Regulators in Europe expect 76 percent of the region’s EASA-registered fleet of airplanes to be equipped with transponders and other enabling equipment necessary to comply the EASA June 7th, 2020 deadline for ADS-B Out surveillance.
At the time of the publishing of this article, the deadline remains firmly in place, with the region’s airlines, avionics suppliers and installers now focused on the new COVID-19 work environment and an amendment to EU Implementing Regulation 1207/2011 proposed by the European Commission in February that would give qualifying airlines a three-year extension on the mandate and others a complete exemption from equipage, if their aircraft’s first certificate of authorization (CoA) registration date occurred before 1995.
In recent years, European carriers have made significant progress in upgrading their airplanes with enabling ADS-B equipment, going from just 20 percent of the fleet equipped as recently as November 2018, compared to nearly 80 percent by March of 2020. The commission posted its draft amendment to the regulation on Feb. 10, which so far has received 69 comments that show a broad agreement from airlines in support of the delay for some airplanes and the complete exemption of others.
“The latest implementation planning is based on a survey conducted in autumn 2019,” Akos Barany, ADS-B communications coordinator for the SESAR Deployment Manager told Avionics International. “For the time being we have no indication of any deviations but, given the state of affairs in the global aviation industry due recent events, significant planning changes can be reasonably expected.”
“Broadly speaking, three exemption provisions are proposed on the carriage of ADS-B and Mode S EHS, one for old airframes with a first certificate of authorization before June 7, 1995 and one for airframes scheduled for retirement within three years and one for retrofits scheduled within the next three years counting from the day of entry into force of the June 7, 2020 mandate,” Barany said. “The exemptions are devised to apply automatically and no application process is foreseen. The operator will be obliged to assert the exempt status in the air traffic control flight plan.”
However, the proposed exemption provisions are still subject to change, and could be further complicated by COVID-19 related work and travel restrictions in Europe.
What the MROs Are Seeing
“We see a significant number of smaller operators sometimes with very special configurations or not so common aircraft types that still are in need for a solution,” Clemens Walter, head of avionics and flight operations solutions for Lufthansa Technik, told Avionics. “This said, we do not have indications that the EASA will change the existing mandate so this will cause potential clashes.”
The European Commission Implementing Regulation (EU) No. 1207/2011 is applicable to aircraft with a maximum takeoff weight of 5,700 kg/12,500 lbs. and maximum cruise velocity above 250 kts. These aircraft types need the following aircraft electronics and equipment to become compliant:
- DO-260B transponders
- ADS-B Out capable GNSS/MMR/FMS
- EASA Approved STC Package
- Updated Aircraft Documentation
GKN Fokker Services, which has an installation facility in the Netherlands, thus far has provided STCs, engineering bulletins, aircraft documentation and materials to nearly 100 operators across more than 600 aircraft, Erik Louis, the company’s product manager for modifications, told Avionics.
Louis said product availability has not been an issue, and the majority of the modifications they’re completing involve GPS or Multi-Mode Receivers (MMRs), which are regarded as providing an aircraft’s primary position, velocity and time reference.
“This mostly relates to the GPS source, especially on the older Airbus or Boeing types,” Louis said. “In these cases new MMR’s or stand-alone GPS sources (with new GPS antennas) are required which due to the many configuration differences might prove to be challenging to resolve.”
Another challenge Fokker has seen for airlines is the use of supplemental type certificates on older aircraft that have existing modifications from the original production airframe type certificate. That complicates the STC process because each aircraft could require an individual engineering bulletin and installation kit, according to Marco Wagendorf, business development manager at Fokker Services.
Wagendorg said COVID-19 restrictions can also present complications for maintenance work.
“During COVID-19 lock-down testing and installation on aircraft may provide a problem with accessibility e.g. for prototype layovers,” Wagendorf said. “A difficulty for some non-standard aircraft that have various other mods installed may be that the aircraft has to be accessed to assess whether the installation of the modification can be performed for that specific aircraft configuration. Not being able to perform this assessment may slow the ADS-B out design work for that aircraft.”
One recent airline that visited Fokker for an ADS-B Out upgrade of its Boeing 747-400F fleet, Cargolux, went through a complex upgrade process that was completed in February. The Luxembourg-based carrier was seeking a more cost-effective option that would not require the replacement of their MMRs.
Finding a suitable location for the GNSS antennas on top of Cargolux’s Boeing 747 aircraft was a challenge due to the pre-existing antenna and structure interference requirements.
Tarek Sabanekh, product manager for CMC Electronics, describes the Boeing 747-400s as existing within three different architectures. These include a first configuration with no GPS and no MMR, a second with a GPSSU, and a third with the MMR.
“For the first two, the non-MMR aircraft, operators have choices either install a CMC GPS or install three MMRs, which is the normal navigation requirement for the 747-400,” Sabanekh siad. “Installing MMRs on a non-MMR aircraft can be very costly. In addition to the cost of the three new MMRs themselves, there will also be additional costs incurred due to service bulletins, wiring kits and re-wiring of the entire aircraft to comply with the required MMR architecture.”
Sabanekh said CMC has had experience installing their units all throughout different areas of an airframe. As an example, he provided the locations for the annotator panels and CMA-5024 GLSSUs on a Boeing 737F Classic. The GLSSUs were installed behind a mid-lower cabin panel on the aircraft’s interior right side.
“Most avionics LRUs need to be installed in the avionics bay,” he said. “However, this is not always possible since most avionics bays are overcrowded to begin with. Moreover, freighters in particular are heavily modified aircraft that may have side doors, rear doors, winches, refrigeration and humidity control units, so they’re notorious for being unique. There’s no guarantee that you can pass the same wire or install the same LRU in the same location on multiple cargo aircraft. Customization may be required to go around aircraft specificities.”
ADS-B Exemption and a New Reality for Airlines
There are two pieces to the puzzle European Union-registered airlines are facing right now concerning the ADS-B mandate: the exemption to Implementing Regulation (EU) No. 1207/2011 and the impact on revenues from the COVID-19 coronavirus pandemic.
On the exemption side, comments submitted by airlines about the proposal were mixed both in support of and opposed of the proposed delay. A key provision required by the European Commission is that airlines must submit a retrofit plan showing what avionics upgrades will get them into compliance within the next three years. One comment on the exemption submitted by HOP, an Air France subsidiary, notes that the airline had already started the modification of its Embraer E-170/190 and Bombardier CRJ 1000 fleet, including the modification of six total aircraft within the last six months of 2019.
“The target date of 07 JUN 2020 won't be achieved for a full fleet modification despite huge Financial Investments and engineering energy,” the HOP commenter noted, adding that Bombardier never issued a service bulletin for another aircraft type that it operates, the CRJ700 and that it is currently negotiating an upgrade with an unnamed Canadian STC holder.
Most airlines were not in a position to comment directly on how the loss of revenue due to the COVID-19 pandemic would impact their ADS-B upgrade plans. A representative for Airlines for Europe (A4E) told Avionics she expects there to be a delay to the June 7th timeline altogether.
“I am told that the regulation with the mandate for June 7th will be amended and the mandate will now be for December,” the representative said.
International Air Transport Association (IATA) CEO Alexandre de Juniac was also in favor of a delay to the June 7th deadline during his weekly COVID-19 media briefing on Apr. 14.
“Yes, we would like to postpone the date, absolutely,” de Juniac said. “Because it’s an additional cost for airlines and we’re not able in this situation to bear any additional costs on our [profit and loss statement], it’s simply impossible for us to pay.”