EUROCONTROL COOPERATIVE NETWORK DESIGN

i EUROCONTROL COOPERATIVE NETWORK DESIGN Implementation of the 8.33 khz Voice Channel Spacing Safety Impact Assessment Report Ref: :8.33<195-SAFREP-2010-0301-IR Edition :1.0 Edition Date :02/01/2011 Status :Proposed Issue Class :CND Stakeholders

DOCUMENT CHARACTERISTICS Implementation of the 8.33 khz below FL 195 Safety assessment report Document Identifier Edition Number: 1.0 Abstract Edition Date: 2 Feb 2011 This safety impact assessment is addressing the implementation of 8.33 khz below FL195 in the ICAO EUR Region where EU Member States are responsible for the provision of air traffic services. This safety assessment is addressing the safety impact of such implementation on the air traffic services which are supported by the air-ground VHF voice communication. Furthermore it addresses also the potential safety impact on the control of the movement of ground vehicles on the manoeuvring areas. Considering this scope, this safety assessment does address the impact on: Air Traffic services delivered to pilots in controlled/uncontrolled airspace and for aerodrome operation where two way radio communication is required The control of the movement of ground vehicle in controlled aerodromes where two way radio communication is required The implementation of 8.33 khz below FL195 in the ICAO EUR Region where EU Member States are responsible for the provision of air traffic services is characterised by: the Interim Implementation for 2014 to ensure a given number of conversions take place in the EU States area defined in the implementing rule 1, the final Implementation for 2018 to ensure 8.33 khz spacing of all possible voice channels in the EU Member States airspace. The safety target was set to demonstrate that ST#1 the risk of an accident following the complete conversion to 8.33 khz VCS shall not be significantly greater than before the start of the introduction of 8.33 khz VCS ST#2 the risk of an accident during the transition to the complete conversion to 8.33 khz VCS shall be reduced as far as reasonably practicable. The overall conclusion is that deployment of 8.33 khz VCS in the airspace of IR applicability below FL 195 according to the draft VCS II IR [16] has the potential to satisfy the above Safety Targets, but some additional safety requirements must be added to the rule. Indeed, it has been shown that all Safety Requirements identified during this safety impact assessment have been satisfactorily addressed either by the draft VCS II IR [16] or by the future draft VCS II IR, which will include the additional/modified requirements, or by other existing regulations (e.g. ICAO). Keywords Implementing Rule, Safety activities, Safety Assurance, Safety Argument, Hazards Contact Person(s) Tel Unit Daniela Grippa daniela.grippa@eurocontrol.int Bruno Rabiller bruno.rabiller@eurocontrol.int +32 2 729 33 30 +33 1 69 88 69 13 CND COE/ PM/ SY CND COE/ PM/ SY 1 This area is called in the rest of the document area of applicability defined in IR, Annex I

STATUS, AUDIENCE AND ACCESSIBILITY Status Intended for Accessible via Working Draft General Public Intranet Draft CND Stakeholders Extranet Proposed Issue Restricted Audience Internet (www.eurocontrol.int) Released Issue Path: ELECTRONIC SOURCE Host System Software Size Windows_NT Microsoft Word 10.0 840 Kb

DOCUMENT CHANGE RECORD The following table records the complete history of the successive editions of the present document. EDITION NUMBER EDITION DATE REASON FOR CHANGE PAGES AFFECTED Rev IR 15/12/2010 Creation All 1.0 2 Feb 2011 Internal Review All WRITTEN BY CHECKED BY APPROVED BY D. Grippa/ B. Rabiller D. Grippa/ B. Rabiller D. Booker, P. Thorsen J. Roca

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Contents 1. INTRODUCTION... 8 1.1. Implementation of 8.33 khz VCS Overview... 8 1.2. Scope and process of the Safety Impact assessment... 9 2. General Approach to Safety Assessment of 8.33 VCS... 10 3. Safety Targets... 11 4. Description of the operational environment... 11 4.1 Air Traffic Services and the A/G Voice Communication Infrastructure... 11 4.2 The Operational Environment for the Interim Phase... 12 4.3 The Operational Environment for the Final Phase... 14 5. Safety Assessment Results for aircraft operation.... 15 5.1 Safety Scenarios Assessed... 16 5.2 Success Approach... 18 5.3 Failure Approach... 19 5.4 Risk Assessment... 23 5.4.1 Overview... 23 5.4.2 Safety Scenario #1... 23 5.4.3 Safety Scenario #2... 24 5.4.4 Safety Scenario #3... 24 5.4.5 Risk Quantification... 25 6. Impact on ground vehicle operation... 25 6.1 Introduction... 25 6.2 Safety Targets... 26 6.3 Safety Scenarios Assessed... 26 6.4 Success Approach... 27 6.5 Failure Approach... 29 6.6 Risk Assessment... 33 6.6.1 Overview... 33 6.6.2 Safety Scenario #4... 34 6.6.3 Safety Scenario #5... 34 6.6.4 Risk Quantification... 35 7. Caveats... 36 7.1 Assumptions... 36 7.2 Safety Issues... 36 8. Conclusions and Recommendations... 37 8.1 Conclusions... 37 8.2 Recommendations... 38 8.3 How the draft IR is addressing the outcome of the safety impact assessment 38 Annex 1: Glossary and References... 40 A1-1 Glossary of Terms and Abbreviations... 40 A1-2 References... 40 Annex 2: Air Traffic Services supported by the A/G Voice Communication service... 42 6

A2.1 Air Traffic Control Service... 42 A2.2 Flight Information Service (FIS)... 42 A2.3 Air Traffic Advisory Service... 42 Annex 3: Safety Log... 43 A3.1 Safety Requirements... 43 A3.2 Assumptions... 45 A3.3 Issues... 45 Annex 4: Identified Safety Requirements versus the content of the Draft VCS II IR 46 7

8 1. INTRODUCTION 1.1. Implementation of 8.33 khz VCS Overview On 15 March 2007, the mandatory carriage and operation of 8.33 khz VCS capable radio equipment came into effect above FL 195 in the ICAO EUR Region. In October 2007, the European Commission published the Regulation ER 1265/2007 which, in particular, includes important articles concerning ground radio conversions and the requirements for State aircraft. In spite of the recent decreasing air traffic levels, the demand for new VHF assignments continues and is expected to increase once traffic levels rise again. Therefore, Europe is reviewing the need for 8.33 khz VCS, as well as other measures to alleviate VHF congestion. The Eurocontrol Stakeholder Consultation Group (SCG) 10 th meeting - held 25/26 Feb 2009 agreed the following conclusions relating to 8.33 khz VCS : Supported a phased implementation of 8.33 khz VCS in the ICAO EUR Region; Agreed that EUROCONTROL should: o o o Develop a European Implementation Plan with the participation of all affected stakeholders, also taking into account the issue of funding; Provide advanced notice to affected stakeholders on potential pan-european milestones and timescales; Ensure a coherent approach between the programme work and the European Commission (EC) Regulation 1265/2007 Noted the related MILHAG support and consideration regarding the phased implementation in terms of time, airspace and geographical areas The SCG was advised on the intention to modify the EC regulation 1265/2007 (the AG-VCS Implementing Rule) in order to address 8.33 khz VCS forward-fit, frequency-usage transparency and the phased deployment. The 8.33 khz VCS stakeholders have analysed the options for the phased implementation below FL 195 and a Europe-wide formal consultation took place early in 2010 to agree the way forward. Two implementation scenarios were proposed to the 8.33 khz stake holders: Scenario 1 Development of regulatory provisions identifying three implementation milestones. Forward Fit Phase starting from 2012 to ensure all new radios comply, Interim Phase by the 31 st December 2014 to ensure a given number of conversions take place, in the European states. Final Phase by the 31 st December 2018 to ensure the conversion to 8.33 khz spacing of all possible European voice channels Scenario 2 Development of regulatory provisions identifying two implementation milestones. Forward Fit Phase starting from 2012 to ensure all new radios comply, Final Phase by the 31 st December 2018 to ensure the conversion to 8.33 khz spacing of all possible European voice channels. Both scenarios propose a Forward Fit Phase and a Final Phase ; these are identical in each case. As result of the consultation of the 8.33 khz stakeholders the definition of two areas where the implementation will be realised, following two different scenarios has been proposed:

Part of the ICAO EUR region 2, where the Interim and Final Phases would be required and the rest of the ICAO EUR Region 3, where only the Final Phase would be required. 1.2. Scope and process of the Safety Impact assessment This safety impact assessment is addressing the implementation of 8.33 khz below FL195 in the ICAO EUR Region where EU Member States are responsible for the provision of air traffic services. This safety assessment is addressing the safety impact of such implementation on the air traffic services which are supported by the air-ground VHF voice communication. Furthermore it addresses also the potential safety impact on the control of the movement of ground vehicles on the manoeuvring areas. Considering this scope, this safety assessment addresses the impact on: Air Traffic services delivered to pilots in controlled/uncontrolled airspace and for aerodrome operation where two way radio communication is required The control of the movement of ground vehicle in controlled aerodrome where two way radio communication is required. This safety assessment does not address the safety impact on: The performance of airline communications 4 which are supported by the air-ground VHF voice communication even if OPC (OPerational Control) frequencies have to be converted in 8.33 khz. Apron management services because air traffic control has normally no responsibility for control of vehicles on apron areas (ICAO Doc 9137 Part 8) and VHF voice communication might not be used (e.g. use of digital radio communication system) Safety assessment typically start at the ATM service level this level may be thought of as being in the interface between the service provider and the service user. Such an approach is particularly valid for the introduction of 8.33 khz voice-channel spacing (VCS) since VHF voice is currently the main mean of communication across the provider / user interface for ATM services to GAT and is likely to remain so for the next two decades. Safety Objectives are specified at the service level, for three purposes: to capture what has to happen in order for the services to operate as required to mitigate the consequences of failure / degradation of the ATM services, however caused to limit the frequency with which the causes of such failures may occur so as to achieve an acceptable level for the associated risk, taking account of the above mitigations. In the first two cases, the Safety Objectives address the functionality and performance to be achieved. In the 3 rd case, the Safety Objectives address the integrity to be achieved 5. In all three cases, only what has to be achieved is specified at the service level this helps to ensure the completeness, correctness and consistency of the Safety Objectives without the unnecessary (at this level) detail of how, or by whom, the Safety Objectives will be achieved. 2 Member States for this interim phase are: Austria, France, Germany, Hungary, Ireland, Italy, Luxembourg, The Netherlands, and United Kingdom see Annex 1 of the IR. 3 Applicable to EU members States responsible for the provision of ATS 4 Airline Operational Communication (AOC) and/or Airline Administrative Communication (AAC) 5 The traditional definition of a Safety Objective (including that in EC 2096/2005) is limited to the 3 rd case. However, recent experience on many EUROCONTROL projects has shown to be very useful to extend this definition to include the first two cases. 9

