Coral, thanks for highlighting the existence of the NASIG letter to Civil Air. Let's address some of the issues highlighted in Mike Smith's response:
1. The Wes Willoughby cost-benefit analysis: the Minister approved the implementation of NAS on the condition that
(a) a system-wide cost benefit analysis be undertaken proving that the implementation of NAS would offer benefits to the industry and
(b) safety analyses be undertaken by CASA before any proposed changes were implemented.
The industry scuttlebutt is that the Wes Willoughby financial report is both substandard in content and extremely flawed in its assumptions and recommendations and, therefore, has not yet received endorsement from the Minister. Yet, NAS implementation activities continue unabated. How can this be allowed to happen?
2. The statement by Mike Smith that "See and avoid is a PRIMARY (my emphasis) means of maintaining separation in VMC, and contributes significantly to the US safety record…." is blatantly incorrect and requires the strongest possible challenge by all of us.
To demonstrate my point let me put up some examples for members' review:
(a) Scenario 1 (the USA): I'm an IFR private flight (Seneca V) departing a non-towered airport in VMC, and on departure will be climbing to my flight planned level of FL150 on a non-published IFR route. After departure, I enter E airspace at 1200 ft agl and contact Centre who advise me (because they have radar) of VFR traffic cruising at 9,500 in my 12 o'clock. I try to call the VFR aircraft to arrange separation with no success (possible comm failure). Because I can't contact the aircraft, Centre offers radar headings to ensure that I avoid the aircraft, which I accept gladly. Once I pass, 10,500 I rejoin my flight planned track, again with the assistance of ATC radar headings. Drama impact rating: 0
(b) Scenarion 2 (NAS Australia): I'm an IFR private flight (Seneca V) departing a non-controlled airport in the middle of Australia under VMC, and on departure, will be climbing to my flight planned level of FL150 on a non-published IFR route. I give Centre my departure call and enter E airspace shortly after. Unfortunately, unknown to both Centre and myself there is VFR traffic on my track cruising at 9,500 feet. As we all know, E airspace in Australia doesn't enjoy full radar coverage and VFR aircraft don't require a clearance or have to communicate with ATC, so Centre had no way of knowing the VFR aircraft was in conflict with me. Passing 9000ft, I saw what looked like dirt smudge on my windscreen. At the last moment, I realised to my horror it was an aircraft on my direct track and I immediately took avoiding action. Unfortunately, I was not successful and I fatally clipped the wing of the other aircraft whilst also suffering structural damage and injuries to my aircraft and passengers. I declared an emergency and finally managed to land successfully, however the other aircraft was totally destroyed in mid-air with the loss of all life. Drame impact rating: 10+
So what is the major difference between these 2 scenarios?
First and foremost is that the US airspace structure under Scenario 1 offers a level of safety redundancy because of the superior aircraft surveillance capabilities available to Centre. These enhanced surveillance capabilities allowed Centre to be able to detect and resolve the potential conflict despite the fact that the VFR aircraft had neither flight planned or was communicating with the ATC system. Secondly, because both the controller and pilot had access to radar suveillance capabilities, allowing the presentation and utilisation of a range of alternative tracking and separation options, the need for "see and avoid" was no longer the PRIMARY means of traffic separation and was therefore, relegated to SUPPLEMENTAL status, as soon as the controller offered, and the pilot accepted, alternative radar headings. The real fact is that, in the US, "see and avoid" is INVARIABLY NEVER relied on as the PRIMARY means of separation in enroute airspace for IFR aircraft because of the wide coverage and integrity of the national radar surveillance system.
On the other hand, the proposed airspace structure for Australia simply cannot be classed as offering the same level of inherent safety as its US counterpart, unless the surveillance capabilities over the whole of Australia are significantly enhanced (maybe through ADS-B). With the present level of surveillance infrastructure, the proposed system for Australia offers no redudancy in terms of conflict detection and resolution options, particularly for aircraft not participating in the ATC system. The proposed Australian system also TOTALLY relyies on "see and avoid" as the PRIMARY and ONLY means of traffic separation in all cases; despite the fact that both BASI and CASA have cast doubts on its suitability as a primary tool in the past following extensive study.
So, where does this leave us? In 1972, the FAA adopted a policy position that recognised that reducting the number of unknown aircraft within the airspace system was one of the most productive steps in collision avoidance. It is also important to appreciate that "surveillance" does not necessarily imply the use of radar or ADS technologies. Many pilots will recall that in the past, large areas of Australia got by very well with procedural position reporting as the (only) method of surveillance, which allowed ATS to first alert pilots to potential conflicts (PRIMARY separation tool) and, second, gave pilots the option of segregating themselves from the conflict area through pilot communications or relying on "see and avoid" for resolution (SECONDARY separation tools).
So long as the NASIG continues to peddle "half-truth" propaganda regarding the "similarity" between the current US system and the proposed Australian NAS, or blatant untruths regarding potential safety and cost benefits, I will always consider the NAS to stand for the "NO AIRSPACE SAFETY" system and I will continue to resist its implementation until the system is properly, and independently, evaluated in terms of safety and cost by reputable organisations. On a positive note, the NAS does offer some improvements and benefits and I would hate to see the whole system canned just because NASIG persisted with its current deceptive tactics, and was eventually "found out" by the industry. That, in my view, would also be a retrograde step.