Stakeholder Consultation Workshop on the Draft Implementing Rule for Mode S Interrogator Code Allocation (MSI)

Transcription

1 Stakeholder Consultation Workshop on the Draft Implementing Rule for Mode S Interrogator Code Allocation (MSI) 25 th October 2007, Brussels, EUROCONTROL European 1 Organisation for the Safety of Air Navigation

2 AGENDA ITEM 1 WELCOME & INTRODUCTION WORKSHOP OBJECTIVES Jean-Luc GARNIER Head of Regulatory Unit EUROCONTROL European 2 Organisation for the Safety of Air Navigation

3 Agenda ITEM TIME SUBJECT PRESENTED BY 1. 10h00 Welcome and Introduction Presentation of the Workshop Objectives 2. 10h10 The MSI Mandate Context & Requirements JL GARNIER (DG/RU) JL GARNIER (DG/RU) 3. 10h20 The MSI Context N EERTMANS (DAP/SUR) 4. 10h45 The Regulatory Approach Overview of the draft IR 11h05 COFFEE BREAK P LOUBIERES (DG/RU) 5. 11h20 Economic Assessment D BOOKER (DAS/BMA) 6. 11h45 Main Outcome of the Formal Consultation + Start Discussion 12h30 Lunch JL GARNIER (DG/RU) 3

4 Agenda ITEM TIME SUBJECT PRESENTED BY 6. (Cont d) 13h30 Discussion of Main Outcome of the Consultation (Cont d) JL GARNIER (DG/RU) P LOUBIERES (DG/RU) 7. 14h30 The Way Forward Next Stepts JL GARNIER (DG/RU) 8. 14h50 Conclusions JL GARNIER (DG/RU) 15h00 End of Workshop 4

5 Workshop Objectives Discussion on the MAIN OUTCOMES of the Formal Consultation Reach a COMMON UNDERSTANDING on the Way Forward 5

6 AGENDA ITEM 2 THE MSI MANDATE CONTEXT & REQUIREMENTS Jean-Luc GARNIER Head of Regulatory Unit EUROCONTROL European 6 Organisation for the Safety of Air Navigation

7 MSI IR Mandate Mandate by EUROPEAN COMMISSION (March 2006) EUROCONTROL to assist in in the development of an interoperability implementing rule on the allocation and use of Mode S interrogator codes and will also address Civil Military Coordination. 7

8 Mandate Requirements Develop a draft implementing rule that identifies: The objective and scope of the rule; The process and procedures to acquire and implement Mode S Interrogator Codes; General requirements applicable to Mode S radar operators to provide the information required for interrogator code allocation; Requirements applicable to Mode S radars particularly on the capability to implement coverage maps; The provisions specifying the implementation conditions. 8

9 Development Process MSI Draft IR Regulatory Approach Consultation 26 Oct > 17 Nov 2006 First Stakeholder Workshop 6 December 2006 Regulatory Approach accepted by Commission 17 January 2007 Draft Final Report submitted to Commission 9 July 2007 Draft Implementing Rule consultation 9 July > 26 Sept 2007 Second Stakeholder Workshop 25 October

10 AGENDA ITEM 3 THE MSI CONTEXT Nicolas EERTMANS Surveillance Unit EUROCONTROL European 10 Organisation for the Safety of Air Navigation

11 Interrogator Codes Allocation Mode S Interrogators need to be allocated an IC Interrogators with overlapping coverage need distinct ICs or safe operation could be compromised Problem is European-wide Need for a safe, efficient and coordinated allocation mechanism 11

12 Initial Code Allocation Gentlemen agreement between France and Great Britain for their respective experimental program: II codes 1-7 allocated to France II codes 8-15 allocated to GB Germany later were allocated some codes for their own experimentation From 2000, need to protect POEMS trials and prepare the installation of operational Mode S radars Set up of the Interim IC Allocation project in 2000 Set up of the formal IC Allocation process in

13 Institutional Arrangements ICAO EANPG Provisional Council Final arbiter on unresolved disputes MODE S OPERATORS -ANSPs -Military ATS/AD(all armed forces) -Experimental -Industry -Other Mode S Operators Request to operate MODE S IC COORDINATION GROUP Member of Mode S IC Coordination Group Produce and update Mode S IC Procedures and Guidelines Accountable To NATIONAL REGULATORY AUTHORITY Assign IC FOCAL POINT(S) Request for IC Decision on IC EUROCONTROL MODE S IC ALLOCATION (MICA) CELL Effect Methodology and Modelling 13