Safety Requirements, on the other hand, are the means by which the Safety Objectives are achieved for this reason they are specified at the system level and result from the appropriate allocation of the Safety Objectives on to the elements of the functional system in general, covering equipment, procedures and human resources. This safety assessment has considered the different safety materials developed prior to the initial safety Impact assessment ([1], [2] and [3] ) and the safety materials developed during the initial safety impact assessment ([4], [5], [6], [7], [8] and [9]). 2. GENERAL APPROACH TO SAFETY ASSESSMENT OF 8.33 VCS BELOW FL 195 Hypothetically, it could be said that if a homogeneous channel spacing (i.e. either 8.33 khz or 25 khz) were to exist in the airspace, and there were to be a corresponding homogeneous aircraft fit, then any hazards associated with air-ground and ground-ground RT communications would be the same whichever channel spacing was deployed - i.e. loss of communication - due to voice-communications equipment failure or incorrect frequency selection by an aircraft or ground vehicle distortion of communication - due to interference caused by incorrect frequency selection by an aircraft or ground vehicle, by inappropriate frequency assignments to proximate sectors, or by external 6 events such as natural phenomena or man-made interference. For the purposes of this safety impact assessment, it is assumed that the likelihood and consequences of any of the following are not affected by the change from 25 khz VCS to 8.33 khz VCS: voice-communications equipment failure external interference events Controller transmitting a wrong frequency to the pilot. Therefore, any risk associated with these three hazard causes does not change and can, therefore, be excluded from this safety assessment, which is concerned specifically with the effects of the introduction of 8.33 khz VCS. Furthermore, it has already been established, from the previous deployment of 8.33 khz VCS above FL 195, that: an 8.33 khz VCS-equipped aircraft is fully able to communicate with a ground station that is equipped with either 25 khz or 8.33 khz VCS a 25 khz VCS-equipped aircraft can communicate only with a 25 khz VCS ground station The VHF air-ground communication frequency assignment planning criteria (ICAO EUR Doc 011) are properly addressing the 8.33 khz spaced channels and no specific assignment criteria are relative to the altitude (implementation above or ). Thus a hazardous situation related to the introduction of 8.33 khz VCS would exist if: an 8.33 khz VCS-equipped aircraft were to mistune a (correct) 8.33 khz VCS frequency a 25 khz VCS-equipped, non-exempt aircraft were to enter, or attempt to enter, a sector that uses primarily 8.33 khz VCS - for example, by selecting an old 25 khz VCS frequency or by trying to select the 8.33 khz VCS frequency assigned to the sector. 6 External here means from outside of the aviation VHF RT communications system 10

a 25 khz VCS-equipped, exempt aircraft were to enter, or attempt to enter, a sector that uses primarily 8.33 khz VCS, unless facilities / procedures for handling such aircraft had already been put in place. Therefore, the safety assessment has to address the above from three perspectives: the specification of Safety Objectives, and then Safety Requirements, to avoid hazardous situations occurring, wherever possible the specification of Safety Objectives, and then Safety Requirements, such that if hazardous situations do occur, for whatever reason, then their effects in terms of safety are reduced as much as possible an estimation of the likely risk associated with the occurrence of hazardous situations, taking account of the above mitigations. The first perspective is known as the success approach; the other two together are known as the failure approach. 3. SAFETY TARGETS Two Safety Targets for which the Safety Objectives are to be derived: ST1 the risk of an accident following the completion of the Final Phase of conversion to 8.33 khz VCS shall not be significantly greater than before the start of the Interim Phase ST2 the risk of an accident during the period between the start of the Interim Phase and completion of the Final Phase, of conversion to 8.33 khz VCS shall be reduced as far as reasonably practicable. 4. DESCRIPTION OF THE OPERATIONAL ENVIRONMENT 4.1 Air Traffic Services and the A/G Voice Communication Infrastructure The Air-Ground (A/G) Voice Communications infrastructure supports the Air Traffic Services (ATS) system by providing the necessary Aeronautical mobile service for safe operations. As specified in ICAO Annex 11, the Air Traffic Services supported by the A/G voice comms are the following: Flight Information Service in uncontrolled airspace Air Traffic Advisory Service in uncontrolled airspace Air Traffic Control Service in controlled airspace (area, approach or aerodrome) In addition to the above services, an Alerting Service is automatically provided to all aircraft receiving an Air Traffic Control Service and, as far as is practicable, to all other aircraft whose pilots have filed a flight plan or are otherwise known to air traffic services. The communication requirements associated with the delivery of each of these services, to General Air Traffic (GAT), are currently provided through a VHF air/ground infrastructure supporting both voice and data communications. Air traffic control will continue to depend heavily upon A/G voice communications. When data-link communication becomes more widespread, voice will still be used for tactical clearances and nonstandard instructions (in line with the SESAR Concept of Operations). Future Communication Infrastructure (FCI) is not expected to replace the VHF AM (25 and 8.33 khz VCS) technology before 2025. 11

A/G voice comms currently uses VHF (very high frequency), AM (amplitude modulation) with channels spaced at 25 khz or 8.33 khz 7. For radio communication the aeronautical VHF band of 118 MHz to 137 MHz is used. In order to provide a high quality of service to many aircraft at the same time, the airspace is organized in sectors - i.e. individual blocks of three-dimensional space which are defined by a bottom and top altitude limit and geographical points (sector boundaries) - with each sector allocated specific voice communication frequencies. Continuous two-way radio-communication is required for IFR operations in all airspace classes (A to G) whereas for VFR operation it is required for class A to D, but not for class E to G. Currently, the A/G voice comms infrastructure uses only one channel spacing standard (25 khz VCS). Annex 2 of this report describes the services supported by the A/G voice comms and should allow a better understanding of the safety role of the A/G voice comms service in the operational environment during the assessment. 4.2 The Operational Environment for the Interim Phase The implementation of 8.33 khz VCS will start with an initial phase called the Interim Phase as described in Figure 1 below. The Interim Phase is described in more detailed in [13]. As agreed after the stakeholder consultation, the Interim Phase is applicable to a number of States in the ICAO EUR region which are listed in the Annex I of the draft IR [16]. 8.33 khz airspace above FL 195 FL 195 25 khz 8.33 khz 25 khz 8.33 khz Airspace class D,E,F or G Airspace class A,B or C E.g. Airspace class not converted because ANSP already converted more than 25 % of their ACC frequencies Airspace class A,B or C (or possibly other airspace class e.g. D,F,G or E can be converted as permitted by the IR) Minor TMA 25 khz E.g. Airspace class E Airport 1 25 khz E.g. FL 095 25 khz or no radio required Airport 3 25 khz Airspace class E,F or G Major TMA 8.33 khz E.g. Airspace class A Airport 2 25 khz Figure 1: Overview of the 8.33 khz Interim Phase 7 As noted in section 1.1 above, the mandatory carriage and operation of 8.33 khz VCS capable radio equipment came into effect in the ICAO EUR Region above FL 195 (but not ) on 15 March 2007 12

ATS airspace is classified and designated in ICAO Annex 11, Section 2.6 Classification of Airspaces using the seven airspace classes (A to G). Annex 11, Appendix 4 identifies for each airspace class (A to G) and type of flight (IFR or VFR), where voice radio communication is required. All the airspace of classes A, B, C, D and E is defined as Controlled airspace while the airspace of classes F and G are defined as Uncontrolled airspace. During the Interim Phase of conversion to 8.33 khz VCS, the more likely scenario is that part of the airspace Class A, B and C will be converted to 8.33 khz channel spacing while the airspace D, E, F and G will continue to operate the 25 khz channel spacing frequencies. This means that in the participating States all non-exempt aircraft operating in class A, B or C airspace under IFR shall be equipped with radio equipment with the 8.33 khz voice channel spacing (VCS) capability. State aircraft are exempt from this requirement and in some States they may continue to use 25 khz VCS. When the Interim Phase is completed, in December 2014, it is assumed that ANSPs will have performed a number of conversions equivalent to at least 25% of their 25 khz ACC assignments for which conversion is feasible. This means that airspace classes A, B, C will not be completely converted during the Interim Phase, and that conversions could also take place in other airspace classes (D to G) and/or for Approach/Tower services. The conversion to 8.33 khz VCS during this Phase is considered not to be feasible in the following cases: sectors where 25 khz offset carrier system is utilised, assignments that must stay in 25 khz VCS as a result of a local safety requirement, 25 khz VCS assignments that are used to accommodate State Aircraft, 121.5 MHz channel (emergency frequency) and the VHF Data Link frequencies will stay in 25 khz VCS. This Phase is therefore characterised by airspace which,, is converted (green in Figure 1 ) or not converted (blue in Figure 1) to 8.33 khz VCS. Airspace users must be equipped with radio equipment with the 8.33 khz VCS capability when flying in 8.33 khz VCS airspace. Because the 8.33 khz Climax 8 will not be applied (only applied in 25 khz), the latest EUROCAE specification will not be mandatory (EUROCAE ED 23C). The Specification of 8.33 khz VCS will not support the use of 8.33 khz offset carrier frequency (Climax) either for the Interim Phase or the Final Phase From the airspace users perspective, it is foreseen that: 8.33 khz VCS airspace will have the same accommodation of non-8.33 khz VCS State aircraft as is the case above FL 195, Airspace users will be affected only if flying in 8.33 khz VCS airspace, Airspace users equipped with or without 8.33 khz VCS equipment will co-exist in the airspace. It is important to note that the Interim Phase objective is to reach a target number of conversions without prescribing a specific airspace to convert. This is likely to lead to non-homogeneous 8.33 khz conversion of sectors/tmas from one State to the other and even potentially within a State. Therefore, as a consequence of non-homogeneous conversion, airspace users may not be able to easily determine the VCS equipment requirements for each part of the airspace using a simple rule. Rather, the airspace users will have to refer to the relevant Aeronautical Information Publication (AIP) to identify the VCS equipment requirements for the airspace they are planning to use. 8 Climax=offset carrier frequency function. 13

4.3 The Operational Environment for the Final Phase This Safety Impact Assessment addresses also the so-called Final Phase as described in Figure 2 below. The Final Phase is described in more detailed in [13] and, as agreed after the stakeholder consultation, it is applicable to the ICAO EUR Region where EU Member States are responsible for the provision of air traffic services. 8.33 khz airspace above FL 195 FL 195 8.33 khz 8.33 khz 25 khz 8.33 khz E.g. Airspace where conversion is not feasible (e.g. climax sector) Minor TMA 8.33 khz 8.33 khz or no radio required Major TMA 8.33 khz Airspace class E,F or G Airport 1 8.33 khz Airport 3 8.33 khz Figure 2 Overview of the 8.33 khz Final Phase Airport 2 8.33 khz The Final Phase is consisting of the full deployment of 8.33 khz VCS. It will lead to all frequency assignments in the aeronautical mobile communications service band being converted to 8.33 khz channel spacing, except for some very specific cases as follows: sectors where 25 khz offset carrier system is utilised, assignments that must stay in 25 khz as a result of a local safety requirement, 25 khz assignments used to accommodate State Aircraft, 121.5 MHz channel (emergency frequency) and the VHF Data Link frequencies will stay in 25 khz spacing. The Final Phase is therefore characterised by airspace / sectors which,, are largely converted (green in Figure 2) but exceptionally not converted (blue in Figure 2) to 8.33 khz channel spacing. Airspace users must be equipped with radio equipment with the 8.33 khz channel spacing capability when flying in the airspace of IR applicability except if exempted. From the airspace user s perspective, it is foreseen that: 8.33 khz VCS airspace will have the same accommodation of non-8.33 khz State aircraft as is the case above FL 195 (exemption policy) All airspace users will be affected by this Phase except the exempted users 14

All airspace users shall be equipped with radio equipment with 8.33 khz VCS except the exempted users. Any mismatch of the flight crew frequency selection and the instructed frequency can lead to an ineffective voice communication service jeopardizing the transmission of ATC clearance or ATS information. As all the airspace users will be impacted by the change, those that were not operating above FL 195 hitherto will be new to the use of the 8.33 khz VCS, potentially increasing the wrong frequency selection by flight crew, in the short term. The following Figure 3 summarise the implementation milestone for the introduction of the 8.33 khz as defined in the draft IR [16]. 2012 2013 2014 2015 2016 2017 2018 6&7 All new radios to be 8.33 khz capable 8 All radio updates to be 8.33 khz capable 9 All IFR aircraft flying in class A-C airspace of the IR applicability area defined in Appendix 1 to be 8.33 khz capable 10-14 More than 25% of possible freqs in Class A-C to be converted to 8.33 khz for the IR applicability area defined in Appendix 1 16 All aircraft and ground radios to be 8.33 khz capable 15 All OPC freqs to be converted to 8.33 khz 17-20 All remaining possible freqs to be converted to 8.33 khz Key n Article 3(n) IR reference After (date) Before (date) Important Note: Figure 3 8.33 khz Implementation Milestones For States where only the Final Phase is foreseen, a transition period must take place so that the Final Phase will be completed by the 31 st December 2018. If some States were start this transition before 1 January 2018 it is likely that the situation would be very similar to the one described for the Interim Phase i.e. there would be a non-homogeneous use of 8.33 khz VCS (i.e. a mix of aircraft capability and a mix of airspace assignments). The main difference between the transition period and the Interim Phase would be that no earliest date is fixed at moment for the start and the end of the transition. 5. SAFETY ASSESSMENT RESULTS FOR AIRCRAFT OPERATION. This safety impact assessment is addressing the impact of the 8.33 khz implementation on air traffic services delivered to aircraft operation in Enroute, Terminal airspace and during landing and taxiing. 15

