There are so many issues in play here but I will try and comment on just two:
1. Can Airservices ATC deal with this proposal - clearly not! The sectors are set up to provide current services, not this proposal. If ATC is to provide a Class E approach control service to any one of the airports included in the proposal then each controller has to have the ability to concentrate on that task (smaller display area) while having information pertinent to the pilot at his/her finger tips. Airservices itself proclaims the requirement to utilise modern information delivery techniques. I know, for a fact, that weather info from an AWS can be uploaded to an ATC position - but it costs money. Furthermore if there happen to be two or more aircraft utlising this service (e,g. Mangalore) then who is watching the rest of the sector's airspace.
2. This proposal has been undertaken in haste and Airservices do not know what they are doing - Airservices is a body corporate established under Commonwealth law to provide air traffic services in Australian airspace, they work for the Minister. (And recover all the costs and provide a dividend to the Commonwealth). If they have disingenuously circulated a proposal that they know to be unworkable then this is a political scandal of the highest order, for which the Minister needs to take responsibility.
For the record - Airservices is not the responsible Government entity for the approval of airspace changes, that role is given to CASA under the Airspace Act 2007 (" This Act binds the Crown in each of its capacities.") . Airservices is perfectly entitled to propose to CASA that there should be an airspace change, but CASA is responsible for ensuring the following:
(a) protection of the environment;
(b) efficient use of that airspace;
(c) equitable access to that airspace for all users of that airspace.
If Airservices wishes to change airspace, it is able to lodge an Airspace Change Proposal (ACP) to CASA, CASA are then required to:
- review the ACP to:
- ensure sufficient information and supporting analysis is available to assess the ACP in terms of safety, efficiency, equitable access, economic and cost impact, national security and if the change is realistic and achievable
- ensure a robust safety case exists to support it. At minimum, this should include a risk assessment (see below for further detail). However, depending on the size and scale of the proposal, further detail including an analysis of the current operating environment and key existing safety issues should be included. Additionally, evidence of consideration of the impact of the change should be provided
- ensure appropriate stakeholder consultation has occurred and evidence of that consultation is supplied with the submission
- ensure the proposed start date leaves adequate time for processing, analysis and further stakeholder consultation
- ensure a risk assessment appropriate to the size and complexity of the proposal is included. The risk assessment should take into account the types of aircraft involved, the density of air traffic, the meteorological conditions, topography and such other factors as may be relevant
- check there are no airspace/aircraft operation implications for Environment Protection and Biodiversity Conservation Act 1999 Matters of National Environmental Significance, noting that aviation safety is always the top priority
- ensure a Regulatory Impact Statement (cost: benefit analysis) is included for major change proposals which considers the cost implications for all airspace users.
- review the safety case to determine if a residual risk remains for airspace users
- advise the ACP proponent if the information supplied is adequate to progress the application to assessment or if further information is required
- assess the ACP in accordance with current legalisation, policy and procedures
- conduct additional stakeholder consultation on the proposal (as necessary)
- assemble the supporting legal and aeronautical documentation to give effect to the ACP
- advise the proponent if the ACP is approved or not approved.
Arguably Airservices is currently conducting - "ensure appropriate stakeholder consultation has occurred and evidence of that consultation is supplied with the submission" Hence it is incredibly important that we respond and also ensure that the Minister knows what we think and that CASA sticks to the law.