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Federal Department of the Environment, Transport, Energy and Communications DETEC Federal Office of Civil Aviation FOCA Safety Division - Infrastructure ADQ – Implementation Switzerland EC Regulation 73/2010 Markus Luginbühl – 20130529 FOCA Section Policy & Rulemaking ANS
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2 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 Subjects 1. Implementation Switzerland – Status 2. Challenges and open issues a. Legal Issues – national high level law changes required b. Implementation Timeline c. Open issue with European Commission d. Cross border Data-processes e. Cost – Cost allocation – Cost recovery f. Data lifecycle management, Evidences for the required Traceability g. ADQ Oversight h. Technical systems and tools 3. National Transition Process - Enablers
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3 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 1. Implementation Switzerland - Status Getting High level attention on the issues Ressources Attention for needed legal changes Getting Regulator/NSA and Parties in Charge Ressources Attention for needed changes START Impl. Alignement Impl. on Timeline National International Analyses; Implementation Doc; Implementation Roadmap
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4 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 1. Implementation Switzerland - Status Required high level aviation law changes are in progress The establishment of the implementation documents are in progress Regulator together with ANSP, Airports and Military Engagement of Airports is demanding A number of open questions e.g.: Cost recovery Issues and missing legal baseline do not support efficient implementation Quick fix to meet timeline vs. Lasting solution. Airport Briefings on ADQ have started – to engage them in the process Engagement of Surveyors overhead organisations is in place legal changes in their domain as well as guidance material for them is being established. Origination Services Discussions are ongoing Implementation is late regarding timeline July 2013! We expect a delay of about 18 month. Status
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5 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues Needs for national legal changes Institutional aspects Cost allocation to aviation-outsiders is very difficult Cost-recovery model Requirements towards Originators or Parties outside of the aviation system Interface issues (e.g. direct electronic connection, data format, etc.) Liability Questions Change Process is ongoing Started early 2011 Will in best case be enforced beginning 2016 Implementation without legal baseline in place Missing legal baseline is hindering efficient implementation Legal Situation Planned enforcement of high level Law: 1.1.2016
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6 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues Missing clear answer (ref. SSC 46 and SSC 47) from the commission regarding the delay-request of several states Switzerland will inform the commission on the Implementation delay and handing in our implementation roadmap and plan Implementation monitoring process across Europe is still missing it would show a very clear picture towards the commission Cross border Data-processes There are huge difficulties to be resolved on Cross border Data issues e.G.: Processes regarding cross border Airspace Structure or processes for Obstacles – which do heavily depend on national legal framework. Data origination and State responsibilities vs. Originator responsibilities Open issue with the commission; Cross Border Issues
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7 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues SES Performance Scheme requirements vs. huge aviation system enhancement-Cost European Performance Targets require great cost saving on ANSP Side – this is contradictory with the increasing demands on changes ADQ neither guidance material does not include any Cost allocation models, neither does eTOD Expectation that States would come up for the Cost or would allocate them to aviation outsiders (e.G.: private non- aviation obstacle owners) is not really realistic. Cost allocation and recovery models are to be established European-wide harmonized! The commission is urged to establish cost allocation and cost recovery models for all regulatory changes making sure, that the aviation sector can afford what is being planned and Performance target setting and comparison must be based on aligned cost allocation and recovery models! Otherwise it is non sense. Cost – Cost allocation – Cost recovery
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8 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues The Requirements as well as the available guidance material leave this issue wide open How is it to be done – what does fulfil the ADQ Requirement really What are the responsibilities How far goes the task of an ANSP regarding traceability? Data could last unchanged for very long time periods what does this mean for the Data lifecycle management and traceability? Only to assure readability over long time periods can be very demanding and costly. Guidance material to establish a harmonised approach across Europe would be very much appreciated! Data lifecycle management
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9 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues Switzerland does believe, that some sort of Data-origination services are needed To ensure digital processes without interference To enable smaller and smallest or even private originators to conform with ADQ Requirements For Data Quality assurance For efficient (incl. cost efficient) Aeronautical Information Management Processes and to not increase the since years growing Publication lead times Cost and cost recovery Responsibilities – ANSP? Technical solution is not available really Data Origination
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10 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues Oversight of Airports Established oversight processes towards airports are being expanded on ADQ Oversight for Airports Oversight of ANSP Established oversight processes (SES Requirements) towards ANSP will suit for ADQ oversight However some adjustments in existing processes are needed PANS OPS and AS Designers are today part of the monopoly ANSP and are therefore in the oversight process on ANSP included Oversight of Surveyors Switzerland will establish an acceptance process for surveyors and publish approved surveyors transparent an clear requirements for surveyors to reach such approval will be published. Re-approval will be required after defined time-period Oversight
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11 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 2. Challenges and open issues How can we reach compliance regarding technical Systems and tools Surveyors or PANS OPS Tools and Software Data Origination or transfer tools of other parties We look for a Process involving the national geodetic institute and the Government Body of the Surveyors to get a generic process of acceptance or a list of accepted tools and software on existing and today used tools and software in place. This issue is not yet solved and finalised - Guidance on this issue would much appreciated! Requirements for technical systems and tools
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12 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 3. National Transition Process The transition process is a very demanding and challenging issue Engage high level management amongst involved Regulators must engage – it will not happen otherwise National Policy and Legal baseline is very important Raise as early as possible appropriate awareness and get things moving Missing or little know how build up know how, networking Establish a harmonized understanding and approach amongst involved Get Originators to align their processes appropriate and in time Cost: Implementation cost to get all data ADQ Compliant and cost for the technical system changes or evolutions are high solve the processes e.G.: Obstacles Area 1 – huge effort is needed – cost allocation to private non aviation organisations or individuals Get Surveyors ready and aligned (they are non aviation organisations and there is no big market) there could be legal changes required?! Enablers
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13 ADQ WS BRU Markus Luginbühl, ANS/AIM Policy & Rulemaking, 20130529 End Questions / Remarks
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