It is well understood that achieving interoperability across the European Air Traffic Management Network (EATMN) can offer several high-level benefits including efficient use of airspace, reduced air traffic delay and support for sustainable traffic growth. However, we also know that these benefits will only be realised if interoperability is achieved at the most detailed level of the value chain. Conformity Assessment (CA) is the process of demonstrating this.
I have supported several ANSPs with their CA activities but if I take a step back from my day-to-day work, I'm left with two overriding questions:
- Does Conformity Assessment actually contribute towards achieving true interoperability in today's world?
- How appropriate is the current process for the future?
Let's start with the first question...
In my view, Conformity Assessment has so far made a limited contribution towards achieving interoperability of the EATMN for 3 reasons:
1. The regulation is difficult for ANSPs to apply
2. Manufacturers do not currently have enough of a role in demonstrating conformity
3. NSAs have several roles to perform and limited resources
Let's look at the issues for each stakeholder in more detail.
Fundamentally, ANSPs have struggled to get to grips with the interoperability regulation. The Essential Requirements are perceived to be too broad to have real meaning – they are difficult to interpret, apply and provide evidence against. In my opinion, this is a consequence of a somewhat ambitious attempt to capture all types of system and constituent in the requirements. The answer here could be to refocus the regulation on those systems that offer the greatest interoperability benefits and on the application of implementing rules rather than Essential Requirements. The requirements need to be clear, concise and testable.
Perhaps the biggest issue is that for project teams, it can be difficult to marry the idea that CA activities for a particular system/constituent offer any realisable interoperability benefit and therefore, it is perceived as onerous. They already have a plethora of regulation and requirements to follow so Conformity Assessment is often relegated down the list of priorities. I am not suggesting that ANSPs do not comply with the Interoperability Regulation but rather that interoperability of constituents is considered too late on in a project, or even presumed.
Both these issues can be addressed by the idea that if CA is planned for in the early stages of a project, it can support teams with the development of system requirements and ultimately help them procure more suitable constituents from manufacturers. Placing requirements on manufacturers to demonstrate that they meet the applicable requirements of implementing rules will force manufacturers to really consider the capabilities of their equipment and whether they are truly interoperable. Currently, the regulation only requires manufacturers to provide a Declaration of Suitability for Use (DSU). However, the level of detail in the DSUs provided by different manufacturers varies greatly and for me, miss a key piece of information – traceability between their system and the applicable interoperability requirements.
What is the role of the NSA in all this? Their role (with regards to CA) is to validate an ANSP's CA activities. However, speak to any NSA and they will tell you that they have several roles to perform including validation of safety cases, inspections, coordination activities, training, quality assurance and validation of Conformity Assessment. Furthermore, they must perform all of these roles with limited resources.
So here's a suggestion for a practical way forwards. Although I'm sure that some NSAs do this already, they would go a long way towards supporting the goals of the Interoperability Regulation by setting clear expectations for ANSPs and providing best practice guidance. What would make this even more valuable is if the guidance and expectations were developed and agreed at NSA Coordination level. Of course, this would add more work to the ever-growing pile but it would be a small, one-off investment that would pay dividends. These are not limited to interoperability benefits but could also include an incremental safety benefit associated with systems that are proven to work together.
To conclude, the benefits of Conformity Assessment to date have been limited. However, if ANSPs, manufacturers and NSAs take a more proactive approach towards understanding the process and the regulation in its current form, there is still value to be gained.
But what about the future…how relevant will the Conformity Assessment process be then? We'll look at that question in my next blog.