Like I said, someone playing with his willy
06 July 2010
CASA strongly recommends that, where terrain permits, NPA procedures be provided as they enhance the safety and efficiency of aircraft operations
CAAP 89P-1(1) Aug 1999 (General 1.3)
CASA strongly recommends that aerodrome operators avail themselves of the benefit of GPS technology
CAAP 89P-1(1) Aug 1999 (General 1.50)
Mr. Kim Jones (CASA, manager Airways & Aerodromes Branch) states in his letter of 12May 2009 “CASR 139.030 could be interpreted to mean that aerodromes without straight in approaches do not have non-precision approach runways and therefore do not need to be registered or certified. However CASR definitions show that this is not the intention of the regulation.”
He then goes on to say that “Regardless of the interpretation of 139 my concern is with CASR173. This CASR regulates the design of instrument approach procedures, with obstacle clearance the primary safety consideration in developing (designing ed.) and maintaining them.”
Now the matter is out in the open.
The procedure was designed by International Air Crewing (IAC) in 1999 who at that time were a CASA approved Procedure Designer. Further the design was thoroughly vetted and test flown in accordance with the procedures of CASR173 and relevant CAAP’s by Ian Mallet of CASA. CASA authorized Air Services publications and Jeppesen to publish the approach plates and the ERSA entry.
Although the original intent was to provide for an NPA approach to an NPA runway RWY18 GPS the approach was truncated at the circling minima and designated as LIL GPS-C pending a new OLS survey for the runway.
This is in accordance with the provisions of CASR 139 MOS 12.5 (allowing for an NPA straight in approach when there is no NPA runway (as at YLIL) but only to a circling minima.)
It should be noted that CASR139 12.8 says that only aerodromes that are certified or registered can have NPA runways. It does NOT say that only certified or registered aerodromes can have an NPA approach.
The very fact that CASR139 12.5 and 12.8 exist prove that it is the intent of the regulation to permit a GPS approach to non certified or registered aerodromes but only to a circling minima.
Turning to the issue with CASR173 which Mr. Jones acknowledges as his prime concern.
CASR 173 and the CAAP’s require Procedure Designers to assess the Obstacle Location Surfaces (OLS) for the approach using published “tall structures” data bases together with a ground survey in the vicinity of the final approach area. This was done in accordance with CASA procedures at the procedure design stage. In addition the Procedure Designer has to accept on-going responsibility for maintaining the safety of the approach in the face of possible penetration of the OLS by development under the OLS.
To assist in maintaining the safety of the approach the aerodrome operator (Lilydale Airfield P/L ) has accepted in writing that it is responsible to advise the Procedure Designer of any threats to the OLS. The operators of YLIL are in a better position than most in monitoring threats and actual construction activity under our OLS because we operate HJ 365 days a year in our circuit area and adjacent training area which encloses the whole of the NPA approach airspace. We are therefore in a good position to meet our obligation to our Procedure Designer to pass on threats to our OLS. There have been threats and they have been dealt with by the aerodrome operator before the OLS was affected.
In March 2006 IAC ceased to be a Procedure Designer and the relevant material for YLIL was handed over to Air Services who are now the Procedure Designers. From that date on, Air Services became the Procedure Designer and became responsible for the on-going maintenance of the NPA procedure for YLIL. Our legal responsibility in regard to the OLS remains with the Procedure Designer. In response to our request in July 2009 Air Services did an air survey of the approach areas.
In summary, The approach for YLIL was designed in accordance with CASR173 and it is maintained in accordance with the CAAPS’s of CASR173.
The debate over the LILYDALE GPS-C is a result of CASA’s assertion that the maintenance requirements for the procedure required under CASR173 can only be met if the aerodrome for which the Procedure was designed is either certified or registered. What about the numerous approaches where there is no aerodrome? Who is legally obligated to monitor the approach surfaces and report to the Procedure Designer? On approaches such as Polo Flat, Warburton, PID, YWE, VRD and several others there is either no aerodrome, or no operator, or if there is an operator there is no arrangement in place to observe threats to an OLS let alone report them.
In the case of YLIL, CASR139 12.5 prohibits an approach in IMC below the circling minima. This reduces the need for security of the final approach surface because the pilot (like a NVFR pilot) is in a position where he can see and decide not to land from the safe height of the circling minima. Because of CAR 92.1(d) the responsibility is placed on the pilot to obtain the necessary information from the Aerodrome Operator to assess whether it is likely to be safe to continue in VMC to land once he reaches the circling minima.
In answer to this CASA has said “what about the pilot who does a practice approach and does not need to seek info from the operator.” Our answer to that scenario is to place a note on the Plate requiring pre-arrangement with the operator before using the approach.
CASA also tried to say that the information to be exchanged under CAR92.1 (d) was confined to the state of the surface of the aerodrome and nothing about the approaches. Anyone who has read CAR92.1(d) will see that that is ridiculous.
We draw the attention of RAPAC that there are clauses in CASR139 permitting agreed exemptions.
And finally.
Between 1969 and 1979 15 people were killed in 3 accidents to aircraft inbound to the Yarra Valley from the North. YLIL is in the foothills of the Great Divide and is the only air port in the area capable of handling cabin class aircraft. Due to the prevailing SW winds cloud frequently builds up on the hills to the North. Inbound VFR pilots should climb over the cloud but if they do then they will be in C airspace. AirServices will usually refuse a clearance over the top to a VFR aircraft. The pilot, being so close to home, is tempted to squeeze between the trees and the cloud.
During the 80’s at least 3 pilots were observed at YLIL removing leaves and branches from their under-carriages. We can assume more of the same has occurred at YMMB.
When GPS approaches became available the owners of YLIL jumped at the chance to add to safety of our customers and the utility of our aerodrome.
There are now 44 IFR aircraft based at YLIL flown by approx 60 IFR pilots. They are now unimpressed with our Regulator.
20 days ago Winter struck. “Special VFR techniques” have had to be used to get back into YLIL on 5 occasions. These have involved flying in decidedly poor visibility under cloud while cleared at “not above 1000ft” over terrain which rises to 1100ft as one tracks from circa PLE towards YLIL.
This is an un-rehearsed activity, the pilot does not know just where he will be vectored. To all but experienced pilots, very familiar with the area, this activity, while legal, is unprofessional and dangerous.
By contrast pilots using the LIL GPS-C could descend to 1010ft using a safe proven procedure (probably rehearsed) which delivers them into familiar terrain (at least for the majority of users).
Any activity which requires great skill and experience and which cannot be rehearsed is prone to accident. This is not what civilian flying should be about.
The Manager Aerodromes & Airways said to me on 23Dec2009 “I am so worried about the continued use of the NPA at Lilydale where someone might hit an obstacle (unknown, un-notified-ed) that I can’t sleep at night.”
I would suggest that there is a negligible chance that such an unknown un-notified obstacle would exist and even less chance that someone would fly into it.
What was even more amazing was his statement that “If I were to agree now to registering YLIL by 29Jan2010 then my (allegedly dangerous) NPA would instantly be OK (presumably safe) and (presumably) he would again be able to sleep at night!
Nevertheless compared to the miniscule chance of an aircraft hitting an object while executing an NPA into non registered YLIL, and in the light of the disasters in the 1970’s and last week’s adventures, the occurrence of another disaster is by comparison almost a certainty.
Of course it will be pilot error, but the coroner will be looking for contributing factors.
I look to the support of RAPAC to persuade CASA to re-instate the GPS NPA-C for Lilydale.