New policy "ATC Frequency Management"

[Jan Doehring]

 

Hi there,

 

with disappointment I have read the newest Policy regarding ATC Frequency Management. There is a few things I’d like to mention to express my opinion on this topic, but first I’d like to say that I am thankful for a policy which finally regulates frequency usage globally. A document like this is long overdue and has been needed. However:

Information and discussion

The Policy has been posted by a bot on the VATEMEA Discord at 00:18 german time. It has been night in the most part of Europe. I woke up to a lot of messages from our vACC’s member and was overwhelmed with the questions. To be honest, I would have liked a small discussion on regional or divisional basis or at least a pre-information for the NAV-/Operations-Teams. With not even a day to go until the policy is enforced, it becomes nearly impossible to get answers to questions and formulate a statement for our controllers.

General idea

Correct me if I am wrong, but from what I can see the regulations are especially useful for big sectors that you will find in America, Asia and Russia. Europe, except for EURM and ADR, does not have such large sectors. Let’s look at Germany for example: A country smaller than most of the US states has 5 FIRs/UIRs: München FIR, Langen FIR, Bremen FIR, Karlsruhe UIR, Hannover UIR. Therefore the sectors are a lot smaller, but the airspace is still packed with a lot of sectors. This is because Germany, lying in central Europe, experiences a lot of overflight traffic and has many important airports in or around it: Frankfurt, München, Amsterdam, Hamburg, Vienna, Copenhagen, Zurich. Because of that, traffic levels can get very high and that’s why the sectors are generally speaking a lot smaller than elsewhere. Since the release of AfV, we have assigned the transceivers in such a way that every airport a center controller may cover is reachable via voice on one frequency. Changing that to the now approved Top-Down message would be a lot of work. From what I have read, the system with transceivers at airports is not interfering with the new regulation. Am I correct with that assumption?

Splits on Ground/Tower stations

Just like the center sectors, we have multiple stations on the ground. For instance München, has 3 apron controllers. We mostly staff the apron with only one controller, but sometimes a quick relief is required and the apron has to be splitted. To this end, we always had the three apron frequencies up and running in the background so that pilots will instantly be on the correct frequency. The new regulation allows that as well, but only within a timeframe of 10 min. What difference does it make, if a frequency change has to be issued 10 minutes prior or at the time the relief controller takes responsibility? In the end, an exchange between pilot and controller still needs to take place on the frequency. This is prevented if the delivery controller is sending the pilots to the right frequency immediately after confirming their clearance. Please confirm, that splits for upcoming transfers on the ground are also not allowed.

AfV Features

I know that Gary has stopped the development of AfV for now which is absolutely fine. He was an individual with the needed skills and knowledge to pull off something like that and he and his team really did a great job! But it has so much more potential! What is with RX/TX-distinction, disturbance through terrain, pseudo stations and so much more?! In my opinion the new policy takes away some of the potential and one aspect which made AfV so useful: The spontaneous opening of a frequency when you realize that it is needed. This might, to some extent, still be possible for center stations but not for ground stations.

Top-down

One of the most useful things with pseudo stations and secondary frequencies would have been, the possibility to uncouple the tower frequencies from a center frequency. When talking about realism, we should keep that in mind first, because I doubt it is likely that you will ever receive service for a controlled aerodrome on a radar frequency in real life. Of course, combining together 15 sectors and frequencies into one big one, is also not how it is done in real life. But that still makes more sense than giving taxi instructions and climb instrcutions on one frequency. It is difficult to explain, but I think you know where I'm going.

 

I'd love to hear your answers/opinions on this.

 

Best regards

Jan Doehring/NAV Chief Germany

[Evan Reiter]

I too am happy we have a policy now. I also agree that a few days' notice for implementation would have been helpful.

Like you, ZBW had several questions come up on a Sunday evening. Fortunately, it not being 1am for us, we were able to put out a statement quickly. However, all it says is that we haven't had the chance to review the policy yet and that no changes will happen until we have. Some of our pilot members were asking what this means and they got "I don't know, we got the same info you did, at the same time you did", which makes us look a little under-coordinated.  That said, given everything is "at the controller's discretion", it's not a huge issue for us that we didn't have much time to review in advance of the new policy becoming effective. It just means that our procedural documentation and AFV configuration won't be updated by tomorrow. 

