8. Possible impact on airspace users

In principle, and as confirmed by recent operational experience and validation activities, remote aerodrome ATS should not negatively impact airspace users. With reference to Regulation (EU) 2017/373 [4], ATM/ANS.OR.A.075 complemented by AMC1 ATM/ANS.OR.A.075(a) in Annex III to EASA ED Decision 2017/001/R [10], an ATS provider is required to ‘provide its services in an open and transparent manner’. This would include the introduction and operation of remote aerodrome ATS. The ATS provider should ensure that relevant aeronautical information is included in the appropriate products and services (see Chapter 9 below). Furthermore, the ATS provider is required to establish a consultation process with the users of its services on a regular basis or as needed for specific changes in service provision, either individually or collectively. Part of this consultation could include the contingency planning for the services provided. In any case, the ATS provider should analyse any possible impacts on airspace users when conducting the safety assessment and propose appropriate mitigation measures as part of the operations manual. Particular care needs to be taken in the case of multiple mode of operation, where the operations at different aerodromes may become interdependent (see also Sections 5.10, 6.5.1 and 6.5.2). The impacts and mitigation measures should be coordinated by the ATS provider and by the aerodrome operator with airspace users as specified in Regulation (EU) 2017/373 [4], ATM/ANS.OR.A.045 and in GM1 ADR.OR.D.027 to Regulation (EU) No 139/2014 [7] respectively. Airspace users are informed through the aeronautical information products and services — see Chapter 9 , and through other means according to Regulation (EU) 2017/373 [4]. Selecting alternate aerodromes remains a responsibility of airspace users. The objective of the ATS provider should be to allow availability of a suitable level of aerodrome ATS at an alternate. ATS providers are recommended to disseminate information in other and more interactive forms, such as regular workshops with airspace users to present amongst other things relevant information for selection of alternate(s) aerodrome(s). As remote tower operations from an RTC generate interdependencies between the ATS provision to several aerodromes, Member States and competent authorities are advised to assess the acceptability of the level of interdependence generated and take measures as deemed suitable. Those measures may include but are not limited to the selection of aerodromes to be served by the same RTC in a given geographical area and/or to the distribution of aerodrome opening hours to ensure adequate availability of a suitable aerodrome.