Trim Ref.' EF14/283
29 August 2014
Mr Neville Howell
Chief Operating Officer
Regional Express
PO Box 807
MASCOT NSW 1460
Dear Mr Howell
I am writing to provide you with the currently available information regarding the ongoing
operation of SAAB 340 aircraft at Coober Pedy. Firstly, let me make it clear that as
previously communicated to you, CASA is seeking means to permit continued safe SAAB
340 operations at Coober Pedy and not to prevent these flights.
Previously, and at present, SAAB 340 operations to runways as narrow as 18m (including
Coober Pedy) have been conducted, in part, under the authority a Flight Manual Supplement
(FMS) that was developed and approved by the then Civil Aviation Authority (CAA) in 1991.
CASA is developing a revised legislative package that provides for the assessment of the
capability of aeroplanes to conduct narrow runway operations. This is the alternative to
requiring aerodrome operators to widen runways at aerodromes that do not meet the
aerodrome standards for larger aeroplane types. The assessment will include evaluation of
aeroplane capabilities and aerodrome facilities. lt should be noted that these approvals
frequently impose limitations, an example of which would be a reduced cross wind limit.
Other major regulators including the FAA, EASA and NZ CAA do not allow operations into
runways narrower than the aircraft code and without CASAs legislative package this kind of
operation would cease.
This revised legislative package (CAR 235A and CAAP) is proposed to come into effect as
early as 13th November 2014. Guidance on how to comply with that regulation, and CA SA's
policy on the matter, is provided in CAAP 235A-1 (0). The regulation remains subject to the
Government's normal regulation approval process, including approval by the GovernorGeneral.
CAAP 235A-1 (0) clarifies that the runway width must be of a homogenous surface material.
Coober Pedy's main runway currently consists of an 18m sealed section and 6m gravel
shoulders on either side. This would be considered an 18m wide runway, not a 30m wide
runway for the purposes of the new regulation. This takes into account the effect of having
different braking and performance characteristics when one set of main landing gear wheels
is on gravel and the other on a sealed surface. Similarly, aircraft certification is based on
keeping both landing gear tracks wholly contained on the same surface with the same friction
characteristics.
The FMS previously approved by the CAA restricts operations on 18m wide runways by
application of a 17kt cross wind limitation. However, CASA has identified issues with the
basis used to approve this supplement, and intends to withdraw this approval at some time in
the future.
Earlier this year CASA conducted some initial simulator testing and this indicated that the
cross wind limit may need to be reduced to 10kt in order to ensure the continued safe
operation of SAAB 340 aircraft on the 18m wide runway at Coober Pedy.
CASA has also sought assistance from SAAB to specifically facilitate ongoing operations at
Coober Pedy. Progressing this matter will need to be done in accordance with CASA's policy
as set out in the proposed CAAP 235. SAAB is currently considering if a suitable FMS might
be generated to allow operation to the 18m wide portion of the runway at Coober Pedy, or if
operations to the wider (30M) non-homogeneous Coober Pedy runway may be viable. lt
should be noted that the outcome of this analysis in no way guarantees that a less restrictive
cross wind limit than that proposed by CASA would result.
Based on the 10kt crosswind limitation proposed by CASA, services at the airport could be
affected up to 10% of the time. This is based on information contained in the 2008 report into
options for Coober Pedy airport that was prepared by Aerodrome Design Pty Ltd for the
Coober Pedy District Council.
Whilst there is no requirement in the regulations to widen the runway at Coober Pedy to a
30m homogenous surface, if the runway was widened it would mean that an FMS would not
be required for services to Coober Pedy with SAAB 340 aircraft, and that REX services could
continue with no operational limitations. An acceptable method to "widen" the runway
includes applying sealant to the gravel shoulders of the runway strip, so that the landing
surface would be extended to a 30 metre wide homogenous surface.
To permit continued SAAB 340 operations at Coober Pedy there are a number of options
including:
1. Awaiting the outcome of SAAB's analysis while operating in accordance with CA SA's
recently determined limitations.
2. Sealing the runway shoulders to provide a homogenous 30m surface, allowing
operations of SAAB 340 aircraft with no additional operating limits.
Another option would be to conduct operations to Coober Pedy with an aircraft type such as
a Dash 8, Fokker 50 or Beech Kingair that has the necessary performance and handling
characteristics, and is already approved by the original equipment manufacturer (OEM) for
operations to an 18m runway.
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The new legislation proposed by CASA means that aeroplane operators will no longer need
to apply for exemptions for narrow runway operations. Instead, aeroplanes will need to have
been assessed by the OEM or by flight test of the aeroplane to determine their capability to
operate on narrow runways.
Irrespective of the proposed legislative changes CASA will continue to work with SAAB and
REX to facilitate ongoing operations of SAAB340 aircraft at Coober Pedy, noting that
depending on the option chosen this may be with appropriate operational limitations to
ensure the safety of such operations.
Yours sincerely
John F. McCormick
Director of Aviation Safety