Report Οκτωβρίου από το Regional Meeting της IAOPA

Monthly ICAO Report October 2024

This month began with a very successful 150th European Regional meeting, held in Bulgaria. It was a pleasure to meet with a very enthusiastic Bulgarian AOPA group and to make new friends there. I thank IAOPA Europe for permitting me to take part.

And thank you, AOPA Luxembourg, for your colorful report of the Regional Meeting. It provides an important reminder of what GA offers, and while I attend slow-moving meetings at ICAO it reinforces the hope that all our various contributions can assure our continued pleasure in flying.

Upon my return from Bulgaria the Air Navigation Commission at ICAO entered a 2-week recess but the technical meetings continued unabated. Though seeming dry and endless, their preoccupations are necessary and the results of those discussions eventually influence what and how your regulators will implement the decisions made.

Air Navigation Bureau held a meeting entitled “Standards and Recommended Practices (SARPS)” in which the focus was Data Management Systems (DMS). The latter issues were deemed to be lacking in transparency and were evaluated as often lacking the ability to clearly identify sources in documents. As well, the wrong versions of a document sometimes were identified, and different language translations did not consistently agree. To make an internal amendment to the SARPS involves 64 steps—no small feat. Impediments to improvements include such realities as States having little time to implement changes after the changes are adopted by ICAO. States receive about 300 State Letters per year notifying of changes to the SARPs. Even when States amend the standards to meet the recommendations of ICAO, they often do not notify the users (pilots, schools, etc.) of the changes in a timely manner, leaving the users no time to adapt. The result is that too often States have a low effective implementation (EI) status.

The effect on GA that you see is that your regulators have insufficient time to devote to matters you ask them to address.

Electronic Documentation and Certificates (EDC) Certificates of Airworthiness (CofA), Certificates of Registration (CofR) and Aircraft Operator Certificates (AOC) are to be accepted inter-regionally. Both paper certificates and electronic visual displays are to be accepted. On-line and off-line documentation each are to be accepted. The format for each type of certificate is to be unified. However, GA operators are to have a simplified version of all documents. You may not have to carry the paperwork associated with your privilege to fly into another State.

Flight Ops Panel (FLOPSP) and the Accident Investigation Group (AIG) met together to review proposals for amendments to Annex 6 regarding Duties of Pilot in Command (PIC) in the case of an occurrence (incident or accident). The Standards currently are unclear as to whether the State of Registry or the State of Occurrence must be notified in the event of an occurrence. A change in all parts of Annex 6 (that includes Part II, GA) is proposed to have pilots report all incidents, ‘serious’ or not. Pilots already have to report accidents (as per Annex 13, Attachment B) as well as all serious incidents. Reporting has legal implications for the pilot and therefore the question of to whom the reporting should be directed is of importance. The meeting agreed that reporting should be the operator’s responsibility, not the PIC’s. For GA the pilot currently is responsible to report an incident if the aircraft weighs over 2250 kg. Of concern is the fact that not all States currently investigate and report occurrences. Due to the lack of personnel required to investigate occurrences, the issue of who is going to do what with whatever data is collected in occurrence reports was questioned.

The definition of a ‘serious Incident’ is to be reconsidered and improved in a future meeting.

Judging by a tabulation of accident causes it appears that neither the causes of GA accidents nor the distribution of relative frequencies in the various causes varies notably in time.

ANC CG-1 Annex 6 Part IV Gap Analysis and Impact Analysis of Remotely Piloted Aircraft (RPAS) was addressed by the ANC over 2 lengthy meetings. Implementation of Annex 6 Part IV is to be delayed, possibly to 2028, in large part because the remaining packages to be delivered by the RPASP--namely Air Traffic Management (ATM), Detect and Avoid (DAA), Command and Control (C2) Link (second package) and aerodromes—are awaited before ANC can consider the final document.

The discussion also focused on the fact that the Impact Assessment paper of a possible C2 link failure did not touch on the safety impact of the proposed mitigations in Annex 6 Part IV (including such as a safety analysis). A safety assessment is being conducted for the overall Part IV. The latter is anticipated to be completed by 2028. Unresolved issues discovered before 2028 may further delay implementation. At this point the worry for GA operators is that the complexity of whatever solutions are proposed for airspace safety will prove costly. The necessity to have its systems overseen and maintained properly by a legion of accessible qualified technicians may require operators to rely on an unproven technology that is only presumed to be effective and failure free.

The Frequency and Spectrum Management Panel (FSMP) continues discussions with the International Telecommunications Union (ITU) regulators in an effort to protect that part of the spectrum used by radio altimeters. ICAO has expressed the need to protect radio altimeters from interference by adjacent band signals from 5G Network operations. Available frequencies to GA are protected by international agreements that negotiate frequency band allotments and protections.

Judging by a tabulation of accident causes it appears that neither the causes of GA accidents

Remotely Piloted Aircraft Panel (RPAS) Working Group of the Whole

Meeting The opening Plenary of the week long Working Group (WG) meeting reviewed the progress of the SARPS making process. It is hoped that all SARP packages (the recommendations made by each of the 8 different Working Groups) will be completed and accepted by the Fall of 2025. It is uncertain if the RPAS manual (the official document governing the RPAS operations, to be distinguished from the “packages”) will be completed by then. Also questioned is if the guidance material could be ready within that time frame.

