AIS-AIMSG/1-SN No. 2221/11/08

AERONAUTICAL INFORMATION SERVICES-AERONAUTICALINFORMATION MANAGEMENT STUDY GROUP (AIS-AIMSG)

FIRST MEETING

Montréal, 2 to 4 December 2008

Agenda Item 7: Annex amendment proposals7.5: Miscellaneous

Agenda Item 8: Guidance material8.6: Miscellaneous

PROPOSAL FOR IMPROVEMENT OF ICAO GUIDANCE MATERIALRELATED TO THE TIMELY PROVISION OF AERONAUTICAL INFORMATION/DATA

(Presented by Paul Bosman)

SUMMARY

This study note proposes several improvements to ICAO guidance material related to the timely provision of aeronautical information /data based on the best practices used in the European region to improve the adherence of the State AIS to AIRAC. The paper also proposes to strengthen ICAO SARPs requirements with description of the processes occurring with aeronautical data after leaving AIS and the consequences of late postponement of major changes.

1. NTRODUCTION

1.1 It is recognised that the future ATM will depend extensively on the provision of timely, relevant, accurate, and quality assured information that allows the ATM Community to make informed decisions. However it is also known that the present provision of aeronautical information/data in many parts of the world does not always comply with the ICAO requirements for timely provision of data.

1.2 The European region was plagued in the late 90’s with frequent last minute publications and cancellations of change information (followed by many users bitterly complaining). However after a series of remedial actions including an AIRAC awareness campaign and provision of the monitoring tool the issue has become minor and the number of non-adherence to ICAO requirements for timely provision of aeronautical data has decreased drastically and is kept at a stable low level. This Study Note describes two of best practices which can be used at the global level.

(16 pages)document.doc

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1.3 The third section of this Study Note looks into the issue associated with the lack of the description in ICAO SARPs of the processes occurring with aeronautical data after it leaves the AIS.

1.4 The last section describes the issue and the consequences of the late postponement of the major changes which still occur and requires additional SARPs to address.

2. AIRAC AWARENESS

2.1 Following a considerable number of last minute publication and cancellations in the late nineties followed by complains from the users of aeronautical data Eurocontrol was charged to introduce effective remedial measures to improve the situation with the timely provision of data.

2.2 Most of the reported issues were related to the non-compliance to ICAO requirements for provision of significant changes in the aviation infrastructure in timely manner (i.e. adherence to AIRAC)

2.3 Within the framework of AIS AHEAD Programme a series of meetings with the users and providers of aeronautical data were held in order to comprehend the origins of the issue.

2.4 It was noted that one of the major reasons for AIRAC non-adherence in the States was the lack of awareness among the data originators, AIS and regulators of the importance of compliance to AIRAC and the possible consequences of the failure to comply on the next intended users.

2.4.1 In order to improve the situation Eurocontrol created a set of frequently asked questions on AIRAC to explain ICAO requirements on AIRAC in simple easy understandable language. The positioning of this information on Eurocontrol website gave even a higher role to AIRAC and the number of visits of these pages prove that the subject was not only of interest to the European region but also beyond it.

2.4.2 These Frequently Asked Questions (FAQ) do not introduce anything new to ICAO SARPs, but according to the feedback from State AIS they have significantly influenced the awareness of all players in the aeronautical data chain and improved the processes in AIS.

2.5 It is proposed to use similar type of AIRAC awareness on the newly created ICAO AIM webpage. The AIRAC FAQ from Eurocontrol website (http://www.eurocontrol.int/aim/public/standard_page/qm_airacadh_intro.html) is in Appendix A.

3. AIRAC PUBLICATION MONITORING

3.1 The requirement for monitoring the timely provision of information/data result from the requirements of ICAO for implementation of Quality Management Systems (QMS) and adherence to AIRAC. ISO9001 requires monitoring, measuring, analyzing and improving the processes in order to demonstrate the conformity of the product.

