EBAA welcomes the amended version of the Data Link Services Implementing Rule which clearly states exemptions for aircraft ‘which have a certified maximum seating capacity of 19 passengers or less and a MTOM of 45359 Kg (100000 lbs) or less, with a first individual certificate of airworthiness issued before 5 February 2020;”

While we warmly welcome this important amendment, several implementing issues still need to be resolved to ensure a smooth deployment of the system;

·         The lack of capacity of the data link system leads to oversaturation, meaning that some ATC messages are not going through.

·         The required communication ground infrastructure is not yet in place, or only partly.

·         More clarity is needed for airspace users that do not hold any agreement with data link service providers

·         Some of the technical requirements need to be better explained and addressed. 

More than 700 aircraft were recently asked to not use data link avionics in some parts of the European airspace (e.g. Maastricht area)  showing the limits of the system as it stands today. The current AOC activity is already saturating the data link system and the situation is not likely to improve anytime soon. The latest generation of aircraft boast more sophisticated systems which continuously emit AOC messages raising capacity demand to unprecedented levels.  Whilst multifrequency provides additional capacity on the short term, a more sustainable solution needs to be found. Business aviation operators don’t usually have significant AOC activity. Most of the newcomers get the datalink equipment onboard solely to comply with the ATC mandate,  while airlines also use this for AOC messages. It is therefore essential to find a workable avionic solution, suitable to all airspace users, and to set up a proper datalink infrastructure (Model D as initially proposed in the ELSA study). If a trade off between ATC messages and AOC messages is required, thesystem should guarantee the flow of ATC messages as a preference at any time. Airspace users that do not hold any agreement with data link service providers should not have any constraint in sending ATC messages.

We will continue to work with the European Commission, EASA and our partners to help find answers that benefit all airspace users.