CASA Discussion Paper (DP) 1006AS

[Hornet306]

This DP is titled "Proposed Strategy and Regulatory Plan in support of the Australian Government's Aviation White Paper" but the bottom line is it proposes ADSB/Transponder carriage for all aircraft in all Australian airspace.
This has not been justified by any risk management analysis or cost benefit analysis and would cost the GFA fleet alone about 8 million dollars for fitout (if it was possible) to address an enroute risk of 5 reported "serious incidents" out of 709 incidents reported between 2003-2008 in the ATSB's very recent report AR-2008-044(2). All the rest of the serious incidents reported were in the vicinity of aerodromes, so should have been mitigated by June 2010 changes, CARGS or Unicom.
It would be nearly impossible to fit Transponders/ ADSB on Hang Gliders, so that would seek to exclude those aircraft with subsequent impossibility of enforcement by HGFA or CASA.
I'm sure RAAus have objections on the grounds of cost/safety benefit justification.
This is like fitting traffic lights at every road intersection!
I'm not sure you can post URL's on PPrune, but you can search for the documents on the CASA and ATSB Websites.
The complex DP is dated 1st October and the deadline for response to CASA is 30th November 2010!
Have you read it or the ATSB document yet?
Not happy with CASA consultation effort with pilots, operators or aircraft owners! :ugh:

[OZBUSDRIVER]

CASA DP1006AS (http://www.casa.gov.au/scripts/nc.dll?WCMS:STANDARD::pc=PC_100228)

It is reiterated that this DP contains suggested broad proposals only

[OZBUSDRIVER]

ANNEX E (http://www.casa.gov.au/wcmswr/_assets/main/newrules/airspace/download/dp1006as-annexe.pdf)

wow...they really did their homework:hmm:

[Sunfish]

My naturally suspicious mind suggests that CASA has found another avenue for bastardisation and micromanagement.

This is "Total information awareness". The ability to cross check ADS-B information after the fact with log books and most probably the ability to "watch" designated aircraft.

Combine this with supposed changes to part 91 and we have a raft of new "show cause" letters that start with "On 28th February 2011 ATSB ADS-B records show that aircraft VH-XXX departed from YYY at time ZZZ and arrived at JJJ at time GGG where the aircraft was met after touch down by CASA officer Mr. ........."

[Bunyan Wingnut]

DP 1006 AS is not acceptable with application to all aircraft and all airspace, particularly Class E and Class G. There is an inexcusable lack of risk justification for this change. Any new requirements must be publicly and unambiguously justified on a risk management basis, using AS/NZS 31000 principles, frameworks and processes. The risk analyses must be supported by rigorous cost benefit analyses, as required by the White Paper and the AAPS. DP 1006 AS is not acceptable with a single technology solution. Other technologies and interoperability options must be investigated. A layered set of solutions might be most appropriate. DP 1006AS is not acceptable if it mandates TCAS, ADS-B and Mode S technology above 10,000ft, nor for VFR in Class E and Class G airspace. Some aspects of this proposal even might subtract from safety!

Yea, it is a crock and it stinketh badly... :ooh: IMHO :uhoh:

[OZBUSDRIVER]

I think you are blind to the technology simply to keep that technology out of your beloved gliders, BW:E

[fencehopper]

RAAus? stand up against CASA? Huh, there as useless as tits on a bull!!

[Bunyan Wingnut]

Hi OBD, I fly GA and RAA as well as GFA. I do think ADS-B and Mode S is part of our future, but if you read carefully I said that DP 1006 AS is not acceptable with a single technology solution. Other technologies and interoperability options must be investigated. A layered set of solutions might be most appropriate. Annex E is deficient. There are other technologies that should be investigated and perhaps modified. FLARM (SwissFLARM and OzFLARM) are in wide use and have advantages in high density "gaggle" environments where ADS-B might go bananas. Low power / low current drain electronics solutions are needed; perhaps standards need to change for some a/c. Low power detection technologies have galloped ahead in recent years. Data links ditto. Interface technologies ditto. These all lead to other interoperability options. The one cap fits all, law of universal implementation approach is simplistic. I am not blind to the technology - I would prefer better technology options suitable for lighter a/c and aircraft without power generation capability. I am sure there is much common ground and room for developing options :8

Furthermore, I stand by my unhappiness with the lack of risk analysis; for enroute / E / G it is debatable.

