EUROPEAN ORGANISATION FOR THE SAFETY OF AIR NAVIGATION EUROCONTROL SUMMARY OF RESPONSES (SOR) DOCUMENT FOR THE Draft Specification for Airspace Management (ASM) Support System Requirements supporting the ASM processes at local and FAB level Part I - Baseline Requirements Formal Consultation 19 December 2016 17 March 2017 26 September 2017 Released Edition 1.0
DOCUMENT CHANGE RECORD The following table records the complete history of the successive editions of the present document Edition Number Edition Date Reason for Pages Affected Change 0.1 22 March 2017 First draft All 0.2 07 July 2017 Revised draft All 1.0 26/09/2017 Released Edition All Edition Status Date Document Number Released Edition 26 September 2017 ESDP/16-002/Released Edition 1.0 1.0 2
TABLE OF CONTENT Contents INTRODUCTION 4 1. GENERAL 4 2. SCOPE OF CONSULTATION 4 3. PURPOSE AND STRUCTURE OF THE DOCUMENT 5 OUTCOME OF FORMAL CONSULTATION 6 1. GENERAL RESPONSE 6 2. CONSOLIDATED RESPONSES 8 2.1. Introduction 8 2.2. Scope of the Specification 8 2.3. Information exchange, data formats and protocols 9 2.4. Specific functionalities 10 2.5. Formulation of requirements 10 2.6. Software Assurance Levels 10 ANNEX A 12 ANNEX B 12 3
INTRODUCTION 1. General The Part I of the draft Specification for Airspace Management (ASM) Support System Requirements supporting the ASM Processes at Local and FAB Level provides a set of commonly agreed Airspace Management (ASM) Support System requirements. Compliance with these requirements, despite the differences in the systems detailed specifications, shall ensure harmonisation of the systems application, the systems interoperability and to facilitate development of a standard interface with the corresponding stakeholder systems. 2. Scope of consultation As required by the EUROCONTROL Regulatory and Advisory Framework (ERAF), the draft Specification was circulated for comment between 19 December 2016 and 17 March 2017 using the EUROCONTROL Notice of Proposed Rule-Making (ENPRM) mechanism for formal consultation. The formal consultation allows all States, Stakeholders and interested parties to express their formal views on the draft EUROCONTROL Specification. The consultation documentation comprised the draft Specification and a Consultation Response Sheet. In the Response Sheet, the addressees were asked to express their formal view on the draft Specification. Copies were sent directly to the following: Civil and Military regulatory authorities and key ATS providers of each EUROCONTROL Member State; Regulatory authorities of States observers at the Provisional Council; EC, ECAC, FAA, ICAO, NATO; International Organisations having observer status at the Provisional Council; Key trade and professional associations having observer status at the Provisional Council; Chairmen of the following bodies: CMIC; PRC; SRC AAB; 4
The documentation was also made available through existing working arrangements and to members of the public via the EUROCONTROL web site. 3. Purpose and structure of the document The purpose of this Summary of Responses (SOR) document is to provide a consolidation of the main comments received as part of the formal consultation activity, as well as to provide EUROCONTROL s responses to, and disposal of, those comments. This SOR is available on the EUROCONTROL website for information. The responses section (below) of the document is structured as follows: General Response providing a general analysis of the comments received; Consolidated Comments and Responses summarising the comments made and providing the associated responses. Two annexes are provided with the document as follows: Annex A contains a list of those Stakeholders that provided comments on the draft Specification; Annex B provides a table containing all of the comments provided by Stakeholders, the proposed disposal by EUROCONTROL and a detailed response to all of the comments. 5
OUTCOME OF FORMAL CONSULTATION 1. General Response A total of 15 Stakeholders responded to the consultation. Out of these 15 Stakeholders, 6 were ANSPs, 6 Civil Aviation Authorities (CAA), 2 National Supervisory Authorities and 1 Military. The 15 Stakeholders provided a total of 57 separate comments. The Stakeholders responding to the consultation considered for most of them the ASM Specification to be acceptable although could be improved submitted some proposals for improvement. No Stakeholder stated that the Specification was not acceptable under all circumstances. The following table shows the distribution of the overall result of the comments across the Stakeholder categories: Response category A B C D Total by stakeholder Stakeholder category ANSP 1 2 3-6 CAA 2 4 - - 6 NSA 2 - - - 2 Military - 1 - - 1 Responses received per category 5 7 3-15 Legend: A = Acceptable without amendment B = Acceptable but would be improved with amendments C = Not acceptable but would be acceptable with amendments D = Not acceptable under any circumstances 6
The distribution of the Stakeholders that submitted comments during the consultation period is shown in the chart below. Responses received per stakeholder category 13% 7% 40% ANSP CAA 40% NSA MIL The breakdown of the overall general responses about the draft Specification is shown in the chart below. Responses received by category 47% 20% Not acceptable but would be acceptable with amendments Acceptable without amendment 33% Acceptable but would be improved with amendments The detailed breakdown per stakeholder type of the overall general responses about the draft Specification is shown in the chart below. 7
4,5 4 3,5 3 2,5 2 1,5 1 0,5 0 Overall general response per stakeholder category Not acceptable but would be acceptable with amendments Acceptable without amendment Acceptable but would be improved with amendments ANSPS NSA CAA MIL 2. Consolidated responses 2.1. Introduction This section summarises the main issues arising from the consultation on the contents of the draft Specification. Other comments, including those of a supportive nature, those correcting minor spelling or grammatical errors, those outside of the scope of the draft Specification and/or those not requiring a response have not been included for the sake of brevity. However, all comments submitted are included verbatim in the table at Annex B with their corresponding response. 2.2. Scope of the Specification 2.2.1. Comment Some stakeholders pointed out that the draft Specification covers ASM Support System Requirements for local and FAB level and does not comprise all relevant levels of ASM. Furthermore it was pointed out that ERNIP Part 3 (ASM Handbook) describes the ASM processes and procedures for local/fab and network level. It was highlighted that the interoperability between systems at all ASM levels and their capability to exchange and process data accordingly is a pre-requisite to support these procedures. It was underlined that the operational requirements for ASM system support (ERNIP Part 3, Annex 12, NOV 2016) cover requirements for all three levels. It was recommended that the scope of the draft Specification be extended to comprise system requirements for local, FAB and network levels and that this should be done in line with the approach allied in the ERNIP Part 3, Annex 12, NOV 2016. 8
