I have covered this consistently. You cannot just separate the Class E airspace away from the Class D airspace controller who has to spread his or her workload. What is the use of changing Class E to Class C to make it “safer” whilst decreasing the safety of the Class D below where the collision risk is far higher? That is why we have different airspace categories. It is to give the same level of safety (as far as possible) at each location.
Surely it is obvious to you that the risk of collision below 4,500 feet is greater than the risk in the link airspace above? Why then are you supporting Class D airspace where the risk is greater and Class C airspace where the risk is obviously less? This is a classic example of “upside down” airspace. It’s like designing an airline aircraft with the thick part of the wing outboard and the thin part connected to the fuselage.
Ok, now it's my turn to bite.
The risk is the risk is the risk. We have what we have; to change the risk, you must have a positive 'Cost Benefit Analysis', risk must be reduced or where it increases there must be savings.
E is more ATC costly than C in the enroute environment (cost neutral in a tower environment). E is more risky than C, fact. (So where you replace C with E you have negative CBA; not so where you replace G with E, reducing risk does not need fiancial offset, just needs to be justified and consulted properly)
This is why ASA rolled back and you know it; they were liable in the event that a VFR pilot with low hours got it wrong and failed to see and avoid when they would have been previously subjected to a clearance. I believe one board member (at the time) was happy with carrying that liablity many others were not.
So the 'phase' of NAS increased risk without realising a cost saving to justify that increased risk; it doesn’t matter that you reduced risk at the circuit, cause you can argue that didn't improve or got worse, cause the ATCs still had the airspace up higher, it was just class E. Even if end state reduced risk, you weren't at end state until you actually got there.
Using the logic that C over D = roadblock, the IFR aircraft in E were more distracting to the class D tower controller than when in Class C as now there are unknown VFRs out there getting in the way, (which needed reaction not planning, very hard without surveillance); ie The risk increased in the airspace above Class D (E vs C) and it increased the risk in the circuit because the ATC were more distracted by the Class E above when compared to Class C)
Dick, I agree with some of your logic about risk and the need for change, just not the conclusions that are drawn from that logic.
Ok I must be one of the "f-worders" that we're not allowed to mention, right, in the past that is the bucket I have been put in.
The same logic you apply to the poor tower bodies not being able to look away from their empty circuits and runways where the risk if 'higher', (only when there is traffic there) is not applied to the enroute environment that can just by the effective stroke of the pen take on all that Class E (effective ATC scanning rates and concentration ability is sadly reduced now, cause we spend a lot of our time scanning empty screens for that mythical VFR pop-up, had one today and had to issue a safety alert, love Class E) and equally so take on low level E let downs to 'protect' the IFRS from CFIT outside (in many cases) effective surveillance; so what is the point.
What is the point of Class E above FL180? Is it ICAO or FAA complient?
There is such a thing as Class C enroute airspace, but there is no such beast for tower operations that are not commensurately supported by an approach service; at present that approach service is conducted in the tower; take it away to save the circuit/runway risk and who does it? Class E is the panacea for the risk reduction in Class D, no address them a separate issues.
I would love to see you state that Class E airspace should be introduced along the lines of your characteristics, but support the controllers when they say to do it effectively they need surveillance and more consoles so that LSALTS etc can be effectively managed; ie you can't monitor a procedural approach in class E, and you can't monitor one or more approaches a large enroute screen safely without increasing the risk elsewhere.
Points where
I agree with Dick Smith:
1) IFRs (especially PAX carrying ones) should get at least Class E protection to the IFR minima.
2) IFRs should be able to declare themselves VFR when they reasonably decide it is safe.
But point 1 will come at more cost, is that cost worth the risk you are addressing. Dick your message is that the naughty ATCs and IFRS get in the way of VFR or set-up roadblocks to exclude VFRs; but what is reality.
If you want to get the big end on town you need to link the NAS to LTOP to get your CBA over the line; ie introduce NAS and we'll stop fuel wasting noise sharing. (but that's worth it's own thread).
I have controlled now for over 10 years, and always had Class C (excluding the 12 month event) not once have I denied a VFR a clearance; I have said the phrase "Clearance not available remain OCTA" closely followed by "standby" implying I've got nothing and I need to talk to someone else to organise the clearance or find some details if I'm the only one involved.
Dick I have in the past attempted to make my points to you directly, I would love to do so again, but would love for you to listen to me, not just talk over me. I think that airspace reform can happen, should happen and must happen; but the method currently applied, crash or crash through, manipulate and politicise the process, hang on a few dodgy words published by a minister but drafted elsewhere is not the best way forward.
Where is the ‘vision’ beyond the USA system, where is the vision beyond CASA draft part 71. Why introduce characteristics not used at large, “VFR on TOP” “Visual climb and Descent in E”, “Flight Following – RIS” etc; all ‘headline events’ all not wanted or used in general, although RIS is at least seen daily, unlike the others limited to annual events.
Where it appears to fall down from my end, is change management / consultation is not real; it is stated to be real, but consultation is not a briefing. The CTAF (R) / CTAF / MBZ and the area frequency debacle is a classic example; it was a change, with a change in risk; not in itself dangerous, but changed. The people opposed to the change did so because they could see benefit from the change; but they could see the change causing location specific problems. Has the world ended in the CTAF environment, no, is the circuit safer, probably but it’s really hard to tell, is the surrounding airspace more risky with frequency confusion abounding, absolutely, but is that risk a show stopper, no.
That is enough for now; I don’t want this to be a thread going down the usual lines of ‘f-worders or the flat earth society’ and ‘terry towellers and sheep’ on opposite sides; where I fear it is headed (and ultimately bans all around again); but perhaps both sides could take a deep breath before hitting the post button. Consider this ‘do I need to criticise the person to prove my point’; despite the difficulty in doing that; I’ve probably done it myself…
Enough for now, I'm getting back in my box.