The deteriorating quality of AIP information
Thread Starter
The deteriorating quality of AIP information
As the amount of distracting dross in AIP about things like 4’ shrubs steadily increases, it appears that the quality of the important information is steadily decreasing. That’s despite the pages of regulations, backed by criminal offences, that are supposed to ensure the quality of the information. Maybe it was just a random cluster (no pun intended), but I was confused at both ends of my most recent trip, by what turned out to be bad information.
I won’t mention the name of the outbound destination, but on the way there I had to wrack my brains about this ‘local regulation’ in the ERSA entry:
The conundrum presented by that ‘local regulation’ is that it is not possible to use either of those runways without taxiing on the RWS, unless you jag a landing which happens to end in a gentle rolling turn into one of the two taxiways near the northern end. As it turned out, the wind and other factors resulted in me landing on 22 and I had no choice but to do a U turn at the end of the landing roll then taxi on the runway back to the first exit. If I had to depart on 04, that would involve taxiing along most of the length of the runway to get to the threshold of 04.
By pure coincidence I later spoke with the Council official responsible for that entry. It became immediately obvious that he did not understand that the advertised 90 metres of runway strip between the gable markers for 04/22 includes the 30 metres of tarmac runway in the middle. He thought that the ‘runway strip’ comprises only the 30 metres of grass on each side of the tarmac runway, but not the tarmac runway itself. He therefore did not realise he’d prohibited taxiing on the tarmac runway as well as on every other part of the runway strip. (The prohibition on the use of the grass is another issue and that’s an ongoing exercise in Council official education.) An instructor from a nearby aerodrome noted that one of his students had been confused by the ‘local regulation’ too.
Confusion is not good for aviation safety.
On the return trip, this NOTAM was current (and remains current) for my destination aerodrome:
I wrote to the responsible Council official in these terms this morning:
The Council official’s response was:
I suggested the official contact Airservices and let them know.
Hopefully the NOTAM won’t be re-issued with “EST” added to the same text…
Confusion is not good for aviation safety.
We used to get this stuff right.
I won’t mention the name of the outbound destination, but on the way there I had to wrack my brains about this ‘local regulation’ in the ERSA entry:
ACFT not permitted to taxi on RWY 04/22 RWS or on grass islands.
By pure coincidence I later spoke with the Council official responsible for that entry. It became immediately obvious that he did not understand that the advertised 90 metres of runway strip between the gable markers for 04/22 includes the 30 metres of tarmac runway in the middle. He thought that the ‘runway strip’ comprises only the 30 metres of grass on each side of the tarmac runway, but not the tarmac runway itself. He therefore did not realise he’d prohibited taxiing on the tarmac runway as well as on every other part of the runway strip. (The prohibition on the use of the grass is another issue and that’s an ongoing exercise in Council official education.) An instructor from a nearby aerodrome noted that one of his students had been confused by the ‘local regulation’ too.
Confusion is not good for aviation safety.
On the return trip, this NOTAM was current (and remains current) for my destination aerodrome:
RWY 16/34 CLOSED DUE VEHICLE TESTING EXC FOR EMERG ACFT WITH 30MIN PN CTC OPR CTAF 126.7 OF TEL: [nnnnnnnnnn]
FROM 04 050630 TO 04 061900
2304050630 TO 2304051900
2304060630 TO 2304061900
FROM 04 050630 TO 04 061900
2304050630 TO 2304051900
2304060630 TO 2304061900
Those times are UTC. When 10 hours are added to convert the UTC times to local … times, the NOTAM closes RWY 16/34:
- from 4:30 pm on the 5th, overnight until to 5:00 am this morning (the 6th).
- from 4:30 pm today, overnight until 5:00 am tomorrow morning (the 7th).
To put this the other way around, RWY 16/34 is not presently NOTAM’d closed [despite all the humans and cars milling around and racing on 16/34]. The NOTAM next closes RWY 16/34 with effect 4:30 pm this afternoon.
