48TH ANNUAL CONFERENCE, Dubrovnik, Croatia, 20-24 April 2009WP No. 105Environmental PolicyPresented by the Executive Board |
Introduction
1.1 At the 47th IFATCA conference in Arusha TOC has presented two excellent working papers on environmental issues, WP 93 (Review Policy on Environmental Issues in ATM) and WP 94 (Study Developments Associated with Environmental Issues in ATC). Both papers give a very good overview on the ongoing activities at a global level – and set the overall issue in the context we are in currently.
1.2 IFATCA Policy is:
“In the operation, maintenance and development of the ATM system:
|
The text introducing the current Environmental policy reads as follows:
“There are several environmental issues in ATM. Aircraft noise and aircraft emissions are the issues that have the greatest impact on efficiency and safety. The aviation industry continues to grow and the focus on environmental issues has increased worldwide as well. Despite this, safety is still the overriding consideration in all aviation activities. While safety management is improving, the level of safety is more often balanced against efficiency and environment. This could result in a decrease of the level of safety while the target level of safety is still met.”
1.3 The Executive Board has had the opportunity since conference in Arusha to comment and to give input to various activities around environment in bodies such as ICAO (Group on International Climate Change and Aviation – GIACC), European Agency for Safety of Aviation (EASA), Eurocontrol and the European Commission.
1.4. Chairman TOC represented the Federation at a seminar on Climate Change, organised by the international Transports workers Federation (ITF).
1.5. IFATCA has published the issue number 4/2008 of the Controller Magazine titled “Environment and ATC”. This issue had a lot of positive feedback from outside IFATCA and can be qualified as a major contribution to the current environmental discussion.
1.6. IFATCA has been approached by IATA to make a common action on the more operational implications of environmentally friendly or conscious procedures and a video clip is being produced in collaboration with IATA.
1.7. This working paper must be read in conjunction with agenda item WP93 and WP94 of the Arusha 2008 conference.
1.8. The Executive Board has decided to organise the conference 2009 panel under the title of Environment and ATC.
Discussion
2.1. Current operational issues with environmental friendly procedures
Controller complexity due to environment
Operational experience at airports which have to deal with environmental friendly operations on a daily basis report that the complexity of the ATM system has increased. As a result of this, the day-to-day work of the controller has become more difficult. Noise abatement procedures force some of the European members to change the operational concept for the airport (active runways etc.) several times a day (up to 20 times a day).
Some of the current procedures in place, place the decision on trading off safety, efficiency versus environment to supervisors and ATCOs.
The need to address Environmental issues by operational ATCOs
It is important that an ATCO has an understanding of the potential impact of environmentally friendly procedures in the air and on the ground. It is important just as for any other new procedure that is introduced in ATM that these new procedures are developed and implemented within a safety management system and that they are introduced in a way that all the actors are aware of the impact and (if needed) mitigation which is in place.
In general the ATM community does not understand what exactly is meant with the environment and especially its impact on ATC operations. As an example the noise driven procedures (environment) might have a negative impact on emissions, as an indicator that environment is more than just noise or emissions and the relation is very important. The interaction among some of the so-called environmental procedures are not fully analysed and distort the operational reality.
2.2. The need for a clear message to the outside world
It is important that IFATCA is able to communicate a clear message to the outside world. At the same time IFATCA acknowledges the importance of being part of the changes towards ATM with regard to environment, and support whatever actions could be proposed. These actions should take into account the already important contribution ATCOs are giving to procedures which are assisting in the reduction of fuel consumption.
This has to be combined with a Policy that assists the Executive Board to participate in discussions that will be held at the global level and at a regional level.
Although IFATCA believes that the current ATM system at a global level is efficient, it also believes that it is still possible to enhance this efficiency,. IFATCA demands that if systems like Emission Management Systems (similar to Safety and Quality Management System) are introduced in ATM environmental measures do not prime over safety. Potential impact on the ATM operations needs to be assessed and mitigated before systems addressing Emission Trading schemes or Performance Indicators are introduced.
2.2.1. Background
The International Panel on Climate Change (IPCC) had inputs in their work by ATM experts in the past.ICAO’s Committee on Aviation Environmental Protection (CAEP) has been working on the follow-up of the IPCC.
IFATCA has put the interaction between safety and environment in ATM high on its agenda. Our members are already confronted with environmental measures which have an impact on their daily work. The EB felt the need to become active in this field.
2.2.2. Ongoing activities
ICAO has recently created a Group on Climate Change and Aviation (GIACC) which has called for opinions from Industry on the work. IFATCA has not been invited to this group but has sent information on GIACC based on the worked carried out so far.
The European Region, especially the trans-national organisations such as the European Commission and EASA, have recently published measures to reduce the impact of aviation emissions on the environment. The European Commission uses the Environment as the main driver for its reform process in ATM.
