And the last part of their responses:
"The full impact of the removal of DTI, particularly the potentially detrimental effects on situational awareness for VFR pilots (for example a VFR pilot may now need to monitor two or three frequencies to maintain awareness of IFR traffic, when previously only one frequency was required)";
CASA Response.
The contention that the full impact of the removal of DTI was not subject to a formal safety analysis is disputed. The original safety case prepared by Airservices in 1996 addressed this issue in detail. It is also noted that BASI has stated that "it is not possible at this stage to compare the overall safety level of the Class G Airspace Demonstration with that of the previous systems.
In terms of situational awareness for VFR aircraft, there was no change from the one frequency they were required to monitor enroute. There were, however, other complications introduced by the removal of Flight Service, such as coordination with ATC for clearances through restricted areas.
"Operational difficulties associated with two concurrent sets of procedures, one for the demonstration airspace and one for the existing system".
CASA Response:
The issue of demonstration area boundaries was identified and given careful consideration by the safety education cadre and was given prominence in the safety education material which was produced. The Authority is satisfied that adequate procedures existed for the en-route situation but acknowledges that the issue of boundary aerodromes was not addressed until after the commencement of the demonstration.
j)"As yet, the investigation team has not found evidence to indicate that there was a clear transfer of roles and responsibilities from Airservices to CASA for the management of Airspace 2000 (which includes Class G Airspace)";
CASA Response.
The Airspace 2000 Program Definition Plan clearly defines the management structure for the project and the roles of the respective agencies.
"A comprehensive and systematic analysis of pilot tasks under the Class G Airspace Demonstration model (including an examination of the combined effects of all the changes on workload, situational awareness and crew coordination, as well as the development and testing of specific operational procedures)";
CASA Response:
This issue was the subject of extensive discussion with airlines prior to the commencement of the demonstration during the course of which pilot workload scenarios (including timings and radio procedures for two pilot operations) were considered, the CASA safety case refers. It is true to say that a comprehensive and systematic analysis of pilot tasks was not carried out. However, advice from the UK CAA Review Team was that this could not be resolved prior to the demonstration and that it could only be fully addressed by close monitoring of the demonstration.
"A systematic comparison of the Class G Airspace Demonstration model (including consideration of the Australian aviation system and environment) with appropriate overseas airspace systems";
CASA Response.
No formal comparison of the Class G Airspace Demonstration model with appropriate overseas airspace systems was carried out. However, it was widely understood that the Demonstration model was very similar to the airspace models implemented in a number of other countries. Moreover, an ICAO compliance matrix was prepared (see attached).
It should also be noted that the UK CAA report drew a comparison between the Australia Demonstration model and the British Class G airspace.
In addition, a considerable body of work was developed, subsequent to the failed implementation of 11/11/93, which extensively relies on comparisons with overseas systems. This material was taken into consideration in the development of Airspace 2000.
"A clear rationale for conducting the demonstration prior to the introduction of TAAATS"; and
CASA Response:
In response to the BASI Interim Recommendation No. IR970112, CASA sought to maximise the use of available radar coverage in the Canberra - Ballina area, especially where RPT flights were concerned.
Implementation of the Class G demonstration is not TAAATS dependent and the introduction of TAAATS would not have required a change to the Class G Demonstration procedures. It is a commonly held misconception that TAAATS incorporates an airspace design. This is incorrect. TAAATS will be capable of supporting multiple designs and classes of airspace.
CASA was concerned to neither delay nor disrupt TAAATS and sought to implement the Class G Demonstration in the window of opportunity offered by Airservices.
"A proactive evaluation of the effectiveness of the pilot education program prior to the introduction of the demonstration".
CASA Response:
There was no proactive evaluation of the effectiveness of the pilot education programme prior to the commencement of the demonstration. However, in accordance with the communication strategy, a number of information sessions were held to assess the effectiveness of the training material. In addition, a 'hot line' was put into operation several weeks prior to the commencement of the demonstration which provided further feedback on frequently asked questions and areas of misunderstanding.
The establishment of monitoring processes (such as a 'hot line', ESIRs, pilots' reports, airborne monitoring etc.) once the demonstration had commenced, provided a variety of inputs from which it was possible to make an assessment of the effectiveness of the pilot education programme. The most common areas of difficulty were identified and the information repeated in Aiming Higher which was distributed to all pilots.
Following discussion of your Bureau's interim report IR980253 with this Authority's Chairman and members of the Board, CASA would like to submit for your consideration, the attached comments.
Further CASA comment on BASI interim report IR980253
The Bureau of Air Safety Investigation issued an interim report IR980253 on 8 December, 1998, in relation to occurrences where aircraft were approaching or departing aerodromes.
Under the heading "Factual Information" BASI made the following statement:
"in both these incidents, prior to the introduction of the Class G airspace demonstration, the crews would have been alerted as to each other's existence through the provision of directed flight information."
The prime reason for the introduction of the Class G demonstration was because of a previously reported serious breakdown of separation, where the provision of a directed traffic information service failed. There have been many reports of incidents under similar circumstances in the airspace system before the demonstration.
BASI also made the following statement in the report:
"G - there are safety deficiencies associated with the current frequency management procedures particularly during departure and arrivals at uncontrolled aerodromes as shown in the occurrences described above. Pilots are required to monitor a .number of different frequencies during these high workload phases of flight, or may not receive critical radio transmissions, or may receive late advice of other traffic."
BASI points out that these safety deficiencies have been ongoing for many years, and were a serious safety problem in the airspace before the demonstration. Over 100 incidents have been reported where pilots have not received critical information on other traffic and this problem was clearly annunciated in the BASI report RP9301 where it was stated:
"Another difficulty at present is that when changing from the surrounding area frequency to the MTAF, broadcasts can be missed. Even with two radios, broadcasts can be overtransmitted or multiple transmissions confused."
"Interviewed crews pointed out that there is thus no means by which a faulty transmitter, incorrect frequency selection or overtransmission may be detected."
"Each of the occurrences investigated during the six week study period and a large percentage of all RPT occurrences in MTAF areas involved a failure to obtain correct traffic information."
BASI points out that CASA has legislated on 16 November 1998 and the CASA Director has signed a Civil Aviation Order to mandate a third party in the terminal area for RPT aircraft of over 10 passengers. This will substantially reduce this endemic problem in the existing airspace system.
It also should be pointed out that in relation to occurrence 9805078, the descending Beechcraft Kingair did not comply with the requirements as listed in AIP Supplement H48198 Annex B para 5.2:
"Pilots of IFR fights intending to conduct an instrument approach in IMC and who have not been able to confirm that the aircraft's radio is functioning and on the correct frequency for the aerodrome, either from another aircraft, through a third party, a UNICOM or an Aerodrome Frequency Response Unit, should contact the ATC unit providing services in the overlying airspace and request known IFR traffic. Provision of this service by ATC will not necessarily include information about all IFR traffic in the area".
If the Kingair pilot had complied with the regulation, the pilot would have been given information on the Bae Jetstream.
It should be noted that BASI has omitted from the report that in a number of incidents during the demonstration period, the chance of a collision was reduced by the use of radar.