ATM ANS interoperability consultation

Interoperability Regulation repeal

We are currently consulting on changes to CAA CAP670 Air Traffic Services for ATM Regulatory Compliance and Interoperability.

On 12 September 2023 the remaining articles of the Interoperability Regulation will be repealed in UK law.

• Article 4 Community Specifications
• Article 5 DoC and DSU
• Article 6 DoV (and TF) Article 6a alternative verification of compliance
• Article 7 Safeguards
• Annex II Essential requirements and Specific requirements
• Annex III Constituents (Contents of DoC and DSU)
• Annex IV Systems (Contents of DoV, including TF)

In the EU a new ATM conformity assessment framework is being introduced to replace the Interoperability Regulation, however the CAA is not currently in a position to fully impact assess this framework and its potential application in the UK.

The other Interoperability Implementing Rules (now UK Regulations) as listed below remain
in force:

• 1032/2006 Flight Data Regulation (COTR)
• 1033/2006 Flight Plan Regulation (IFPL)
• 633/2007 Flight Message Transfer Regulation (FMTP)
• 262/2009 Mode S Interrogator Regulation (MSI)
• 29/2009 Data Link Services Regulation (DLS)
• 1206/2011 Aircraft Identification Regulation (ACID)
• 1207/2011 Surveillance Performance and Interoperability Regulation (SPI)
• 1079/2012 Voice Channel spacing Regulation (VCS)

The CAA will still require ANSPs to continue to demonstrate compliance with the ATM ‘systems and constituents’ elements of the essential requirements in the Basic Regulation; ICAO SARPs and CAP 670; and the other Interoperability Regulations, to demonstrate that air traffic service equipment is fit for purpose as required by Article 205 of the Air Navigation Order.

For an interim period after 12 September 2023, the CAA will maintain the current status quo as far as possible, before establishing a new UK regulatory framework for ATM interoperability. Broadly, documentation will be required to be provided that will remain similar to that prior to 12 September 2023.

The CAA will therefore add new Acceptable Means of Compliance (AMC) to CAP 670 to require ANSPs to provide similar documentation. However, declarations for interoperability will no longer have a legal basis and the CAA can no longer require declarations for interoperability to be provided, therefore Declarations of Verification and Declarations of Suitability of Use can no longer be used to be demonstrate compliance.

A Technical File will continue to be used, together with a new Record of Verification and Manufacturer Summary of Compliance.

Record of Verification

This provides the evidence that verification has been carried out. ANSPs should note the specific requirements for verification in each of the UK Interoperability Regulations.

Technical File

The Technical File is substantially similar to the existing document but now refers to the Essential Requirements in the Basic Regulation (UK Regulation (EU) 2018/1139). The Technical File will cross-reference and provides complementary evidence to the Safety Case.

The Technical File will also include references to evidence of compliance with the other Interoperability Implementing Rules. Compliance templates are already available for some of these, and others will be introduced for the remainder to demonstrate compliance where this is required.

Manufacturer Summary of Compliance

An ANSP could previously use a DSU to presume manufacturer compliance. This will no longer be the case although it may be impractical for ANSPs themselves to demonstrate compliance to detailed technical requirements.

Manufacturers should still however provide evidence of compliance with the regulatory requirements that their equipment that has been contracted to meet. This evidence will take the form of technical design documents and test evidence for which an ANSP should satisfy themselves if acceptable. The Summary of Compliance will be used to list this evidence, although by agreement between the ANSP and manufacturer it can be documented in other ways providing the same information is provided. Copies of templates for these documents are published on the CAA Website. These documents should be submitted with the safety assurance. Where certain test evidence may not be available until immediately prior to transition, this should be agreed with the allocated ATS Engineering Inspector.

Transition 

For systems and changes to ATM functional system implemented before and up to 12 September 2023 the extant DoV, Technical File and DSUs are still valid and should be retained by ANSPs.

For systems introduced after 12 September, any new systems or constituents should have evidence of verification against the Interoperability Implementing Rules and Essential Requirements described and recorded in the TF and RoV, as well as reference to evidence of manufacturer compliance. However, it is recognised that Technical Files may relate to new systems or constituents, as well as other unchanged elements, which will have extant DSUs. In this case, the DSUs for unchanged equipment can still be referenced and included in the Technical File as still providing evidence of compliance.

Where an EU Community Specification was established, a manufacturer could issue a Declaration of Compliance (DoC). DoCs for equipment supplied before 12 September 2023 can still be considered as valid and DoCs can be referenced in Technical Files.

For equipment changes immediately after 12 September 2023 it is recommended that ANSPs contact their allocated ATS Engineering Inspector for clarification on any issues.