Jet_A_Knight, here is the answer that CASA gave to BASI in relation to their see and avoid “absolute” recommendation.
BASI Research Report – ‘Limitations of the See-and-Avoid Principle’, 1991
The Civil Aviation Safety Authority responded to Recommendations 1 and 4 of the above report on 12 November 2001 having noted that most of the recommendations, including those concerning the implementation of TCAS and education initiatives, have been implemented and continue to provide positive safety outcomes. (CASA’s 1998 response to the other four recommendations in the report (2, 3, 5 and 6) were classified by the then BASI as CLOSED - ACCEPTED.) As CASA has noted, since the 1991 BASI report was released, the 1995 Risk Management Standard has been promulgated.
Recommendation 1 “The CAA should take into account the limitations of see-and-avoid when planning and managing airspace . . .”
CASA response: CASA agrees that the limitations of see-and-avoid should be taken into account when planning and managing airspace. Where traffic densities are such that see-and-avoid does not provide the required level of safety, CASA will require Class D or a higher level of airspace.
“. . . and should ensure that unalerted see-and-avoid is never the sole means of separation for aircraft providing scheduled services.”
CASA response: CASA understands the intent of this recommendation but does not agree with its absolute form. The wording of the recommendation reflected its time and was prior to the 1995 Standards Australia AS/NZS4360 Risk Management Standard. CASA also understands that the use of the absolute “never” is not consistent with current ATSB practice.
To accept the absolute form of the recommendation would require the allocation of Class D or higher airspace wherever scheduled services operate. This would result in an allocation of resources that is not commensurate with risk.
ICAO Class E and G airspace specifically has no radio requirement for VFR aircraft. ICAO has introduced both of these classifications with the full knowledge of the limitations of see-and-avoid. ICAO makes no recommendation in relation to scheduled services not operating in these airspace classifications.
Overly discounting the effectiveness of see-and-avoid and devising unique procedures has itself led to unintended consequences that are unresolved. Pilots may scan significantly less and become over reliant on radio alerting through a concept known as diffusion of responsibility. The BASI report RP/93/01 (December 1993) and the continuing incident reports that are being filed listing near misses in mandatory radio Class E and G airspace may support this concern. CASA believes that radio alerting is only effective when the alerting area is small with readily identifiable reporting points so that the alert is specific.
The Australian Transport Safety Bureau has classified the CASA response as CLOSED – ACCEPTED on the basis that CASA agrees that the limitations of see-and-avoid should be taken into account when planning and managing airspace and has indicated that appropriate risk management techniques will be used to establish airspace regulatory safety requirements. ATSB agrees that the use of the absolute ‘never’ has been overtaken by risk assessment.
Jet_A_Knight, in relation to your complex combination of radio frequencies etc in Griffith and Narrandera, I believe the situation hasn’t changed much. That is, that if you think a typical VFR pilot would be able to monitor such a complex range of frequencies and absorb what is going on, I think this is unlikely.
In the USA, with 20 times the density of air traffic in roughly the same land mass, simple US CTAF procedures work – with no requirement or recommendation to monitor ATC when enroute – and give a slightly higher level of safety than we obtain in Australia (when taking equivalent traffic densities into account).
Considering the terrible weather in many parts of the USA for 3 to 4 months of the year, I’m sure you would have to agree that the US system must be pretty good.
Please note that the US does not use a radar service in the CTAF area. It relies on simple radio procedures, good discipline and remaining vigilant.
You state:
So why make aircraft outside of an airfield’s airspace monitor that airspace that they may have no intention of entering?
I believe you may have a misunderstanding in relation to the education material. The facts are simple. If you are flying enroute in the airspace normally used for approach and departure at an airport, you monitor the frequency of that airport. What could be simpler? It is also recommended, just as in the USA, that if you are not planning to land at an airfield that you plan your flight (where practical) to avoid the airspace normally used for approach and departure traffic at that airport.
A most important point about monitoring ATC frequencies when VFR enroute. When you or your friends go driving on the weekend, you are not forced to constantly monitor the truck CB channel. It could be shown that there would be a slight increase in safety if you did this, as once every 5 or 10 years, you may hear of an accident that was around the bend or over the top of a hill. Presumably the reason it is not mandatory to monitor the truck channel, is that people want to relax when they are driving privately on a weekend and may even wish to listen to their stereo while looking at the magnificent scenery. Couldn’t this be the same with people flying privately?
Rather than force them to monitor the ATC frequency, why not let them fly enroute, avoiding the approach and departure airspace of airports, and then allow them to fly in blissful silence? Surely that would be fair if you wanted to compare flying privately with driving privately.
I entirely agree that with a commercial pilot it is totally different. A commercial pilot is paid to be in the air, and is therefore paid to constantly monitor a radio frequency. Surely a private pilot should be allowed to have a different, quieter and simpler method of flying if it can be done safely.
I believe the US system – where there is not even a recommended frequency for enroute flying – shows that this can be done with very high levels of safety.
What do others think?
Chief galah, thanks for the advice direct to me regarding the Essendon approach. I no doubt thought I’d been issued a visual approach by Melbourne Approach, however I was obviously mistaken.
Thanks for the advice