European perspective with regard to the Single Sky initiative does not differ markedly from the liberalization processes observed in other utilities industries. It makes use of conventional instruments to create an internal market level playing field. It relies on the Commission being the prime regulator, leaving national monopoly structures vertically integrated as in Telecoms. The Commission uses environment to achieve the hegemony strategy of the EC towards the USA, India and China, where it pools aviation and energy intensive industry in order to use it as a bargaining mass. Aviation according to press (H-J. Luhmann, in NZZ “Europa auf dem Weg zur Klimaweltmacht” 08042008) will have to reduce by 18% the emissions in order to fulfil the negotiation leverage needed by the EU in the international discussion on climate change. (annex 1 depicts in a graph what is meant)
EC is introducing Emission Trading Scheme in Europe. This (if introduced at all in aviation) should be first established globally to be effective and righteous. The airlines have complained that this is an unacceptable way of introducing it. Recently aviation representatives have linked the ETS to the efficiency of ATM – and requested to have it put in place together with efficient measures achieved thru SES in the ATM infrastructure.
Aviation accepts generally to take responsibility regarding the environment, but one has to remain realistic in what is possible. Some figures:
Current anthropologic emissions of greenhouse gases is 3% of all worldwide emissions, for this percentage aviation is, calculated by the IPCC (IPCC Special Report on Aviation and the Global Atmosphere 1999) responsible for only 3.5% of the total amount (5% in 2050).
According to Eurocontrol present ATM is efficient between 92-94%, this could be increased to 96-98% by measures like FABs and CDA’s. So we are talking about maximum 6% of 3.5% of 3%, this is 0.0063% of the total emission of greenhouse gases which ATM can improve (according to Eurocontrol) if they are able to reach the maximum result in efficiency
IFATCA had as well the opportunity to make a presentation at a conference organized by the International Transport Workers’ Federation (ITF) – to explain how the environmental issues do affect ATC’s daily operational business.
CANSO’s environmental working group has recently published a paper produced for the GIACC called: ATM Global Environmental Efficiency Goals for 2050. With the following key conclusions:
- The Global ATM system is already between 92% and 94% efficient;
- Total inefficiency in the Global ATM system represents 0.3% of global CO2 emissions (according to the IPCC and Eurocontrol statistics this is only maximum 0.21% (of all anthropologic emissions). This is not a proven fact, it is probably less than 0.21%);
- 100% ATM efficiency is not achievable as some inefficiency is unrecoverable due to necessary operating constraints and interdependencies, such as Safety, Capacity, Weather and Noise;
- Congestion plays a large part in the efficiency of the ATM system. ATM efficiency will decrease significantly with increased congestion brought about by traffic growth unless there is a corresponding increase in airport and airspace capacity.
- ATM efficiency improvements may be achieved by introducing a range of initiatives. Some of these can be directly introduced by ANSPs, such as new operating procedures. However, many rely on other participants in the aviation system, such as institutional change to reduce airspace fragmentation;
- The CANSO ATM Inspirational Goal is for a Global ATM system that is between 95%and 98% efficient by 2050.
IFATCA is discussing with IATA how best to give support to IATA’s initiative to use the environmental protection on a political level to improve the current efficiency of the overall ATM system.
2.2.3. Sense of urgency
All the global and regional activities have the tendency to influence our operational environment in a not too distant future without taking into account any adjustments that will decrease the existing level of safety. It is the opinion of IFATCA that any environmental improvement and benefit achieved by measures on behalf of safety will be statistically demolished conclusively.
There is a sense of urgency for IFATCA to make its be voice heard, as other organisations are not waiting for our input.
2.3. The operational point of view shall not be forgotten
IFATCA stresses that aviation in general is putting up the maximum effort to safely reduce fuel consumption which will automatically decrease the level of emissions by aircraft. It is a fact that the level of emission of greenhouse gasses by aircraft is in percentage much lower compared to other industries (i.e. agriculture and steel), conversely the economic and social benefits of aviation are crucial in today’s world.
IFATCA does share the recently adopted recommendation of APIRG on adopting an approach to the planning and implementation of ATM systems and ATM improvements that supports collaboration and considers best outcomes for safety, capacity, efficiency and the environment.
By adopting an approach where environmental issues are integrated in the planning and implementation of ATM systems and improvements and thus remain at the strategic planning level, the risk of increased complexity and the associated drift into failure by a reduction of the safety margin has to be assessed and mitigated. This will have the benefit of not shifting the responsibility into the tactical operational environment. By assessing and mitigating the risk of any new procedures (including environmental ones) it becomes additionally measurable.
All measures to increase safety and capacity have in the past resulted in substantial increase in efficiency and a reduction of the environmental impact of aviation. As the efficiency of the ATM system is close to 100% and the environmental impact of ATM operations is extremely small results in the fact that any new measures which are environmentally, instead of safety and efficiency, driven will have to be offset by a reduction in capacity. IFATCA has indicated to organisations such as EASA that by working in isolation at reducing the environmental impact of ATM Measures or aviation measures, a theoretical approach is created which will be offset immediately by the operational reality such as weather, airspace organisational structure and have an impact on operational safety.