All pilots inbound will hopefully nonetheless work out what’s going on (the organisers this time are very competent on the CTAF), but this is untidy. The NOTAM system assumes that NOTAM orginators understand time formats in submitted NOTAMs, as do pilots reading NOTAMs.
- from 4:30 pm on the 5th, overnight until to 5:00 am this morning (the 6th).
- from 4:30 pm today, overnight until 5:00 am tomorrow morning (the 7th).
To put this the other way around, RWY 16/34 is not presently NOTAM’d closed [despite all the humans and cars milling around and racing on 16/34]. The NOTAM next closes RWY 16/34 with effect 4:30 pm this afternoon.
All pilots inbound will hopefully nonetheless work out what’s going on (the organisers this time are very competent on the CTAF), but this is untidy. The NOTAM system assumes that NOTAM orginators understand time formats in submitted NOTAMs, as do pilots reading NOTAMs.
I submitted the paperwork in Eastern Standard time.
Hopefully the NOTAM won’t be re-issued with “EST” added to the same text…
Confusion is not good for aviation safety.
We used to get this stuff right.
With the second example, it may be that the NOTAM Office misread the form stating local time instead of UTC.
NOTAM Request Form
NOTAM originators are supposed to check the issued NOTAM:
NOTAM DATA QUALITY REQUIREMENTS FOR AERODROME OPERATORS
NOTAM Request Form
NOTAM originators are supposed to check the issued NOTAM:
6.3 Checking NOTAM
It is the responsibility of the ADO to ensure that information promulgated by the
NOTAM Office is correct. All NOTAM will be available via NIS after publication and any
discrepancies must be raised with the NOTAM Office by phone as soon as the error
has been discovered.
It is the responsibility of the ADO to ensure that information promulgated by the
NOTAM Office is correct. All NOTAM will be available via NIS after publication and any
discrepancies must be raised with the NOTAM Office by phone as soon as the error
has been discovered.
Most local council airport managers/staff have little idea of operations of aircraft and submit NOTAM information because they were told to via the forms. If you have operated long term to country council strips in aircraft over 5700kg eventually you will get staff tell you to park somewhere that has no data on pavement strength or wingspan issues and you then have to tell them unless they can provide data you can't do that. I assume all conversion from local to UTC for NOTAM production is done by the NOTAM office, not by the council staff.
I assume all conversion from local to UTC for NOTAM production is done by the NOTAM office, not by the council staff.
Thread Starter
Thanks, Captain Midnight.
It seems that if the Council NOTAM originator ticked the Eastern Standard time box on the form, the NOTAM office failed to do the conversion to UTC or make clear that the times were the local timezone, and the Council NOTAM originator then failed to do an adequate quality check after promulgation to pick up the NOTAM office's error.
If the Council NOTAM originator failed to tick the Eastern Standard time box on the form, the NOTAM office promulgated what it had been asked to promulgate and the originator then failed to do an adequate quality check after promulgation to pick up the originator's own error.
(alpha centauri: The form at the link in Captain Midnight's post has time zone tick boxes, so it seems reasonable that originators would assume the NOTAM office will do a conversion to UTC (or include text making clear what time zone is used) in the promulgated NOTAM. Does not excuse the originator from doing a proper post-promulgation quality check, though.)
I would have thought that all appointed NOTAM originators under Part 175 would be required to understand UTC and conversions to different zones. Otherwise, how can an originator be competent to do an adequate post-promulgation quality check?
It seems that if the Council NOTAM originator ticked the Eastern Standard time box on the form, the NOTAM office failed to do the conversion to UTC or make clear that the times were the local timezone, and the Council NOTAM originator then failed to do an adequate quality check after promulgation to pick up the NOTAM office's error.
If the Council NOTAM originator failed to tick the Eastern Standard time box on the form, the NOTAM office promulgated what it had been asked to promulgate and the originator then failed to do an adequate quality check after promulgation to pick up the originator's own error.