3.2 In the case of AIS the conformity of the product means the compliance of AIS products (e.g. AIRAC AIP AMDT paper based or electronic CD) to ICAO requirement for the timely delivery of aeronautical information to the customers (>28 days before the effective date for AIRAC and >0 day for normal AMDT).

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3.3 It is to be noted that despite the statement in ICAO AIS manual (DOC8126) that if the publication is received late then “the recipient will report this to the originating AIS. It is the duty of the originating AIS to investigate the reason for the delay and take remedial action as required.”

3.4 The reality shows that AIS rarely receives any feedback from the recipient on timely/delayed reception of the publication, which makes it difficult to comply with ISO9001 requirements of monitoring and improving the performance. For that reason Eurocontrol, supported by many stakeholders, has developed a web-based application to assist AIS to measure their performance in conformance to the timely delivery of the product.

3.5 The principle of work of this web based tool is described in Appendix B.

3.6 It is proposed that this tool be made available for use by the international community and on Eurocontrol or ICAO websites.

4. MISSING LINK IN THE AERONAUTICAL DATA CHAIN

4.1 One of the findings of the AIRAC awareness campaign was the lack of description in ICAO guidance material about the aeronautical information processes and schedule between the 28 day of delivery and effective date. There is a lack of recognition of the role played by third party service providers who currently play a major role in transforming most State aeronautical data into a digital format suitable for loading into the flight management systems of modern aircraft.

4.2 It has been noted that this material is available in other ICAO material (DOC 9613 – PBN manual) and aeronautical industry standards (ED77/DO201A).

4.3 Appendix C provides copies of the material from these documents suggested to be included in DOC 8126.

5. LATE POSTPONEMENT OF MAJOR CHANGES

5.1 Despite all the efforts of Eurocontrol on improving AIRAC adherence there is still an issue that can not be tackled due to the insufficiently stringent ICAO requirements and description of the consequences of the late postponement of major changes.

5.2 The consequences of the last minute postponement of major changes can result in serious flight safety issues for both airline operators and ATC. The data uploaded in the FMS related to this change can not be modified until the next AIRAC cycle and the pilots should be prevented from using it.

5.3 The major changes announced by AIRAC also affect many other documents used for flight operations (e.g. impact on operations/performance and modification of the manuals, flight fuel plans and logs, briefing of flight crews at many locations etc.) and a late postponement leads to the situation that users cannot respond effectively to a late change.

5.4 It is urgently required that the ICAO SARPs be strengthened and the description of the consequences of such a late postponement can have on the flight safety.

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5.5 Eurocontrol and Jeppesen have collaborated to prepare proposal on strengthening the ICAO SARPs.

6. ACTION BY THE AIS-AIMSG

6.1 The AIS-AIMSG is invited to:

a) consider the use of AIRAC FAQ and their inclusion on ICAO AIM webpage ;

b) consider the global exploitation of a monitoring tool (e.g. pTracker) to assist the States in monitoring the timely provision of their product;

c) consider the addition, into ICAO SARPs, of the description of aeronautical information processes and timeline after leaving AIS; and

d) discuss the issues and consequences related to the late postponement of major changes and support the preparation of the proposal for strengthening the present ICAO SARPs.

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APPENDIX A

AIRAC FREQUENTLY ASKED QUESTIONS

Aviation "environment" data is constantly changing: airspace structures and routes are revised, navigation aids change, SIDs and STARs are amended, runway and taxiway information changes.

It is essential, for both efficiency and safety, that Pilots, Air Traffic Controllers, Air Traffic Flow Managers, Flight Management Systems and Aviation Charts all have the same data set.

But how can this be achieved? The answer is AIRAC.

What is AIRAC?

AIRAC stands for Aeronautical Information Regulation And Control and steps from the ICAO Annex 15 - Aeronautical Information Services (AIS) document and defines a series of common dates and an associated standard aeronautical information publication procedure for States.

  ICAO Annex 15 - Aeronautical Information Services (AIS) document

In short it defines that in all instances, information provided under the AIRAC system shall be published in paper copy form and shall be distributed by the AIS unit at least 42 days in advance of the effective date with the objective of reaching recipients at least 28 days in advance of the effective date. Whenever major changes are planned and where additional notice is desirable and practicable, a publication date of at least 56 days in advance of the effective date should be used.Three dates are to be remembered from this:

The two weeks between Publication date and Reception date is basically to allow for postal distribution of the (mostly) paper publications.And the AIRAC cycle?The AIRAC was adopted by ICAO in 1964 and further improved over the years.

Key in the cycle are the worldwide effective dates with 28 days intervals (e.g. 4 August 2005, 1 September 2005, 29 September 2005, ...). Effective days are always on a Thursday.

AIS-AIMSG/1-SN No. 22Appendix A

AIS-AIMSG/1-SN No. 22Appendix A A-2

Where can I find these AIRAC Effective dates ?The AIRAC effective dates are published in ICAO Doc 8126, the Aeronautical Information Services Manual, 'Table 2-1. Schedule of AIRAC effective dates, 2003-2012'. They are also referred to in most national AIPs when providing the data delivery dates for data originators. view the AIRAC calendarOk, but 28 ( or even 56) days ! ?This looks indeed like a lot, but it should be understood that aeronautical information changes (mostly published through so called AIRAC Amendments) require:

1.  Changes to local systems which includes interpreting, re-typing and re-coding the information.

2.  Verification and Correction as publications are unfortunately seldom perfect.

3.  Validation against other data; Flight Plans are just one example.

4.  Re-distribution. Hereby think of Charts and Flight Management Systems to a fleet which can be anywhere in the world.

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And around Christmas and New Year? ICAO Annex 15 - Chapter 6 is clear: "The use of the date in the AIRAC cycle which occurs between 21 December and 17 January inclusive should be avoided as an effective date for the introduction of significant changes under the AIRAC system".

And in ICAO Doc8126 - Chapter 4, because of reduced staffing and increased postal delays, "it is recommended that the AIRAC cycle date occurring in the 28-day period from 21 December to 17 January (both dates included) no longer be used as an AIRAC effective date for the introduction of significant operational changes. States experiencing similar problems during other holiday periods may wish to adopt a comparable system".And what about this 'freeze' date ?Each recipient has an internal date, called 'freeze' date, before the effective date after which he can not accept changes anymore. E.g. Aircraft Flight Management Systems need the data often 17 days before the effective date to allow for the information re-coding (into ARINC424 format), information uploading and distribution.

Note that these freeze dates are strictly speaking the recipients own business, however they become important in the context of AIRAC Non-adherence.

AIRAC Non-Adherence

Sounds clear... so what is the issue ?

The issue is that unfortunately sometimes 'AIRAC-type' aeronautical information publications do not follow the AIRAC cycle. This is generally referred to as AIRAC Non-adherence. 

How exactly?

Publications are published/received too late, cancelled/postponed at the last minute or published incorrectly as non-AIRAC.

And then?

And then, the troubles start. Users are unaware of latest changes. Different users are using different versions of the aeronautical information. Charts are inconsistent with Flight Management Systems. Pilots fly around with outdated information. ... ... In short, users are not sure of anything anymore.

AIS-AIMSG/1-SN No. 22Appendix A A-4

Is this safety related?

The issue

The issue is that unfortunately sometimes 'AIRAC-type' aeronautical information publications do not follow the AIRAC cycle. This is generally referred to as AIRAC Non-adherence.

Publications are published/received too late, cancelled/postponed at the last minute or published incorrectly as non-AIRAC.

And then, the troubles start. Users are unaware of latest changes. Different users are using different versions of the aeronautical information. Charts are inconsistent with Flight Management Systems. Pilots fly around with outdated information. ... ... In short, users are not sure of anything anymore.

