Dear COPA Flight Captains,
NavCanada recently released the enclosed Aeronautical Study pertaining to their planned NavAid Modernization program. This program proposes to decommission most non-directional beacons (NDB) and very high frequency (VHF) omni-directional ranges (VOR) across the country in favor of a satellite based navigation system. This proposed system has been under discussion for some time and COPA has held numerous meetings and discussions, both with TCCA and with NavCanada on the subject. In the process, NavCanada has maintained that they have led an extensive consultation with all stakeholders across the country, a claim that COPA does not support based on the information we have gathered. Nonetheless, the attached document presents a compendium of the feedback NavCanada received from some customers. Note the attached document does reflect some of the concerns that COPA voiced to NavCanada, and includes the results of their consultation process, as well as their responses and mitigations.
We would greatly appreciate your sharing of this document with your members, and giving us your feedback on the impact of this program on small GA aircraft operation, as you perceive it. We recognize that this is a complex document, we are happy to offer some guidance with respect to the document.
Main Content of the enclosed Aeronautical Study:
- Section 3: Consultation: the comments from various industry stakeholders and NavCan’s reply and mitigation to these issues. Note that most of the issues in this section are more relevant to commercial operators but several are relevant to small GA aircraft, particularly in IFR operation;
- Section 3: Risk Analysis: note that this paragraph does not identify any risk or hazard. We recommend that you review appendices A and D as referred to in that paragraph;
- Section 3: Mitigation: we recommend that you review the relevant appendices referred to in this paragraph;
- The various other appendices of the study identify the NavAids that will be decommissioned and the proposed mitigation to be implemented, indexed per FIR’s;
- The operational characteristics of this GNSS based ANS will not provide complete radar coverage below 10,000 ft.;
- The possibility of a prolonged GNSS outage is briefly discussed in different paragraphs, including the proposed mitigations;
- In the event of a prolonged GNSS outage, small GA aircraft below 10,000 ft will be forced to navigate by dead reckoning. When in IMC conditions, the pilot will have to climb to 10,000 ft for proper coverage, or dead reckon to a recovery site, which could become a serious issue in either case.
COPA’s Preliminary Position
Considering the logistics and financial aspects of maintaining and/or replacing Canada’s aging ground-based Air Navigation System, we understand NavCanada’s vision in making the best use of available resources, including maximizing the use of satellite-based navigation.
Consequently, COPA believes that the NavCanada vision of moving to a GNSS based ANS system is sensible, practical, and efficient. This position is further supported by the fact that an increasing number of small GA aircraft are equipped with certified GNSS navigators and this tendency keeps growing.
COPA also perceives a very serious issue: that of potential prolonged GNSS outage. In this situation, any small GA aircraft flying in IMC below 10,000 ft., which is the case of all small aircraft, will face an issue of significant importance.
Review and Feedback
We request that you review this Aeronautical Study with your members, including as many COPA members as possible in your region. We suggest that your review should focus on the following points:
- Review, discuss, and understand the Executive Summary and the Background information on pages 2 and 3 of the document;
- Review, discuss, and understand the aspects of Section 3 listed in item 1 (more specifically pages 8 and 9 of the document), as well as items 2, and 3 in the Main Content paragraph above;
- Analyze item 4 for its impact in your area;
- Determine how many of your COPA members actually fly IFR in IMC and the impact items 5, 6, and 7 will have on their ability to continue to operate IFR in IMC under GNSS outage conditions.
We request that each COPA Flight provide feedback to this office by 31 May 2018 to enable some discussion at the COPA convention on 21 – 23 June 2018. Your feedback and our discussions will contribute to finalizing our COPA Position for submission to NavCanada and TCCA.
Click the link below to access the document: