumble the cookie are CONTROL - or not? That's what I need to know (with refs if possible.....) Someone in the CAA told me they'll be outlawed shortly.

??
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Old 15th Aug 2019, 15:15
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No. We will not be able to provide vectors to any traffic outside CAS, unless for emergency avoiding action. So no DS, and no Approach Control Service (i.e. vectoring to an instrument/visual approach) as we know it today for Class G airports.

EASA view is that if an airport has ATC, it must have CAS.

The pragmatic (??) solution is to create lots of Class E.

ATS.TR.200:
ATS.TR.200 Application Air traffic control service shall be provided:
(a) to all IFR flights in airspace Classes A, B, C, D and E;
(b) to all VFR flights in airspace Classes B, C and D;
(c) to all special VFR flights;
(d) to all aerodrome traffic at controlled aerodromes.
CAA response from this doc:

https://www.easa.europa.eu/sites/def...-09%28B%29.pdf

CAA Comment: At present, the UK permits elements of an ATC service to be provided outside controlled airspace by air traffic controllers. Historically, the UK’s stance has been that the requirement for controlled airspace was required to be proven based on the nature of the operation and its associated risks. This stance was supported by the UK’s codification of ICAO FIS requirements through the development and application of ATS outside controlled airspace and the performance-based safety oversight by the competent authority.
Consequently, from the UK’s perspective, Part-ATS represents a paradigm-shift in ATS provision and the application of the airspace classification system. The UK CAA supports the principle that ATC service is provided by air traffic controllers within controlled airspace and aspires to move towards this position. However, implementation of these provisions represents a significant challenge – specifically in terms of our operations within uncontrolled airspace – which we believe will require considerable time to bring to a conclusion.
The UK CAA assesses that this implementation period will extend well beyond the traditional timescales applied by EASA and the Commission for transitional arrangements, given the need to address and mitigate structural, procedural and resource impacts. As such, the UK CAA seeks to engage further with the Agency and the Commission to determine how that transition can be safely managed. Justification: UK implementation of Part-ATS proposals concerning the provision of air traffic services in uncontrolled airspace represents a significant challenge which the UK CAA believes will require considerable State, Competent Authority and industry resource to bring to a conclusion. The impacts and potential ways forward cannot yet be definitively identified nor costed; however the cost impacts are currently considered to be considerable. Transition must be undertaken in a safe and efficient manner and cannot be undertaken in haste; hence the UK CAA's firm belief that an extended transition period is required in this regard.
EASA Response: Partially accepted. The ATS organisation in the UK and the challenges relevant to the implementation of Part-ATS are duly noted. EASA is prepared, during the transitional period, to allocate the necessary resources needed to support its implementation in the Member States. The intent is to organise various implementation workshops and, when necessary, bilateral consultation events. The proposed date for entry into force of the amendments to Regulation (EU) 2017/373 concerning Part-ATS is 27 January 2022. EASA also proposes a flexibility in the applicability date by proposing the possibility to derogate from the application or requirements concerning the provision of services in Class G airspace, up to 22 January 2025, under specified conditions.
More EASA
​​​​​​​The provision of ATC service within Class G airspace seems to be unusual in consideration of the variety of airspace Classes which are available in Regulation (EU) No 923/2012 (SERA) for the selection when deciding the appropriate service to be provided. Since the provision in ATS.TR.150(a) foresees that the competent authority could suspend the VFR operations in the vicinity of an aerodrome, that would mean that this possibility implicitly exists also for uncontrolled aerodromes.
...
​​​​​​​Vectoring in uncontrolled airspace should only allowed in adverse weather conditions, as stipulated in point (a)(3) of AMC1 ATS.TR.160(d)(3) as proposed with NPA 2016-09. Allowing vectoring in class G airspace would de facto transform that part of the class G airspace into controlled airspace.
​​​​​​​

Last edited by Gonzo; 15th Aug 2019 at 15:35.
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Old 15th Aug 2019, 16:45
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Gonzo,

My dear fellow, that is EXACTLY what I was after. Thanks. You may have gathered that I am running to catch up a bit on this and jumping onto a roundabout that has been spinning for a while is challenging. Your post and the links mention vectoring but do not specifically mention the usual Procedural Approach Control techniques to achieve separation, requiring a/c to fly specific tracks, levels, arcs etc. I take it though that the spirit of EASA's logic would apply equally to APP. This therefore will have as big a knock on effect for non-radar procedural units as those with surveillance. Take a scenario where an APP has a deemed separation stating that once an a/c has gone beacon outbound on a published instrument approach, a departure may climb straight ahead until above the arrivals level before turning on track. "Control"? Well, yes sort of but not quite in the sense of a controller "choosing" a vector depending on a/c position. EASA are doubtless not going to stop IFR a/c flying published approaches outside of CAS! (Are they.....?!!)

I agree that therefore a pragmatic approach might be class E. But to me that changes little for non-radar units. You still don't know that the "unknown" VFR traffic, who is not talking to you and does not require a clearance to enter the airspace, is out there! Now a "situation display" of a surveillance nature - with TMZ if needed by the technology in use - to give APP some idea that there is VFR traffic out there, when combined with class E - now that makes sense to me.

