Alexa, When Will the UK’s Year of PinS Be…? 

“There's No Point In Asking [CAA], You'll Get No Reply”

Believe it or not, this blog began its journey in early summer, when we had hoped not only to tell you about our trip to Pildo Labs in Barcelona, but also to herald the hard-won successful progression and anticipated implementation of a GNSS IFP (“PinS”) ACP to support the operations of one of the UK’s HEMS (air ambulance) operations - you may recall our mentioning this earlier…

2023… 2024… 2025 now appears to possibly be shaping up to potentially be the year of PinS for UK HEMS - we hope - as we will elucidate. Contrary to CAA and DfT’s 2022 drive and optimism, the resulting 5 GNSS IFP ACPs have not fared as well as anticipated on Stage 5 contact with the UK’s aviation regulator… (other understatements are available, please contact us for details).

Our delay in getting this news out to you has been a direct result of our requesting and waiting for formal notification of a delay of at least 12 months in the erstwhile aviation regulator’s ability to begin its 17-week Stage 5 (Decide) process for the 5 HEMS GNSS IFP ACPs. Hence, the title for this now our end of year offering to our loyal readership.

Where was I? Oh, yes… Latterly, my cycle rides to the office on many a beautiful, crisp winter’s day have been severely interrupted by a series of ridiculous diversions to accommodate multiple roadworks. One must question those in their ivory towers that make the decisions (informed, or otherwise…) that necessitate the simultaneous closure of several roads around a village in rural Dorset causing road users extensive disruption, diversions and detours.  It would appear that the planning function in the local council departments might be less than efficient…

Recently, while navigating these many, many detours, my frustrations have led me to start singing “Pretty Vacant” that anarchic 1970s song by the Sex Pistols: vacant in this context pertaining to “either having or displaying no intelligence”, i.e. the local authority planners who had overseen these ridiculous local diversions! 

Source: Smolensky Gallery

Hold on a minute… “Pretty Vacant” has a direct resonance with where we are in our ongoing GNSS IFP (PinS) ACP application and, as regular readers will know, we do like a music/popular culture reference or two in our blogs...

When we caught up with you last, we were a little more than mildly optimistic that the PinS odyssey was nearing its apogee - its zenith, if you will - and that our air ambulance customer would soon be the proud owner (and, more critically, operator) of a shiny new and CAA-approved IFP at their operating base. We did, however, conclude our last blog with the caveat that “[We] are very much still waiting for the man - like it or not!”...  To coin a song title from another one of my favourites, the late, great Tom Petty, “I Should Have Known It”, which contains the rather apt line “I should have known it yeah you gonna let me down”… Apposite?  We think so... and all without the aid of a crystal ball!

Source: Spotify

Quite the segue into a sitrep on where we are in our/our customer’s PinS implementation journey and the CAA’s inability to follow its own agreed timeline, resulting in (extensive) delays and ACP sponsors left waiting for the concomitant enhancement to their life-saving operational capability!

So, “what now?” you might well ask (we certainly did…); and how did it come to this? 

In our earlier blogs, we set out the pathway and the optimistic and long-awaited assertions of Ministers of Aviation various and CAA’s Director SARG, heralding the GNSS roll-out programme and DfT drive and fiscal support to the same.  It was also determined that “[t]he CAA [would] provide specialist knowledge and support on the relevant processes through its Facilitation Team, helping guide sponsors through their project.  The Programme has also been extended to included helicopter landing sites for Air Ambulance emergency services”. Fabulous, laudable and just cause for optimism in equal measure, I’m sure we all agree...

After a delayed start (which offered no corresponding movement in the proposed completion date, by the way…), the roll-out programme got underway, an agreed timeline articulated the requirements and commitments of all parties and the CAA provided its GNSS Facilitation Team to support the 5 GNSS IFP ACP sponsors; the Facilitation Team’s sterling support - both direct and indirect - must be acknowledged. The ACP sponsors (and their consultants) were put under pressure by CAA to meet stringent deadlines to satisfy DfT requirements - not CAA and CAP1616 requirements... Responding to this - frankly - unnecessary and unprecedented temporal pressure, all 5 GNSS IFP sponsors presented their respective CAP1616 Stage 4 submissions inside the deadline and waited (beer in hand) for the CAA to do its Stage 5 thing. The sponsors had met their commitments, and it was over to CAA to deliver their side of the bargain - the known and established process.

