No Regulatory Impact Statement for CASA GAAP Changes

[Dick Smith]

Under the direction given by CASA for Airservices Australia to limit numbers in the circuit and to move to Class D airspace at GAAP aerodromes, the CASA document says,

“Regulation Impact Statement. The Office of Best Practice Regulation does not require a Regulation Impact Statement because a preliminary assessment of the business compliance cost indicates that the amendment will have only a low impact on business”.

I have had emails and phone calls from business operators at these airports who say that this is not true and that the changes have had a major financial effect on their business. How about giving us some details here?

[Rudder]

How the hell could they arrive at it having minimal financial impact without assessing the organisations and getting feedback.

[Dick Smith]

Interesting ! No facts provided after 6 hours!

[VH-XXX]

Perhaps everyone is out idling on the tarmac waiting for a circuit spot and too busy to respond?

PPrune user "Ultralights" was saying recently about this that the taxi times were something like 45 minutes as Bankstown, surely this would be an example of a financial impact? Ultralights?

[ARFOR]

Mr Smith,

A very good question!

Presumably you would also expect a thorough Regulatory Impact Statement for changing RPT (PTO) serviced ICAO D airports to GAAP (FAA D and E)!

[LeadSled]

ARFOR,
That is the requirement.
You probably already know where to find the Airspace Act, which includes the Airspace Policy, you will find the OBPR handbook equally easily.
There is on point that should, perhaps, be considered. The CASA DAS/CEO has the power to issue a certificate negating this requirement, if it is an urgent/critical safety issue, or words to that effect.
Tootle pip!!

[YPJT]

Whilst many have been pontificating and posturing back and forth on these threads, some have actually made the trouble of contacting the right people within CASA.

There is going to be some clarificaton on this whole issue in the next few days.

[Charlie Foxtrot India]

Hi Dick,

Perhaps people are unwilling to share their financials on a public forum.

However I've already given you the retail analogy of losing up to 40% of floor space and up to 40% of trading hours, because that is what reducing the circuit availability from 10 to 6 will do. Add the internationals having to increase the time to train the stude by up to 40% and it starts to get very expensive.

So far we are seeing lost flights in the region of 20% by managing it carefully. After Staurday's debacle at Jandakot, I now have to consider further limits on ops to avoid having my staff exposed to the chaos at the busy inbound times. So lose another two hours of trading a day there.

Cheers

[ARFOR]

Leadsled
the Airspace Act, which includes the Airspace Policy, you will find the OBPR handbook equally easily.
There is on point that should, perhaps, be considered. The CASA DAS/CEO has the power to issue a certificate negating this requirement, if it is an urgent/critical safety issue
100% Correct. Rightly or wrongly, the review of MAC's and the like around GAAP + an audit has perhaps driven a decision in haste for which we are most all in agreement as to effect and perhaps even remedy.

The same 'safety urgency' driver does not exist for RPT (PTO) regional D and C towers. To make the same arbitrary (GAAP to D) type change to those services at this point would be very difficult to defend! ;)

[Ultralights]

it hasnt effected us too badly, just some booking shuffling for circuits lessons before lunch hr, so if there are major delays, it doesnt push other bookings. fortunatly most of our training is done during the week, and we now conduct circuit work at YSCN. if there are a few booking for circuits on weekends, we will take an aircraft to YWOL. or get them in early at YSCN. before 9 am.

financial effects are minimal.(from my POV anyway) booking nightmares, well, yes.

[OZBUSDRIVER]

Leadsled....that would be "touche, mon ami":ok:

ARFOR- two for two....:E

[Dick Smith]

Changing our existing D procedures to NAS FAA D means simplifying the radio calls and standardising so all non radar towers in Australia have similar procedures.

Must be safe as AsA operate towers in the USA and they wouldn't do so if it wasn't- too much liability to the board members.

And yes I would do a RIS.

[ARFOR]

Clearance request and issue is only different with 'the implied' clause. The operation of and controls for each are the same. It is a mute argument and clutching at straws!

