Leadsled
Let's put the written words of, The Act, The AAPS, and CASA's CRMF on the table for interested readers!
I rather think you are referring to ALARP as embodied in the Airservices SMS as per the NAS 2b era, that no longer applies
I am reliably informed [by the legislated documents below] that your claim is incorrect!
ALARP as a concept is still with us
A 'legislated' and well understood concept!
but in proper risk analysis it does not mean quite the same thing as during the period prior to the Airspace Act, and as applied by Airservices
Incorrect!
The Airspace Act 2007
ComLaw Management - Series- Airspace Act 2007
8 Minister must make Australian Airspace Policy Statement
(2) (c) describe the processes to be followed for changing the classifications or designations of particular volumes of Australian-administered airspace
(4) The statement must be consistent with the Chicago Convention. However, if Australia has notified differences under Article 38 of that Convention, the statement must be consistent with those differences.
Australian Airspace Policy Statement 2010
Release of the Australian Airspace Policy Statement (AAPS) 2010
Process for Changing the Class or Designation of a Volume of Airspace
15 Changes to an existing airspace classification or designation should be the consequence of a clear and consistent risk management process.
16 CASA‟s risk management process should be consistent with published Australian Standards for risk management as updated.
17 The process for change will commence with CASA identifying the volumes of airspace it will be reviewing in accordance with section 13 of the Airspace Act 2007.
18 The review process will then lead to the completion of a risk assessment of the particular volume of airspace under review.
19 The risk assessment should take into account the types of aircraft involved, the density of air traffic, the meteorological conditions, and such other factors as may be relevant.
20 On completion of the risk assessment process, CASA shall outline its proposals on the overall safety requirement for a particular airspace classification or designation.
21 These proposals will be to (a) change the classification or designation of airspace, (b) not change a classification or designation, but make other proposals to improve airspace arrangements, or (c) recommend a continuation of current airspace arrangements without any other proposals.
22 CASA will provide these proposals for public comment and, after considering these comments, then make a determination to be implemented as directed by CASA, by the relevant parties.
And;
Government’s Policy Objectives
25 The Government considers the safety of passenger transport services as the first priority in airspace administration and CASA should respond quickly to emerging changes in risk levels for passenger transport operations. Airspace administration should also seek to deliver good safety outcomes to all aviation participants.
26 The Government expects that CASA will continue the reform of Australia‟s airspace and move towards closer alignment with the ICAO system and adoption of proven international best practice.
27 The Government has also identified three specific airspace policy objectives in relation to the administration and use of Australian-administered airspace which are detailed in paragraphs 28 to 34 and outlined below:
support for ICAO‟ Global Air Traffic Management (ATM) Operational Plan and use of ICAO airspace classifications;
enhanced ATM services at regional aerodromes regularly served by passenger transport services, as determined by CASA; and
effective cooperation between CASA and Australia's air navigation service providers, including Airservices and Defence.
Support for ICAO’s Global Air Traffic Management Operational Plan and Use of ICAO Airspace Classifications
28 The undertaking of airspace administration will reflect the Australian Government‟ commitment to the ICAO Global ATM Operational Plan.
29 The ICAO Global ATM Operational Plan is the international vision for an integrated, harmonised and globally interoperable ATM system and includes a component on airspace management and organisation‟
30 The Government fully supports the use of the internationally-recognised ICAO airspace classification system (Class A to G airspace) in airspace administration.
Regional Aerodromes
31 The Government is committed to ensuring that effective ATM infrastructure and systems are used to protect and enhance air safety, with ATM services being extended to more regional areas as appropriate, where there has been or is likely to be growing passenger transport services.
32 CASA should ensure that appropriate airspace arrangements are in place at major regional aerodromes regularly served by passenger transport services which respond to changes in aviation activity over time such as changes in traffic density, the mix of aircraft types and increases in passenger transport services.
Cooperation with Australia’s Air Navigation Service Providers
33 The Government is committed to the continuing development of a seamless, harmonised national ATM system. The classification and designation of airspace is seen as an essential component of that system.
34 CASA is to work closely with Australia‟s air navigation service providers to ensure that the needs of all airspace users are properly considered; the provision of ATM services are properly coordinated; and the administration of Australia‟s airspace is both safe and efficient.
And;
Airspace Strategy
35 The Government requires CASA to carry out its responsibilities as the airspace regulator in accordance with the Airspace Act 2007 and the Airspace Regulations 2007.