(alpha centauri: The form at the link in Captain Midnight's post has time zone tick boxes, so it seems reasonable that originators would assume the NOTAM office will do a conversion to UTC (or include text making clear what time zone is used) in the promulgated NOTAM. Does not excuse the originator from doing a proper post-promulgation quality check, though.)
I would have thought that all appointed NOTAM originators under Part 175 would be required to understand UTC and conversions to different zones. Otherwise, how can an originator be competent to do an adequate post-promulgation quality check?
[rant]
It is my unfortunate experience that local councils are efficient at only one thing - taking money off you. What happens after that is often a complete dog's brekky
In general I don't believe a council could, or should, be entrusted to generate accurate/reliable information about almost any airfield business. To expect your average council officious person to comprehend things like UTC is not reasonable, and certainly not an output I'd trust.
To put it more simply: garbage in, garbage out (or, in the case of councils, we all know the end result of a dog's breakfast!).
[/rant]
That over; to me NOTAM's are something that should be completed by a person who is entirely familiar with aviation, and is qualified to do so. From what I read here it would seem in Oz that there is no qualification necessary, and thus no real bar to incompetence, nor is there any real filtering or adequate checking of the information...
... which lead me to look at things a little further south. I found that two companies seem to be preeminent in the field:
Aeropath (https://www.originators.aeropath.co.nz/)
and
Airways (https://www.ifis.airways.co.nz/)
The latter site is where it seemed a person could log in and generate a notam. In order to do so it seemed necessary to read the 'terms and conditions' here. Said terms included a lot of stuff about website content, who 'you' 'your' 'we' and 'our' meant etc, but there appeared to be no competency requirements for a login, let alone to generate a NOTAM per se.
That said there are NOTAM guidelines here, which seem to require a name and signature, but that seems to be the extent of things down here as well, so I guess it's possible similar issues could occur.
As for the proliferation of 'stuff' in the AIP, I suggest it's all part of modern culture whereby anything inanimate needs an orange cone and everything else needs a shiny yellow jacket. CYA abounds!
FP (who hasn't had his own breakfast yet!).
It is my unfortunate experience that local councils are efficient at only one thing - taking money off you. What happens after that is often a complete dog's brekky
In general I don't believe a council could, or should, be entrusted to generate accurate/reliable information about almost any airfield business. To expect your average council officious person to comprehend things like UTC is not reasonable, and certainly not an output I'd trust.
To put it more simply: garbage in, garbage out (or, in the case of councils, we all know the end result of a dog's breakfast!).
[/rant]
That over; to me NOTAM's are something that should be completed by a person who is entirely familiar with aviation, and is qualified to do so. From what I read here it would seem in Oz that there is no qualification necessary, and thus no real bar to incompetence, nor is there any real filtering or adequate checking of the information...
... which lead me to look at things a little further south. I found that two companies seem to be preeminent in the field:
Aeropath (https://www.originators.aeropath.co.nz/)
and
Airways (https://www.ifis.airways.co.nz/)
The latter site is where it seemed a person could log in and generate a notam. In order to do so it seemed necessary to read the 'terms and conditions' here. Said terms included a lot of stuff about website content, who 'you' 'your' 'we' and 'our' meant etc, but there appeared to be no competency requirements for a login, let alone to generate a NOTAM per se.
That said there are NOTAM guidelines here, which seem to require a name and signature, but that seems to be the extent of things down here as well, so I guess it's possible similar issues could occur.
As for the proliferation of 'stuff' in the AIP, I suggest it's all part of modern culture whereby anything inanimate needs an orange cone and everything else needs a shiny yellow jacket. CYA abounds!
FP (who hasn't had his own breakfast yet!).
Thread Starter
I wonder what the point of all this is, then:
175.445 Aeronautical data originators—AIP responsible person and NOTAM authorised persons
AIP responsible persons
(1) An aeronautical data originator commits an offence if:
(a) the originator provides aeronautical data or aeronautical information to an AIS provider; and
(b) the originator has not appointed a single senior manager within the originator’s organisation as the AIP responsible person for the originator.
