If the European Commission’s Implementing Rule is not enough to jump-start data link, what is?

On 14-11-2012, in SES News, by steve

At the recent meeting of the Project Steering Group on Data Link, it was revealed that some States will not be able to meet the 7 February 2013 date by which “all LINK Region ANSPs shall have implemented an operational compliant system”. One State actually reported that they will not be ready before 2019!

The Data Link Services Implementing Rule (DLS-IR) was adopted on 16 January 2009 by the European Commission and published as EC Reg. No. 29/2009. The DLS-IR is legally binding and applies directly to Air Navigation Service Providers (ANSPs) and to Aircraft Operators.

The main deadlines of the IR are as follows:

1 January 2011 – After this date all new aircraft operating above FL 285 shall be delivered with a compliant system.

7 February 2013 – By this date all LINK Region ANSPs shall have implemented an operational compliant system.

5 February 2015 – By this date all aircraft operating above FL 285 shall have been retrofitted with a compliant system.

5 February 2015 – By this date all EU Region ANSPs shall have implemented an operational compliant system.

31 December 2017 – Aircraft which are at least 20 years old and which will cease operation in the concerned airspace before 31 December 2017 are exempt.

1 January 2014 – Aircraft with individual airworthiness certificate before this date that are equipped with Future Air Navigation System (FANS) are exempt for the lifetime of the aircraft. Aircraft entering into service after 1 January 2014 shall comply with the rule.

1 January 2014 – New transport type State aircraft should comply with the rule if equipped with non-military data link.

Since 1 January 2011, all new aircraft are being delivered with VDL Mode 2/ATN compliant avionics and apparently, like so often in the past, they will be carrying their gear and burn the investment for no good reason at all, since the ground capability will not be in place.

Mind you, we are not talking about rocket science here. Data link capability has been demonstrated many times over and while a few minor issues still had to be ironed out, the thing works and people know how to implement it.

So what is keeping the problem ANSPs from doing what has been mandated for them? Probably the old European ATM evil of inertia, parochial ideas and a reluctance to think out of the box.

What is different this time is that the credibility of the whole SES regulatory regime is at stake here.

If, like in the past when SES was still not even a glimmer in the European Commission’s eyes, States can just ignore an implementing rule deadline and delay at will, who will believe that things will go better in the future?

Who will believe that the FABs are actually making it easier to implement things on the sub-regional level than it was on the European level?

Who will believe in SESAR being able to achieve anything? Especially since trajectory based operations and other new elements in ATM called for in the SESAR Concept of Operations will require far more complicated systems upgrades than puny little data link does.

The airspace user associations will doubtless react strongly to this latest manifestation of obfuscation in European air traffic management but the big question is, how will the European Commission react?

If they accept without a fight, they might as well kiss SES good-buy and admit that Europe is incapable of having an effective air traffic management system. Hopefully they will rise to the occasion and use all their powers to show that they mean business. Whether the States like it or not…

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  1. Hanspeter says:

    Dear Steve
    I fully agree on what you say and what you state. However I guess that the following issues are still not clear yet:
    1. Need to have clear understanding on how to link aircraft to the ground infrastructure (connectivity)
    2. Requires a clear understanding of the avionics needed onboard aircraft
    3. Requires datalink and network security and key management (ICAO Doc 9880, Part IVB – ATN Security for AMHS)

    Isn’t this the reason, that Datalink is not perfoming at the pace required?
    Best regards Hanspeter

  2. steve says:

    Dear Hanspeter,

    I think most of those issues have been tackled after a fashion… and new aircraft are coming out of the shop with VDL Mode 2/ATN and CPDLC installed. When prerparing the implementing rule, the technicl aspects have been looked into… with the exception of security which is still an issue to be solved. So, the airlines are equipping… Now the ground says, sorry we will not be redy.

    I think the big problem here is the message this is sending. If there is an IR and people can just ignore it, how far have we progressed from the old days when the ground usually lagged behind airborne equipage and sometimes never even bothered to catch up?

    If there is a technical reason or an operational one, than that should be put on the table and the deadlines (for both grojd and air) reviewed. Something like that is regrettable but can be seen as part of the game.

    As far as I was able to discover however, there is no technical reason, neither real operational considerations for the delay…
    Cheers,

    Steve

  3. Mark Brown says:

    This doesn’t bode well.

    The air-ground connectivity is technically a no-brainer – SITA and ARINC can both provide bilingual (AoA and ATN) VDL Mode 2 ground stations and I believe can offer test bed services. Similarly the avionics requirements are clear and are well understood by the vendors. Multiple VDL Mode 2 frequencies will be required some time down the road to deal with channel congestion but planning is in hand. The ATN air-ground security provisions are not required for Link 2000+ (the threat analysis indicates that alternative measures are sufficient). (AMHS security is a completely different issue by the way.) In other words, I don’t believe there can be any technical reason for a delay either.

  4. alex1 says:

    Steve,

    Could you do everyone a favour and name and shame the guilty parties? And while you’re at it, how many ANSPs will be implementing operational procedures that (a) actually make use of the D/L capability, (b) offer advantages to the users in the form of increased capacity, reduced delay, increased efficiency or reduced costs, and (c) do things they previously couldn’t do? Doesn’t seem too much to ask, does it? But I suspect it is!

  5. Carlo says:

    Dear Steve,

    Can you please tell me the reference or where a I can find an official paper about that European ANSPs will not be ready before 2019 to implement the data link compliant with VDL Mode 2/ATN. I am working in a European project called SANDRA (Seamless Aeronautical Networking Through Integration of Data Links, Radios and Antennas) and the project road map is, as usual, more optimistic. I really appreciate your blog.

    Best Regards
    Carlo

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