The implementation of 8.33 khz below FL195 in the ICAO EUR Region where EU Member States are responsible for the provision of air traffic services is characterised by: the Interim Implementation for 2014 to ensure a given number of conversions take place in the EU States area defined in the implementing rule 9, the Final Implementation for 2018 to ensure 8.33 khz spacing of all possible voice channels in the EU member States airspace. 5.1 Safety Scenarios Assessed The possible aircraft operations when considering the Interim Phase is depicted in Figure 4 and is applicable to European States listed in the VCSII IR Annex 1. For the Final Phase, which is applicable to all EU member States, Figure 5 is depicting such case. It should be noted that for the Final Phase and outside of the airspace where EU Member States are responsible for the provision of air traffic services, the 25 khz VCS might continue to be used and this aspect has to be considered during the safety assessment. 8.33 khz airspace above FL 195 FL 195 25 KhZ 8.33 KhZ 25 KhZ 8.33 KhZ Major TMA 8.33 khz Transit Flight Minor TMA 25 khz Transit Flight Major TMA 8.33 khz 25 KhZ or no radio required Airport 1 25 khz Airport 2 25 Khz Figure 4 : A/C operations when considering the Interim Phase 9 This area is called in the rest of the document area of applicability defined in IR Annex I 16

8.33 khz airspace above FL 195 FL 195 8.33 KhZ 8.33 KhZ Transit Flight 25 KhZ E.g. Airspace where conversion is not feasible (e.g. climax sector) 8.33 KhZ Major TMA 8.33 khz Minor TMA 8.33 KhZ Transit Flight Major TMA 8.33 khz 8.33 KhZ or no radio required Airport 1 Airport 2 8.33 KhZ 8.33 KhZ Figure 5: A/C operations when considering the Final Phase The following scenarios for the safety assessment were deduced from the above description: Safety Scenario #1 8.33 khz VCS-equipped aircraft operating in a 8.33 khz airspace Safety Scenario #2 25 khz VCS-equipped, exempt aircraft operating in 8.33 khz VCS airspace Safety Scenario #3 25 khz VCS-equipped, non-exempt aircraft operating in 25 khz VCS airspace close to the boundary with 8.33 khz VCS airspace. Safety Scenario #1 describes the normal operation in the 8.33 environment and applies indefinitely from the beginning of the airspace conversion to 8.33 khz VCS, in the area of applicability defined in IR annex I [16]. It is used to address the problem that an 8.33 khz equipped aircraft could encounter in an 8.33 khz sector due to the mistuning of the assigned frequency. Safety Scenario #2 addresses the (legitimate) presence of 25 khz VCS-equipped, exempt aircraft in 8.33 khz VCS airspace. Such aircraft are likely to exist for many years, even after 31 December 2018 10. Therefore, this Safety Scenario applies: to 8.33 khz VCS airspace in the area of applicability defined in IR Annex I; to 8.33 khz VCS airspace in the IR applicability area 11, from the start of the transition period of the Final Phase; thereafter, in the IR applicability area, until all non-8.33 khz VCS, exempt aircraft have been either retrofitted to 8.33 khz VCS or eventually withdrawn from service. 10 Articles 5(9) and 5(10) of the IR allows this situation to exist even after 2025 as some exemptions are open. 11 ICAO EUR Region where EU Member States are responsible for the provision of air traffic services 17

Safety Scenario #3 applies in the IR applicability area 12 due to some airspace and/or individual sectors being converted to 8.33 khz VCS before 31 December 2018. It applies therefore: in the area of applicability defined in IR Annex I during the Interim Phase in the IR applicability area, due to the fact that States with a particular serious frequency congestion problem are permitted to convert sectors to 8.33 khz before the 1 January 2018 (target date for conversion of all installed ground and aircraft radios to 8.33 khz VCS). Safety Scenario #3 applies also at the boundary of the IR applicability area, as follows: as soon as any airspace /sector close to the boundary is converted to 8.33 khz VCS indefinitely thereafter, because conversion to 8.33 khz VCS in neighbouring States is outside the scope of the implementation These Safety Scenarios are next used to derive Safety Objectives and Safety Requirements for the success and failure cases. 5.2 Success Approach Table 1 lists the Safety Objectives derived from the success approach for the scenarios indicated. ID Safety Objective Scenario SO#1. SO#2. SO#3. SO#4. 25 khz VCS-equipped, non-exempt aircraft shall not be routed through 8.33 khz VCS airspace (except where this is unavoidable for overriding safety reasons) States shall ensure that provision is made for providing adequate air traffic services to exempt aircraft in 8.33 khz VCS States shall ensure that all frequency assignments, for the purposes of providing air traffic services to exempt and non-exempt aircraft, are made so as to avoid interference to 8.33 khz VCS and 25 khz VCS communications in, or from, proximate airspace Prior to entering a 8.33 khz sector,the flight crew shall select the correct 8.33 khz VCS frequency for the sector Table 1: Safety Objectives from the Success Approach #3 #2 #1, #2 and #3 #1 The Table 2 shows the Functional Safety Requirements for the system elements and the Safety Objectives from which they were derived. ID Functional Safety Requirement Parent SO SR#1 SR#2 SR#3 State AIPs (supported as necessary by NOTAMs) shall provide up-todate information to all Aircraft Operators and Flight Crew concerning the VCS requirements of the airspace for which the State is responsible Aircraft Operators and Flight Crew shall be made aware of the consequences of using 25 khz VCS radios in 8.33 khz VCS airspace unless specifically authorised (i.e. State aircraft) Aircraft Operators and Flight Crew of 25 khz VCS-equipped, nonexempt aircraft shall not submit Flight Plans that would take the aircraft through any part of 8.33 khz VCS airspace SO#1 SO#1 SO#1 12 ICAO EUR Region where EU Member States are responsible for the provision of air traffic services 18

SR#4 SR#5 SR#6 SR#7 SR#8 SR#9 SR#10 Aircraft Operators and Flight Crew shall ensure that the Flight Plan for any flights which pass through any part of the EUR Region indicates the VCS capability and status (exempt / non-exempt) of the aircraft concerned Controllers shall not route a 25 khz VCS-equipped, non-exempt aircraft through 8.33 khz VCS airspace unless there is an overriding safety reason for so doing and they apply published procedures covering this situation Controllers shall not accept a 25 khz VCS-equipped, non-exempt aircraft into an 8.33 khz VCS sector unless there is an overriding safety reason for so doing and they apply published procedures covering this situation Before handing over an aircraft to an 8.33 khz VCS sector, Controllers shall ensure that the receiving sector is advised of the VCS capability and status (exempt / non-exempt) of the aircraft concerned ANSPs shall develop and implement strategies to ensure the safe handling of (non-8.33 khz) exempt aircraft in 8.33 khz VCS airspace State s frequency assignment plan shall comply with EUR Frequency Management Manual ICAO EUR Doc 011 (2009) in order to ensure that any ATS assigned frequency does not interfere with other assigned frequencies and is free from harmful interference. Flight Crew shall be adequately trained in the use of the 8.33 khz radios SO#1 SO#1 SO#1 SO#1 SO#2 SO#3 SO#4 Table 2: Functional Safety Requirements from the Success Approach 5.3 Failure Approach The assessment considered both abnormal conditions in the operational environment (e.g. airport / or airspace closure requiring aircraft to be diverted) as well as failures within the comms services (e.g. operational errors). Table 3 illustrates the hazards identified, along with their operational effects. The table also illustrates the possible mitigation means that could be implemented to reduce the effects (or consequences) of the hazards and the severity of the consequences that the hazards may lead to. It must be noted that the severity allocated to the hazards is done at very general level, and may be influenced by the several parameters, specific to the local implementation, such as the traffic level in the sector, the operational environment, the particular system architecture etc. Therefore allocation of the severity should be re-evaluated during the local safety assessment. 19

20 ID Hazard Operational Effects Possible Mitigation of Effects Severity 13 Haz#1 A 25 khz VCS-equipped, nonexempt aircraft enters 8.33 khz VCS airspace failure of SO#1 Inability to communicate with 25 khz VCS aircraft and/or interference to communications with 8.33 khz VCS aircraft Try to establish communication on 121.5 Mhz In case of serious interference to comms with other airspace users, try to contact 25 khz VCS aircraft on emergency frequency to stop the interfering transmissions (see SO#7 below) Cat 3 (possibly Cat 2 for interference if prolonged) Apply normal lost-comms procedures (see SO#5 below) Apply normal lost-comms procedures, plus emergency procedures when appropriate( see SO#6 below) Interception of the aircraft Haz#2 Inadequate provision of facilities / procedures for handling of exempt aircraft in 8.33 khz VCS sectors failure of SO#2 Inability to communicate with (and therefore provide ATS to) exempt aircraft Try to establish communication on 121.5 Mhz Apply normal lost-comms procedures (see SO#5 below) Cat 3 (possibly 2 depending on the number of aircraft involved at one time) Haz#3 Electromagnetic Incompatibility between 8.33 khz VCS and 25 khz VCS frequencies failure of SO#3 Interference to communications with aircraft Reduction in communications performances In case of serious interference to comms with other airspace users, try to contact 25 khz VCS aircraft on emergency frequency to stop the interfering transmissions (see SO#7 below) Try to contact 25 khz VCS on emergency frequency, if appropriate. Cat 3 (possibly Cat 2 if serious and prolonged) Stop all transmission on this frequency and revert to a backup frequency Haz#4 Incorrect frequency selection by the Flight Crew of an 8.33 VCSequipped aircraft failure of SO#4 Loss of communications with the offending aircraft Apply normal lost-comms procedures (see SO#5 below) Cat 3 (possible Cat2 if serious and prolonged Table 3 Hazard Identification and Effect Analysis. 13 Based on the Severity Classification Scheme as defined in ESARR 4 [19]

The Safety Objectives to provide the above mitigations are as follows. ID Safety Objective Related Hazard SO#5. SO#6. SO#7. In the event that a 25 khz VCS-equipped, non-exempt aircraft mistakenly enters 8.33 khz VCS airspace, or an 8.33 khz aircraft selects the wrong frequency, appropriate procedures associated to loss of comms 14 events shall be applied either by pilots or controllers. In the event that it is necessary, for safety reasons, for a 25 khz VCSequipped, non-exempt aircraft to be routed through 8.33 khz VCS airspace, appropriate procedures associated to loss of comms events shall be applied either by pilots or controllers. In case of serious interference to comms with other airspace users by an aircraft, the Controller should contact this aircraft to stop the interfering transmissions and apply appropriate procedures associated to loss of comms events for this aircraft Haz#1, Haz#2, Haz#4 Haz#1 Haz#1, Haz#3 Table 4: Safety Objectives for Mitigation of Operational Effects of the Hazards Specific Safety Objectives are not specified for the other suggested mitigations because they rely on the Controller exercising his/her professional judgement in determining the appropriate course of action for a given situation. The Functional Safety Requirements listed in Table 5 below will ensure the satisfaction of the Safety Objectives identified in Table 4. ID Functional Safety Requirement Parent SO SR#11 In the event that a 25 khz VCS-equipped aircraft is unable to communicate with ATC, the Flight Crew shall apply the appropriate procedures associated to a loss of comms event. SO#5 SR#12 In the event that ATC is unable to communicate with an aircraft in 8.33 khz VCS airspace, the Controller shall apply the appropriate procedures associated to a loss of comms event. SO#5 SR#13 SR#14 In the event that a 25 khz VCS-equipped, non-exempt aircraft has to be routed through 8.33 khz VCS airspace, the transferring Controller shall instruct the Flight Crew to either switch to a 25 khz VCS frequency (if available) or to apply the appropriate procedures associated to a loss of comms event (or emergency event). In the event that a 25 khz VCS-equipped, non-exempt aircraft has to be routed through 8.33 khz VCS airspace, the receiving Controller shall apply the appropriate procedures associated to a loss of comms event (or emergency event). SO#5, SO#6 SO#5, SO#6 14 the procedures for the loss of comms cases are defined locally and include the procedures to contact the transferring controllers, to contact other pilots in the vicinity to request assistance, the use of other available frequencies or communications means, the ICAO Communication Loss procedures and other measures that may be available locally. 21