Penalty: 50 penalty units.
(2) An AIP responsible person is responsible for the provision of aeronautical data or aeronautical information, other than in NOTAMS, from the originator to an AIS provider.
(3) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as the AIP responsible person for the originator; and
(b) the person does not have the knowledge and competence to carry out the responsibilities of an AIP responsible person.
Penalty: 50 penalty units.
NOTAM authorised persons
(4) An aeronautical data originator commits an offence if:
(a) the originator asks an AIS provider to issue, review or cancel a NOTAM; and
(b) the originator has not appointed a person in the originator’s organisation as a NOTAM authorised person for the originator.
Penalty: 50 penalty units.
(5) A NOTAM authorised person is responsible for requesting the issue, review and cancellation of NOTAMS for the originator.
(6) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as a NOTAM authorised person for the originator; and
(b) the person does not have the knowledge and competence to request the issue, review and cancellation of NOTAMS.
Penalty: 50 penalty units.
175.445 Aeronautical data originators—AIP responsible person and NOTAM authorised persons
AIP responsible persons
(1) An aeronautical data originator commits an offence if:
(a) the originator provides aeronautical data or aeronautical information to an AIS provider; and
(b) the originator has not appointed a single senior manager within the originator’s organisation as the AIP responsible person for the originator.
Penalty: 50 penalty units.
(2) An AIP responsible person is responsible for the provision of aeronautical data or aeronautical information, other than in NOTAMS, from the originator to an AIS provider.
(3) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as the AIP responsible person for the originator; and
(b) the person does not have the knowledge and competence to carry out the responsibilities of an AIP responsible person.
Penalty: 50 penalty units.
NOTAM authorised persons
(4) An aeronautical data originator commits an offence if:
(a) the originator asks an AIS provider to issue, review or cancel a NOTAM; and
(b) the originator has not appointed a person in the originator’s organisation as a NOTAM authorised person for the originator.
Penalty: 50 penalty units.
(5) A NOTAM authorised person is responsible for requesting the issue, review and cancellation of NOTAMS for the originator.
(6) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as a NOTAM authorised person for the originator; and
(b) the person does not have the knowledge and competence to request the issue, review and cancellation of NOTAMS.
Penalty: 50 penalty units.
That over; to me NOTAM's are something that should be completed by a person who is entirely familiar with aviation, and is qualified to do so. From what I read here it would seem in Oz that there is no qualification necessary, and thus no real bar to incompetence, nor is there any real filtering or adequate checking of the information....
Aerodrome reporting officer guide.
I don't know if it still happens, but in the past I think CASA Airport Surveyors used to check them out.
Airservices do not always get NOTAM information correct even when it is given to them correctly.
EG: The NOTAM said Goulburn NSW YGLB was closed due flooding.
YGLB aerodrome reference level is about 35 feet above the town of Goulburn, population 32,000.
The weather in the area was CAVOK and it had not rained in ages, so a few slight reasons to doubt the veracity of the NOTAM.
Quick phone call to Airservices who said the NOTAM was correct and had been properly supplied by the ARO - what would I know?
Turned out it was South Goulburn Island airport YGBI in the Northern Territory which was flooded.
EG: The NOTAM said Goulburn NSW YGLB was closed due flooding.
YGLB aerodrome reference level is about 35 feet above the town of Goulburn, population 32,000.
The weather in the area was CAVOK and it had not rained in ages, so a few slight reasons to doubt the veracity of the NOTAM.
Quick phone call to Airservices who said the NOTAM was correct and had been properly supplied by the ARO - what would I know?
Turned out it was South Goulburn Island airport YGBI in the Northern Territory which was flooded.
Thread Starter
But surely that's the point of the originator doing the post-promulgation check. The originator of the YGBI flooding NOTAM should have noticed that it had not been promulgated. (Airservices could have helped by contacting the YGLB ARO to double check the NOTAM was for YGLB...)