Thanks for the assistance. Further thoughts welcome.

LISSART
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Old 15th Aug 2019, 17:08
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Even if civilian controllers are prevented from providng ATSOCAs, the RAF will still have a 'need' to provide them as apart from Brize Norton and Northolt, they operate entirely in class G airspace. .
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Old 15th Aug 2019, 17:53
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This is one hell of a change proposed and without a ‘fudge’ could severely effect many airports- how does somebody vector a sequence outside CAS for example?
So- reclassify all airspace so there’s hardly any class g left or expand every control zone so they’re all linked up ?

Any bright ideas on this?

Sorry- can’t find the relevant reference either!
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Old 15th Aug 2019, 18:44
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Does not Chevrron make an excellent point? PAR and all... Maybe they will fudge it with extended MATZ dumbbells or something. Or just call it "military imperative."
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Old 15th Aug 2019, 19:07
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Sounds like an expensive exercise with little safety benefit to me. Creating swathes of Class E that are going to require ATCOs to provide a service at a time when there is a national shortage is surely not the best solution:ugh
Given that aircraft flying VFR in class E have no obligation to receive an ATC service, other than separating against other IFR aircraft which will likely be receiving a service anyway, why would vectoring in class E be any safer than class G?
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Old 15th Aug 2019, 19:54
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Originally Posted by possibleconsequences View Post
This is one hell of a change proposed and without a ‘fudge’ could severely effect many airports- how does somebody vector a sequence outside CAS for example?

That's the point, EASA thinks that shouldn't be happening, and in the next 5 years or so it won't be (usual assumptions about the B-word and EASA apply). Quite a few airports also commented on the NPA, but EASA is standing firm. ATC = inside CAS. Outside CAS = FIS/AFIS (as in limited to radar-derived traffic information at the top end).

Anyone fancy doing a CAP1616 process for about 50 airfields?..........
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Old 15th Aug 2019, 20:28
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I have read through the first 400 pages of the 600-odd in the EASA link posted by Gonzo above. Actually, a lot of it was really interesting. Interesting also to note who responded from the UK - Humberside for example. Clearly EASA are committed to seeing this through. While I would instinctively support folk's rights to do what they like, where they like, if they are legally allowed to do so - I'd support the freedom principle if you like - surely that is all very well until people exercising those freedoms choose to fly through the instrument approach track for CAT into a class G airport at 1000' and 3 miles. Having worked procedurally at a radar unit I've seen some worrying moments. (Yes, I know what the ATM is supposed to be used for!!) Freedom to do what you want is one thing but sound airmanship is another. Can any GA pilot really complain about having to carry and operate a transponder to have access to a TMZ for example? If the same is contiguous with class E you can drive through it VFR without talking to anyone but the people who NEED to know you are there do! So you won't hit that airliner you didn't see.... What ever the statistics about mid-airs and airprox's surely nobody will argue too much with that argument. Procedural Approach in class G has never been (for me) about separation of known traffic - that was the easy bit. It is about what you didn't know. Although the rule book said that if you didn't know about the traffic then it was not your problem. Maybe we should ask the Italians. I was under the impression that ALL of their airspace is controlled.
As to the CAP 1616 process, if the CAA support the principle of CAS - which they say they do - and EASA are mandating it, then surely the process becomes rather more straight-forward!
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Old 15th Aug 2019, 21:10
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I am with EASA. I have always thought that vectoring IFR traffic in Class G is dangerous - ever since I tried it at Coventry in 2007/8. ATCOS operating in busy Class G do a wonderful job, but they are risking their licences every time that they do it !
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Old 16th Aug 2019, 08:50
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The following paragraph is taken from mats part 1, section 1, chap 1.

5.3 Air traffic control service shall be provided:
(1) to all IFR flights in airspace Classes A, B, C, D and E;
(2) to all VFR flights in airspace Classes B, C and D;
(3) to all special VFR flights;
(4) to all aerodrome traffic at controlled aerodromes

Doesn't this mean that we are all complying with the proposed EU legislation already?

Unless EASA are mandating that we abandon the UK flight information services, but I can't see any reference to that.


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Old 16th Aug 2019, 10:58
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Originally Posted by kcockayne View Post
I am with EASA. I have always thought that vectoring IFR traffic in Class G is dangerous - ever since I tried it at Coventry in 2007/8. ATCOS operating in busy Class G do a wonderful job, but they are risking their licences every time that they do it !
I did it at Lindholme in '73 (Northern Joint Radar Service Area) and at Farnborough from 1974 to 2008.
It's OK when you get used to it and the Area Radar course at the college included a few sessions on it.
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Old 16th Aug 2019, 11:15
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I worked it for 18 years at Newcastle, when they only had a small class D zone, less towards the end when Newcastle was linked into the airways system. It is manageable especially now the military are significantly reduced. At times it can be difficult I remember giving a BA B752 three virtual orbits on its way to Pole hill trying to keep my 5nm from military fast jets. We used to have LHR controllers come up on FAM flights and say they couldn't do this!! Happy days....
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Old 16th Aug 2019, 11:53
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Originally Posted by Lissart View Post
Can any GA pilot really complain about having to carry and operate a transponder to have access to a TMZ for example?
As long as buying and installing a transponder cost between 20 and 25% of the value my aircraft, I will complain.