AsA no doubt won a contract, to provide the same services that existed at the day of take-over, nothing more, nothing less!

RIS, from where, at what cost, to improve how?

[Chimbu chuckles]

Dick people directly effected have come on here day after day outlining the very serious real life detrimental economic effects and added risks they are facing almost daily and your only input is to repeat your mantra,

Changing our existing D procedures to NAS FAA D means simplifying the radio calls and standardising so all non radar towers in Australia have similar procedures.

Must be safe as AsA operate towers in the USA and they wouldn't do so if it wasn't- too much liability to the board members.

And yes I would do a RIS.

I think your grasp on reality is getting more tenuous as time goes by.

[Dick Smith]

Chimbu, The posts have been refering to changing our GAAP procedures. And I agree with the posts as the restrictions introduced by CASA at these GAAP airports are not restrictions that exist anywhere in the USA under NAS.

My post refers to our non GAAP airports (ie our existing class D procedures).

[ARFOR]

Mr Smith,

On the regional multi use RPT ICAO D airspace discussion, in summary then, you would prefer

1. A GAAP 3nm CTR up to 1,200agl, with class E steep steps above

In preference to

2. The proven, safe, flexible, efficient ICAO D and C (global standard) arrangements that provide affordable protection to RPT (PTO) and all other airspace users (including low time GA pilots)

Australia currently enjoys very high safety and efficiency levels from these tried and true formats, why on earth would you have a bee in your bonnet about this classification? Surely it is not that annoying bothersom and no doubt embarrassing 'roll-back' business? :=

In the extremely unlikely event our ICAO D and C areas reached or exceeded the MAC and NMAC levels (and cost of provision) of the US brand of D and E you are auctioning, then lets do lunch!

[The Green Goblin]

I think what Dick needs to do is actually write down in words that we can understand what we already have, address what he wants changed and the logical reason for doing so.

Not everybody understands what NAS is or how US airspace works. Who would? Australias airspace is difficult enough to get your head around at the best of times.

So far I only ever see Dick micro managing, throwing facts and figures and discussions with people most of us industry folk have never heard of.

So what do you stand for Dick and what do you want changed? (In plain English that say a GFPT student may understand!)

[goin'flyin]

And Dick, while you're at it, do it in one of the already running threads regarding the recent and proposed changes - let's not start another thread on the same ongoing topic.

[Dick Smith]

Green Goblin

A good question.

In the early ‘90s, a panel at ICAO (International Civil Aviation Organisation) decided that rather than have dozens of different names for different classifications of airspace in different countries, that an alphabet code system should be placed on airspace so that it would be easily interpreted by pilots flying internationally and for pilots training in one country and then moving to another.

This was all good common sense.

It was clear that when the letters were allocated from G to A, that the allocation was based primarily on the US airspace. In fact, the FAA was one of the first to change their airspace categories (one was called “visual exempt” for example) to A, B, C, D, E and G. There was, of course, an advantage with this. If you see E marked on a chart – which you do in the terminal area in France for example – you know that IFR will be separated from IFR and given known VFR traffic, and that VFR aircraft are not separated from anyone.

The US changed all its non-radar towers to Class D airspace - yes, even the lightly trafficked ones in country towns right through to the busiest non-radar tower airports with over 300,000 movements per annum. This meant that it was possible to fly anywhere in the USA and know what obligations you had as a pilot and what service would be given by Air Traffic Control.

In Australia, when I was Chairman of the CAA, we moved to the categories A, C, D, E and G during a process called the “AMATS changes”.

Under the more recent Australian Government decision to move to the FAA (US) NAS airspace system, it was decided that all non-tower airports in Australia would go to NAS Class D. This would mean there would be a harmonisation of procedures at all non-radar towers. Very simple for compliance and, therefore, for safety.

So how do we fix the GAAP unique category – which would mislead pilots coming from overseas and pilots who trained here when they got a job overseas?

