The reporter has raised the following safety concerns in relation to the proposed new En Route Conditional Endorsement (ECE).
The reporter advises that Airservices Australia (AsA) is proposing to introduce the ECE for 'like type' controllers as a measure to prevent airspace from becoming TIBA (Traffic Information Broadcast by Aircraft). Airspace becomes TIBA in situations where there are no sector-qualified controllers available on shift for that particular section of airspace. During TIBA, clearances to aircraft are severely limited, risk is on the aircraft to transit the airspace, and most commercial airliners will avoid the airspace completely.
The reporter states controllers can receive up to 260 hours to become fully endorsed (160 hours initial sector and a further 100 hours for a second sector). With the ECE, controllers can start a shift and be instructed to operate a sector they may not have qualifications for, nor previous experience. The reporter states that ECE airspace controllers will be provided with only a 30-minute handover at the commencement of their shift to cover the geographical intricacies and potential hot spots which in times of extreme weather, high traffic flow and / or abnormal aircraft operations would normally be safely handled by fully trained and endorsed controllers.
The reporter is concerned of the potential safety consequences of controllers being directed to operate in ECE airspace and further states that the ECE is not used anywhere else in the world and with good reason.
Airservices appreciates the opportunity to respond to the concerns raised in the REPCON.
The En Route Conditional Endorsement (ECE) is a program of work that is ongoing and not yet implemented. It is important to note that the as we progress through the operational change management work, the information
below is subject to change.
We have several initiatives underway as part of a broader program to improve service resilience in the face of the post-pandemic return of air traffic. One such initiative is an En Route Conditional Endorsement (ECE), a form of Restricted Endorsement. As the name suggests, a Restricted Endorsement allows for the provision of Air Traffic Services (ATS) under restricted conditions. We currently issue a number of different Restricted Endorsements around the country. These endorsements are typically used to provide Air Traffic Services (ATS) by experienced controllers during very low traffic conditions overnight in parts of the country where it is safe to do so. It is important to note that whilst ECE is a new initiative – Restricted Endorsements have been in use for many years.
The ECE, being a type of Restricted Endorsement, could be executed across a number of units, subject to the specified ruleset. The ECE Activation Plan (AP) and ECE Letter of Agreement (LoA) will document this ruleset.
The AP is the ruleset for the activation of ECE – namely things such as hours of use (2200 - 0600 local), applicable units for use, restrictions on when ECE cannot be used and importantly, multiple traffic restrictions that reduce the already low predicted traffic volume and complexity to an even lower risk environment.
The LoA is the ruleset used by the controller whilst exercising ECE, alongside the Manual of Air Traffic Services (MATS) and National ATS Procedures Manual (NAPM). The requirement for localised knowledge and skills is minimised through these documented rulesets. The reporter is correct that the targeted usage of ECE is in last resort situations to avoid contingency procedures and implementation of a Temporary Restricted Area (TRA) impacting customers. An ATS contingency exists when disruption due to the failure or non-availability of staff, facilities or equipment affects the provision of ATS. ECE will provide an improved service when compared to a contingency event.
We continue to apply our Safety Management System to the introduction of ECE to ensure safe implementation of the change. The training requirements for ECE are being assessed by completing a detailed Training Needs Analysis (TNA). Such a TNA is prepared when airspace and/or organisational changes require creation of a new endorsement training course, or a significant redesign of an approved published course is required. The TNA is prepared with the input of ATC Subject Matter Experts (SME), National Check and Standardisation Supervisors, the Training Planning and Quality department and then endorsed through the Training Planning and Quality Lead. The purpose of the endorsement is to confirm agreement by all stakeholders that the training needs and the training strategies defined in the TNA are correct and acceptable to the various stakeholders.
This TNA will identify the skills and knowledge requirements and/or gaps and will determine the appropriate training and assessment strategy. All training courses must include emergency training. In accordance with regulations, emergency training is designed to prepare a candidate for unforeseen circumstances and may include, but is not limited to, compromised separation recovery, in-flight emergency response (IFER) and/or aerodrome emergencies, degraded modes, or contingency and business continuity. Where applicable, emergency training should include skills-based training in a simulated environment.
A mandated handover period is stipulated in the draft AP as the reporter notes. Situations such as extreme weather or abnormal aircraft operations and management of these are part of every controller’s existing skillset. ECE
activation is prevented in situations where high traffic flow exists and cannot be regulated to a suitably low volume and complexity level.
Of note, at the International Federation of Air Traffic Controllers’ Association (IFATCA) 58th Annual Conference in 2019 the Performance Based Endorsement (PBE) concept was tabled. The intent of PBE is not to be geographically constrained to a particular airspace volume. It will instead be issued to controllers performing a particular type or function of air traffic control. For instance, controllers working exclusively in oceanic airspace above FL 245 could be issued with an ‘Oceanic performance-based endorsement’. This will permit them to work any oceanic airspace within a FIR, configured dynamically to meet traffic demands. Another performance-based endorsement might be for ‘high density enroute’ permitting a controller to work in any high density enroute environment within a FIR. ECE is a step towards PBE, however will be geographically constrained using existing sector divisions.
CASA have been briefed on our progress towards the introduction of ECE over the past 12 months, most recently on 12 September 2023. The associated documentation is in the final stages of development, review and approval and can be provided once this process is completed.
The risk management plan in the form of hazard identification workshops, human factors assessments and associated safety statement are now complete and signed off. Our current rollout plan is targeting training and initial endorsement issue in October 2023.
The REPCON and response have been reviewed. CASA has been engaged with Airservices on this change and expects this to continue. CASA has not yet seen the final safety change assessment or an approval request. CASA expects Airservices to complete robust safety assessments and change management as per their Safety Management System.
The ATSB notes ECE concerns have previously been raised through REPCON RA2022-00053. At the time, CASA had not been provided detailed information on the proposed implementation.
The ATSB has since received additional concerns as above. The ATSB therefore asked Airservices and CASA to provide any updates / comments on the proposed implementation and risk management plan.