14 ICAO EANP Attachment K to the ICAO EUR Air Navigation Plan (Doc 7754) Volume II, FASID Defining the Principles and Procedures for the Allocation of Secondary Surveillance Radar Mode S Interrogator Codes (IC) For ATS Purposes High-level provisions regarding the implementation and monitoring of Mode S IC allocations in Europe 14

15 EATMP Document Mode S IC Allocation Process Developed and endorsed by the MICoG Defines the detailed coordination process Focuses on: Process Roles & Responsibilities MICA Cell Focal Points Mode S Operators 15

16 IC Allocation Special II Codes II Codes 0 & 15 (not managed by MICA Cell) II 0 Reserved for operation w/o an assigned code Specific mode of operation prescribed in ICAO Annex 10 Vol IV Does not require international coordination Foreseen for mobile interrogators (airborne, shipborne and ground mobile or field-deployable interrogators) No operation on any other code without coordination!!! II 15 Under NATO management Could be used for fixed or mobile operations (eg AWACS) No operation on any other code without coordination!!! 16

17 IC Allocation Special II Codes II Code 14 (managed by MICA Cell) To relief the pressure on II codes available for operational radar, the principle of TRD stations sharing a single II code (14) agreed (CIMSEL, MICoG in 2002) No guaranteed detection performances Bilateral Coordination when required 17

18 IC Allocation Status October TRD, 128 operational ATC/AD fixed interrogators applied for an IC Since beginning 2005, demand exceeds supply, II code shortage experienced Conflict resolution proposed by the Cell are based on coverage restrictions Since September 2005, 75% of the code allocations were assorted with coverage restrictions Since September 2007, SI codes started to be allocated, with II/SI codes operation, but only to 4 capable radars fictitious coverage restrictions 18

19 Agreement on IC Allocation proposals becoming more difficult to achieve Increased number of installed radars Favoured ways forward: Clustering Technical, maintenance and cost issues SI codes II/SI mode, required to cope with less than 100% compliant transponders, not universally adopted Other options Coverage restrictions May jeopardise operational coverage requirements SLO RF congestion and acquisition performance impacts Since mid 2006, some radars could not get a code allocated for several cycles 19

20 Incident Happens People make mistakes Benefit of programming procedures IC Conflicts result in loss of detection from radars It can take time to identify Benefit of IC conflict monitoring It can take time to fix Benefit validated fall-back scenario 20

21 Opportunities for Regulation Ensuring that all Stakeholders meet specific obligations related to a common and harmonised Mode S IC allocation process Definition of a proper arbitration procedure Clarification of the responsibility of all EU States to ensure that all operators, in a particular State, are complying with the adopted IC allocation Mandating specific technical radar capabilities (e.g. II/SI code operation) to support the smooth implementation of allocations 21

22 AGENDA ITEM 4 THE REGULATORY APPROACH OVERVIEW OF THE DRAFT IR Pierre LOUBIERES Regulatory Unit EUROCONTROL European 22 Organisation for the Safety of Air Navigation

23 Outcome of the Regulatory Approach PREFERRED OPTION: Minimum prescription package Support of SI codes II/SI code operation with transition period MINIMUM PRESCRIPTION PACKAGE Required to guarantee the proper application of the existing process High level requirements in the IR & detailed technical requirements in Community Specification (CS) 23

24 Application of IR & CS Implementing Rule Radar Head Electronics Constituent Community Specification Conformity Assessment Verification of System EC Declaration of conformity 24

25 Minimum Prescription Package Includes basic rules to ensure that the allocation process works properly: Eligibility conditions for radars Mode S ICs subject to allocation coordination Definition of procedural obligations on: States Mode S Operators ANSP & ATSP 25

26 MSI Draft IR MAIN BODY Obligations of Mode S Operators Obligations of ANSPs and/or ATSP Obligations of Member States Obligations of Manufacturers Some obligations are specified with references to Annexes containing definitions or high level interoperability / performance requirements 26

27 MSI Draft IR (2) Article 1: Subject matter and scope Article 2: Definitions Article 3: Interoperability and performance Requirements Article 4: Associated procedures Article 5: Contingency requirements Article 6: Civil-military coordination Article 7: Safety requirements Article 8: Conformity assessment Article 9: Verification of systems Article 10: Additional requirements Article 11: Entry into force and application 27

28 Implementing Rule Layout IR Main body Articles Stakeholders obligations Annex II: Requirements for: IC application data IC allocation data Annex III: Requirements for II/SI Code Operation Which data exchange? Which required operation mode? Which conformity guarantees? Annex IV & V : Conformity Assessment & Verification of Systems 28

29 AGENDA ITEM 5 ECONOMIC ASSESSMENT David BOOKER Business Management Unit (BMA) EUROCONTROL European 29 Organisation for the Safety of Air Navigation

30 Value of the Rule Objective long term sustainability of Mode S deployment throughout whole implementation area avoidance of risks due to IC conflicts Demand for interrogator codes already exceeds supply of II codes Lack of SI code support would result in: difficult allocation coordination radar coverage constraints greatly reduced radar coverage radars to revert back to traditional Mode A/C These risks could jeopardise seamless operation of Mode S surveillance 30

31 Value of the Rule Special II/SI mode short-term alleviation of the II code shortage supports early introduction of SI codes before all Mode S transponders upgraded to SI capability IC Conflict Monitoring and Reporting enable IC conflicts to be detected and alleviated more readily reduces hazards associated with undetected conflict common solution avoids potentially hazardous proliferation of systems 31

32 Requirements of the Rule Implementing Rule: makes current code allocation arrangements mandatory adds IC conflict monitoring and reporting Implementation of the Rule will require: upgrades to radar equipment functionality the operation of code allocation procedures IC conflict monitoring and reporting supervision 32

33 Costs of implementation Principal costs upgrades to radar equipment functionality IC conflict monitoring and reporting Other costs central IC allocation no incremental costs supervising application of Regulation minimal 33

34 Upgrade to radar equipment No information available from manufacturers Estimates based on assumptions (expert judgement) software development costs - 98k to 140k three suppliers installation and hardware - 30k to 50k per site 45 sites extra costs at 5 sites (older systems) Total estimated cost - 1.6m to 2.7m Cost per radar site - 36k to 60k 34

35 IC Conflict Monitoring and Reporting Rule requires Mode S operators to: monitor performance of their Mode S systems to detect a conflict by third parties switch to a fallback mode of operation as required monitoring of own systems also encouraged Requires radar stations to be linked to a monitoring system which: monitors radar output produces standardised reports Central monitoring system not envisaged for military shipborne and airborne interrogators 35

36 IC Conflict Monitoring and Reporting Assumptions for cost estimates software development - 560k to 840k four suppliers installation and hardware purchase - 40k to 60k per site installation at 54 ACCs Estimated cost total - 4.4m to 6.6m cost per ACC - 81k to 147k no incremental communications costs With single common solution total estimated cost m to 3.84m cost per ACC - 47k to 71k Costs excluded clustering costs automatic reversion to fallback mode 36

37 Summary of costs Low estimate High estimate Upgrades to radar equipment functionality 1.60m 2.70m Operation of code allocation procedures - - IC conflict monitoring and reporting 2.56m 6.60m Supervision - - Total 4.16m 9.30m 37

38 AGENDA ITEM 6 MAIN OUTCOME OF THE FORMAL CONSULTATION Jean-Luc GARNIER Head of Regulatory Unit EUROCONTROL European 38 Organisation for the Safety of Air Navigation

39 Comments received by Stakeholders Acceptable without amendment Acceptable but would be improved with amendments Not acceptable but would be acceptable with amendments Not acceptable under any circumstances Total by Stakeholder % Authority (Civil & Military) ,0% Service Providers (ANSPs) ,0% Airspace Users ,0% Airport Operator ,0% Industry ,7% Other ,3% Total Received Comments by Category % Percentage (%) 40,0% 16,7% 43,3% 0,0% 100% 39

40 Comments received by Groups of Stakeholders Service Providers (ANSPs) 40% Authority (Civil & Military) 50% Other 3% Industry 7% Airspace Users 0% Airport Operator 0% 40

41 Categories of Responses Received Acceptable but would be improved with amendments 17% Not acceptable but would be acceptable with amendments 43% Acceptable without amendment 40% Not acceptable under any circumstances 0% 41

