As of Jan 2020, there are new CPDLC and ADS-C mandates and requirements to be mindful of, but minimally-equipped operators still have options.
By Grant McLaren
North Atlantic airspace is typically the busiest oceanic airspace in the world. Each day, about 2000 aircraft traverse this region, with up to 80% of oceanic traffic passing through Shanwick Oceanic Control Area (OCA) as the gateway to Europe.
For general aviation (GA) operators, particularly those who are new to the North Atlantic Organized Track System (NAT-OTS), this can be one of the more challenging and potentially complex flying environments worldwide. Over the past couple of years NAT-OTS has undergone major regulatory and procedural changes aimed at safely reducing aircraft separation.
As of Jan 30, 2020, operators are now mandated to use datalink services (Controller-Pilot Data Link Communications [CPDLC] and Automatic Dependant Surveillance – Contract [ADS-C]) almost everywhere in the NAT-OTS between FL290 and FL410.
To legally fly most North Atlantic ops, aircraft need to be properly equipped, pilots must have required certifications, and all mandated procedures need to be followed.
All this puts additional layers of restrictions and limitations on business aircraft operators planning to fly the North Atlantic. The days of jumping in your vintage Gulfstream II, firing up the engines and blasting off to the other side of the North Atlantic are fading quickly.
In fact, according to international support providers (ISPs), many such flights have now become virtually impossible or impractical due to new equipment and certification mandates. “Over the past 2 years, we’ve seen increased complexities when operating across the North Atlantic,” says Universal Weather Master Mission Advisor Jeff Kelley.
“These days, if you don’t have High Level Airspace (HLA) approvals and associated equipment, you’re basically staying at or below FL270, unless able to climb straight up above FL420.
Many operators, especially those with older equipment or non-updated avionics, find it’s not practical to operate through this airspace, particularly since Phase 2C North Atlantic Datalink Mandate coverage came into effect in January this year.”
Jeppesen International Trip Planner Matt Neff adds, “Operating over the North Atlantic is probably 4 times more restrictive than what it was a few years ago. It used to be that if you had MNPS, HF radios and RVSM approval, you were good to go.
Today, you need to have CPDLC and ADS-C between FL290 and FL410, as separation has been reduced from about 50 nm to 14 nm, and accuracy needs to be there.” ITPS Ops Mgr Ben Fuller declares, “NAT-OTS is unique in terms of airspace management, and traffic flows can be heavy.
We recommend giving yourself 1–3 weeks just to familiarize yourself with all the rules, regs, required letters of authorization (LoAs) and current CPDLC requirements. Most clients who come to us will just wait until they have all their required LoAs, as fuel burn can be an issue if they’re not able to fly legally into or above the NAT-OTS.”
Prior to Jan 30, 2020, CPDLC-mandated routings within NAT-OTS only covered FL350–FL390, and workarounds were available for non-equipped aircraft. Today, there are fewer alternatives in avoiding CPDLC airspace.
Everything north of 80º N is still free of most datalink mandates, and there are datalink exceptions for ops via New York Oceanic East.
Routes T9 and T290, which provide a corridor of airspace between Canada and Iceland, are open to non-CPDLC-equipped aircraft, say ISPs.
Those without required datalink capabilities can still request to climb/descend through datalink-mandated airspace, but options are limited and it’s only considered by ATC on a tactical basis.
Meanwhile, non-equipped flights filing as medevac or state ops are permitted to flight-plan and fly through datalink-mandated airspace but may not get requested flight levels. “The non-CPDLC corridor crossing the middle of Greenland is a saving grace for operators who do not have CPDLC and who cannot maintain FL430 to fly over the tracks,” points out Neff.
“However, options in avoiding CPDLC airspace are more limited today than what they were earlier in the year.” Be mindful that reporting requirements kick in at every 10º longitude over oceanic airspace, and every 20º longitude while north of 70º latitude.
NAT-OTS reporting is normally done via ADS-C. Alternate and ETP planning remains as important as ever for NAT-OTS ops.
Preparing for new datalink requirements
To enjoy relatively free movement through the NAT-OTS, requirements now include datalink equipment and relevant authorizations. If your Flight Standards District Office (FSDO) is efficient, some mandated LoAs can be obtained in just a couple of weeks, but others take much longer.
“Certain LoAs for NAT-OTS can take anywhere from a couple of months to 2 years or more to obtain,” says Avfuel Account Mgr David Kang. “This all depends on how your aircraft is documented, the FSDO you’re using, and any problems you might encounter.
In most cases we recommend planning about 3 months in advance to gather required paperwork and to update all crew documents. Keep in mind that the US may allow you to get away with simply a commercial license for the right seat, whereas in Europe both pilots need to be PIC type rated with ATPs.
So, this adds another layer of requirements that not all US-based operators may be accustomed to.” Be mindful that, in order to fly legally in the European Union (EU) regulatory environment, operators require certain mandated equipment, such as radios with 8.33 kHz channel spacing.
“This has potential to open up another can of worms, as you’ll need sufficient documentation to pass a Safety Assessment of Foreign Aircraft (SAFA) check and everything needs to be in an EU-compliant format,” reminds Kang. “While this may seem to be a big task, it’s not really that bad – it’s just different.
But still it can be a lot to deal with for a 1st-time operator to Europe.” When subjected to a SAFA check, you’ll need, for example, to provide evidence of fuel and fuel reserve calculations for your route across the North Atlantic in an EU-mandated format.