The Airworthiness WG-1 group (RPAS) stated that its work is completed. The Command and Control (C2) link group still has major outstanding working elements to resolve, such as that no Required Link Performance for the C2 technology is yet to be endorsed. Nor has it been established how States will determine the required performance level for a C2 link. In any case, the DAA operating requirements will determine the required link performance level. The available link performance will be governed by the aircraft’s needs.

The overall mood by the end of the meeting was that there are still many loose ends and fundamental issues to be resolved in the thorny problem of operating remotely piloted aircraft with manned aircraft. Some difficulties are technical, some procedural, some research- related and some logistical. Indeed, Secretariat reminded the Panel that RPAS work is not yet done. Much work needs to be completed, and advertised timelines may be overly optimistic. The problem has been that the ANC was asked to develop guidance for a new type of aircraft operation, the details of which were unknown and are still evolving. Guidance is meant to clarify Standards, and in this case, Standards have not yet been formalized. Consequently, the ANC, and therefore the industry, is now faced with developing and approving guidance to States which is not based on a complete understanding of the eventual operations to which the industry aspires. The reason for the ANC having agreed to developing guidance before having the Standards was an attempt to have world-wide regulators adopt harmonised regulations to ensure interoperability of RPAS operations.

The work the ANC has been asked to do has been very intensive and time consuming, making

it virtually impossible to raise GA issues. For my part, I am working to have the process of establishing ANC work priorities approached in a different manner. Currently, ANC is prioritizing issues from a general list of requests. Instead, I want ANC to establish its priorities from within each sector, so that GA can remain a priority, and its list of requests can then be prioritized. In this way, no priority of a given sector can eliminate the priority of another sector. Because ICAO’s priority is international commercial operations, GA concerns will never rise to the forefront, but neither should they be ignored.

Although of no concern to the Panel, at one point the Panel was briefed on the progress made on the Advanced Air Mobility (AAM) Standards and Recommended Practices (SARPs). The ICAO AAM Secretariat reported its work under the title of “A global holistic vision of the advanced air mobility aspirations”. Their Paper opined that the new flight rules required further work. The aim is to go beyond traffic management (UTM) to develop a more advanced scheme, not yet defined. The Secretariat is looking to develop initial guidance material and to aim at early implementation of electric vertical takeoff and landing (eVTOL) operations in the current ATM environment.The AAM Secretariat advised that the group agreed to pause further aspirational

work and instead to first focus on completing a Gap Analysis. Some WG members, apparently at the RPAS meeting but with an AAM agenda, voiced the opinion that ICAO is moving too slowly on developing SARPs for AAM.

For the remainder of the week the various sub groups (6) met in an effort to resolve the gap issues. Specifically the areas of Detect and Avoid, Air Traffic Management, Command and Control (C2) and Aerodromes are not completed. Still, the applicability date for the SARPs is presumed for November 2028. The Air Navigation Commission (ANC) is hoping to have completed its final review of the SARPs in 2027.

The ANC was briefed by the RPASP ATM WG group focused on Air Traffic Management

(ATM). The proposal is that in the case of C2 link loss that the event is not classified as an emergency, but that the pre-programmed lost C2 link contingency procedures would be engaged. The lost C2 link failure would be signalled by squawking a 7400-transponder code.

Although the ATM WG assumes a low probability for a C2 link failure, the reality is that interference, spooking and cybersecurity issues are on the rise, putting the claimed robustness of the C2 link in question.

GA will be affected in the same way that commercial operations will be, so GA will benefit from any work on cybersecurity issues done by ICAO.

Air Navigation Commission (ANC) Briefing. The ANC was provided with a briefing by Istanbul’s international airport administration. This ANC talk focused on exploring the transformative impact of Collaborative Decision Making (CDM) on commercial airport operations. By implementing CDM processes, the argument presented was that enhanced coordination among airlines, airports, air navigation service providers, and other major operational stakeholders will lead to a more streamlined approach to managing commercial air traffic. The session highlighted key benefits, including improved operational efficiency, reduced delays, and enhanced passenger experience. Presented were insights into successful CDM strategies and practical examples of collaboration that have resulted in measurable improvements in airport performance.

Absent from the presentation was any mention of what facilities such as customs, parking, fuelling etc. are planned for International GA operations at that airport.

WRAP-UP October’s meetings dealt with intricate matters, many of which had no direct impact on General Aviation operations. However, November will offer various meetings more closely aligned with GA concerns. In addition to the regular ANC meetings, Panel meetings will be held dealing with personnel training and licensing (PTLP), airworthiness, electric power, True North-Magnetic North, more RPAS DAA discussions, in sum more meetings than I am able to attend because of the over-layering of the meetings scheduled.

As I look back, though the meetings at ICAO were dry affairs, by contrast the Regional Meeting hosted by Bulgaria’s AOPA was a breath of inspiration. Again, many thanks to the generous Bulgarians!

Frank Hofmann
IAOPA Observer to ICAO November 1, 2024