Nav Canada recently released their aeronautical study pertaining to the planned NAVAID Modernization Project. The aeronautical study is available to all for review on the COPA website (oldcopa.org). This project proposes to decommission most non-directional beacons (NDB) and very high frequency (VHF) omni-directional ranges (VOR) across the country in favour of a satellite-based navigation system. This proposed system has been under discussion for some time and COPA has held numerous meetings and discussions, both with TCCA and with Nav Canada, on the subject. In the process, Nav Canada has maintained that they have led an extensive consultation with all stakeholders across the country, a claim that COPA does not support based on the information we have gathered. Nonetheless, the study presents a compendium of the feedback Nav Canada received from some customers. Note that the Study does reflect some of the concerns that COPA voiced to Nav Canada, and includes the results of their consultation process, as well as their responses and mitigations.

We would greatly appreciate your reviewing this document, including your aviator colleagues, and giving us your feedback on the impact of this project on small GA aircraft operations, as you perceive it. We recognize that this is a complex document and we are happy to offer some guidance with respect to it.

Main Content of the Aeronautical Study

1. Section 3 – Consultation: the comments from various industry stakeholders and Nav Canada’s reply and mitigation to these issues. Note that most of the issues in this section are more relevant to commercial operators, but several are relevant to small GA aircraft, particularly in IFR operations;
2. Section 3 – Risk Analysis: note that this paragraph does not identify any risk or hazard. We recommend that you review appendices A and D as referred to in that paragraph;
3. Section 3 – Mitigation: we recommend that you review the relevant appendices referred to in this paragraph;
4. The various other appendices of the study identify the NAVAIDS that will be decommissioned and the proposed mitigation to be implemented, indexed per FIRs; 
5. The operational characteristics of this GNSS-based ANS will not provide complete radar coverage below 10,000 feet. 
6. The possibility of a prolonged GNSS outage is briefly discussed in different paragraphs, including the proposed mitigations.
7. In the event of a prolonged GNSS outage, small GA aircraft below 10,000 feet will be forced to navigate by dead reckoning. When in IMC, the pilot will have to climb to 10,000 feet for proper coverage, or dead-reckon to a recovery site, which could become a serious issue in either case.

COPA’s Preliminary Position

Considering the logistics and financial aspects of maintaining and/or replacing Canada’s aging ground-based Air Navigation System, we understand Nav Canada’s vision in making the best use of available resources, including maximizing the use of satellite-based navigation.

Consequently, COPA believes that the Nav Canada vision of moving to a GNSS-based ANS system is sensible, practical and efficient. This position is further supported by the fact that an increasing number of small GA aircraft are equipped with certified GNSS navigators, and this tendency keeps growing. 

COPA also perceives a very serious issue: that of potential a prolonged GNSS outage. In this situation, any small GA aircraft flying in IMC below 10,000 feet, which is the case of all small aircraft, will face an issue of significant importance.

Review and Feedback

We request that you review this Aeronautical Study, including as many fellow aviators in your area. We suggest that your review should focus on the following points:

• Review, discuss, and understand the Executive Summary and the Background information on pages two and three of the document;
• Review, discuss, and understand the aspects of Section 3 listed in item 1 (more specifically pages eight and nine of the document), as well as items 2 and 3 in the Main Content paragraph above;
• Analyze item 4 for its impact in your area;
• Determine how many of your fellow aviators actually fly IFR in IMC, and the impact items 5, 6 and 7 will have on their ability to continue to operate IFR in IMC during GNSS outages.

We would appreciate receiving feedback sent to this office (operations@oldcopa.org) by May 31, 2018 to enable some discussion at the COPA Convention on June 21-23, 2018. Your feedback and our discussions will contribute to finalizing our COPA position for submission to Nav Canada and TCCA.