We could change all of our non-radar towers to the unique Australian GAAP and notify a difference to ICAO. Unfortunately, pilots from overseas would not really have a clue as to what service was provided. Some may say, “who cares”, however we have an internationally harmonised road system – why can’t we do this in aviation?

Alternatively, we could change our GAPP airports and other non-radar towers to the US NAS Class D. We could, of course, go to ICAO Class D where a full clearance request must be made and repeated every time a VFR plane flies into D. This verbosity sometimes would jam the frequency at busy airports like Bankstown or Moorabbin.

The decision was made, and is now Government policy, that all of our non-radar towers should go to FAA NAS Class D. This is very similar to GAAP, however IFR aircraft are separated by IFR if each pilot is in VMC but only if each pilot desires this.

In our unique GAAP procedures, whether a pilot wants it or not, IFR aircraft are not separated from other IFR when VMC exists. Of course, in the US system, one or the other pilot simply has to (cancel IFR) or use other terminology so that the resultant service is similar to what we now offer in GAAP.

One advantage of FAA NAS class D is that clearance requests are simple statements like “Coffs Tower Kilo Tango Kilo is five miles to the south inbound with Alpha”.

The controller would simply come back saying “Kilo Tango Kilo join downwind for runway 30. Traffic is a 737 on final for 30”.

Another advantage of US NAS Class D is that VFR aircraft do not have to give a verbose departure call. This is, of course, similar to GAAP. But the change would apply to all of our non-radar towers, reducing radio congestion and complexity or low-time pilots.

So, it’s all about harmonising our system with one of the most experienced aviation countries in the world – the USA. In fact, Canada and New Zealand also follow the US non-radar tower procedures.

There are those who want to keep the two different systems in Australia, ie. GAAP at some airports and Class D at others. This, I believe, comes mainly from a resistance to change.

Now I’m sure you will ask, “why hasn’t CASA explained the reason that they have required Airservices to move to Class D”? I believe this is because there is a group within CASA who don’t want any change at all. Their minds are set in concrete.

I have even spoken to people in CASA who want to go back to the old mandatory full position reporting for VFR. This would cost a fortune for our industry and would give no measurable increase in safety.

Our present Government policy is that GAAP should change to US FAA NAS Class D. Surely, it is sensible to harmonise all our non-radar airports so all the procedures are similar and that pilots coming from overseas, and Aussie pilots going overseas, will be trained and know what service is provided.

[The Green Goblin]

Sounds sensible enough Dick. So are they going to remove the inbound points at a GAAP too? And if so will that mean you can approach from any point to the circuit provided you are cleared to do so? Or will we have a similar operation at the GAAP's to somewhere like Essendon?

I have not flown into the GAAPs in a long time but can see that this could cause a little confusion for some students who often struggle to work out how to join from 1 of 2 points at somewhere like Jandakot. (Adventure World and Forrestdale lake)

If we can have increased traffic processed in a safe manner minimizing delays to traffic (which in turn saves operators and students money) then I am all for it.

[Dick Smith]

Probably the most proven and safest system is to have some recommended inbound routes at really busy airports. This spreads out the collision risk compared to one or two VFR reporting points.

Different recommended altitudes for inbound and outbound would also add to safety.

[Dick Smith]

Cynical, calm down- we already have different altitudes for going into the GAAP and leaving it!

So my statement complies with your wish for no change.

[LeadSled]

Folks,
One of the great mistakes, perpetrated by those opposed to "alphabet airspace", is that A through G represents "levels of safety". ie A is most safe, G is least safe.

This is quite the opposite of the fact that: A through G represents levels of service provided in that airspace. In Dick's post explaining the history of A through G, this is very clear.

If the traffic analysis is correct, the level of service (or no service where there is little or no traffic) ensures that the "separation assurance" targets are achieved. Be clear that the separation assurance target is the same for all airspace. Eurocontrol make it quite easy to see their standards, and they also regularly publish an analytical report on the achieved results, compared to the standard. I mention Eurocontrol just to make it clear that FAA is not unique.