36 This legislative framework enables CASA to examine and determine future Australian airspace requirements and has established that safety of air navigation is the most important consideration.
37 The Government‟s airspace strategy, to be implemented by CASA, involves the adoption of a risk-based approach to determining Australia‟s future airspace needs.
38 The implementation of this strategy requires the identification of risks to aviation safety using both quantitative and qualitative analysis, and ultimately the safety judgment of CASA as the airspace regulator.
39 The Government expects CASA to adopt international best practice in airspace administration. This includes adopting proven international systems that meet our airspace requirements. The Government‟s airspace strategy recognises that international airspace systems (such as the National Airspace System of the United States of America) include a range of characteristics that should be considered, and implemented as appropriate, by CASA.
40 ICAO standards and recommended practices (SARPs) also provide an important basis for airspace administration. The airspace strategy requires any deviations from ICAO SARPs to be well justified, documented, and formally notified to ICAO as a difference.
And;
41 The airspace strategy requires transparency so that the aviation industry has clear insight into the way in which airspace administrative decisions will be developed, taken and implemented including industry and agency consultation. The strategy does however recognise there will be times when urgent decisions are required to meet a safety imperative.
42 The airspace strategy is a proactive one based on a dedicated CASA work program, identifying priority locations where airspace should be reviewed, and consistent with the review requirements of the Airspace Act 2007 and Airspace Regulations 2007.
43 The strategy does not pre-determine the adoption of a particular class of airspace before airspace risk reviews are completed, but rather requires that the determination of the class of airspace reflects the most appropriate safety outcome as determined by CASA after completion of these reviews and consistent with the Government‟s policy objectives.
Common Risk Management Framework for Airspace and Air Traffic Management
Release of the Australian Airspace Policy Statement (AAPS) 2010 [bottom of page]
6.0 Framework Structure
Outline
6.1 Each agency will maintain a risk management system which is in conformance with published Australian/New Zealand Risk Management Standards as updated - currently AS/NZS ISO31000:2009 (see Appendix 2 for an outline of the risk management process).
6.2 As indicated in the standards mentioned above, all risk management systems will be premised on the concept of As Low As Reasonably Practicable (ALARP).
There are however limits to the extent to which the government, industry and the community will pay, to reduce adverse risks
The nub of the discussion
Leadsled!
E costs verses C costs [at volume specific locations]! Reducing adverse risk for NO COST!
The concerned experts here are calling for exactly what the Gov't, The Act, The Minister [AAPS], and the CASA [CRMF] all
require!
6.3 The Defence Aviation Risk Management process conforms to the standards that apply to the civil risk management regimes. These civil risk management systems are to be accessible to the public.
And;
Analyse Risks
9.4 To facilitate risk analysis an appropriate data exchange should take place between agencies. Most risk identification and analysis methods are dependent on data to drive underlying assumptions. The results of the analysis must then be assessed against appropriate criteria to determine if the risk levels are intolerable.
9.5 This agreement embraces the notion that the magnitude of the change proposal under consideration will drive the level of analysis (and reporting). Determination of magnitude will be driven by the internal protocols within each agency’s risk management system. However the following principles will need to be incorporated within the individual systems:
a. scale of the proposal, e.g. users, airframes, geographic region impacted;
b. complexity of proposal, e.g. interaction with other systems, services;
c. duration, i.e. temporary or ongoing;
d. originality, i.e. has it been proven anywhere else in Australia or overseas or there is already established knowledge about the topic e.g. ICAO standards or requirements.
How long has D with overlying C operated safety and efficiently in Australia? A very long time!
And;
Evaluate Risks
9.7 The qualitative criteria used by agencies, which are usually expressed in terms of consequence and likelihood matrix, may be specific to the agency given their differing roles. However, safety criteria must be premised on the basis of the effect on aircrew, other safety critical staff, the travelling public and the community.
9.8 Large scale assessments will embrace formal Cost Benefit Analysis including full economic, social and environmental impacts.
Treat Risks
9.9 In identifying risk treatments, the agencies will identify a hierarchy of preference for treatment. The highest priority will be given to solutions which seek to eliminate the negative risk.
And;
12 Conflict Resolution
12.1 The Aviation Implementation Group will oversight the application of this agreement.
It is abundantly clear the processes that need to be followed, and ultimately who is responsible for
'negligent' non-compliance!
Where is the 'proper', 'publiclly available' safety analysis work for YMAV, YWLM, YBRM and YPKA that transparently compares [as per the reg's above] options such as E or D or C in specific airspace volumes?