Certainly, as a general point of feedback, I'd advocate for VATSIM to start providing some form of notice before changes go live. It would certainly be of benefit to us in ATC leadership around the network and would even help give pilots the chance to see the changes before they start happening.

--

Jan, since you asked, one aspect I would have liked to see included is the concept of "lateral air traffic control" to be expanded to the local environment: allow true "up/down" facilities (where there is a Tower and Approach combined in one place) to work the frequencies they do in real life, in a top down manner. Still keep the rule that ensures a pilot can call on the primed frequency and receive service, wherever they are. However, also allow a pilot to call on the published/charted frequencies and receive service there as well. Using some examples from our home airspace: 

• At KBOS, a pilot could call on any of the published the DEL (121.65), GND (121.90), or TWR (128.80) and receive service from the TWR controller if no underlying ATC was online. Regardless of where the initial call is made, the TWR will respond, with the requirement of 128.80 being primed and monitored at all times. The inherent advantage is that, if relief is needed, pilots are already on the correct frequency. This would encourage a change to the culture of "who to contact" on the network, from looking at the ATC list to looking at the published frequencies. I think that would be a good thing. (That said, pilots who didn't want to do that, or didn't know how to find frequencies, wouldn't be forced into it; they could simply do as they always have and look at what's published.)
• BOS_APP would not provide top-down coverage at KBOS, since BOS_APP is a different facility, located in a different building. 
• At KBDL, where the Tower and Approach are in the same building, the APP controller could work frequencies down to DEL. However, they would still be required to monitor and respond to calls on the primary frequency. 
• BOS_CTR would not use any Approach or Tower frequencies, except as described in the existing policy.

Note: this post reflects my personal opinion and hasn't been vetted or reviewed by the ATC leadership at ZBW.

[Matthew Bartels]

Fair points to be sure. We did submit this policy as approved to all division directors for review and comment by their local facilities about 3 or 4 weeks ago. Something that has never been done in VATSIM’s history of policy writing, and something we will continue to do in the future. Not all policies are going to be agreed upon unanimously, but we do want the membership to have more input on the direction we take our network now and in the future. 

As far as top-down ATC goes, it’s something that was heavily debated but the underlying point that drove the policy the way it did was to protect the controller’s experience. In a situation such as Evan suggests, the controller would always have to have all those frequencies monitored for a pilot to contact ATC via the chart. If a controller did not want to do that, they could be subjected to bad feedback or pressured to provide the service by pilots; or worse stop controlling because it was mandated by the local facility in order to provide that service. A key issue that was reviewed when developing this policy were controllers who operated outside of the Audio for VATSIM Users Guide, which while not official policy, recommended that multiple frequencies not be used. The data we collected from these controllers, some of which were operating up to 50 separate frequencies for every position they could possibly cover in their airspace, and forced pilots to comply with frequency changes, was largely negative and received complaints from pilots who stated it was very confusing. 

Policies are not written in stone anymore and the BoG has committed to keeping policies live and reviewing them from time to time to ensure that they still serve their purpose. So this one as well can be tweaked as we find out how it works in production. I like to think we found a happy middle ground with the first run of this policy but we will have to wait and see how it actually pans out.

[Evan Reiter]

Thanks for the response Matt.

I will say that I did receive the draft policy back on October 15 and provided the same feedback as on this thread. I didn't hear whether it went anywhere, which is why I suggested it here again. Ultimately, it's great to see the network looking for more input. I guess my comment is that publishing the policy as you did, but just with an effective date about 2 weeks after it's published publicly, might have been helpful.

Your points around top-down ATC are well taken too. I can see the logic in the way you've done it. There is definitely value in being inclusive, as you have done here. Certainly agree that there's limited value in multiple frequency changes when it's all going to the same place.

Edited November 30, 2020 at 11:37 PM by Evan Reiter

[Jan Doehring]

@Matthew Bartels Thanks for your response, I really appreciate it! That definitely clarified some things for me. 

