The following is doing the rounds of some organisations in reference to this ASA proposal which to date does not have any charts on display. It should be noted that some of the RAPACs have been asking for ADSB coverage at 3000 ft and a symbol on the charts where the ADSB facility is located for around two years. Nothing from ASA to date on either.
Now that CASA have moved the goal posts on how consultation is undertaken both CASA and ASA transmit but sadly there is not much listening going on. We have only seen the tip of the iceburg with this proposal and it needs to be put on the table in full, prior to moving forward. Where is the five year airspace plan that was meant to be in place by now?
Seems also that the tragic state of GA at the moment has not been considered in proposing such a change (?)
- International consistency… we are ALREADY aligned to the ICAO airspace system… it’s why we have alphabet airspace in the first place!
- Improved safety… how? Show your working, there is no safety case to answer. The result will actually be delays because of the requirement to separate aircraft without surveillance coverage. Ostensibly E airspace without active surveillance (ie radar) is LESS safe because it means that VFR aircraft are operating undetected in the airspace. IFR aircraft legally need a clearance to change route or altitude, so we are now forcing them to rely on TCAS?
- Reduced complexity… explain how. G is very uncomplex!
- Current and future needs?? Expressed by WHOM? Which operators have asked for this. Also equitable access is complete blowing snow, you need a functioning transponder and VHF to access E, you need neither in G.
- 1500AGL is hard to manage… because (shock) the terrain moves! We don’t have radio altimeters in GA aircraft. So you expect an RA or GA pilot to calculate 1500AGL for their ENTIRE route of flight?
- Maximise surveillance??? The surveillance doesn’t fully support the E airspace we already HAVE and CERTAINLY doesn’t support it to 1500AGL, there will be MASSIVE swathes of non-surveillance airspace where the controllers will have ‘nothing’ other than ‘one in, one out’ to use as a standard. Especially when you consider that ADS-B is NOT mandatory for VFR aircraft. (can you see where that is going??)
Let’s take aim at the “benefits”:
- Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management.
o Australia is already aligned with ICAO airspace ever since the demise of GAAP. Modelling on the US NAS has been shown time and again to be inappropriate, Australia does not have close to the same level of traffic, risk, ANS infrastructure or ATC staffing/sector density to support moving to a US NAS-like low level E airspace.
- Improved safety for Regular Public Transport (RPT) and other airspace users - reducing complexity for pilots and controllers.
o Adding large non-surveillance areas as class E airspace increases risk as VFR aircraft are completely unknown, making IFR aircraft reliant on un-alerted see and avoid (or TCAS) for separation. Worse these aircraft are subject to a clearance so any deviation requires a clearance request from a controller which they may not be able to facilitate if separating with other IFR traffic, terrain or radio congestion inhibits. There are no complexity issues that the addition of this airspace would solve (on either side).
- Enables enhanced surveillance service.
o There is zero increase to surveillance coverage proposed. Additional controlled airspace is not required to provide more surveillance services… these are already provided to IFR aircraft where available and VFR aircraft on request in Class G airspace.
- Class E does not restrict access for VFR aircraft.
o Incorrect. Class E airspace imposes aircraft equipment requirements that are not required for VFR aircraft in class G airspace. This would have the effect of pushing non-equipped aircraft down to very low altitudes to avoid the airspace. Also VFR aircraft may not be monitoring the area frequency so even if in surveillance coverage (and equipped, as most low level coverage will be ADS-B only) the aircraft will be completely uncontactable by ATC.
- Controlled airspace containment and separation for IFR flights.
o However due to the lack of low level surveillance coverage there will be large delays. Australian pilots are not inclined to cancel IFR like American pilots. These restrictions will likely result in forcing aircraft to operate VFR in marginal conditions to avoid these delays. Also airspace containment is moot, aircraft will STILL need to leave the E airspace to land! Moreover no operator in the effected airspace has expressed any desire to have this level of airspace containment. This also causes a large increase in ATC required knowledge as ALL approaches for ALL airports in their airspace will become required knowledge so they can correctly process IFR aircraft to leave the class E airspace on descent via an instrument approach (and any potential missed approach).
- Fosters equitable access for airspace users.
o Airspace access to Class G airspace is already equitable by default. Class E imposes equipment requirements for VFR aircraft and potential traffic issues for IFR aircraft.
- Caters for current and future needs of airspace users.
o What known need that has been expressed by any airspace user group?
- Improved use and value of existing investments (e.g. ADS-B, ACAS).
o More airspace (that Airservices can charge for) is not a reason to increase airspace. ADS-B is only mandated for IFR aircraft, meaning that literally half the traffic will not be visible to ATC. Controllers will have NO awareness that their clearance may have actually increased the collision risk.
o ACAS IS A SAFETY NET, NOT A SEPARATION TOOL! (Note also ACAS may not be used as a factor in airspace design).
- Facilitates Continuous Descent Operations.
o False, CDO is inhibited by this proposal as ATC will be required to separate well below existing surveillance coverage so aircraft will be held up to allow departing aircraft. Also the airspace proposed doesn’t enhance CDO any more than the current structure as the aircraft will STILL need to leave class E airspace on descent, just doing this at a much lower level (and potentially being delayed by the inflexibility of non-surveillance separation standards which will be basically a ‘one in, one out’ service without a tower being present (which is how the extant non-radar airspace is able to operate with some level of efficiency.