Avigation’s previous (ACP) experience is that, there is invariably open dialogue between sponsors and ACP account managers to ensure that all is on track for the impending gateway/milestone date; only fair, as any slip in date can have resource implications that could ripple out. Similarly, resource constraints on the CAA side of an ACP are communicated to sponsors expediently to highlight an identified constraint and manage expectations - less than ideal, but courteous nonetheless.

So, the agreed and promulgated GNSS IFP ACPs’ Stage 5 decision date came and went. Tom Petty’s dulcet tones grew ever louder in our ears: we should have known it… We received nothing - radio silence, nada - in the 2 weeks following the CAA’s decision date; it took a query from us to elicit any response. The CAA’s response, however, could be assessed as falling somewhat short of that which had been anticipated.

CAA and its regulator teams knew at least 2 years earlier that Stage 5 dates and associated activities were coming; CAA drove an aggressive timeline for the ACPs and agreed the same (including Stage 5 dates) with sponsors at regular intervals. In so doing, CAA had a clear and unequivocal indication of their forward-load (and resource requirements) for the concomitant Stage 5 (“Decide”) elements of the subject ACPs.  Yet, CAA appears to have failed to identify - and communicate to the ACPs’ sponsors - that CAA would not have sufficient resource in place at le moment critique… until 2 weeks after the fact...

The paucity in communications aside, is one really left to surmise that the UK’s aviation regulator lacks the ability to plan and foresee critical pinch points in its regulatory departments to ensure that it can meet the requirements of and agreed commitments to its own regulatory processes? Frankly, we would contend that such a situation is barely comprehensible; however, decorum prohibits any assessment of how acceptable such a situation might be from a national aviation regulator. Discuss…

Thus, the ACPs and the air ambulance charities’ wider (non-CAA) operations must now accept a delay of at least 12 months before the CAA will begin its 17-week Stage 5 process, which translates to at least a 12-month delay in the delivery of this critical operational enabler to support HEMS operations at the subject ACPs’ locations. This seems very much at odds with CAA’s Director SARG’s earlier assertion that “Emergency services [would] benefit from improved flight safety and increased resilience for helicopter services, which will allow landings to take place in severe weather and challenging conditions - potentially saving lives in critical situations”; he went on to offer that CAA “[would] work with applicants to deliver these benefits across the UK and enable the GNSS procedures to be implemented safely and efficiently”.

How efficient are we then led to believe might the forward planning function(s) be within the CAA?  One might posit that the outputs from the same activity did not identify - with the requisite efficiency - the need to ensure that adequate resources were in place for the CAA to discharge its regulatory responsibilities? Or, might another assessment be pretty vacant?

So, what else has been happening in 2024? Notwithstanding the foregoing, from Avigation’s perspective 2024 has been fairly routine. We have, however, a couple of noteworthy observations.

Post-pandemic Traffic Recovery

According to ICAO’s latest data, 2024 will see commercial air traffic movements exceed pre-pandemic levels, which is excellent news for not only the aviation industry, but also all the other industries who support and benefit from the movement of people and cargo by air. 

CAP1711b: Airspace Modernisation Strategy 2023-2040 Part 3: Deployment Plan

Some may have noticed that CAA heralded another evolution of its Airspace Modernisation Strategy, which sets out a series of 'delivery elements' that will modernise the design, technology and operations of airspace. Notable absences - you guessed it - any reference to air ambulances, emergency services and the introduction of HEMS GNSS IFPs!  

Are we, therefore, to conclude that the drive for HEMS to benefit from the modernisation of the design, technology and operations of airspace for improved flight safety and increased resilience is not to be afforded due consideration in the UK’s Airspace Modernisation Strategy?

Honestly, we often liken the airspace regulator’s modernisation strategy - including its approach to and prioritisation of the multitude of airspace users and their different requirements - to an attempt to rearrange items of furniture on the deck of a stricken maritime vessel...

It has been quite the year!  On a more positive note, we did have an excellent trip to Barcelona to see our good friends at Pildo Labs -  molt agradable!

And Finally...

From all at Avigation, we wish you and those around you the felicitations of the season, a wonderful Christmas and a well-deserved break, and here’s to a successful 2025 (and some HEMS PinS, please, Santa!). Oh, you know which album “Pretty Vacant” is featured on, don’t you?  See you next year!

P.S. Eat your sprouts.

#AvigationLtd #PildoLabs #Aviation #ATM #Airspace #GNSS #PinS #HEMS #CAP1616 #ACP #CAA #peaceandgoodwill #eatyoursprouts

It has been quite the year!