2.4. Environment as part of the current system
Considering the recent emphasis from many sources and, in particular, ICAO governing bodies, on the need for aviation to address the environment, particularly with respect to C02 emissions, many initiatives over many years have contributed to reduced greenhouse gas emissions. Just to list a few; RVSM, RNP, BRNAV, CDA etc.
A fair amount of so-called “environmentally minded” procedures affect their operational work. Runway utilisation, CDA, Noise abatement procedures, speed control measures flown by users with cost indicator and not the expected speeds increase the complexity of the daily tasks significantly. IFATCA insists that any environmental measure is addressed at the highest current existing strategic level of ATM management. We are concerned from the current experience that introducing environmentally driven procedures in the ops room, leads inevitably to a further increase in complexity. Based on this experience IFATCA asks that more effort is taken to manage such environmentally driven procedures at a strategic level and shall include considerations to reduce capacity on behalf of the environment.
The current policy of IFATCA is sufficient to cover this.
2.5. Environment as part of the system design of the future air traffic management
Safety is being addressed by ICAO’s Global concept among others thru the use of conflict management layers.
Conflict management layers as proposed by the ATM Global Concept:
The concept takes a holistic and systemic view of air traffic management, which includes “all airspace as a useable resource” and everyone involved in activities in that airspace as members of the “ATM Community”.
The concept defines three layers of conflict management; that is the layers of: strategic conflict management, separation provision and collision avoidance.
IFATCA cautions that the design of the ATM system needs to respect the different nature of these layers and incorporate them appropriately in the system design; therefore a solid methodology for environmental issues has to be automatically part of the system design.
IFATCA argues that Environment is part of strategic conflict management as it is directly linked with demand and capacity balancing and traffic synchronization.
Strategic conflict management relates to issues of airspace organization and management, demand and capacity balancing and traffic synchronisation. When future systems of air traffic management are discussed, there is a tendency to favour either strategic or tactical solutions; however, IFATCA considers that both have an important role and that they are interrelated and highly dependent today as well as in the future. Today, the nature of the dependencies and interrelationships are often little understood in terms of their effects across and within the ATM system. In the future, the principles of conflict management, as espoused in the concept, will substantially add to the complexity of interactions and dependencies. A concomitant of such a system is a greater tightening of the coupling between system components.
It will be essential to the success of the concept that full consideration is given to supporting the coupling requirements of these system components to ensure resilience and smooth interactions. IFATCA therefore supports the concept paragraph that states:
“strategic conflict management measures aim to reduce the need to apply the second layer — separation provision — to an appropriate level as determined by the ATM system design and operation.”
Strategic only solutions are not possible because the ATM system is not a system where all events are controllable; for example weather related events cannot be controlled or always accurately predicted in sufficient time in advance. In addition, to achieve maximum efficiency, some flexibility is required to accommodate changes, such as the early release of airspace, missed approaches or late changes to an airspace user’s mission and the requirement to handle aircraft and national emergencies.(see experience after 9/11).
Whichever way future proposed measures on efficiency and environment are heading, IFATCA insists that they should not be proposing to use the conflict avoidance or the separation provision layer of the conflict management layers for the environmental benefits. Environmental regulation can only be acceptable for IFATCA at the strategic conflict management layer and shall not be delegated to the separation provision or conflict avoidance level and have to be designed into the system strategic conflict management layer.
Conclusions
3.1. IFATCA has a solid policy on environment, however the EB has determined that a refinement of the policy is required for political reasons.
3.2. The political initiative to address the environment and its impact on aviation has been addressed by various international and regional organisation for various reasons (political, fuel efficiency), besides environmental benefits and has found its way into the operational theatre without being assessed properly from a systemic point of view. This leads to sometimes competing operational realities between safety, efficiency and environmental consideration and even to competition between different actors. This has in most cases added a layer of complexity for the ATCO which is not sound on a longer term for the overall ATM system.
3.3. When talking about preservation of the environment, a mix of measures are being applied without listening to the operational feedback and experience. This needs to change and any new proposed measures need to be part of the safety management system.
3.4. For the design of the future ATM system, Environment has to be placed at the strategic management layer in order to avoid any actions due to environmental measures to be applied at the separation provision level.
Recommendations
It is recommended that;
4.1. IFATCA Policy is:
“In case environmentally driven procedures are introduced in the ATM System, these must be introduced taking into consideration the increased complexity for the controller. This complexity must be managed at the appropriate, strategic, level. A trade-off between environment and capacity must be considered as part of this management of complexity, as safety is paramount.”
and is included on page 3 2 3 25 of the IFATCA Technical and Professional Manual.
Annex – Example how the European Commission tries to use Environment in the utility sector to achieve market principles
Last Update: September 29, 2020