The relation with safety

Investigations in Europe have shown that as reported by three (well-known) European States, in 1999, there were at least twenty safety incidents stemming from AIRAC Non-adherence. Whether this was all or just the tip of the iceberg is impossible to say. European wide, systematic, standardised safety reporting would be required to answer this question satisfactory.

Other consequences have been shown during an AIRAC Adherence Stakeholder Meeting (April 2000). An analysis session conservatively estimated that, overall in Europe, pre-flight consequent to European non-adherence to AIRAC costs are 11 Million Euro. These costs are mainly Staff (having to continuously check for latest information and acting upon it) and Reproduction (reprinted charts etc) costs.

This happens every AIRAC cycle. (European) monitoring results over the last three years have shown that, on average, three significant AIRAC Non-adherence events occur per cycle.

The relation with commercial data providers

All users, including commercial data providers like Jeppesen, Lufthansa Systems Aeronautics, European Aeronautical Group (to name just a very few) depend on aeronautical information publications as published by a national AIS. They are affected as much as any aircraft operator. So as any Briefing Office will tell you; Always check for the latest information before taking off!

The freeze dates

Because of the different freeze dates (and it is re-iterated that it is the recipients 'right' to act so) there is, in the case of a late publication, an increased chance that different end-users find themselves with different versions of the aeronautical information (Just think of an Amendment that arrives after the freeze date of one user but before the freeze date of another).

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The causes

At a first sight, it seems to be all the fault of the national AIS whose prime responsibility it is to publish on time. However, things aren't that simple. An AIS is not the 'creator' of any aeronautical information and depends fully on many different data originators (route & airspace planners, procedure designers, Navaid maintainers, airports, etc.) to provide data both timely and correctly to them.

Analysis of European AIRAC Non-adherence events led to the following classification:

— Non-awareness among stakeholders of the importance of sticking to the AIRAC rules.

— Insufficient planning and co-ordination (nationally, bilateral among neighbouring states and even international).

— Correction of timely but incorrect earlier publications.

— Variable and slow communication means. Even at state level, information is communicated in varying formats, using different (read: paper = slow) communication means which introduces delays. This can be further aggravated by the need for translation from national to any other publication languages and printing/distribution delays.

— Postal Delay. Surprisingly enough, the average European postal delay of any Amendment is three (!) weeks. This makes a mockery of the two week allowance planned in the AIRAC regulations.

— Monitoring and Regulation. There is no (centralised) monitoring/policing body. It is the States' own responsibility to adhere to AIRAC.

— The occasional 'force majeure'.

AIS-AIMSG/1-SN No. 22Appendix A A-6

AIRAC Adherence – Solutions

With the huge variety of causes, the 'solutions' vary for each different organisation.

States are already doing a lot about it (awareness campaigns, training, national regulations, etc.). However, this has proven to be insufficient to eradicate the problem.

In spite of its name, Eurocontrol does not control AIRAC. It is merely acting on behalf of its Member States and so any activity can only be to assist the States. The activities are therefore concentrated on:

— Monitoring, as you can only improve what you measure. Participation in pTracker provides the necessary data to monitor the AIRAC adherence.

— Creating awareness on the problem, the consequences, the causes and the solutions is a continuous activity and has in the meantime addressed itself to many different fora.

— Facilitation of publication dates, (links to) advanced and late publications, points of contacts. Key hereby is the internet based AIS AGORA which has proven to be the central place for 'Voicing problems and Sharing solutions'. It is further assisted by National AIRAC Publication Review and the @is online.

pTracker - AIS publication postal delivery time tracking tool

AIS AGORA - Aeronautical Information Forum

National AIRAC Publication Review

@is online

There is evidence to believe that campaigns to date have been reasonably successful in the European region. From a particularly bad 1999 with many last minute publications & cancellations (followed by many users bitterly complaining), the situation has now changed to being somewhere between a nuisance and a minor issue (and the users, including IATA, have started to express this as well). The number of AIRAC Non-adherence events is pretty stable but major events seem to have disappeared and/or at least have been anticipated and mitigated through AIS AGORA. So, do not be mistaken, more is still required and one should remain highly vigilant as it only takes one major late Amendment and the situation is back to where it started from.