Originally Posted by Lissart View Post
If the same is contiguous with class E you can drive through it VFR without talking to anyone but the people who NEED to know you are there do! So you won't hit that airliner you didn't see.... What ever the statistics about mid-airs and airprox's surely nobody will argue too much with that argument.
Pure class E works in plenty of places in the world. Why does UK ANSPs and UK CAA cannot trust the pilot to judge and maintain VMC?
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Old 16th Aug 2019, 20:35
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Because operating in UK Class D, a significant element of CAT aircrew, and many GA pilots, have little understanding of the responsibilities pertaining to the provision of ATS. Many CAT crews have an expectation that ATC will ensure that their flight does not encounter conflicting GA traffic, even if pertinant traffic traffic information has been passed to both aircraft, and they can see each other. If a TCAS alert is received, CAT crews have an obligation to respond. This automatically generates a Safety Report from both aircrew and ATS, resulting in a chain of events starting with the pulling of the controller for investigation, and potentially leading to Licence suspension. This has been discussed at great length on another British GA forum.
Some GA pilots operating VFR believe that it is acceptable to fly in close proximity with IFR traffic that they can see and avoid: fine for them, but almost inevitably the CAT crew will file a report. Again, this results in action under the SMS, and, if the number of reports increases, those running the SMS may turn to the ANSP manager and request the adoption of practices that stop the encounters happening.
The guidance being offered recently from the ATS regulatory side is that these conflicts should be prevented, meaing that ATC have to actively segregate or deconflict the aircraft involved.
The upshot of all this is that ANSPs, in order to satisfy the regulators and the local SMS, are likely to become very cautious when granting access to CAS of VFR traffic, and if it is allowed to enter, to proactively manage potential conflicts, using a level of intervention which is far more restrictive that permitting VFR pilots to 'see and avoid'. Access to CAS, and VFR operations within it, have been discussed at length on another British GA forum.
Another consideration that must be be understood is that the ATS system in the UK is not 'national'. ATS operations in many Class D zones, and at those airports hosting CAT which are located outside CAS, are supporting the business of the airport. If the SMS of an airline operating into one of these airports is recording a high number of incidents involving conflict or perceived conflict with GA VFR aircraft, it is likely that the airline's safety department will approach the airport operator for an explanation, or more probably, a resolution that stops their operations being impinged on by the VFR traffic. The business priorities of the Airport, its operator, and its shareholders, will come first. Transiting GA traffic, or the provision of ATSOCAS in adjacent Class G areas, will not generate any income, and will require staffing. If I am managing an airport in the UK, competing with an adjacent airport for high end traffic that pays the highest fees, service provision to aircraft that are not landing at or departing from my airport will not be my priority. I need to keep my paying customer satisfied, and if it means restricting the transit of GA aircraft through our airspace, or minimal service provision to aircraft flying adjacent to it, so be it. I can always use our SMS to claim that I am reducing risk.
There has been much discussion about ATS provision outside CAS, access to CAS, and ATS operations within CAS, on another GA forum. Many of the contributors call for a a level of service provision to the GA community that mirrors that of the USA, or one that offers a level of service that is far in advance of what is available now. What these posters should remember is that ATS outside the airways system in the UK has been privatised, fragmentised, and encouraged to adopt a business-based model. The result is a disconnected service that reflects on the business needs of the airport from which it is provided, and is provided on the basis of the local business requirements and resources. If the GA community believe that this can be replaced by some kind of national joined-up system funded by the taxpayer, they are in clooud cuckoo land.
Assuming the UK complies with the EASA requirements, there will seemingly be an expansion of CAS to accomodate the instrument procedures for those airports presently sitting in Class G. Where the associated controllers are going to come from, and how they will be funded, I cannot say. What I do forsee, however, is an increasing reulctance of ANSPs, for all the reasons I have expanded on above, to permit GA traffic the access to this new CAS on a see-and-avoid basis, and a reduction in ATSOCAS provision to aircraft operating outside CAS, further adding to the level of discontent felt by elements of the GA community.
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Old 17th Aug 2019, 08:54
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A very comprehensive , informative & factual answer. Thank you.
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Old 17th Aug 2019, 10:49
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As kc said, except...

If I am managing an airport in the UK, competing with an adjacent airport for high end traffic that pays the highest fees, service provision to aircraft that are not landing at or departing from my airport will not be my priority. I need to keep my paying customer satisfied, and if it means restricting the transit of GA aircraft through our airspace, or minimal service provision to aircraft flying adjacent to it, so be it. I can always use our SMS to claim that I am reducing risk.
...the concept of "our" airspace. It is airspace of a notified classification in which the procedures for the application of ATS are/should be consistent world-wide.

​​​​​​​2 s
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Old 17th Aug 2019, 11:16
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Controlled airspace doesn´t have to be Class A-D. For small airfields with few IFR movements Class E down to the ground allows IFR and doesn´t prevent VFR operations for no good reason.
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