ID Functional Safety Requirement Parent SO SR#15 SR#16 In case of serious interference to comms with other airspace users by a 25 khz aircraft that has inadvertently entered an 8.33 khz sector, the Controller shall apply appropriate procedures in order to try to contact the 25 khz VCS aircraft on emergency frequency to stop the interfering transmissions. In case of serious interference to comms with other airspace users by a 25 khz exempt aircraft operating legitimately in an 8.33 khz sector, the Controller should contact the 25 khz VCS aircraft to stop the interfering transmissions and apply the procedure associated to a loss of comms event for this aircraft SO#7 SO#7 Table 5: Functional Safety Requirements for Mitigation of Hazardous Operational Effects The final step in the failure approach was to identify all the possible causes of the hazards and to identify Functional Safety Requirements that would reduce the likelihood that the cause will occur and/or reduce the likelihood that the cause would actually lead to a hazard. These are shown in Table 6, for each hazard. ID Hazard Causes Safety Requirement Haz#1 A 25 khz VCS-equipped, nonexempt aircraft enters 8.33 khz VCS airspace Incorrect airspace information Aircraft Operator / Flight Crew error SR#1 to SR#7, SR#11to SR#16, SR#17 below, Controller error SR#18 below Unexpected and unavoidable operational situation or emergency Haz#2 Inadequate provision of facilities / procedures for handling of exempt aircraft in 8.33 khz VCS sectors Inadequate strategy e.g. due to too many exempted aircraft in the considered sector SR#8, SR#11, SR#12 Haz#3 Electromagnetic incompatibility between 8.33 khz VCS and 25 khz VCS frequencies Inappropriate frequency assignments Uncoordinated frequency assignments SR#9, SR#15, SR#16, SR#19 below Haz#4 Incorrect frequency selection by the Flight Crew of an 8.33 VCS-equipped aircraft Flight Crew error SR#1, SR#10 Table 6: Hazard Causal Analysis Three further Functional Safety Requirements emerge from this, as shown in Table 7. 22

ID Functional Safety Requirement Related Hazard SR#17 SR#18 SR#19 IFPS shall check each flight plan that is routed through one or more 8.33 khz VCS sectors to ensure that it indicates that the aircraft is 8.33 khz VCS capable otherwise the flight plan shall be rejected unless it is an exempted aircraft and the appropriate information is included in the Flight plan. If the Flight Crew of a 25 khz VCS-equipped aircraft is requested to transfer to an 8.33 khz VCS channel they shall immediately advise ATC that the aircraft is not 8.33 khz VCS capable States shall ensure that all LOAs are updated in accordance with their respective VCS implementation status. Haz#1 Haz#1 Haz#3 Table 7: Additional Functional Safety Requirements for Mitigation of Hazard Causes 5.4 Risk Assessment 5.4.1 Overview As it is not practicable for a generic safety assessment such as this to address the factors specific to local operational environments, it is not possible to assign meaningful quantified Safety Objectives / Safety Integrity Requirements for 8.33 khz VCS or to draw quantitative conclusions regarding the risk of its deployment. That said, however, it is possible for the safety assessment to draw some qualitative conclusions, as follows. In the long term, when all aircraft operating in Europe are 8.33 khz VCS equipped (Safety Scenario #1), then for flights that originate in airspace of IR applicability (and for 8.33 khz VCS-equipped flights originating outside this airspace) the only increased risk of an accident, compared with today s 25 khz VCS communications, arises from incorrect selection (mistuning) of an 8.33 VCS frequency as explained in section 5.4.2 below. Risk increases arising in the shorter-term and/or from equipage exceptions (Safety Scenarios #2 and #3) are discussed in sections 5.4.3 and 5.4.4 below. 5.4.2 Safety Scenario #1 This scenario covers 8.33 khz VCS-equipped aircraft operating in 8.33 khz VCS airspace. It reflects what will be normal operations in 8.33 VCS below FL195 and applies indefinitely. There is only one hazard associated with Safety Scenario #1: Haz#4: Incorrect frequency selection by the Flight Crew of an 8.33 VCS-equipped aircraft Haz#4 addresses in general mistuning of the correct frequency - in human factors terms this would be a slip, that is correct intention but incorrect execution 15. It should be noted that the airspace users will range from General Aviation to Commercial Air Transport and State aircraft and some risk increase is likely to occur because of: 15 In contrast, selection of an incorrect frequency - in human factors terms a mistake (ie incorrect intention) - is out of scope of this safety assessment as explained in section 2 above. 23

an increase of one in the number of digits to be selected for 8.33 khz VCS frequencies - this is already the case above FL 195 part of the airspace user population, who have limited or no experience of 8.33 khz VCS operations above FL 195 - that was of course the case for all airspace users when 8.33 khz VCS was first introduced above FL 195. For Haz#4, satisfaction of Functional Safety Requirements SR#1 and SR#10 should ensure that any risk involved is reduced significantly. This hazard has been assessed as Cat 3 (possibly Cat 2, depending on the specific local circumstances). 5.4.3 Safety Scenario #2 This scenario covers 25 khz VCS-equipped, exempt aircraft operating (legitimately) in 8.33 khz VCS airspace. It applies until all 25 khz VCS-equipped, exempt aircraft have been retrofitted to 8.33 khz VCS or have eventually been withdrawn from service probably many years after the 1 st of January 2018. There are two hazards associated with Safety Scenario #2: Haz#2: inadequate provision of facilities / procedures for handling of 25 khz VCS-equipped, exempt aircraft in 8.33 khz VCS sectors. Haz#3: Electromagnetic incompatibility between 25 khz VCS and 8.33 khz VCS frequencies. These two hazards (Haz#2 and Haz#3) have been assessed as Cat 3 (possibly Cat 2, depending on the specific local circumstances); however, they are entirely avoidable by satisfaction of Functional Safety Requirements SR#8 and SR#9 respectively. 5.4.4 Safety Scenario #3 This scenario covers 25 khz VCS-equipped, non-exempt aircraft operating in 25 khz VCS airspace close to the boundary with 8.33 khz VCS airspace. It applies, for the area of applicability defined in IR Annex I, to the Interim Phase and is assumed to apply indefinitely in States bordering the IR applicability area because conversion to 8.33 khz VCS, outside of this area, is not regulated by the IR. There are two hazards associated with Safety Scenario #3: Haz#1: a 25 khz VCS-equipped, non-exempt aircraft enters 8.33 khz VCS airspace this has been assessed as a Severity Category (Cat) 3 hazard and may be due to an operational error or as a result of the need to divert an aircraft into 8.33 khz VCS airspace for some reason Haz#3: Electromagnetic incompatibility between 8.33 khz VCS and 25 khz VCS frequencies - this has been assessed as a Cat 3 (possibly Cat 2) hazard The risk associated with Haz#3 would be reduced substantially, probably to a very low level, by satisfaction of Functional Safety Requirement SR#9. For Haz#1, the satisfaction of Functional Safety Requirements SR#1 to SR#7, SR#11 to SR#16 and SR#17 to SR#18 (inclusive) should ensure that any risk involved is reduced substantially. However, what it would not ensure is that the risk is reduced as far as reasonably practicable, for two reasons, as follows. Firstly, Article 3(10) of the draft IR [16] requires those States listed in Annex I thereto to convert at least 25% of possible frequency assignments to 8.33 khz VCS by 31 December 2014. Although this enables the possible occurrence of Haz#1, it is justifiable on the basis of the pressing need for an increased number of voice channels in those States and is reinforced by Article 3(9) of the IR which 24

requires aircraft flying as IFR in Classes A to C airspace in those States to be 8.33 khz VCS equipped. However, the issue associated to the possible inconsistency between the equipment carriage requirement (article 3(9)) and the airspace conversion requirement (article 3(10)) needs to be addressed in order to satisfy Safety Target ST2 - see Safety Issue Iss001 described in section 7.2 below Secondly, the draft IR does not prevent the other States in the IR applicability area from converting some (if not all) of their possible frequency assignments to 8.33 khz VCS well before 31 December 2018. This would not be a safety problem if no conversions took place until all non-exempt aircraft had been fitted with 8.33 khz VCS radios and therefore ST2 would be satisfied in this respect if the draft IR [16] were amended so that: Article 3(16) makes it clear that it applies to all installed radios - see Safety Issue Iss002 described in section 7.2 below. in relation to Article 3(17) and when considering the whole IR applicability area prior to the date of mandatory carriage of 8.33 khz VCS radios (1 January 2018), unnecessary conversions should be limited or a local safety assessment should show that such conversions are safe considering all the potential airspace users impacted by such change - see Safety Issue Iss003 described in section 7.2 below 5.4.5 Risk Quantification The absolute assessment of risk for Haz#1 ( a 25 khz VCS-equipped, non-exempt aircraft enters 8.33 khz VCS airspace ) is very difficult at a generic level because it will depend on the number of opportunities for the hazard to arise i.e. on the number of interfaces between 8.33 khz VCS and 25 khz VCS sectors which, in turn, will depend on local factors including the number and distribution of sectors to be converted and the actual rate of 8.33 khz VCS aircraft equipage. It is necessary, therefore for individual States to carry out a full safety assessment, specific to their areas of responsibility, prior to the deployment of 8.33 khz VCS comms - see Assumption A004 described in section 7.1 below. For Haz#4 ( Incorrect frequency selection by the Flight Crew of an 8.33 VCS-equipped aircraft ), a similar conclusion can be raised even it applies to a different topic. Indeed local factors like category of airspace users (GA, VFR, Gliders, ) in the converted airspace, their training, their experience, the level of information provided to them by States will impact the number of opportunities for the hazard to arise. A proper satisfaction of SR#10 is essential. For Hazards #2 ( inadequate provision of facilities / procedures for handling of 25 khz VCS-equipped, exempt aircraft in 8.33 khz VCS sectors ) and #3 ( Electromagnetic incompatibility between 25 khz VCS and 8.33 khz VCS frequencies ), it has been assessed that proper implementation of the identified SRs will prevent the occurrence of the Hazards. However for Haz#2, it is important that the service provider determine very precisely the amount of exempted aircraft they have to handle in their airspace. Indeed a large amount of exempted aircraft in a given airspace could lead to an unachievable SR#8. 6. IMPACT ON GROUND VEHICLE OPERATION 6.1 Introduction The movement of vehicles on the manoeuvring area of an aerodrome shall be controlled by the relevant air traffic services. When so prescribed by the service provider continuous two way radiotelephony is necessary. It must be noted that the rules for the control of the vehicles on ground may be different from one airport to another one. Air Traffic control is responsible for the control of the movement of vehicles on the manoeuvring area. To maintain such control and if so prescribed, vehicles operating on the manoeuvring area should be fitted with VHF-Com R/T on the appropriate channel (Ground or tower frequency), or closely escorted 25