Possible ways to solve the problem

1.1.1 ISO9000

Since 1998, ICAO Annex 15 explicitly requires AIS organisations to implement a Quality Management System (QMS). Any such QMS enforces the formalisation of all incoming, processing and outgoing

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processes. This in itself, is a big step towards as it forces organisations to structure their activities. Within Europe all States have adopted the implementation of an ISO9000 system (further enforced by a Eurocontrol ECIP Objective). This is well underway, but no QMS in the world can stop people violating the AIRAC rules.

ISO9000 in AIS

1.1.2 EAD

The European AIS Database (EAD) is the prime source of European aeronautical information and contains mechanics to hinder publications violating the AIRAC rules. This is a major step forward. However, States remain solely responsible for the publication of their aeronautical information and will so always be able to 'bypass'.

EAD web site

1.1.3 Electronic AIP

Any electronic publication (and the Electronic AIP (eAIP) more in particular as it will allow the data to be electronically downloaded/interpreted) allows faster distribution of the data and so reduces the distribution delays. Although many states publish now on web and/or CD-ROM often liability and copyright issues remain to be solved.

eAIP web site

What can be done?

— Spread the word AIRAC (use, re-use anything of this web page, inform all your colleagues etc.) and the importance of adherence;

— Participate to AIS AGORA and post any planned and/or (potential) late publication;

— Verify your postal delays and monitor your own AIRAC adherence results in pTracker.

More Information?

— ICAO Annex 15, Doc 8126 (specifically Chapter 4, AIRAC)

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APPENDIX B

PRINCIPLES OF WORK OF P-TRACKER MONITORING TOOL

Originating AIS logs through a secured web application the following information related to their product:

- Originating State

- Document Type (AIRAC AMDT, AIP SUP etc)

- Document number

- Effective date

- Dispatch date

The recipients (presently several AIS and data houses have volunteered to provide data) log the following information for each received product:

- Reception date

- Reception method (Post, DHL, etc)

As a result AIS are provided in pTracker with two key performance indicators:

- reception date - # of days before the effective date (>28 for AIRAC and >0 for normal AMDT); and

- time required for postal delivery – postal delay.

The availability of pTracker through the WWW, makes it easy to be accessed from any point in the world. Taking into account the acuteness of the problem with the timely delivery of data outside Europe that tool can serve greatly the AIS community to monitor the conformance of its products to the timely delivery requirements.

The application is hosted by PRISME and is available at: http://prisme-web.hq.corp.eurocontrol.int/ptracker

The read-only access is available to all registered AIS AGORA users via the forum.

Data submission to pTracker requires a special authorization, which is now managed by Eurocontrol.

AIS-AIMSG/1-SN No. 22Appendix B

AIS-AIMSG/1-SN No. 22Appendix B B-2

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APPENDIX C

1. The commentary in ED77 and graph in PBN manual introduce well the players involved and timeline between Day28 and effective date:

ED77/DO201A: 2.4.2

PBN Manual (ICAO DOC 9613) Attachment B (3.2)

AIS-AIMSG/1-SN No. 22Appendix C

AIS-AIMSG/1-SN No. 22Appendix C C-2

2. Though most of the bullet point of ED77/DO201A 2.4.2 are covered in DOC8126, the fourth bullet is rather important since it has been echoed on several occasions by AIS as one of the reasons for not being able to supply data

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3. The following text provided in 2.4.3, 2.4.6-2.4.7 of ED77/DO201A is not covered in DOC8126, however some parts can be useful to be added to the guidance material.

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