15 hours ago, Matthew Bartels said:

some of which were operating up to 50 separate frequencies for every position

Well, I understand your approach now : ). But honestly, when thinking about it globally and keeping in mind that some controllers work outside the limits defined in the AfV manual, I see that there have to be precise rules. 

 

15 hours ago, Matthew Bartels said:

We did submit this policy as approved to all division directors for review and comment by their local facilities about 3 or 4 weeks ago

How was it distributed? Via mail, discord, etc? I'm asking because our division director did not receive the draft.

 

15 hours ago, Matthew Bartels said:

Policies are not written in stone anymore and the BoG has committed to keeping policies live and reviewing them from time to time

That's great news! Does this mean, that some of the restrictions may be lifted, once pseude stations are fully supported?

 

One last practical example and question: Let's say we are at Frankfurt Airport and there is one apron controller. However, traffic suddenly reaches an abnormally high level (which has happened before). For better sequencing and reducing the stress for the pilots, he decides to open up a secondary apron frequency. Is that process in conform with the new policy? He then asks the delivery controller to send the aircraft to the correct apron frequency immidiately after confirming the clearance. This method shall be used for an undefined timeframe until traffic reaches normal levels again or a relief controller comes online.

Edited December 1, 2020 at 12:37 PM by Jan Doehring

[Matthew Bartels]

31 minutes ago, Jan Doehring said:

One last practical example and question: Let's say we are at Frankfurt Airport and there is one apron controller. However, traffic suddenly reaches an abnormally high level (which has happened before). For better sequencing and reducing the stress for the pilots, he decides to open up a Is that process in conform with the new policy?second apron frequency. He then asks the delivery controller to send the aircraft to the correct apron frequency immidiately after confirming the clearance. This method shall be used for an undefined timeframe until traffic reaches normal levels again or a relief controller comes online.

I think you intend to follow the policy as written but am confused by your wording. Essentially if it is so busy that we need a ramp controller, then it will cause confusion for pilots and increase controller workload if they have to use another frequency. Remember that if you do not cross couple, pilots will not be able to hear each other on the separate frequencies, which can lead to lots of step ons for the controller and cause a loss of situational awareness, and if you do cross couple to mitigate that issue, then you might as well have all aircraft on the same frequency.

So the idea here is that to ease the transition as a new controller comes online, he would have his airplanes already on his frequency and just start working. We are ok with this but it needs to be subject to use only when a new controller is committed to taking a position. We don’t want to be switching aircraft onto unpublished frequencies just in case a new controller comes online. This would then be a form of top-down control that is not allowed. Hence the restriction of the controller who will assume responsibility for the new sector needs to be online already but can be unprimed as he is taking the position briefing. During this time, the other controller can begin moving aircraft to the correct frequency so that when the oncoming controller does set primary frequency his airplanes are there waiting for him.

Does this answer your question?

As far as the division directors go. We distributed the policy through the Regional VPs for cascade down to division directors and local facilities. If your division director did not get it, I suggest that he contact the Regional VP to figure out why.

[Jan Doehring]

Okay, I will ask our chief to ask the Regional VP.

 

An yes, this answers my question to the extent whether its allowed or not. Thx.

[Adrian Williams]

As with any policy, questions do arise when trying to apply it in a practical way. This policy could be really useful for a region like Africa where traffic/ATC can be quite sporadic and therefore provide for greater coverage. I have read the policy a number of times and would appreciate clarity as to whether I have understood it properly. I can see that the policy refers to it being primarily for en route/APP controllers (S4.1.15) which could allow say for Kenya Centre to use the secondary frequency to cover Uganda, both countries being within area (S2.2) of the East Africa Community  VACC/local facility. Also that an APP Controller could use the secondary frequency to control another approach position within say Nigeria i.e Lagos and Abuja or Lagos( Nigeria) and Accra ( Ghana) as all under West Africa VACC/local facility.  All these being subject to Section 4 of policy and, local policies developed and implemented by the local facility (S2.6)under the auspices of the new policy. Am I on the right track or wholly misguided?