Originally Posted by
Geoff Fairless
Now that the ATSB report has been released, it may interest PPruners to see the contribution I made to the investigation. I have removed the names quoted because this is a public forum.
Please note that ATSB refers to CASA not having taken over-flying traffic into account. You will see, from my letter that this was the basis for me recommending that a CA/GRS would not be able to function efficiently. So, CASA were aware of this traffic but, according to ATSB, apparently chose to ignore it.
There is also mention of the Minister's parameters, in the AAPS, for introducing Class D airspace, and that one of the parameters had been exceeded. You will not be surprised when you read the new AAPS to see that CASA has removed them!
Finally my comment about AFIS (as it is practised in Australia) being only suitable for low traffic environments, includes the SFIS introduced by Airservices.
Dear ATSB,
I write regarding your ongoing inquiry into the separation incident at Ballina Aerodrome. I would like to address the CA/GRS issue as well as commenting about Ballina, I hope you will bear with me.
Until November 2019 I was the Aviation Safety Inspector within the CASA CNS/ATM office who was charged, by the then CNS/ATM Manager [Name Deleted], with oversight of operations within Class G airspace. I should add that after [Name Deleted] left and was succeeded by, first [Name Deleted] and then [Name Deleted] that the position was no longer recognised. I did however continue to authorise CA/GRO certificate issuing, conduct audits of CA/GRS at Ayers Rock and Ballina and the Airservices Aerodrome Flight Information Service (AFIS) at Port Hedland. I do not know which of the current inspectors, if anyone, has carried on my work since I left.
The reason I was given the work by [Name Deleted] was because he became aware, through the operator of the CA/GRS at Ayers Rock, [Name Deleted], that audits were not being carried out. This was because the Aerodromes Branch, under which the CA/GRS service (Ch 22, Part 139 MOS) is authorised, did not have, and to the best of my knowledge, still do not have the expertise to assess what is fundamentally an air traffic service. CNS/ATM branch originally considered the CA/GRS outside of it's terms of reference (CASR Part 172), many still do. I tell you this to indicate that this area of pseudo-ATC could easily become ignored again by the regulator.
It was my view, within CASA and still, that AFIS procedures are only viable in very low traffic environments. This is because pilots are required to respond to other pilot's radio calls and organise their own separation. Consider that the IFR pilot is getting traffic from ATC on the area frequency, traffic from the CA/GRO on the CTAF, calls from other aircraft on the CTAF, is it any wonder that VFR pilots get confused? All of this results in a rapid duplication of radio calls on frequency as the traffic increases. In a busy environment, this degrades safety instead of enhancing it. Ballina, in this respect, is different from Ayers Rock or Port Hedland where traffic levels are lower, more predictable and there are very few VFR movements.
In regard to Ballina, I carried out the majority of the CASA work required to grant the CA/GRS certificate. My reports to my managers' were that the Ballina environment was potentially (not all of the time) too busy for the CA/GRO to effectively assist with safety. I noted that the major differences between Ballina and the Ayers Rock and Port Hedland environments were:- A proposed very poor operator position for the CA/GRO, caused by Airservices unnecessarily offering space within the fire station area used by the duty fireman to observe movements. Before that Ballina was willing to erect a small "tower" complying with Ch 22 at the time. (Since then CASA has changed the regulations to avoid having to provide exemptions!)
- A controlled airspace base of 8500 feet with lower steps to the north
- The presence of two other moderately busy aerodromes, Lismore and Evans Head, sharing the CTAF, plus an unknown number of private airstrips and recreational hang-gliding
- An NDB, owned by the Council, and used extensively by training organisations from Coolangatta and other airports (How many NDBs are still in existence?)
- The funnelling effect on overflying VFR aircraft caused by the adjacent control areas
- The reported, by the airport and local pilots, reluctance of overflying VFR traffic to use CTAF procedures when "in the vicinity of" the CTAF aerodromes
- The inability of pilots on the ground to be able to hear calls from pilots on the ground at other aerodromes and ALAs
- The Lismore call-back tone sounding over traffic information being passed at Ballina
My conclusion often voiced to my managers, was that Ballina needed a small control tower with Class D airspace, similar to Camden, or Hamilton Island, or Launceston. This is because those three have levels of traffic that can be handled by one ATC per shift to minimise costs. The ATC is able to organise the circuit area, for safety, and manage runway occupancy for safety and efficiency. Unfortunately, even though, this model of Class D operation exists in Australia, CASA OAR and Airservices seem to consider that it only applies to what they call "Metro D" airports.
It is my view that Ballina would be more safely managed by a small Class D towered control zone overlaid by Airservices-controlled Class Class E or C control area. Given Airservices habit of building very expensive buildings staffed by highly paid ATCs, I might also suggest that, if the cost is too great, the Minister considers allowing airport operators to own and manage control towers under Part 172. The CA/GROs at Ballina, when I left CASA, were all retired ATCs, they need only to regain medical status and be subject, amongst other things, to a compliant operations manual. Airservices is not needed to do that, any competent experienced ATC manager, could provide the exposition required by CASA.
I hope I have given you a few things to consider and not wasted your valuable time. Should clarification be required I am very happy to assist.
Kind Regards
Geoff Fairless
Well said Geoff Fairless.