Having some experience with the event and airport in question…pretty sure this exact thing has happened every year they run this event. Few years back a local flyer even argued with them over the radio and pointed out that they had their times wrong…
You are correct that the originator is supposed to check, post promulgation, that the NOTAM has been issued correctly. However, if I don’t really know the correct information when I submit the form, I’m probably not knowledgeable enough to detect that its been issued in error.
This establishment of data originators more broadly who have no knowledge of the operating environment that they work in, is the reason for the deterioration in data quality. This is compounded by the fact that Airservices no longer have responsibility for the quality of the data in AIP.
To the mental giants who came up with the CASR175 regulation, what did you think was going to happen when you don’t require any recognised training from the data originators?
You are correct that the originator is supposed to check, post promulgation, that the NOTAM has been issued correctly. However, if I don’t really know the correct information when I submit the form, I’m probably not knowledgeable enough to detect that its been issued in error.
This establishment of data originators more broadly who have no knowledge of the operating environment that they work in, is the reason for the deterioration in data quality. This is compounded by the fact that Airservices no longer have responsibility for the quality of the data in AIP.
To the mental giants who came up with the CASR175 regulation, what did you think was going to happen when you don’t require any recognised training from the data originators?
He thought that the ‘runway strip’ comprises only the 30 metres of grass on each side of the tarmac runway, but not the tarmac runway itself.
That reminds me many moons ago receiving a call on landing from the head of safety of the major oil and gas company (for whom we were doing aerial survey) asking why I’d flown through a NOTAMMED restricted area - they were blasting UXO on an island.
Still couldn’t find the NOTAM anywhere on a reread after the phone call.
Subsequent enquiry determined that the blasting manager only put a notice in the local paper classifieds for 2 days more than 4 weeks prior….
Still couldn’t find the NOTAM anywhere on a reread after the phone call.
Subsequent enquiry determined that the blasting manager only put a notice in the local paper classifieds for 2 days more than 4 weeks prior….
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I suggest some of you go have a beer(or simple chat) with your local ARO who does the NOTAMs. There is a lot of variation of competency and care factor, and a lot are not really aviation savvy, some not particularly motivated, they just do what they were told to do (or want to do).
CaptainMidnight, ARO is one of many data originators….the other ones have no training requirements.
I think you will also find that the ARO training is simply how to issue a NOTAM. I think we would both agree there is more to it than that.
I think you will also find that the ARO training is simply how to issue a NOTAM. I think we would both agree there is more to it than that.
I suspect the NOF have to hold the hands of many including making up templates, and with the best of intentions still the odd error creeps through.
I was at a RAPAC once where one of the attendees with a note of glee and triumph told Airservices that a temporary restricted area they'd declared at the request of a state authority was in the wrong place, stating that the actual location was clearly a couple of km away. I asked him who he'd told when he detected the error, and the response was "Not my problem ".
I got the impression all the other attendees thought he had a neon sign on his forehead flashing "D-H", and someone pointed out that somewhere in AIP it says something about pilot responsibility to report errors in operational information detected.
I was at a RAPAC once where one of the attendees with a note of glee and triumph told Airservices that a temporary restricted area they'd declared at the request of a state authority was in the wrong place, stating that the actual location was clearly a couple of km away. I asked him who he'd told when he detected the error, and the response was "Not my problem ".
I got the impression all the other attendees thought he had a neon sign on his forehead flashing "D-H", and someone pointed out that somewhere in AIP it says something about pilot responsibility to report errors in operational information detected.
Having some experience with the event and airport in question…pretty sure this exact thing has happened every year they run this event. Few years back a local flyer even argued with them over the radio and pointed out that they had their times wrong…
You are correct that the originator is supposed to check, post promulgation, that the NOTAM has been issued correctly. However, if I don’t really know the correct information when I submit the form, I’m probably not knowledgeable enough to detect that its been issued in error.