In a properly managed system, all airspace is equally safe from MAC, from G to A.

Prior to AUS/NAS being adopted as Government policy, in reality all Australia did was give A through G names to existing airspace, meaning we have never achieved all of the possible savings of only providing necessary services, to achieve the target separation assurance. All providing additional services does is increase the cost, without "increasing safety", because the MAC risk is already so small, that no additional level of service will reduce the risk.

In short, a classic case of economic waste, and we all pay. If anybody has any doubts about this, look up the history of the Airservices risk analysis for mid-level C versus D, the final "decision" is a triumph of (Australian cultural) fantasy over (ICAO compliant) fact.

Thus the nonsense of C over D, where the "services provided" (in reality restrictions on VFR) increase as the MAC risk decreases. Have a look around the world , it is not only US that has E over D. It is not "automatic" that high level airspace is A or C.

Somebody mentioned that C over D was "world's best practice" or words to that effect. All that proves is that the meaning of world's best practice is not comprehended. Any system that produces economic waste, cost without benefit, by definition cannot be world's best practice.

Those of you who will dispute the above, and undoubtedly will, cannot change the facts, the above is easily verifiable fact.

Tootle pip!!

PS: It was the FAA "VFR exempt" ( and equivalent in several other countries) that mostly became E.

[le Pingouin]

Funny, I distinctly remember being fully conscious when the airprox near LT occurred. Sounds like worlds best practise to me :ugh:

[Capn Bloggs]

Lead,
Somebody mentioned that C over D was "world's best practice" or words to that effect. All that proves is that the meaning of world's best practice is not comprehended. Any system that produces economic waste, cost without benefit, by definition cannot be world's best practice.

"Economic waste" and "cost without benefit". Please produce the numbers on cost, and then links to the studies that confirm C over D is costly with no benefit. Thanks.

[peuce]

... or, the Cost-Benefit Analysis for dumping our current GAAP system !

[LeadSled]

Funny, I distinctly remember being fully conscious when the airprox near LT occurred. Sounds like worlds best practise to me :ugh:LePin,

Why not pay a visit to the ATSB web site, have a close look, and then come back and tell us that Airprox's never happen in Australia in C or A ---- that Airservice (and it's predecessors) have a pristine record --- after all, we never have TCAS resolution advisories in A or C in Australia --- Do we????

Yes we do, and by no means can it be said that ATC is always blameless.

I have been around long enough to remember Ansett and TAA fitting early model TCAS, long before any Australian regulatory requirement, because of the frequency of "loss of separation" incidents in "controlled airspace". Those two domestics had to be seriously concerned, to have committed that money, "voluntarily" fitting equipment that was not mandated ( and wouldn't be for years) by regulation was hardly common, and is not common, to this day.

Bloggs,
You are just as capable as me of sorting through the mass of bumpfh on AA, ASTRA etc., and when you do, you will find the risk analysis referred to. The result you will read is that both C and E provided a "separation assurance standard" several orders of magnitude less (better) than the ICAO recommended target.

In fact, in statistical terms ( and this is all statistics) in both cases the probabilities were well into the "vanishingly small" range, the statistical equivalent of zero. From memory, 1E12 or thereabouts, but don't quote me. For those of you who have a problem with statistics, sorry, folks, but that's the way it is done.

I really don't mind if you want to believe it or not, but there are costs to both operators and the service provider ( even though AsA claim otherwise) of having C rather than E, where the traffic does not justify C.

If several Regional airlines ( and their unions) do not want to take advantage of the potential savings on offer from E, compared with C, that is their choice, but that should not be foisted on every other operator, IFR or VFR.

Tootle pip!!

[OZBUSDRIVER]

Leadie, selective with your history....How much radar coverage was there near BHI and all those other little incidents in PROCEDURAL C...AN and TN could not rely on the CAA/DCA to provide separation over the GAFA so.....what would you do?

