NAS Stage 2c is Fundamentally Flawed
I have very, very carefully read the whole of NPRM 0401 AS, and it is fatally flawed.
Section 4 refers: all pilots of aircraft to take all reasonable steps to ensure that they do not cause a danger to other aircraft being operated in the vicinity of the aerodrome
Whilst this 'due care and regard' statement reads well - it fails, because a pilot simply cannot comply with it when all traffic is not meeting the same standards for communication.
Without radio use, pilots cannot be fully situationally aware , as recommended in 4.4.1 of the NPRM.
The optionality of radio use must increase the risk to all users CTAF/MBZ airspace. Who is going to conduct a straight in approach to a main runway, in marginal VFR conditions, when there is even the remotest chance of non-radio traffic? Only the suicidal is my suggestion!
My experience with traffic conflicts in MBZ's and CTAF's has been that it's mostly radio related all right - because the average private pilot doesn't carry out a sufficient cross check on matters radio...including, volume up, audio switched correctly,headset plugs in, and lastly the correct frequency.
But it's not just the denigrated PPL who has finger trouble. I was confronted with a B200 landing straight in on the main runway here,(an MBZ),a year or two back, while we were doing circuits on the cross runway. He subsequently apologised at the flight school, because he'd been on area frequency up until he shutdown!
Now if we have had difficulties in the past, there is no way that an optional system is going to improve things. And please, don't anyone mention the word training to me. We currently hammer pilots with lookout, and radio use in MBZ's - I don't beleive you can just write on a 24 page NPRM that
4.5.1 Note: The recommended broadcast procedures require significant pilot training and education
and it will automatically translate into safety. The issue is that we already train pilots as well as the system allows in terms of 'see and avoid', and 'situational awareness'.
Once you remove their confidence that not all aircraft will be on radio, and others might be - but choose to not talk, I forsee a great decline in pilot's confidence in the 'system'.
It just defies logic and common sense, (not a bureaucratic term, or even understood in Canberra), to not require radio. They are cheap, and if you can afford even a bug-smasher Mk3, then you can sure afford a hand held VHF.
Are hand signals still used by cars - of course not - lights replaced them years ago, and you cannot register a vehicle without them. I see a fair comparison with radios and aircraft. Forget what type of aircraft - if it flies, then it should communicate. Lets remember it's the 21st century, and the standards need to lift, not revert to the steam age!
This NPRM fails to bring aviation into the 21st century, and will further erode safety in terminal area airspace.
I do not support it in several areas, and will be holding a pilot/aircraft owner meeting in Albany WA to encourage pilot responses to this NPRM.
happy days