You’ll be penalized if you don’t have evidence of fuel logs and correct alternate airport and ETP planning during a SAFA check. Note that your chosen alternates/ETPs must be open and weather needs to be suitable for an emergency landing. Airports in the Azores usually close at night. SMA (Santa Maria, Azores, Portugal) does have “watch status” available, whereby they’ll open in an emergency, but they need to be contacted in advance.
Greenland has fewer airports available now to use in the south, and they’re usually only open from 0800–1700 local and closed on Sundays. “Alternates and ETPs are absolutely important in terms of NAT-OTS planning.
During SAFA checks, they’ll look at your flight plan to determine if anything is missing,” says ITPS Sr Flight Planner Keith Quibodeaux. “Warnings and penalties will be issued for operators not in compliance.”
From time to time, a mistake operators make is flying a flight planned route rather than the oceanic clearance given at the coast out point when entering the NAT-OTS.
“Just because they accept your flight plan on the ground does not mean it’s the route you’ll be cleared for on the oceanic sector,” warns Kang. “When you receive your oceanic clearance, check it carefully against your flight log to ensure it’s identical, or update the FMS to reflect the new route.
Otherwise, you may be guilty of a gross navigational error (GNE). GNE busts initiate follow-ups, and this can be serious because NAT separation has become tighter and tighter.” In terms of picking up oceanic clearances for the NAT-OTS, this varies depending on direction of flight.
“For eastbound flights, you can call the tower at YQX (Gander NL, Canada) or YYR (Goose Bay NL, Canada) and obtain clearance on the ground about 30 minutes prior to departure. If en route, request clearance from Gander Oceanic at least 1 hour prior to your coast out point,” explains Kelley.
“For westbound ops, you’ll get it on the ground at airports like SNN (Shannon, Ireland) by contacting Shanwick Oceanic at least 20 min prior to departure. If en route, contact Shanwick Oceanic 30–90 min before entering oceanic airspace.”
Tips for those minimally equipped
Non-CPDLC and non-ADS-C equipped aircraft operators need to consider either flying outside the NAT-OTS, above FL410 or below FL290, or on a non-CPDLC corridor over Greenland.
Universal Weather Flight Planning Specialist Filip Aarsland explains that the boundary of this corridor is about halfway between Goose Bay and Frobisher Bay.
“You’d operate to the Goose Bay area and head north to get into this corridor, which then heads east over Greenland and Iceland,” he says. ”Other than flying in this particular corridor, you’d need CPDLC to operate within the NAT-OTS.”
As of Jan 30, 2020, when CPDLC airspace was extended to FL410, it became much more challenging for many operators to overfly NAT-OTS.
“You need to be certified and capable of flying at least at FL420 to avoid CPDLC NAT-OTS requirements, and this is affecting several operators,” says Aarsland. “Many aircraft are only certified to FL410, but you now need to fly higher than this, or drop down to FL270 or so, to avoid NAT-OTS restrictions.”
If you don’t have HLA approval, which covers from FL285 to FL420, you’ll be staying down at FL270 or below unless you’re able to climb up above FL420. Securing HLA approval from FAA typically takes anywhere from 3 weeks to 3 months.
Mid and South Atlantic crossings
Although this is relatively rare, NAT-OTS coverage may extend southward into the Santa Maria FIR or New York Oceanic at times, based on jetstream position.
Operating from, say, the Iberian Peninsula to AUA (Queen Beatrix Intl, Aruba) is normally outside NAT-OTS, but in some cases you may end up flying the NAT-OTS for a while. As there are few published airways across the Mid and South Atlantic, you’ll normally fly direct routings in this region.
However, there are oceanic position reporting requirements every 10º longitude. A handful of preferred airways also exist between Brazil and southern Africa, but this operating environment is straightforward. “We generally see random routing over the Mid Atlantic,” says Neff.
“BGI (Grantley Adams Intl, Barbados) to SID (Sal Intl, Cape Verde), for example, is mostly all random routing. And while some preferred airways exist between Brazil and South Africa, it’s still pretty much direct routing until you reach an FIR boundary.”
The North Atlantic is a region of the world where operating considerations, changes, and restrictions have been occurring fast and frequently lately.
There’s a lot to be mindful of, say ISPs. If you’re new to flying the North Atlantic or have not flown here in some time, it’s best to work with an expert who can explain everything that’s required. Take advantage of North Atlantic international procedure training, and use an ISP to help confirm all required procedures and equipment mandates.
Looking ahead, ISPs do not anticipate NAT-OTS mandates or aircraft spacing to tighten dramatically, unless some revolutionary new system or technology is introduced. “NAT-OTS spacing is now down to about 1/3 of what it was, and we don’t anticipate datalink requirements to expand down to the surface – at least not yet,” says Quibodeaux.
The original intent was to capture about 90% of traffic over the North Atlantic on CPDLC routes, and, as of Jan 30, this was up closer to 95%. Aarsland points out that there’s a big push now in the EU to require CPDLC for operations in more of the continental airspace.
“While the plan, for now, seems to be restricting new CPDLC requirements to aircraft over 100,000 lb, the general push is toward CPDLC and RNAV capabilities when approaching airports in the EU. NCE (Nice, France), for example, already requires RNP1 arrivals with enhanced equipment mandates, and we expect to see more airports in Europe introducing this in the future.”