Flew that airspace a few times too...VHF starts running out somewhere ABM LRE going north(this is in 1978)and the only contact on the HF is Honollulu...not good for continuing in CTA without radio contact.

[LeadSled]

OZ,
Look a little harder, there are no shortages of examples in the J curve and terminal C. And that was where the DC-9 and B 727 did spend most of their time.
Tootle pip!!

[le Pingouin]

Lead, if a new system is introduced and it results in an airprox how can you argue that it's an improvement? Particularly when said systen was a significant & direct cause.

[le Pingouin]

Lead, would you care to provide some figures to support the claim that it's cheaper for AsA to provide E than C? It still needs a bum in a seat.

I fail to see the hordes of IFRs & VFRs electing to avoid airspace you seem to think exist. Care to support that as well?

[ARFOR]

Leadsled

Part of what you say in isolation I agree with, that being that properly assessed volumes of airspace should be serviced to provide an acceptable cost and safety outcome.

What is missing from your summary is the incalcuable number of collision opportunities each and every day that are successfully resolved by the operating procedures, be they pilot to pilot in CTAF G, or ATC provided in D, B or A classes of airspace.

The safety outcomes of each go to the acceptable risk benchmark applied to the area of operation and the classification of operations contained within.
One of the great mistakes, perpetrated by those opposed to "alphabet airspace", is that A through G represents "levels of safety". ie A is most safe, G is least safe.
It is not possible to sustain the argument that classes of airspace do not provide different levels of safety. It is correct in my opinion to say that where operations (volume and particularly type) has changed in the period since proper objective establishment criteria were mandated, then it is quite probable insufficient protections exist in some locations.

A separate argument is what classification provides the most comprehensive safety outcome whilst retaining reasonable flexibility, where diverse options flow out from a relatively static threshold cost base such as the establishment of a proper ATC service be it same/similar cost C or D or E )

Good discussion!

[Capn Bloggs]

Leadsled,
Hang on sport!
You are just as capable as me of sorting through the mass of bumpfh on AA, ASTRA etc., and when you do, you will find the risk analysis referred to.
You are the one making the claims; YOU provide the evidence.

I really don't mind if you want to believe it or not, but there are costs to both operators and the service provider ( even though AsA claim otherwise) of having C rather than E, where the traffic does not justify C.

Well, what are they??

[Dick Smith]

Keep your minds in concrete. Lets bring DC4's back to replace all those 2 engined 737's and there like.

4 engines gotta' be better than 2 any day-- I don't believe the so called "experts" who tell us differently!

[ARFOR]

I fail to see the relevant link between DC4's, B737's, ICAO and FAA!

[Joker 10]

AH M'Seiu Le pingion,

Lead, if a new system is introduced and it results in an airprox how can you argue that it's an improvement? Particularly when said systen was a significant & direct cause.

And if the existing system results in an airprox is it thus less safe ???

Or could it just be that the random nature of aircraft tracks will from time to time result in statisical probabilty that 2 aircraft will be close to one another inside airspace that requires stutory reprting due to the reuglatory nature of the airspace envelope ????

Change for the sake of Change is a dangerous place to be !!!!!

[le Pingouin]

And if the existing system results in an airprox is it thus less safe ??? Who knows without analysis. What do you call having a serious airprox weeks after a new system is introduced?


Or could it just be that the random nature of aircraft tracks will from time to time result in statisical probabilty that 2 aircraft will be close to one another inside airspace that requires stutory reprting due to the reuglatory nature of the airspace envelope ????Greeeeaaaaaat! So you're quite happy to randomly place high capacity RPT aircraft in close proximity with VFRs in a totally uncontrolled manner? Except that it wasn't random. The VFR was flying on a known IFR track at a level that made a conflict far more likely.

And golly gosh! Then it happened at CANTY too!:ugh:

[peuce]

Leadsled,

The result you will read is that both C and E provided a "separation assurance standard" several orders of magnitude less (better) than the ICAO recommended target.