by an R/T equipped vehicle. The Airport operator is responsible for ensuring that operational R/T equipment is provided on vehicles being operated on the manoeuvring area and drivers are fully conversant with proper R/T procedures. On apron areas, ATS has normally no responsibility for control of vehicles. The airport operator is responsible for regulating vehicular traffic movement on the apron in order to reduce to a minimum the risk of aircraft/vehicle and vehicle/vehicle conflict and to promote the safety of pedestrians. The Apron Control service can be exercised by regulating the vehicles that can enter the apron and by instruction of driver. ICAO is providing detailed information relative to the ground vehicle communication aspect in the following documents: [20], [21], [22], [23] and [24]. Taking into account that the arrangement in each airport might be different, it is necessary to perform a local safety impact assessment which will consider the local aerodrome environment (runway, manoeuvring and apron physical layout, traffic density, ) and the possible different actors delivering services to vehicles (i.e. ANSPs, Airport operator). This generic safety impact assessment does not address the Apron area environment because normally no ATS service is delivered in such area. If however it is the case for a specific environment and if VHF voice communication is used, the local safety assessment should address this aspect and scenarios identified in this section could be extended also to the Apron area. The implementation of 8.33 khz will impact any vehicle equipped with a radio operating on the manoeuvring area where the ATC is supported by 8.33 khz VCS. Indeed each vehicle shall be equipped with 8.33 khz VCS (or the driver shall have an appropriate hand-held equipment) for e.g. movement instructions and for crossing runways or if not-equipped should be guided/escorted by an 8.33 khz equipped vehicle in order to operate in the manoeuvring area. 6.2 Safety Targets Safety targets identified in section 3 above are referring to the implementation of the 8.33 khz in general and are applicable also to the airport operation when considering ground vehicles on the manoeuvring area. 6.3 Safety Scenarios Assessed The following scenarios for the safety assessment were deduced from section 6.1: Safety Scenario #4 Non 8.33 khz capable vehicle operating near the manoeuvring area where ATC is supported by 8.33 khz VCS. Safety Scenario #5 8.33 khz capable vehicle operating in a manoeuvring area where ATC is supported by 8.33 khz VCS. Note that: Safety Scenario #4 addresses the possible presence of a vehicle on or near the manoeuvring area unable to communicate for e.g. one of the following reasons: o o o is equipped with the wrong radio (alias with non compatible 8.33 khz radio); radio failure; is not equipped. 26

Safety Scenario #5 addresses the normal operation where the vehicle is 8.33 khz VCS equipped and the air traffic service delivered in the manoeuvring area is supported by 8.33 khz VCS. These Safety Scenarios are next used to derive Safety Objectives and Safety Requirements for the success and failure cases. Note: In the rest of this document when the term VCS-equipped vehicle is used, it means either a fix installation onboard the vehicle or the use of hand-held equipment by the vehicle driver. 6.4 Success Approach Table 8 lists the Safety Objectives derived from the success approach for the scenarios indicated. 27

ID Safety Objective Scenario SO#8. SO#9. SO#10. SO#11. A non-8.33 khz VCS-equipped vehicle shall not operate on 8.33 khz VCS manoeuvring area unless escorted. Airport Operator shall ensure that provision is made for authorising non- 8.33 khz equipped vehicle to operate on 8.33 khz manoeuvring area for overriding safety reasons (e.g. fire fighting vehicle not equipped) The ANSP shall ensure that the assignment of frequency for ATS delivered in the manoeuvring area is done so as to avoid interference from other ground/airborne transmissions Airport operator shall ensure that ground radio equipment used by ground vehicle drivers are interoperable with 8.33 khz standard Table 8: Safety Objectives from the Success Approach #4 #4 #5 #5 With regard to the SO#11, it should be noted that airborne equipment should be compliant with the Eurocae Standard ED23B[18] derived from the ICAO Annex10 [14], while ATS ground base stations should be compliant with the Standard ETSI EN 300 676 [17] also derived from the ICAO Annex10 [14]. For ground vehicle radio equipment, it is assumed that compliance with ICAO Annex 10 [14] is sufficient to ensure the interoperability between ground vehicle and the ATS. It should be noted that the Standard ETSI EN 300 676[17] is also applicable to ground mobile and hand-held radios for ground use. The Table 9 shows the Functional Safety Requirements for the system elements and the Safety Objectives from which they were derived. ID Functional Safety Requirement Parent SO SR#20 SR#21 SR#22 SR#23 SR#24 SR#25 Aerodrome information/publication (aerodrome manual) shall provide up-to-date information to all vehicle drivers concerning the VCS requirements applicable to the aerodrome manoeuvring areas. Vehicle drivers shall be made aware of the consequences of using non-8.33 khz VCS radios in 8.33 khz VCS manoeuvring areas unless specifically authorised. Airport operator/ansp shall develop and implement strategies to ensure the safe handling of non-8.33 khz VCS-equipped vehicle in 8.33 khz VCS airport area. State s frequency assignment plan shall comply with EUR Frequency Management Manual ICAO EUR Doc 011 (2009) [15] in order to ensure that any aerodrome assigned frequency does not interfere with other frequencies assigned in the aerodrome vicinity and is free from harmful interference. Airport operator shall ensure that vehicle drivers operating on the manoeuvring area are fully conversant with the proper R/T procedures associated to 8.33 khz VCS. Airport operator shall ensure that the vehicle radio equipment (including hand-held equipment) used for ATC are compliant with the ICAO Annex 10 [14] standard. Table 9: Functional Safety Requirements from the Success Approach SO#8 SO#8 SO#9 SO#10 SO#11 SO#11 28

6.5 Failure Approach Implementation of the 8.33 khz Voice Channel Spacing The assessment considered both abnormal conditions in the operational environment (e.g. vehicles coming from another aerodrome where 8.33 khz is not yet implemented, fire fighting operation necessitating vehicles reinforcement but not 8.33 khz equipped,.) as well as failures within the comms services (e.g. operational errors). Table 10 illustrates the hazards identified, along with their operational effects. The table also illustrates the possible mitigation means that could be implemented to reduce the effects (or consequences) of the hazards and the severity of the consequences that the hazards may lead to. It must be noted that the severity allocated to the hazards is done at very general level, and may be influenced by the several parameters, specific to the local implementation, such as the traffic level in the manoeuvring area, the operational environment, the particular system architecture etc. Therefore allocation of the severity should be re-evaluated during the local safety assessment. 29

30 ID Hazard Operational Effects Possible Mitigation of Effects Severity 16 Haz#5 A non-8.33 khz VCS-equipped vehicle enters in the 8.33 khz VCS airspace manoeuvring area failure of SO#8 Inability to communicate with non-8.33 khz VCS vehicle and/or interference to communications with 8.33 khz VCS vehicle and aircraft Inform other vehicles operating in the vicinity of the presence of this vehicle (SO#12 below) Inform aircraft landing and/or taxiing of the presence of this vehicle (SO#12 below) Try to establish communication using all other available means Cat 3 (possibly cat 2 for interference) Intercept and escort vehicle if situation dictates it (SO#13 below) Haz#6 Inadequate provision of facilities / procedures for handling non-8.33 khz equipped vehicle (exempted) failure of SO#9 Inability to communicate with (and therefore provide ATS to) vehicles authorised to operate on the manoeuvring area. Inform other vehicles operating in the vicinity of the presence of this vehicle (SO#12 below) Inform aircraft landing and/or taxiing of the presence of this vehicle (SO#12 below) Cat 3 Try to establish communication using all other available means Intercept and escort the vehicle if situation dictates it (SO#13 below) Haz#7 The 8.33 khz assigned frequency generates interference failure of SO#10 Interference to communications on the manoeuvring area and possibly for Departure and Arrival operations Apply normal lost-comms procedures for aircraft impacted by this interference during departure or arrival. Stop all transmission on this frequency and revert to a backup frequency Cat 3 (possibly Cat 2 if serious and prolonged) Haz#8 The 8.33 khz assigned frequency is impacted by interference failure of SO#10 Interference to communications on the manoeuvring area Inform other vehicles operating in the area affected by this interference (SO#12 below) Stop the traffic if interference is severe Cat 3 (possibly Cat 2 if serious and prolonged) Intercept and escort vehicle if it is shown to be the interference source(so#13 below) 16 Based on the Severity Classification Scheme as defined in ESARR 4 [19]

Haz#9 Wrong selection of the 8.33 khz channel by the vehicle driver Loss of communication with the vehicle Inform other vehicles operating in the vicinity of the presence of this vehicle (SO#12 below) Cat 3 SO#11. Inform aircraft landing and/or taxiing of the presence of this vehicle (SO#12 below) Try to establish communication using all other available means Intercept and escort the vehicle if situation dictates it (SO#13 below) Table 10 Hazard Identification and Effect Analysis 31

The Safety Objectives to provide the above mitigations are as follows. ID Safety Objective Related Hazard SO#12. SO#13. When situation might lead to taxiway collision or runway incursion, inform other vehicles and aircraft operating on the manoeuvring area or aircraft landing of the presence of a vehicle in the event that: a non-8.33 khz VCS-equipped vehicle mistakenly enters in a 8.33 khz VCS manoeuvring area communications with an 8.33 khz VCS-equipped vehicle are disrupted by interference or, a vehicle driver has selected the wrong 8.33 khz channel When situation might lead to taxiway collision or runway incursion, intercept and escort the vehicle in the event that: a non 8.33 khz VCS-equipped vehicle mistakenly enters in a 8.33 khz VCS manoeuvring area communications with an 8.33 khz VCS-equipped vehicle are disrupted by interference or, a vehicle driver has selected the wrong 8.33 khz channel Haz#5 Haz#6 Haz#8 Haz#9 Haz#5 Haz#6 Haz#8 Haz#9 Table 11: Safety Objectives for Mitigation of Operational Effects of the Hazards Specific Safety Objectives are not specified for the other suggested mitigations because they rely on the Controller exercising his/her professional judgement in determining the appropriate course of action for a given situation. The two Functional Safety Requirements listed in Table 12 below will ensure the satisfaction of the Safety Objectives identified in Table 11. ID Functional Safety Requirement Parent SO SR#26 SR#27 In the event that no contact can be established to a vehicle on the manoeuvring area and when situation might lead to taxiway collision or runway incursion the controller shall: inform other vehicles in the vicinity and taxiing aircraft to immediately stop unless the vehicle has been visually acquired by them whenever required, ask to a landing aircraft to execute a missed approach due to runway obstruction. In the event that a vehicle is unable to communicate with ATC and when situation might lead to taxiway collision or runway incursion, the airport operator shall, in liaison with the ATC, intercept and escort the vehicle outside of the manoeuvring area. SO#12 SO#13 Table 12: Functional Safety Requirements for Mitigation of Hazardous Operational Effects The final step in the failure approach was to identify all the possible causes of the hazards and to identify Functional Safety Requirements that would reduce the likelihood that the cause will occur and/or reduce the likelihood that the cause would actually lead to a hazard. These are shown in Table 13, for each hazard. 32

