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15th October 2024

Inappropriate NOTAM

Initial Report

Earlier this summer, [Airport] issued the NOTAM that I have attached a copy of. NOTAMs are a contentious issue for nearly all involved in aviation and in my view this NOTAM is an example of how the system should not be used. There is far too much text – 222 words in the main body of the NOTAM. Essentially the NOTAM is a reminder to crew to comply with speed restrictions and MROT, but includes a lengthy explanation of why. Whilst I appreciate what the airport is trying to do here, a NOTAM is not the place to explain these reasons and the airport should be finding alternative means to communicate with operators. The NOTAM should be short and to the point as to what is required. The risk here is the NOTAM becomes meaningless as there is too much to be read. In fact I had to read it several times to interpret what it is actually asking for.

Whilst I understand the issues [Airport] has in trying to sequence arrivals, I don’t think this NOTAM will do anything to help the situation. It may in fact make it worse in the short term by increasing confusion for the reasons I have outlined above. I’m based at [Airport] and operate in and out several times a week; whilst I don’t pretend to always get it right, I have a pretty good idea of what ATC expect from us. I can see a crew visiting [Airport] for the first time would read the NOTAM, then their plates, and probably be at a complete loss as to what ATC were expecting from them.

NOTAM Text

PROCEDURES FOR INBOUND AIRCRAFT:

PILOTS SHOULD TYPICALLY EXPECT THE FOLLOWING SPEED RESTRICTIONS TO BE ENFORCED: 220KT FROM THE HOLDING FACILITY DURING THE INTERMEDIATE APPROACH PHASE THEREAFTER, AND UNTIL ESTABLISHED ON FINAL APPROACH, THE HIGHEST POSSIBLE SPEED WITHIN THE BAND 160-180KT WHEN ESTABLISHED ON THE ILS AND THEREAFTER UNTIL 4DME, 165KT WITH A TOLERANCE OF +/- 5KT. THESE SPEEDS ARE APPLIED FOR ATC SEPARATION AND RUNWAY CAPACITY PURPOSES AND ARE MANDATORY. IN THE EVENT OF A NEW (NON-SPEED RELATED) ATC CLEARANCE BEING ISSUED (EG AN INSTRUCTION TO DESCEND ON ILS), PILOTS ARE NOT ABSOLVED FROM A REQUIREMENT TO MAINTAIN A PREVIOUSLY ALLOCATED SPEED. ALL SPEED RESTRICTIONS ARE TO BE FLOWN AS ACCURATELY AS POSSIBLE. AIRCRAFT UNABLE TO CONFORM TO THESE SPEEDS SHOULD INFORM ATC AND STATE WHAT SPEEDS WILL BE USED. IN THE INTERESTS OF ACCURATE SPACING, PILOTS ARE REQUESTED TO COMPLY WITH SPEED ADJUSTMENTS AS PROMPTLY AS FEASIBLE WITHIN THEIR OWN OPERATIONAL CONSTRAINTS, ADVISING ATC IF CIRCUMSTANCES NECESSITATE A CHANGE OF SPEED FOR AIRCRAFT PERFORMANCE REASONS. THE SPACING PROVIDED BETWEEN AIRCRAFT WILL BE DESIGNED TO ACHIEVE THE MAXIMUM RUNWAY UTILISATION WITHIN THE PARAMETERS OF SAFE SEPARATION MINIMA (INCLUDING VORTEX EFFECT) AND RUNWAY OCCUPANCY. IT IS IMPORTANT TO THE VALIDITY OF THE SEPARATION PROVIDED THAT RUNWAY OCCUPANCY TIME IS KEPT TO A MINIMUM CONSISTENT WITH THE PREVAILING CONDITIONS.

Airport Comment

The issue we had was the urgency to get this out to the community; the NOTAM bridged the gap between implementation and the AIRAC Cycle. Unfortunately the length of the NOTAM was unavoidable due to it having to be exactly as the proposed AIP entry. This NOTAM has since been removed as this information is now published in the AIP.

CHIRP Comment

Notwithstanding the Airport’s comments about the need for urgent publication of the procedure, the reporter has a point about the NOTAM’s length and the safety implications of pilots becoming word-blind when reading long and complex NOTAMs. That being said, and whilst sympathising with the reporter about always striving for brevity in NOTAMs, there’s a balance to be made in ensuring enough information is passed on. But including things like “ALL SPEED RESTRICTIONS ARE TO BE FLOWN AS ACCURATELY AS POSSIBLE” and “THE SPACING PROVIDED BETWEEN AIRCRAFT WILL BE DESIGNED TO ACHIEVE THE MAXIMUM RUNWAY UTILISATION WITHIN THE PARAMETERS OF SAFE SEPARATION MINIMA (INCLUDING VORTEX EFFECT) AND RUNWAY OCCUPANCY” seems like the sort of extraneous content that is probably unnecessary.

With regard to the reporter’s criticism of confusion about the NOTAM and the exisiting operating procedures, the point of the NOTAM was to highlight a change from the standing procedures and so it would have primacy over those. We think that that would be understood by those reading the NOTAM but the bottom-line remains that NOTAMs should be as brief as possible and probably only need to replicate the absolutely essential parts of any AIP entries when outlining new procedures.