Call me dumb ... but how on earth is separation assurance achieved in Class E airspace, where VFRs operate .. as required :confused:

Surely Class E has a higher (worse) order of magnitude than Class C? Ah, but re-reading your words, that's not what you're saying is it?

You're saying that they both are less than the standard target of, say, 10 ... but Class C could be a 2 and Class E could be a 9 ...

See, that's where all this statistics type stuff can get confusing for us mere mortals :=

[LeadSled]

Folks,

Not surprisingly, there has been confusion and not a little fear about what is proposed by April next year at GAAPs ---- will it be "FAA D" or "ICAO D", particularly given the present arbitrary movement limitations imposed on GAAPs. Also given the range of possible interpretations of what has been published about this matter.

I can say, without fear of contradiction, that if you ring Peter Cromarty, Head of the Office of Airspace Regulation at CASA, the answer is FAA D.

Peter ( as has Dick Smith) makes the point that the FAA regard their implementation of D as ICAO compliant, including the differences, but as a convenient description, we understand what "FAA D" means in practice.

It's about time to push for ALL D towers and GAAPs to be the same standard, the FAA implementation of ICAO D, it would make life a lot simpler for a lot of people. Properly handled, it will quickly get us back to long standing GAAP capacity, and the withdrawal of the current crippling movement limitations.

Tootle pip!!

[Charlie Foxtrot India]

Thanks Led.

Is there somewhere we can look at a refererence to see exactly what we are up for, and what the differences are between FAA D and ICAO D. Is one like being a little bit pregnant? If it is all about standardisation why are there two Class Ds.

Was CASA planning to tell us GAAP operators any of this at some stage?

And is Dick going to tell me how I can save money by having less trading capacity and more controllers to pay for?

[Capn Bloggs]

Leadsled,
One of the great mistakes, perpetrated by those opposed to "alphabet airspace", is that A through G represents "levels of safety". ie A is most safe, G is least safe.
Mistake? The only "mistake" is that you make such a claim. The whole issue here is not whether each level of alphabet airspace is as safe as or less safe than the next level (anybody with half a brain can see that it depends on the traffic level) in absolute terms; the issue is what airspace level is applied to a certain traffic level. If I take an airport with a certain level of traffic then the safety of that airport definitely depends on the airspace level. A-maximum safety; G-least safety. Keep your arguments "commonsensical" please.

I'm still waiting for the details of:
there are costs to both operators and the service provider ( even though AsA claim otherwise) of having C rather than E, where the traffic does not justify C.

[mostlytossas]

Captain Bloggs, You obviously don't own an aircraft. Let me tell you from someone who does and pays AsA each year for the tower and en route services they provide. Each time you go flying in any airspace you get charged for it. Therefore if you are VFR and fly in say C airspace this will incur a charge for approach/tower service. If however you fly in E airspace no charge is payable because as VFR you recieve no service and are invisible to the system as it were. Flying IFR ofcourse incurs far greater charges because the service recieved is far greater. Savvy so far?
Savings are made because in E airspace less controllers are required than in C as there are far fewer IFR aircraft out and about than VFR. Even IFR aircraft can choose to fly VFR and save if in VMC. Airlines ofcourse don't because at the altitudes they fly at are always in ATC airspace among other reasons. For GA and private operations however it is common practice to save money. Now why would anyone wish to go back to the old full reporting etc ways and increase costs, make flying less affordable, less jobs etc? FAA class D? Bring it on!

[LeadSled]

Bloggs,

Old mate, all you have revealed by your last post is that you have no idea what "Separation Assurance" means in matters of airspace management, no do you have an inkling about the basis of ICAO Airspace classes.All I can recommend is a remedial reading course amongst the cubic meters of paperwork on the subject, I often recommend Eurocontrol, at least its gets you away from the FAA.

