This came via email a day or two ago. I haven’t read it but it appears to regulate the use of GPS databases in some way. On a quick look it looks like a regulation to regulate what people do anyway…
A tricky issue would be if there is something there which prohibits flight with an out of date database – even if your AFMS authorises such flight provided you have verified that nothing has actually changed.
I don’t see much change for us, except that LoA now becomes Type 2 DAT provider.
if there is something there which prohibits flight with an out of date database
IANAL but I don’t see a problem here.
The operator should distribute current and unaltered aeronautical databases to all aircraft requiring it
You could always argue that you didn’t intend to shoot LPV approaches (because typical AFMS supplements require current databases for LPV approaches), and your AFMS supplement didn’t require a current database, so the aircraft didn’t require it.
However, the regulation IMO completely misses the problem. The problem is the way the countries and the ANSP publish aeronautical data. The FAA directly publishes a high quality electronic database obtainable for basically only a handling fee. All a navigation device manufacturer has to do is convert it to the format understood by its devices. Contrast that to europe. EAD was supposed to do just that, but it has been a failure so far, there are even AIC that prohibit its use (here and here). So a database provider first has to hunt down 39 paper AIPs and try to make sense of them. This is something that EASA should address.
Regarding the economic impact analysis: Impact analyses from EASA always seem to only explore the status quo and more regulations, never less regulation.
4.1.4, who is affected?
There are today … 1 DAT provider Type 2 ‘overseen’ by the Agency.
Isn’t that an implicit admission of failure? It means there is an artificial government created monopoly that causes expensive and low quality products. Granted, nothing new here, I haven’t checked the GTN but the Jepp database for my previous GPS device had all SIDs and STARs coded completely wrongly (in the sense that if you followed its guidance, you’d be in deep trouble) for LSZH for years. I reported that but Jepp wasn’t interested at all.
It not only puts us but also the agency into a bad bargaining position – if the agency wanted something to change, Jepp could tell them either we do it our way or quit, and the agency couldn’t do a lot against that, apart from grounding most of european air traffic.
4.4.4, Economic impact
New DAT providers applications:
Am I the only one who finds this outrageous? That means it’s well over a million US$ just for the DAT type 2 application. No wonder noone wants to compete.
Following years (oversight) 500 hours
I.e. about 12 work weeks for a person just to keep the agency busy every year and just for the extension from navigation to aeronautical databases. Again outrageous, IMO.
Finally, 5.1. Affected regulations.
1034/2011 and 1035/2011 basically apply to ANSP, while 965/2012 only applies to CAT, so I don’t even see the authority of EASA to regulate this for us.