ID Hazard Causes Safety Requirement Haz#5 A non-8.33 khz VCSequipped vehicle enters in the 8.33 khz VCS aerodrome manoeuvring area Incorrect information aerodrome vehicle driver lack of proficiency SR#20, SR#21 Haz#6 Inadequate provision of facilities / procedures for handling non-8.33 khz equipped vehicle (exempted) Haz#7 The 8.33 khz assigned frequency generates interference Haz#8 The 8.33 khz assigned frequency is impacted by interference Haz#9 Wrong selection of the 8.33 khz channel by the vehicle driver Table 13: Hazard Causal Analysis Inadequate comms strategy In appropriate frequency assignment Inappropriate verification Inappropriate frequency assignment Inappropriate verification Inappropriate training HMI issue SR#20, SR#21, SR#22 SR#23, SR#25, SR#28 below SR#23, SR#25, SR#29 below SR#24,SR#25, SR#27, SR#30 below Three further Functional Safety Requirements emerge from this, as shown in Table 14. ID Functional Safety Requirement Related Hazard SR#28 SR#29 SR#30 Airport operator/ansp shall verify (e.g. through operational trial) that the 8.33 khz assigned frequency does not generate interference to other already assigned frequencies (ground, tower) Airport operator/ansp shall verify (e.g. through operational trial) that the 8.33 khz assigned frequency is not impacted by interference Vehicle drivers shall receive adequate training on the usage of the 8.33 khz VCS system Haz#7 Haz#8 Haz#9 Table 14: Additional Functional Safety Requirements for Mitigation of Hazard Causes 6.6 Risk Assessment 6.6.1 Overview The generic safety assessment cannot address factors linked with the local aerodrome environment (runway, manoeuvring and apron physical layout, traffic load).therefore it is not possible to assign meaningful quantified Safety Objectives / Safety Integrity Requirements for 8.33 khz VCS in the airport area or to draw quantitative conclusions regarding the risk of its deployment at aerodrome level. That said, however, it is possible for the safety assessment to draw some qualitative conclusions. 33

6.6.2 Safety Scenario #4 Implementation of the 8.33 khz Voice Channel Spacing This scenario is used to address the problem of a vehicle operating on or near the 8.33 khz VCS aerodrome manoeuvring area and unable to communicate with the ATS because either non-equipped or equipped with wrong radio. The following hazards are associated with Safety Scenario #4: Haz#5: A non-8.33 khz VCS-equipped vehicle enters in the 8.33 khz VCS aerodrome manoeuvring area Haz#6: Inadequate provision of facilities / procedures for handling non-8.33 khz equipped vehicle (exempted) Haz#5 addresses in general the non correct application of the procedures for driving in the manoeuvring area or the lack of knowledge of the airport surface. Haz#5 is avoidable by satisfaction of Functional Safety Requirements SR#20 and SR#21. However, if such hazardous situations do occur, for whatever reason, satisfaction of SR#26 and SR#27 will reduce as much as possible their effects in terms of safety. Haz#6 addresses the problem linked with unclear definition of procedure for driving in the aerodrome and lack of resource to guide non-8.33 VCS equipped vehicles in the aerodrome manoeuvring area (i.e. maintenance vehicles, ambulances, fire brigade ). Haz#6 is avoidable by satisfaction of Functional Safety Requirements SR#20, SR#21, SR#22, SR#26 and SR#27 which should ensure that any risk involved is reduced significantly. 6.6.3 Safety Scenario #5 This scenario covers 8.33 KHz VCS-equipped vehicles operating in 8.33 khz VCS manoeuvring area. It reflects what will be normal operations in an 8.33 khz airport and applies indefinitely. There are three hazards associated with Safety Scenario #5: Haz#7: The 8.33 khz assigned frequency generates interference Haz#8: The 8.33 khz assigned frequency is impacted by interference Haz#9: Wrong selection of the 8.33 khz channel by the vehicle driver Haz#7 and Haz#8 address the problem linked with the correct assignment and use of the frequencies in the airport area. The risk associated with Haz#7 and Haz #8 would be reduced substantially, probably to a very low level, by satisfaction of Functional Safety Requirements SR#28 and SR#29 respectively in addition to SR#23 and SR#25. However, if such hazardous situations do occur, for whatever reason, satisfaction of SR#27 will reduce as much as possible their effects in terms of safety. Haz#9 addresses the mistuning of the correct frequency by the vehicle drivers due to the increase number of digit to be set. The increase in risk linked with this hazard is very limited because vehicles operating in the airport use a limited number of frequencies/channels (e.g. the ground or the tower frequency only) as opposed to pilots changing frequencies/channels frequently (e.g. at each sector). The risk associated with Haz#9 would be reduced substantially by satisfaction of the Functional Safety Requirement SR#30 in addition to SR#24 and SR#25. However, if such hazardous situations do occur, for whatever reason, satisfaction of SR#27 will reduce as much as possible their effects in terms of safety. 34

6.6.4 Risk Quantification Implementation of the 8.33 khz Voice Channel Spacing The absolute assessment of risk for hazards identified for the airport operation when considering ground vehicle operation is very difficult at a generic level because it will depend on the number of opportunities for the hazards to arise that is linked with local aerodrome environment (runway, manoeuvring and apron physical layout, electromagnetic environment, ) and the possible different actors delivering services to vehicles (i.e. ANSPs, Airport operator). It is necessary, therefore for individual States to carry out a full safety assessment, specific to their areas of responsibility, prior to the deployment of 8.33 khz VCS comms in the airport area - see Assumption A004 described in section 7.1 below. 35

36 7. CAVEATS The conclusions in section 8.1 below are subject to the following caveats. 7.1 Assumptions The safety assessment assumes the following: ID Assumption Rationale A001 Current VHF comms i.e. using 25 khz VCS are acceptably safe. A002 A003 A004 7.2 Safety Issues The 8.33 khz VCS comms infrastructure and aircraft equipage will comply with the necessary ICAO standards, as already applicable to the EUR region above FL 195. In addition to 8.33 khz channel spacing capability, the aircraft and mobile equipment is able to tune to 25 khz spaced channels and to operate in an environment which uses offsetcarrier frequencies Individual States / ANSPs must carry out a full safety assessment specific to their areas of responsibility, prior to the deployment of 8.33 khz VCS comms. The following outstanding safety issue needs to be addressed ID Description Rationale Iss001 Article 3(10) of the draft VCSII IR [16] does not refer to any specific airspace for 8.33 conversions whereas Article 3(9) mandates 8.33 carriage only for aircraft flying IFR in Class A, B and C airspaces. Iss002 Article 3(16) of the draft VCSII IR [16] specifies that all radios shall have the 8.33 khz channel spacing at the latest the 1 January 2018 but it is not clear what are the exact radio users impacted by this article. Does it apply to ANSPs (ground radios), to Aircraft Operators (airborne equipment, OPC radios, ), etc? There is no historical evidence to suggest otherwise. Any risks inherent in VHF airground comms are therefore deemed to be outside the scope of this safety assessment - see also section 2 above. The operational use of a primarily homogeneous 8.33 khz VCS comms infrastructure /aircraft fit has already been demonstrated above FL 195 and is therefore deemed to be outside the scope of this safety assessment. This is part of the design requirements for the aircraft 8.33 khz VCS radios and is reinforced by article 3(21) of the draft IR [16] The safety assessment covered herein is necessarily generic and cannot therefore cover the factors specific to local operational environments many of which have a direct bearing on the safety risks involved this is addressed by Article 6 of the draft IR [16] There is a potential inconsistency between the equipment carriage article (3(9)) and the airspace conversion article (3(10)). It is necessary to clarify the applicability of article 3(16).

Iss003 When considering the whole IR applicability area and prior to the date of mandatory carriage of 8.33 khz VCS radios (1 January 2018), unnecessary conversions could significantly increase the risk of communications failure with non-exempt aircraft that legitimately retain their existing 25 khz VCS capability. Unnecessary conversions could significantly increase the risk of communications failure unless a local safety assessment is carried out by the Member State to show that such conversation is safe when considering the different airspace users impacted by such conversions. 8. CONCLUSIONS AND RECOMMENDATIONS 8.1 Conclusions The safety target was set to demonstrate that: ST#1 the risk of an accident following the complete conversion to 8.33 khz VCS shall not be significantly greater than before the start of the introduction of 8.33 khz VCS ST#2 the risk of an accident during the transition to the complete conversion to 8.33 khz VCS shall be reduced as far as reasonably practicable. Subject to the identified Assumptions and issues listed in section 7, the overall conclusion is that deployment of 8.33 khz VCS in the airspace of IR applicability according to the draft VCS II IR [16] has the potential to satisfy the above Safety Targets. Specific conclusions are as follows: 1. For the airspace of IR applicability in general there are three risks associated with the deployment of 8.33 khz VCS: an increase in the risk of mistuning to an 8.33 khz VCS because of the additional digit that has to be selected and, initially, because of a number of airspace users (e.g. General Aviation) unfamiliar with 8.33 khz VCS above FL 195 the risk associated with having to accommodate 25 khz VCS-equipped State aircraft, up to the date by which all such aircraft will have been retrofitted or eventually withdrawn from service; and the risk associated with having two different VCS arrangements across the border with the airspace of IR applicability. In all three cases, Functional Safety Requirements have been derived to reduce the risk to what is likely to be a low level, though that needs to be confirmed by specific safety assessments to be carried out by the States concerned. 2. For the airspace area of applicability defined in IR annex I for which there is an urgent need to solve pressing frequency-shortage problems, which requires conversion of the infrastructure to 8.33 khz VCS before 31 December 2018, there will be an additional risk associated with operating 25 khz VCS, non-exempt aircraft in a mix of 25 khz VCS and 8.33 khz VCSequipped sectors / airspace. Functional Safety Requirements have been derived in order to reduce that risk but, because of the number of variable factors involved and the complexity of the relationships between them, it has not been possible in this necessarily generic safety assessment to determine quantitatively what that risk would be that needs to be done by the States / ANSPs concerned. 3. For the airspace of IR applicability, the conversion of frequency assignments should not start until after the date by which the IR requires all non-exempt aircraft using this airspace to be 37

equipped with 8.33 khz VCS-equipped radios unless a local safety assessment has been carried out to show that such conversion is safe when considering the different airspace users impacted by this change. 4. For the specific case of ground vehicles operating in the manoeuvring area, there will be a slight increase in the risk of mistuning the frequency/channel. Nevertheless this increase in risk will be very limited because those vehicles will mainly use a single frequency/channel (e.g. the ground or the tower frequency) and will not change it so often. Finally it shall be shown that these systems (fixed or hand-held) used by vehicle drivers are complying at least with the ICAO Annex 10 requirements in order to prevent any harmful interference and to be fully interoperable. Functional Safety Requirements have been identified to reduce the risk linked with the vehicles operating on the manoeuvring area. The different Safety requirements, Assumptions and Issues identified during this safety impact assessment are listed in the safety log (See Annex 3). 8.2 Recommendations It is recommended that: 1. The draft VCSII IR [16] be amended so as to clear safety Issue Iss001 identified in section 7. To address this safety issue, the following safety requirement will be added to the draft VCS II IR Annex 3: Member States who convert frequency assignments to 8.33 khz in any part of their airspace shall: (1) ensure that operators of aircraft flying in such airspace are informed that these aircraft must be equipped with radio equipment with 8.33 khz channel spacing (2) perform a local safety assessment prior to the conversion that takes into account all the traffic expected to cross that airspace and the potential issues arising from the VCS in operation in all surrounding airspace. 2. The draft VCSII IR [16] be amended so as to clear safety Issue Iss002 identified in section 7. To address this safety issue, a new definition will be added to clarify that in this document by the term radio we refer to any electronic device designed to transmit and/or receive transmissions in the aeronautical mobile communications band. 3. The draft VCSII IR [16] be amended so as to clear safety Issue Iss003 identified in section 7. This safety issue is addressed by the new requirement to be added in the IR which is proposed in the resolution of issue 1 above. 8.3 How the draft IR is addressing the outcome of the safety impact assessment Annex 4 shows how the results of the safety assessment are addressed by the VCSII IR. The table, included in this annex, identifies three possibilities associated to the different Safety requirements: The SR is fully addressed by the present draft IR [16] and no action is necessary. The SR is not directly addressed by the present draft IR [16] but existing regulation (e.g. ICAO) might be sufficient to address this safety requirement. An action has been carried out by the IRDG and the drafting group decided that the situation is acceptable without modifying the IR VCSII IR Draft. 38

The SR is not addressed by the present draft IR [16] and an IR modification is necessary. The proposal attached to this table will be included in the final VCSII IR Draft. As indicated in this table, it has been shown that all Safety Requirements identified during this safety impact assessment have been satisfactorily addressed either by the draft VCS II IR [16] or by the future draft VCS II IR which will include the additional/modified requirements or by other existing regulations (e.g. ICAO). 39