Using letters A through G was always going to be misrepresented as some kind of safety scale, maybe ICAO should have been given colour names, (or kept the original US descriptive names) or something not associated with a scale, then people like you would not get the wrong idea.

To those others who have a problem with the term, a question, does Life Assurance assure life??

Tootle pip!!

[ARFOR]

Leadsled a snapshot for the futrure!

mostlyatossers quite, until the dullist sharks get a sniff :E

Go hard you paper warriors!! ;)

[mostlytossas]

That's what I meant. If I fly into Canberra for example will be charged for terminal charges, Tower,approach etc all class C. Got the accounts to prove it. Then there is the airport parking daily fee...but don't start me on that.:}

[Capn Bloggs]

Thanks Direct No Speed.

Mostly Tossas,

Each time you go flying in any airspace you get charged for it. Therefore if you are VFR and fly in say C airspace this will incur a charge for approach/tower service. If however you fly in E airspace no charge is payable because as VFR you recieve no service and are invisible to the system as it were. Flying IFR ofcourse incurs far greater charges because the service recieved is far greater. Savvy so far?

I suggest you have a read of this:

http://www.airservicesaustralia.com/pilotcentre/avcharge/price/contract2009/std_april2009.pdf

and in particular section 5.7.

Now why would anyone wish to go back to the old full reporting etc ways and increase costs, make flying less affordable, less jobs etc?
I'm not sure. Enlighten me please, if you know.

Savings are made because in E airspace less controllers are required than in C as there are far fewer IFR aircraft out and about than VFR.
and
in E airspace no charge is payable because as VFR you recieve no service and are invisible to the system as it were.
Now I can relax. Gimme as much E as you can! :ouch:

Leadsled,
So keep it real simple for me. At an airport with 40 jet movements and 100 lighty movements HJ, is A airspace going to produce a safer outcome than G or not?

[Charlie Foxtrot India]

You get charged for VFR in C if you contact the tower, so even if you only overshoot you still pay the fee.

However there are some schools at Jandakot who tell pilots that contact with any controller in Class C, eg approach for a Victor route clearance will "cost" and bill pilots even though there is no charge at all. :mad: so that may be why there is some confusion.

[LeadSled]

So keep it real simple for me. At an airport with 40 jet movements and 100 lighty movements HJ, is A airspace going to produce a safer outcome than G or not?Bloggs,

All I can say is, as a comedian, don't give up your day job.

An A tower, where can I find one. Even if there was one, that's a lot of IFR "lighty" movements, or a lot of (written) exemptions (in advance --- what a load of paperwork) , or don't you know the basic rules for A.

40 jet (presumably you mean passenger aircraft -- mostly RPT) ---- did Jetstar ever get up to 40 a day at Avalon?? ---- but no GA aircraft there, so you didn't mean Avalon. Certainly not found in the US.

Whether you want to accept it or not, the fact is that, if the separation assurance standard is met with D service, the additional cost and cost of limitation in A will not "make it safer". The separation assurance standard is set so low, that anything lower is "vanishingly small", a statistical zero, and if you want to believe zero can have different values, be my guest. Obviously you are having trouble with the basic concept.

I have recommended a way forward for you knowledge deficit re. principles of modern airspace management, the rest is up to you. Perhaps, along the way, you could acquaint yourself with the probabilistic basis of much modern airframe/systems (failure) design and certification, particularly digital avionics ---- perhaps the numbers behind Cat 11/Cat 111 operations will surprise you.

Tootle pip!!

PS: The ICAO standard (as above) has been described as about the same probability as earth being hit by by a lump of space rock big enough to wipe out the human race ---- a very small probability, but always a probability ------ but far smaller than the probabilities attached to all the other common causes of complete hull losses, including all on board.

[peuce]

Leadsled,

We acknowledge that you are a great wordsmith and that you have a greater grasp of ICAO Regulations, Statistical Standards and Risk Management theory than most of us .... however, we enjoy discussing more in common sense terms as we can all relate to the ideas penned. Sometimes we can even understand what Dick is trying to propose.

