We are still not sure, in which category some specific equipment falls and thus we would appreciate a more detailed allocation oversight of specific systems to categories (e.g. electr. flight strips; network equipment, Server HW, virtualisation and operating systems, used for all kinds of systems).
First step is to assess the scope of the equipment and which function it supports. This assessment will determine the category to which it belongs.
Division of today's EATMN components into CA categories. For some existing systems, the categorization is debatable (e.g. EFS). Does the new regulation require anything similar as so called “distribution of systems and constituents within the functional system”?
The new regulatory framework clearly defined the ATM/ANS equipment subject to the various attestation methods – certification/ declaration of design compliance and statement of compliance. The scope will be further illustrated at DS/AMC/GM level.
Does a primary surveillance radar (PSR) being provided to the European Union require certification under Regulation (EU) 2023/1768? If so, are there any published detailed specifications (DSs) for PSRs?
No, the PSR that only performs the surveillance function does not require certification.
Since the PSR is used to provide surveillance data for the purpose of ensuring safe and interoperable air navigation, it is considered ATM/ANS equipment that falls under Article 5(1)(b) of Commission Delegated Regulation (EU) 2023/1768. Therefore, a PSR would require a declaration of design compliance (see also Annex III to Regulation (EU) 2023/1768) rather than certification.
At the moment, DSs only contain general requirements for PSRs, but no specific technical requirements. However, DSs will follow regular updates in accordance with Rulemaking Task (RMT).0744.
Does the European Union Aviation Safety Agency (EASA) provides for the possibility of Air Traffic Management / Air Navigation Services (ATM/ANS) equipment supporting multiple functions, which falls into different categories and hence is subject to more than one attestation method?
EASA provides for the possibility of ATM/ANS equipment supporting multiple functions, which falls into different categories, and in such case, the attestation process for the highest-severity function would apply. For example, if one piece of equipment hosts two functions (one falling under certification and one under declaration), then the equipment would follow a certification process.
Article 4 states that "equipment supporting air traffic control (ATC) services when enabling the separation of aircraft or the prevention of collisions" should undergo certification. And Article 6 specifies that system used for meteorological services (MET) should have a statement of compliance (SoC) that "…supports air traffic services, communication, navigation or surveillance services, airspace management, air traffic flow management, aeronautical information services or meteorological services." Is the weather system used in towers classified as a system that "prevents collisions" (with the ground) or as a MET system? Should the system provide the controller with the wrong mean sea level pressure (QNH) or misleading runway visual range (RVR), it could have an impact on the separation. We all remember the incident in Paris where the wrong QNH almost led to an accident. How should it be classified? For certification or SoC?
GM1 Article 4 Certification of ATM/ANS equipment; Article 5 Declaration of design compliance of the ATM/ANS equipment; Article 6 Statement of compliance of the AMC & GM Regulation (EU) 2023/1768 at Issue 1 provides examples of which means of conformity assessment applies to various types of ATM/ANS equipment.
Item 8 of the table in GM1 notes that meteorological services (MET) typically fall under Article 6 "Statement of Compliance".
Regarding ED Decision 2023/015/R, Annex I (DS-GE.CER/DEC), in Part 3 – ATM/ANS Equipment Subject to Design Conformity Declaration, Subpart C – Surveillance (SUR), Section 1 – General, point DS GE.DEC.MSS.101 ''Scope'', three types of technology are listed: (a) Mode S; (b) ADS-B; (c) WAM. Does this refer to a classification of ground equipment? Or does it refer to which technologies/functionalities are applicable to each ground equipment? For example, if a multilateration system utilising Mode S is available, which standards would apply? Would the standards listed in Section 4 – Wide Area Multilateration be applicable? Or are the standards listed in Section 2 – Mode S ground station (MSS) also applicable?
The three technologies listed under Part 3, Subpart C, Section 1 should be understood as falling under Article 5, subparagraph 1, of Regulation (EU) 2023/1768. Article 5 applies to equipment that "...generates, receives, and transmits data and/or signals in space for the purpose of ensuring safe and interoperable air navigation...". Therefore, the three technologies require a declaration of design compliance in order to be integrated by an air traffic management (ATM)/ air navigation servives (ANS) provider in their functional system.
Section 1 – GENERAL is applicable to all equipment falling under Subpart C (i.e. Mode S, ADS-B, and WAM). In the case of a multilateration system utilising Mode S, Section 2 and Section 4 would be applicable.
However, Section 4 of DS-GE.CER/DEC at Issue 1 does not contain any requirements at this time. Since DS-GE.CER/DEC does not impose specific standards that must be included in the declaration, the applicant may select an appropriate standard. The same would be true for equipment that is not listed under Section 1 – GENERAL.
Note: EASA has planned Rulemaking Task RMT.0744 to prepare Issue 2 of DS-GE.CER/DEC, which will add requirements to Section 4. At this stage, EASA cannot specify which standard might be applicable.