ANNEX 1: GLOSSARY AND REFERENCES A1-1 Glossary of Terms and Abbreviations ACC A/G AIP ANS ANSP AO Arg ATAS ATCO ATM CAT CND Comms FCI FL FHA FIS FDP GSN IFPS IR IRDG LoA PSSA MILHAG MoM NSA RE RT SAM SAR SCG SES SOP SSR SR ST VCS Area Control Centre Air Ground Aeronautical Information Publication Air Navigation Service Air Navigation Service Provider Airline Operator Argument Air Traffic Advisory Service Air Traffic Controller Air Traffic Management Commercial Air Transportation Cooperative Network Design Communications Future Communication Infrastructure Flight Level Functional Hazard Assessment Flight Information Service Flight Data Processing Goal Structuring Notation Integrated Initial Flight Plan Processing System Implementing Rule Implementing Rule Drafting Group Letter of Agreement Preliminary System Safety Assessment Military Harmonisation Group Minutes of Meeting National Supervisory Authority Requirement-Engineering Radio Telephony Safety Assessment Methodology Safety Assessment Report Stakeholder Consultation Group Single European Sky Standard Operating Procedure Safety Summary Report Safety Requirements Safety Target Voice Channel Spacing A1-2 References [1] Safety Assessment (FHA/PSSA) 8.33 khz BELOW FL 195, (ACC Services), Edition 0.2, 31 st March 2006 [2] Safety Assessment (FHA/PSSA) 8.33 khz BELOW FL 195, Medium and Massive Scenario, Edition 1.1, 22 nd November 2006 [3] Safety Assessment Report, 8.33 Below FL 195 in ICAO EUR Region, Edition 1.3, October 2008 [4] Initial Safety Impact Assessment-Safety Plan for 8.33 khz ref 8.33<FL 195-40

SAFPLN-2009-0101-A Draft, dated 17/09/09 [5] Implementation of the 8.33 khz Voice Channel Spacing - Initial Safety impact assessment-report for the interim phase, 8 33belowFL 195-SAFREP-2009-0101-D V0 1 08-03-10 [6] Implementation of the 8.33 khz Voice Channel Spacing - Initial Safety impact assessment-report for the Final phase, 8 33 -SAFREP-2009-0201-D V0 1 08-03-10 [7] Minutes of Meeting, Initial Safety Assessment for 8.33 khz workshop, 30 July 2009 [8] Minutes of Meeting, Initial Safety Assessment for 8.33 khz workshop, 16 December 2009 [9] Eurocontrol powerpoint presentation Air-Ground Voice Com service 8.33 khz below FL 195 - Initial Safety impact assessment operational scenario 1 [10] EUROCONTROL Air-Ground Communication Safety Study - Causes and Recommendations - DAP/SAF 2006-09, Edition 1.1 [11] EUROCONTROL, 2007, Air Navigation System Safety Assessment Methodology (SAM), SAF.ET1.ST03.1000-MAN-01, Edition 2.1 [12] REGULATORY APPROACH for the 2nd phase of the Air-Ground Voice Channel Spacing ( airspace ) draft V1.0 dated 07-05-10 [13] PSG3-WP3 IR Draft Justification material dated 11 October 2010 [14] ICAO annex 10 Volume III Communication Systems First Edition - July 1995 [15] ICAO EUR Doc 011 EUR Frequency Management Manual (2009) [16] draft VCS II IR V10, this is the version distributed as Annex 4 to the Minutes of the 3 rd meeting of the 8.33 Programme Steering Group (PSG). [17] ETSI EN 300 676 V1.3.1 (2003-03) Electromagnetic compatibility and Radio spectrum Matters (ERM); Ground Based VHF hand-held, mobile and fixed radio transmitters, receivers and transceivers for the VHF aeronautical mobile service using amplitude modulation; Technical characteristics and methods of measurements. [18] EUROCAE ED-23B (March 1995) and Amendments No 1, 2 and 3: Minimum operational performance specification for airborne VHF receiver-transmitter operating in the frequency range 117.975-136.975 MHz [19] ESARR 4- Risk Assessment and Mitigation in ATM- V 1.0 (05-04-2001) [20] ICAO Annex 11 Air Traffic Services -2001- [21] ICAO Doc 9476 Manual of Surface Movement Guidance and Control Systems (SMGCS) -1986- [22] ICAO Doc 9184 Part I Airport planning Manual -1987- [23] ICAO Doc 9137 Part 8 Airport service manual -1983- [24] ICAO Doc 9432 Manual of Radiotelephony -2007-41

ANNEX 2: AIR TRAFFIC SERVICES SUPPORTED BY THE A/G VOICE COMMUNICATION SERVICE These services are described in [20]. A2.1 Air Traffic Control Service In controlled airspace, the ATM model for current operations conforms to the ICAO Doc 9854 description of Conflict Management: whose purpose is to limit, to an acceptable level, the risk of collision between aircraft and hazards, and Which is applied in three layers: Strategic Conflict Management; Separation Provision; and Collision Avoidance. Layers, which are supported by the A/G voice communication system, are the separation provision and the collision avoidance ones. A/G voice comms service supports these layers for different operations (airport, TMA and Enroute) and consequently mitigates the relevant pre-existing risks such as MAC, CFIT, Wake vortex Turbulence and runway incursion. Indeed for all of these operations the A/G voice communication is the media to provide clearance, instruction and information to aircraft in the considered airspace. It contributes de facto to address all of those pre-existing risks inherent to Air Traffic operations. A2.2 Flight Information Service (FIS) Flight Information service is a service provided for the purpose of giving advice and information useful for the safe and efficient conduct of flight. A flight information service may be provided on its own (uncontrolled airspace) or in conjunction with an air traffic control service (controlled airspace). FIS includes meteorological information, changes in the serviceability of navigation aids and in the condition of aerodromes and associated facilities and any other information likely to affect safety. The service may provide traffic information in general terms to assist with the pilot s situational awareness. The A/G voice communication service is one of the main enablers for the Flight Information service by providing a media to support the transmission of flight information to aircraft. A2.3 Air Traffic Advisory Service Air Traffic Advisory Service is a service provided within advisory airspace to ensure separation, insofar as practical, between aircraft which are operating on IFR flight plans in uncontrolled airspace (e.g. Class F airspace). The objective of the air traffic advisory service is to make information on collision hazards more effective than it would be in the mere provision of flight information service. Advisory service does not provide the degree of safety and cannot assume the same responsibilities as air traffic control service in respect of collision avoidance, since information regarding the disposition of traffic in the area may be incomplete. Advisory service does not deliver clearances but only advisory information. The A/G voice communication service is one of the main enablers for the advisory service by providing a media to support the transmission of advisory information to aircraft. 42

ANNEX 3: SAFETY LOG A3.1 Safety Requirements SR#1 SR# 2 SR#3 SR#4 SR#5 SR#6 SR#7 SR# 8 SR# 9 SR#10 SR#11 SR#12 SR#13 SR#14 SR#15 State AIPs (supported as necessary by NOTAMs) shall provide up-to-date information to all Aircraft Operators and Flight Crew concerning the VCS requirements of the airspace for which the State is responsible Aircraft Operators and Flight Crew shall be made aware of the consequences of using 25 khz VCS radios in 8.33 khz VCS airspace unless specifically authorised (i.e. State aircraft) Aircraft Operators and Flight Crew of 25 khz VCS-equipped, non-exempt aircraft shall not submit Flight Plans that would take the aircraft through any part of 8.33 khz VCS airspace Aircraft Operators and Flight Crew shall ensure that the Flight Plan for any flights which pass through any part of the EUR Region indicates the VCS capability and status (exempt / non-exempt) of the aircraft concerned Controllers shall not route a 25 khz VCS-equipped, non-exempt aircraft through 8.33 khz VCS airspace unless there is an overriding safety reason for so doing and they apply published procedures covering this situation Controllers shall not accept a 25 khz VCS-equipped, non-exempt aircraft into an 8.33 khz VCS sector unless there is an overriding safety reason for so doing and they apply published procedures covering this situation Before handing over an aircraft to an 8.33 khz VCS sector, Controllers shall ensure that the receiving sector is advised of the VCS capability and status (exempt / non-exempt) of the aircraft concerned ANSPs shall develop and implement strategies to ensure the safe handling of (non-8.33 khz) exempt aircraft in 8.33 khz VCS airspace State s frequency assignment plan shall comply with EUR Frequency Management Manual ICAO EUR Doc 011 (2009) in order to ensure that any ATS assigned frequency does not interfere with other assigned frequencies and is free from harmful interference. Flight Crew shall be adequately trained in the use of the 8.33 khz radios In the event that a 25 khz VCS-equipped aircraft is unable to communicate with ATC, the Flight Crew shall apply the appropriate procedures associated to a loss of comms event. In the event that ATC is unable to communicate with an aircraft in 8.33 khz VCS airspace, the Controller shall apply the appropriate procedures associated to a loss of comms event. In the event that a 25 khz VCS-equipped, non-exempt aircraft has to be routed through 8.33 khz VCS airspace, the transferring Controller shall instruct the Flight Crew to either switch to a 25 khz VCS frequency (if available) or to apply the appropriate procedures associated to a loss of comms event (or emergency event). In the event that a 25 khz VCS-equipped, non-exempt aircraft has to be routed through 8.33 khz VCS airspace, the receiving Controller shall apply the appropriate procedures associated to a loss of comms event (or emergency event). In case of serious interference to comms with other airspace users by a 25 khz aircraft that has inadvertently entered an 8.33 khz sector, the Controller shall apply appropriate procedures in order to try to contact the 25 khz VCS aircraft on emergency frequency to 43

stop the interfering transmissions SR#16 SR#17 SR#18 SR# 19 SR#20 SR# 21 SR#22 SR#23 SR#24 SR# 25 SR#26 SR#27 SR#28 SR#29 SR#30 In case of serious interference to comms with other airspace users by a 25 khz exempt aircraft operating legitimately in an 8.33 khz sector, the Controller should contact the 25 khz VCS aircraft to stop the interfering transmissions and apply the procedure associated to a loss of comms event for this aircraft IFPS shall check each flight plan that is routed through one or more 8.33 khz VCS sectors to ensure that it indicates that the aircraft is 8.33 khz VCS capable otherwise the flight plan shall be rejected unless it is an exempted aircraft and the appropriate information is included in the Flight plan. If the Flight Crew of a 25 khz VCS-equipped aircraft is requested to transfer to an 8.33 khz VCS channel they shall immediately advise ATC that the aircraft is not 8.33 khz VCS capable States shall ensure that all LOAs are updated in accordance with their respective VCS implementation status. Aerodrome information/publication (aerodrome manual) shall provide up-to-date information to all vehicle drivers concerning the VCS requirements applicable to the aerodrome manoeuvring areas. Vehicle drivers shall be made aware of the consequences of using non-8.33 khz VCS radios in 8.33 khz VCS manoeuvring areas unless specifically authorised Airport operator/ansp shall develop and implement strategies to ensure the safe handling of non -8.33 khz VCS-equipped vehicle in 8.33 khz VCS airport area. State s frequency assignment plan shall comply with EUR Frequency Management Manual ICAO EUR Doc 011 (2009) in order to ensure that any aerodrome assigned frequency does not interfere with other frequencies assigned in the aerodrome vicinity and is free from harmful interference. Airport operator shall ensure that vehicle drivers operating on the manoeuvring area are fully conversant with the proper R/T procedures associated to 8.33 khz VCS Airport operator shall ensure that the vehicle radio equipment (including hand-held equipment) used for ATC are compliant with the ICAO Annex 10 standard In the event that no contact can be established to a vehicle on the manoeuvring area and when situation might lead to taxiway collision or runway incursion the controller shall: inform other vehicles in the vicinity and taxiing aircraft to immediately stop unless the vehicle has been visually acquired by them whenever required, ask to a landing aircraft to execute a missed approach due to runway obstruction. In the event that a vehicle is unable to communicate with ATC and when situation might lead to taxiway collision or runway incursion, the airport operator shall, in liaison with the ATC, intercept and escort the vehicle outside of the manoeuvring area Airport operator/ansp shall verify (e.g. through operational trial) that the 8.33 khz assigned frequency does not generate interference to other already assigned frequencies (ground, tower) Airport operator/ansp shall verify (e.g. through operational trial) that the 8.33 khz assigned frequency is not impacted by interference Vehicle drivers shall receive adequate training on the usage of the 8.33 khz VCS system 44

A3.2 Assumptions Implementation of the 8.33 khz Voice Channel Spacing ID Assumption Rationale A001 A002 A003 A004 A3.3 Issues Current VHF comms ie using 25 khz VCS are acceptably safe. The 8.33 khz VCS comms infrastructure and aircraft equipage will comply with the necessary ICAO standards, as already applicable to the EUR region above FL 195. In addition to 8.33 khz channel spacing capability, the aircraft and mobile equipment is able to tune to 25 khz spaced channels and to operate in an environment which uses offset-carrier frequencies Individual States / ANSPs must carry out a full safety assessment specific to their areas of responsibility, prior to the deployment of 8.33 khz VCS comms. ID Description Rationale Iss001 Article 3(10) of the draft VCSII IR [16] does not refer to any specific airspace for 8.33 conversions whereas Article 3(9) mandates 8.33 carriage only for aircraft flying IFR in Class A, B and C airspaces. Iss002 Article 3(16) of the draft VCSII IR [16] specifies that all radios shall have the 8.33 khz channel spacing at the latest the 1 January 2018 but it is not clear what are the exact radio users impacted by this article. Does it apply to ANSPs (ground radios), to Aircraft Operators (airborne equipment, OPC radios, ), etc? Iss003 When considering the whole IR applicability area and prior to the date of mandatory carriage of 8.33 khz VCS radios (1 January 2018), unnecessary conversions could significantly increase the risk of communications failure with non-exempt aircraft that legitimately retain their existing 25 khz VCS capability. There is no historical evidence to suggest otherwise. Any risks inherent in VHF airground comms are therefore deemed to be outside the scope of this safety assessment. The operational use of a primarily homogeneous 8.33 khz VCS comms infrastructure /aircraft fit has already been demonstrated above FL 195 and is therefore deemed to be outside the scope of this safety assessment. This is part of the design requirements for the aircraft 8.33 khz VCS radios and is reinforced by article 3(21) of the draft VCS II IR V10 The safety assessment covered herein is necessarily generic and cannot therefore cover the factors specific to local operational environments many of which have a direct bearing on the safety risks involved this is addressed by Article 6 of the draft VCS II IR V10. There is a potential inconsistency between the equipment carriage article (3(9)) and the airspace conversion article (3(10)). It is necessary to clarify the applicability of article 3(16). Unnecessary conversions could significantly increase the risk of communications failure unless a local safety assessment is carried out by the Member State to show that such conversation is safe when considering the different airspace users impacted by such conversions. 45

ANNEX 4: IDENTIFIED SAFETY REQUIREMENTS VERSUS THE CONTENT OF THE DRAFT VCS II IR xxxxxx: Safety Requirement (or Assumption) addressed by the draft VCS II IR [16] xxxxxx: Safety Requirement not fully addressed by the draft VCS II IR [16] but a final review by the IRDG concluded that other existing regulation (e.g. ICAO) are sufficient. xxxxxx: Safety Requirement (or Issue) not addressed by the present [16] necessitating the IR modification proposed in the table to be introduced in the final IR draft text. SR ID Responsible Actor IR Articles (V10) SR#1 Member States/AIS Art 9(6) AIP SR#2 A.O/Pilots Art 9(5) Operator competency SR#3 A.O/Pilots Art 4(4) Operator to fill correctly the flight plan when aircraft is 8.33 khz equipped Art 4(5) Operator to fill correctly the flight plan when aircraft is exempted Art 4(6) Operator must advise when 8.33 khz capability status is changed SR#4 A.O/Pilots Art 4(4) Operator to fill correctly the flight plan when aircraft is 8.33 khz equipped SR#5 ANSP Art 3(28) ANSP shall implement the notification and initial coordination processes in their FDPS: 8.33 khz capability of a flight transmitted between ATC Units Display of the 8.33 khz capability to the working position Capability for the controller to modify the information about the 8.33 khz capability of a flight Art 9(1) ANSP personnel competency SR#6 ANSP Art 3(28) ANSP shall implement the notification and initial coordination processes in their FDPS: 8.33 khz capability of a flight transmitted between ATC Units Display of the 8.33 khz capability to the working position Capability for the controller to modify the information about the 8.33 khz capability of a flight Art 9(1) ANSP personnel competency SR#7 ANSP Art 3(28) ANSP shall implement the notification and initial coordination processes in their FDPS: 8.33 khz capability of a flight transmitted between ATC Units Display of the 8.33 khz capability to the working position Capability for the controller to modify the information about the 8.33 khz capability of a flight 46

Art 9(1) ANSP personnel competency SR# 8 ANSP Member States/AIS Art 5(11) Alternate means of com (UHF, 25 khz) for State aircraft not 8.33 khz equipped. Art 5(12) Procedure to be published through AIP for the handling of non- 8.33 khz State aircraft. The next draft VCSII IR version will include the additional requirement in the Annex 3: Annex III (9): Air navigation service providers shall ensure that procedures for handling non-8.33 khz equipped aircraft through 8.33 khz airspaces are published and applied as appropriate. These procedures would have to include all the requirements for any local exemption and not only the consideration of State aircraft. SR# 9 Member States ANSP Art 3(26) Member States shall ensure that appropriate VHF assignments are notified to ANSP Art 3(27) ANSP shall implement the VHF assignments in accordance with Art 3(26) SR#10 ANSP and A.O/Pilots Art 4(1) Identification of the 8.33 channel in VHF radio-telephony Art 4(2) air ground voice communication procedures are in accordance with ICAO provisions specified in Annex II(4) Art 9(5) Operator competency SR#11 A.O/Pilots There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, PANS-ATM and PANS-OPS) and in SERA IR might be considered sufficient. It should be highlighted that loss of comms events is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. SR#12 ANSP There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, PANS-ATM) and in SERA IR might be considered sufficient. It should be highlighted that loss of comms events is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. SR#13 ANSP There is no traceable IR article for this Safety Requirement. Procedures specified in ICAO regulation (Annex 11, PANS-ATM) and in SERA IR might be considered to be too generic to address that particular 47

requirement. The next draft VCSII IR version will include the additional requirement in the Annex 3: Annex III (9): Air navigation service providers shall ensure that procedures for handling non-8.33 khz equipped aircraft through 8.33 khz airspaces are published and applied as appropriate. Therefore appropriate ANSP procedures shall be available to meet this requirement. SR#14 ANSP Same as previous (SR#13) SR#15 ANSP There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, PANS-ATM) and in SERA IR might be considered sufficient. It should be highlighted that communication interference is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. SR#16 ANSP There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, PANS-ATM) and in SERA IR might be considered sufficient. It should be highlighted that communication interference is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. SR#17 Member States/ Network manager Art 4(7) IFPS to process and distribute 8.33 khz capability received in flight plans Art 9(2) IFPS personnel competency SR#18 A.O/Pilots A reference to the ICAO PANS-ATM phraseology procedures will be included in the next draft VCSII IR version in order to mandate the procedures and the phraseology that must be used in these cases. SR# 19 ANSP Art 4(3) Air navigation service providers shall ensure that the procedures applicable to aircraft equipped with radio equipment with 8.33 khz channel spacing capability and aircraft which are not equipped with such equipment are specified in the letters of agreement between ATC units. SR#20 Member States/AIS Art 9(6) AIP SR# 21 Airport Operator/Ground Art 9(5) Operator competency 48

vehicle driver Implementation of the 8.33 khz Voice Channel Spacing SR#22 Airport operator/ansp The next draft VCSII IR version will include the additional requirement in the Annex 3: Air navigation service providers and/or Airport Authorities shall ensure that procedures for handling non-8.33 khz equipped vehicles through airport areas using 8.33 khz are published and applied as appropriate. SR#23 Member States ANSP Art 3(26) Member States shall ensure that appropriate VHF assignments are notified to ANSP Art 3(27) ANSP shall implement the VHF assignments in accordance with Art 3(26) SR#24 Airport Operator Art 9(5) Operator competency SR# 25 ANSP and Airport Operator The next draft VCSII IR version will include the following modifications: *Articles 3(22) and (23) will be modified to replace: Users of ground installation shall ensure By Users of ground installation and users of portable and handheld radios used on the ground, shall ensure. *Article 3(24) will be modified to replace Users of airborne installations of 8.33 khz voice communication systems shall... By Users of airborne installations of 8.33 khz voice communication systems and users of portable and handheld 8.33 khz voice communication systems inside an aircraft in flight shall SR#26 ANSP There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, and PANS-ATM) and in SERA IR might be considered sufficient. It should be highlighted that loss of comms events is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. SR#27 ANSP There is no traceable IR article for this Safety Requirement but procedures specified in ICAO regulation (Annex 11, and PANS-ATM) and in SERA IR might be considered sufficient. It should be highlighted that loss of comms events is not specific to 8.33 khz implementation and is already encountered with 25 khz. The IRDG is of the opinion that PANS-ATM is enough to meet this requirement. Moreover the 8.33 rule is not the most appropriate mechanism to solve non-8.33 issues. 49

SR#28 ANSP VCSII IR Annex 3 Item 7 is addressing this requirement. 7. Member States shall ensure that 25 to 8.33 khz conversions are operated for a trial period of an appropriate duration, during which time safe operation is verified, prior to coordination in the Table COM2 of ICAO Doc 7754. SR#29 ANSP VCSII IR Annex 3 Item 7 is addressing this requirement. 7. Member States shall ensure that 25 to 8.33 khz conversions are operated for a trial period of an appropriate duration, during which time safe operation is verified, prior to coordination in the Table COM2 of ICAO Doc 7754. SR#30 Ground vehicle driver Art 4(1) Identification of the 8.33 channel in VHF radio-telephony Art 9(5) Operator competency A001 None Does not necessitate to be addressed by an IR article. A002 ANSP and Airport Operator A.O/Pilots Art 3(22) Users of ground installation shall ensure that performance of installation comply with ICAO Annex 10 Art 3(23) Users of ground installation shall ensure that performance of the transmitter/receiver ground constituent comply with ICAO Annex 10 Art 3(24) Users of airborne installation shall ensure that performance of installation comply with ICAO Annex 10 Art 3(25) ANSP shall ensure an acceptable voice communication between controllers and pilots within DOC A003 A.O Art 3(21) Capability to tune 25 khz spaced channels and to operate in offset-carrier frequencies environment A004 Member States Art 6 Safety requirements (Local safety assessment considering the different safety requirements identified by this IR) Iss001 ANSP To address this safety issue, the following safety requirement will be added to the next draft VCSII IR version Annex 3: Member States who convert frequency assignments to 8.33 khz in any part of their airspace shall: (1) ensure that operators of aircraft flying in such airspace are informed that these aircraft must be equipped with radio equipment with 8.33 khz channel spacing (2) perform a local safety assessment prior to the conversion that takes into account all the traffic expected to cross that airspace and the potential issues arising from the VCS in operation in all surrounding airspace. Iss002 IRDG Addressed by the new definition of radio proposed in recommendation 2 to be included in the next draft VCSII IR version. 50

Iss003 ANSP Requirement to be added to the next draft VCSII IR version (Same as Issue 001) ----------------------------------------- 51