So, from a common sense, absolute basis .... one could never say that YSSY would be just as safe if it was declared Class G airspace. It would never happen. Why? Because your Separation Assurance standard could never be achieved.

Yes, Class G could be declared at Argadagada and it could be just as safe as Class C at YSSY. It is, of course, horses for courses.

So, no, I guess we can't blankly say that one class of airspace is generally safer than another, however, I think we are entitled to say that, in any particular location, one class of airspace can be safer than another.

[Capn Bloggs]

Leadsled,
Your inability to answer a simple question disappoints but doesn't surprise me.

[LeadSled]

Bloggs,

My dear fellow, I have answered your question, I doubt whether you want to understand the answer.

It is no skin off my nose if you don't want to accept the basic principles of modern ICAO airspace management SARPs(or the management of many areas or activities in the modern world), but that doesn't change the fact that it "is what it is". Statistical measurement and analysis, as a basis for sound decisionmaking, is inescapable.

I really do, in all sincerity, recommend you bone up on the basic workings of how particular CNS/ATM problems are measured, assessed and subsequently catagorised and managed. I am quite certain that it has made me a better PIC, you too can have your own signed copy of the big picture.

Then you would not be suggesting the invalid comparisons, such as YSSY as G ---- it would never be G, so questions based on such an assumption can have no answer.

YSSY as D, versus C or B, the answer all depends on the data, right now it comes up C --- and I have no argument with that answer. So the question could be "would B be safer"??.

My answer remains the same: NO, YSSY would not be safer, because C services fit the bill. The additional costs to operators, for no safety benefit, fits the definition of economic waste.

Tootle pip!!

[Capn Bloggs]

Question Time's over, Lead, with, as usual, no answer. Plenty of ducking, weaving and pontificating, but no answer. :{

Policy by statistics. "Reaction" if I ever heard it. I hope I'm not one of the statistics that you lot then use to "up" the airspace standard required after the Midair. :(

[Howabout]

OK,

I have been endeavouring to keep an open mind in relation to 'separation assurance' and what this really means.

However, for the life of me, I can't figure out what ultimately provides that 'assurance' between IFR and VFR in non-radar E other than TCAS. And I am sure I've read somewhere that ICAO has a view on the use of TCAS for that purpose.

Unless there is some other form of mitigation of which I am unaware. (big sky? unalerted see-and-avoid?). Got me stumped.

[Dick Smith]

Surely you don't think it is then better to have G airspace at and above busy jet airports like Ballina?

Oh,I forgot, where we already have G we must not change it- and where we have C in link airspace we must not change that either.

Never change anything- stick to Nomads and DC4's

[Howabout]

Brilliant riposte Dick; I expected something better than that.

Can you please answer my legitimate question on the other thread?

[mostlytossas]

How does C sound?
Over regulated and expensive!:}

[peuce]

Dick,

Surely you don't think it is then better to have G airspace at and above busy jet airports like Ballina?

Actually, that's a fair question.

Let's look at the alternatives (in a very basic sense Leadsled):


Class G Ballina: IFRs get traffic on each other and see and avoid VFRs
Class E Ballina: IFRs get separated from each other and see and avoid VFRs, whilst complying with ATC instructions


My "vibe" on that is that the IFRs will have little chance of hitting each other (a lot less chance than if they only had traffic information? I don't know), but their see and avoid tasks with VFRs will be made a bit more complex.

On the cost side, it's reasonable for the IFRs to expect delays from time to time. If its down to the circuit then there is an ATC Approach Training component to consider. There is also a reasonable expectation that more ATC bodies "could" be required. So, on balance, I think we can assume there would be a cost increase of some magnitude. I definitely couldn't see a cost decrease.

So, from a cost benefit point of view, is the change worth it? Not interested in "harmonisation" or "world's best practice" ... but is the cost worth the benefit?

I guess only the guys who operate there can answer that one.