BTW debate and dialogue is healthy - there appears to have been a distinct lack of CASA dialogue with ASAC in developing this paper. Unfortunately this has the effect of making the required dialogue appear reactionary. Proposing changes is different to being a blind naysayer. :)

[Joker 10]

Now I remember the AOPA goons telling us this would be subsidised and we would all get new kit as a result so we should be grateful for the advance in technology.

And it would solve the dilemma over SAR in central Australia ( designated remote areas)

The reality now comes home to bite us all, ADSB out for everybody, croppies, C150 that live in the circuit and adjacent training areas, gliders, Balloons (yikes)

The goons at AOPA have gone I am told, the hangover now starts to bite and there is no fix, technology will be forced on us all.

Wonderful democratic ??? answer to a problem that doesn't really exist.

[peuce]

If I remember correctly ... and I couldn't be bothered going back through old posts ... "the believers" pointed out to the "road-blockers" that if you didn't put your support behind the then "ADS-B for Free" proposal ... then it was likely that it would be thrust upon you, at cost, at a later date.

The words chickens and roost come to mind.

[Jabawocky]

peuce = nail on head :D

The goons at AOPA have gone I am told

I was of the belief that happened a number of years ago. :hmm:

[Joker 10]

There was NEVER a subsidy, a few Air Services staff speculated on one without any Administrative backing, neither political party is going to back subsidies for Private General Aviation, owners are seen as fat cats.

Throwing support behind an unsupportable idea is tantamount to rank stupidity.

Better to throw support behind canning the whole idea for low level aviation where there is no demonstrable safety case that ADSB solves.

[FokkerInYour12]

Wasn't it originally justified through the removal of radar facilities, and installations into GA aircraft would be subsidised by such cost savings.

Annex F seems to show ADSB and radar coverage.

What would ADSB be alone without SSR?

Looking at the coverage map at 5000 foot I'm somewhat surprised that an ADSB ground station at 23 Mile Ridge (NE of Perth) doesn't give much coverage.

I can tune into 23 mile ridge on VHF for ATC enroute to Kalgoorlie and get plenty of range even at 5000'. Annex F seems to indicate that about halfway to Kalgoorlie I'll be invisible to ATC.

[Joker 10]

The original overenthusiastic "concept" was everyone would have both ADSB in and out so not only would SSR be able to be replace every one would have the ability to see all other aircraft so TCAS would also be on the replace list in the Australian FIR.

This was always dependent on subsidy as the original cost of the equipment was prohibitive and even now whilst there is lots of talk about ADSB mode S transponders there is still the C145/146 TSO GPS and associated interfaces to install, mighty useful in a C150 in the training area for Ab Initio students.

[OZBUSDRIVER]

Joke/2 trust you to dredge up an old argument:hmm:

Regardless, tomorrow is the deadline if you haven't made a submission. It's not too late:E

[Joker 10]

Might be an old argument but it is still very valid and the do gooders should hold their heads in shame, architects of disaster for General aviation.

[peuce]

Joker 10,

No matter how much you bleat that "there was never going to be any compensation"... the reality is ... we'll never know for sure ... as we only have your word for it.

What we do know, is that it's very unlikely NOW. The horse has bolted.

I suggest that we might have been better off calling their bluff back then ... and seen what eventuated.

[Joker 10]

Peuce, Their bluff was called and the bureacrats ran like rats and hid.

[The Chaser]

.... hehehe ... ah dear :} ... you, four eyes, and the piss tank are really trying hard to re-write history :D ;)

... hide, ... think again 'has been' ... you must be that 12th man dude, you know .... 'heneverwaas' :E

OooRoo ;)

[Joker 10]

God AK is back amazing

[The Chaser]

Joke/10God AK is back amazingBwhahahahaha .... tool :E ... not even close :}

[LeadSled]

Folks,
Seems like the closing date has been extended to 14/12/2010.
Tootle pip!!

PS: If it waddles like a duck, and quacks like a duck???

[Joker 10]

Definatively a duck, quack quack !!!!

[Frank Arouet]

Bwhahahahaha .... tool http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/evil.gif

Is a "tool" something like an 8" shifter? Probably handy for undoing spiteful irritating nuts.:ooh:

[Joker 10]

Maybe its a dog, woofs like a dog, scurvy coat as well.