This establishment of data originators more broadly who have no knowledge of the operating environment that they work in, is the reason for the deterioration in data quality. This is compounded by the fact that Airservices no longer have responsibility for the quality of the data in AIP.
To the mental giants who came up with the CASR175 regulation, what did you think was going to happen when you don’t require any recognised training from the data originators?
You are correct that the originator is supposed to check, post promulgation, that the NOTAM has been issued correctly. However, if I don’t really know the correct information when I submit the form, I’m probably not knowledgeable enough to detect that its been issued in error.
This establishment of data originators more broadly who have no knowledge of the operating environment that they work in, is the reason for the deterioration in data quality. This is compounded by the fact that Airservices no longer have responsibility for the quality of the data in AIP.
To the mental giants who came up with the CASR175 regulation, what did you think was going to happen when you don’t require any recognised training from the data originators?
Thread Starter
This is compounded by the fact that Airservices no longer have responsibility for the quality of the data in AIP.
175.065 AIS provider certificates—conditions
(1) It is a condition of a certificate issued to an AIS provider that the provider must comply with:
(a) this Subpart [175B]; and
(b) any direction given to the provider, or obligation imposed on the provider, by CASA under a provision of these Regulations.
(2) An AIS provider commits an offence if the provider contravenes the condition mentioned in subregulation (1).
Penalty: 50 penalty units.
(3) An offence against this regulation is an offence of strict liability.
(1) It is a condition of a certificate issued to an AIS provider that the provider must comply with:
(a) this Subpart [175B]; and
(b) any direction given to the provider, or obligation imposed on the provider, by CASA under a provision of these Regulations.
(2) An AIS provider commits an offence if the provider contravenes the condition mentioned in subregulation (1).
Penalty: 50 penalty units.
(3) An offence against this regulation is an offence of strict liability.
175.175 AIS providers—correction and notification of errors and omissions in aeronautical data and aeronautical information
(1) This regulation applies if an AIS provider becomes aware of an error or omission in aeronautical data or aeronautical information that the provider publishes:
(a) in the Integrated Aeronautical Information Package; or
(b) on an aeronautical chart.
(2) The provider must, as soon as practicable after the provider becomes aware of the error or omission:
(a) record and investigate the error or omission; and
(b) ensure that the error or omission is corrected by the most appropriate means taking into account the operational significance of the error or omission; and
(c) ensure that notice of the corrected aeronautical data or aeronautical information is given to persons who had received the data or information; and
(d) identify the root cause of the error or omission; and
(e) establish and implement processes to eliminate the root cause of the error or omission.
(3) The provider must give CASA written notice of any significant error or omission that may affect the safety of air navigation as soon as practicable after the provider becomes aware of the error or omission.
(1) This regulation applies if an AIS provider becomes aware of an error or omission in aeronautical data or aeronautical information that the provider publishes:
(a) in the Integrated Aeronautical Information Package; or
(b) on an aeronautical chart.
(2) The provider must, as soon as practicable after the provider becomes aware of the error or omission:
(a) record and investigate the error or omission; and
(b) ensure that the error or omission is corrected by the most appropriate means taking into account the operational significance of the error or omission; and
(c) ensure that notice of the corrected aeronautical data or aeronautical information is given to persons who had received the data or information; and
(d) identify the root cause of the error or omission; and
(e) establish and implement processes to eliminate the root cause of the error or omission.
(3) The provider must give CASA written notice of any significant error or omission that may affect the safety of air navigation as soon as practicable after the provider becomes aware of the error or omission.
I consider a runway closure NOTAM that gets the closure times wrong to be a “significant error”. (I’m submitting a concern to ATSB.) CASR 175.175 does not distinguish between the sources of errors or omissions. Once an AIS provider becomes aware of an error or omission in the AIP or aeronautical chart the provider has published, the obligations arise, irrespective of the source. That’s kinda the point of the obligations.