2.2.2. Response The draft Specification is not intended to provide requirements applicable to NM systems. It addresses only Local/National systems. It is recognised that interoperability is of paramount importance. Part I of the Specification addresses common local ASM functionalities aiming at having a common baseline to build interfaces between local-local and local-nm systems. The Specification document Part II - currently under development - will address the interfaces between systems involved in ASM at local, sub-regional and regional levels in order to ensure interoperability. ERNIP Part 3, Annex 12 is used as a reference to the draft Specification. 2.3. Information exchange, data formats and protocols 2.3.1. Comment It was stressed that the ASM Support System shall use and be consistent with standard data formats and protocols agreed on regional (pan-european) level. It was clarified that data exchange could be done by using standard protocols and format in system as well as by using various types of converters. However, NMOS, ATC systems and others are interested in receiving the data in commonly agreed protocols and format. The importance of cybersecurity issues and ensuring security of data exchange was highlighted, notably the need for use of cryptographic protocols. 2.3.2. Response It is recognised that ASM Support System shall be capable of processing and exchanging data in standard data formats and protocols agreed on regional (pan-european) level. The use of cryptographic protocols provides options for various implementation solutions while ensuring that the desired result - endpoint authorisation and communication privacy is effectively achieved. A new requirement has been added to reinforce the need for ASM Support systems to be developed in accordance with state-of-the-art cyber security principles. 9
2.4. Specific functionalities 2.4.1. Comment It was highlighted that, due to the differences in civil-military coordination procedures, there could be specific national requirements for functionalities in national ASM system. Therefore, it was suggested to specify this in a dedicated requirement. Furthermore, a number of comments suggested rewording of certain functional requirements for more precision and completeness. 2.4.2. Response While the Specification is aimed at specifying a minimum level of necessary functionalities to ensure harmonisation and interoperability, it is recognised that ASM Support System may need to have additional functionalities necessary to satisfy specific national requirements. Therefore, this possibility has been provided by adding a new requirement in the Specification. A number of requirements have been revised in line with the comments to making them more precise and complete. 2.5. Formulation of requirements 2.5.1. Comment Some stakeholders felt that for a number of requirements the descriptions in ASM Handbook better reflect required the functionalities; therefore it was proposed to use the wording from the ASM Handbook. 2.5.2. Response The requirements in the ASM Handbook are placed on ASM/ATFCM stakeholders. The requirements in the draft Specification are addressing the functionalities of the ASM Support System that are needed in order to ensure that the ASM/ATFCM stakeholders are able to comply with the requirements from the Handbook. In any case, the requirements in the draft Specification are consistent with those in the ASM Handbook. 2.6. Software Assurance Levels 2.6.1. Comment It was stressed that ASM Support System shall be developed in compliance with the requirements stemming from Regulation (EC) No 482/2008. 10
It was also highlighted that taking into account the upcoming amendments to EC (EASA) legislation, reference should be made not to Regulation (EC) No. 482/2008, which is to be repealed, but rather to specific requirements which are to be incorporated in the future revisions of the Regulation (EU) 2017/373 (the Common Requirements regulation). 2.6.2. Response The importance of compliance with the legal requirements in Regulation (EC) No 482/2008 is fully recognised. EASA Notice of Proposed Amendment (NPA) 2017-10: Software assurance level requirements for safety assessment of changes to air traffic management/air navigation services functional systems, issued on 28 June 2017, proposes a set of acceptable means of compliance (AMC)/guidance material (GM) for the definition and implementation of a software (safety) assurance system by providers of ATM/ANS and other ATM network functions that is based on the requirements laid down in Regulation (EC) No 482/2008, which is repealed by Regulation (EU) 2017/373. The NPA proposes a transposition of the already known provisions (with some adaptations) in Regulation (EC) No 482/2008 to the AMC material and the introduction into the GM part of the references to some of the existing industrial standards, which may be used by the ANSPs to build their software assurance systems. The aim of EASA is to issue the ED Decision (and the associated CRD) on the additional AMC/GM addressing (at least) SWAL well in advance of the applicability date of Regulation (EU) 2017/373, i.e. 2 January 2020. Currently, Regulation (EC) No 482/2008 is applicable until 2 January 2020; therefore, systems put into operation until this date, have to be compliant with its provisions. 11
ANNEXES ANNEX A Annex A contains a list of those Stakeholders that provided comments on the Airspace Management (ASM) Support System Requirements supporting the ASM Processes at Local and FAB Level Part I Baseline Requirements formal consultation. ANNEX B Annex B provides a table containing all the comments provided by Stakeholders. The table shows the Disposal of each comment, i.e. Accepted, Partially Accepted, Rejected or Noted and EUROCONTROL response to each comment. 12