Today I made the following short submission to Airservices about the proposed AFIS at Ballina
I was the CASA ATM Inspector that oversaw the introduction of the CA/GRS at Ballina and I have audited the CA/GRS at Ayers Rock twice and the AFIS at Port Hedland once, on behalf of CASA. I came to the conclusion that the operations at Ayers Rock and Port Hedland were fit for purpose and that the AFIS model was superior to the CA/GRS. I advised CASA management of my conclusions but also that I did not believe that the CA/GRS being introduced at Ballina would be successful. (There is not enough space here to list the reasons) I recommended to CASA OAR management and the ATM management that Ballina required a control tower with Class D airspace. An AFIS, provided by surveillance-equipped ATCs, will not be able to lower risk levels below those achieved by the current CA/GRS. When I last inspected this was staffed by personnel who have ATC licenses, albeit without current medicals, ratings, or endorsements. The surveillance in the Ballina area, unless it has been improved, does not detect non-ADSB equipped aircraft at lower levels and there will be no greater incentive for VFR pilots to lift their radio procedure activities than those that currently exist. In short, the airspace does not need another voice on the CTAF adding to the confusion. This is the major reported problem with the CA/GRS and an AFIS under Australian Class G procedures would have to operate the same way. The airspace has reached the point when ATC needs to be introduced to sequence aircraft around the Air Traffic Zone (ATZ) and manage runway operations. It need not be expensive if created within an overlying Class E airspace structure.