42 Key Issues IC Conflict Monitoring Fallback Mode II/SI Code Operation NATO Code(s) 42

43 Main issues for Discussion/ IC Conflict Monitoring Comment 1. Rule should only refer to monitoring means, which would allow also procedural solutions, at least on an interim basis. 2. Deadline of 31/12/2010 seen as too demanding in view of above remark. 3. Proposal to replace requirement of conflict monitoring by that of detecting any use of a wrong, non-allocated IC. 4. Necessity contested, for SSR Mode S systems used for testing, to be capable of conflict monitoring. Proposed Response 1. Proposal of a 2-steps approach: Monitoring means to be prescribed from the entry into force of the IR; Automated monitoring systems still prescribed, but at a later date (end 2012?). 2. Detection of use of wrong IC not to replace the general detection of IC conflict with other, potentially uncoordinated interrogators. But checking the use of IC to be explicitly added to this article. 3. Test systems cannot be in conflict with operational SSR Mode S interrogators if they stick to their specific allocated II code 14. Therefore no general prescription needed. But operators of test systems to make sure that they don t use an operational code. Specific obligation to be introduced, to check the use of wrong IC, to be applied to test systems as well as to operational systems. 43

44 Main issues for Discussion/ Fallback Mode Comment In absence of automated conflict monitoring system, fallback requirement questioned. The detailed prescriptions of article 5.4 for a fallback unnecessary. Who will be in charge of checking conformance? Proposed Response No automated monitoring does not prevent contingency plan including fallback mode. Requirement to identify, develop, validate, and be able to demonstrate, a fallback mode of operation similar to other SES requirements on specific functions with impact on safety. NSA to check the conformance 44

45 Main issues for Discussion/ II/SI Code Operation Comment Support II/SI considered by 2 respondents as too demanding for military operators. Cost of upgrade related to the II/SI requirement considerably underestimated. Proposed Response II/SI part of the supported regulatory approach. Wide support needed. Not applicable to military systems using special codes. Exemption considered for others if very few? Cost base under review. Manufacturers welcome to contribute. 45

46 Main issues for Discussion/ NATO Code(s) Comment Explicit statement needed on reservation of II code 15 to NATO Misunderstood notion of a single code to be used by NATO and any other military purpose. Proposed Responses Existing consensus between EUROCONTROL and NATO, later formalised in the Mode S IC Allocation Plan. However, application from NATO for the exclusive use SI codes. Legal constraints in community context. Reduction of flexibility if statement explicit. NATO-managed code(s) to come in addition to military-used IC. 46

47 Other Main Comments Confidentiality of data Add note in Annex II about the possible confidentiality of some key allocation items. As suggested a formulation will be chosen to take into account such confidentiality request, using a formula like Without prejudice to national procedures for the communication of information. Periodicity of Status Reports Suggestions to increase the period of status reporting from 6 months to 12 months. There is no reason to weaken the validated existing process by increasing the reporting period. 47

48 Other Main Comments (2) Obligation on ANSPs using third States radars Objections by ANSP to the ATSP obligation to verify that Mode S radars they use data from are properly coordinated. Reformulation of Art. 4[12] needed to obtain a positive formulation. Use of conventional Mode A/C What if a decision is made to operate a Mode S capable interrogator allocated with an IC as a conventional Mode A/C only interrogator? Is it a breach of Article 4 (9). IR not applicable to SSR in mode A/C Safety & ESARR Suggestions that safety requirements were superfluous in the IR as they were covered by more generic ESARR prescriptions. IR in line with general approach of interoperability regulations 48

49 Other Main Comments (3) Verification Requirements What would be the outcome of a failure in the verification process: would a grace period be granted for rectification? This is the responsibility of the national authority to decide the modalities of the IR application. No grace period in principle. System versus Service A number of comments were received requesting clarification on what was meant by Mode S IC Allocation System versus IC Allocation service The Interoperability Regulation allows for its Implementing Rules setting obligations on sub-systems of the EATMN. This is not the case with the corresponding service delivered to the stakeholders. 49

50 AGENDA ITEM 7 THE WAY FORWARD NEXT STEPS Jean-Luc GARNIER Head of Regulatory Unit EUROCONTROL European 50 Organisation for the Safety of Air Navigation

51 The Way Forward Updates of IR articles to address received comments Update of the relevant parts of the JMA document, including economic appraisal Finalisation of the Final Report Delivery of the Final Report to the Commission in December. 51

52 Next Steps Finalisation of SOR Update of draft Rule Submission of Final Report Publication of SOR November 2007 December 2007 December 2007 December

53 AGENDA ITEM 8 CONCLUSIONS Jean-Luc GARNIER Head of Regulatory Unit EUROCONTROL European 53 Organisation for the Safety of Air Navigation

54 54 Second Stakeholder Consultation Workshop on the Draft Implementing Rule for the allocation and use of Mode S Interrogator Codes (MSI)