Airspace Design - Some Background

[Voices of Reason]

Airspace Design – Some Background

We have been watching the “comings and goings” over airspace management issues in Australia – and in other countries – for several years, both on PPRUNE, and in your press. We don’t often proffer an opinion in this or other forums, leaving that for more erudite contributors – however, we are moved to contribute in this instance to place some balance into your sometimes emotive arguments.

Perhaps a historical lesson might help your perspectives, and focus your debate[s]:

The current so-called “alphabet” Airspace Classification System was developed by a technical panel of the Air Navigation Commission [ANC] of the International Civil Aviation Organization [ICAO] in the late 1980’s. That panel was called the Visual Operations Panel [VOP] – and, as the name implies, was tasked with codifying and facilitating the operation of VFR flights within the airspace systems of the world. The panel comprised “technical experts” from the United States, Canada, Australia, the United Kingdom, European States, and other States.

Until ICAO promulgated the airspace classification table and [less than] descriptive paragraphs in 1991, there was no uniform method to describe or codify certain common elements of VFR and IFR flight. Some States operated systems using terms like Visual Exempt, Instrument Visual, Controlled and Uncontrolled and so on. It wasn’t only the terminology that differed – it was the application.

The VOP, in addition to developing the currently adopted “alphabet” codes, also developed a framework that would allow States to determine the need – or otherwise – for certain airspace management practices, based on the changing risk to IFR operations of increasing numbers of VFR operations. You need to access and examine the suite of working papers that supported the classification system to fully understand the intent. You also need to see the draft guidance material that was developed by VOP – none of this was ever published by ICAO.

We have seen that material - it CLEARLY enunciates a framework where IFR operations with very few proximate VFR operations should be contained within a low third party intervention environment – i.e., Class G – BUT as the amount of traffic – IFR and VFR increases – AND the potential risk levels increase – the level of intervention capability – OR the amount of restriction on VFR flights – changes. The KEY is that the level of risk that IFR flights are exposed to remains within a [relatively] constant band. Class A was NEVER meant to afford a higher level of protection to IFR flights that Class G. The level of risk to IFR flights was meant to be maintained at an appropriate SAFE and COST-EFFECTIVE level by regulating the services provided to IFR - and the restrictions placed on VFR operations [when in proximity to IFR operations].

Hence, you’ll [no doubt] notice that for all intents and purposes, there is little or no difference to the set of operating parameters for IFR flights in the airspace tables, from Class G to Class A – BUT the services and restrictions on VFR operations change substantially as you move from Class G to Class A.

The VOP guidance material also discusses in some detail the operation of jet aircraft at various speeds in relation to VFR flights, the ability of IFR pilots to break from cloud and “see” VFR flights and so on. Hence the use of differing “clearance from cloud” requirements. There was a good deal of science behind the standard – just not enough background or guidance material to see it implemented uniformly – not just in your country, but around the world.

So, it is somewhat amusing to see the endless arguments that are taking place in Australia over the need, or otherwise, for a class of airspace here, or a level of service there – when it is clear that very few people – least of all your airspace designers - understand the background to the airspace classification system at all.

Now on the matter of transponder operation. In the late 1980’s, when VOP was doing its work, transponders were used by higher end IFR operations, and lower end where possible – but were not widely fitted to VFR aircraft. Equally, whilst some major States and Regions [USA, Europe] had widespread secondary radar coverage, few other States had secondary surveillance radar. Most certainly, the development of collision avoidance systems was embryonic. Hence, the classification system – published in 1991 - omits reference to transponder carriage and activation.

Does the use of transponders mitigate risk – most certainly – but from an airspace design viewpoint, you can ONLY factor that risk mitigation where a third party service [advisory or control] is being used. That is, it aids surveillance, which aids the provision of [meaningful] services to aircraft – IFR or VFR. That means that in certain cases, in radar coverage in particular, the carriage and operation of transponders may allow an airspace designer to impose a lesser classification of airspace. The continental portion of the United States of America is a good example, where the high [but not total] coverage by secondary radar allows the application of Class E, rather than Class C, airspace.

You CANNOT [yet], however, design a system that relies on aircraft-to-aircraft surveillance or separation based on the use of transponders – that is, the use of airborne collision avoidance systems, like TCAS and Mode A/C transponders, as an airspace design tool, is prohibited. You may want to have this verified [we understand you have a member on the ICAO Air Navigation Commission]. Effectively, ICAO – and the ANC specifically – has determined that ACAS MAY NOT be used as a risk mitigator under any circumstances in the design of airspace management procedures. ALL ICAO Technical Panels have been directed that they may not factor such systems in the development of separation standards, the design of procedures, or the development of future systems. ACAS is a “last line of defence” for pilots – NOT a system design tool.

We are dismayed to read in some of your postings – and in education material we have seen associated with your recent changes – that pilots are being instructed that TCAS is a design risk mitigator. We suspect that Australia will run a fairly solid gauntlet of international condemnation should that be the case.

Good luck.

The Voices of Reason

[4Greens]

An excellent dissertation. I trust it is widely read. It is axiomatic in research to go back to source documents.

[tobzalp]

A somewhat interesting post. My first question for you is who is WE? You refer to WE often and i would like to know who you are posting on behalf of.

I think you and I are on the same side with your last paragraph about TCAS separation. Is this the intent of the post? There is much talk of unrealeased documentation and hearsay. From what i can gather you would have us in Austraia designate Airspace above f180 as class G not A as stands now

it CLEARLY enunciates a framework where IFR operations with very few proximate VFR operations should be contained within a low third party intervention environment – i.e., Class G

and also have curent G as B as that is where the most IFR v VFR risk is therefore more intervention required

IFR and VFR increases – AND the potential risk levels increase – the level of intervention capability – OR the amount of restriction on VFR flights – changes. The KEY is that the level of risk that IFR flights are exposed to


Are we to believe that the entire world has got this backwards? when it is clear that very few people – least of all your airspace designers - understand the background to the airspace classification system at all.

While your final point to do with TCAS is in my opinion valid, your method or arriving there is not.

[karrank]

Marvellous dissertation, how would the current airspace debacle look if somebody had held a meeting with this document as a starting point instead of letting others do what they want because the p1ssweak minister is frightened of them...

Every meeting I have attended that has discussed mitigation has started with the frenzied yelp "TCAS is not a mitigator for any stage of NAS" (usually followed by "Nothing you say will actually change part of the model").

However, from what the "voices" are telling me (I hope this sentence isn't quoted in my next medical) those high volume areas outside radar coverage (YMAY, YMHB, YBAS for eg.) should be C unless we ARE using TCAS as a mitigator. Sounds good to me, we don't have the radar coverage of Gooberland.

[Voices of Reason]

It is difficult to answer all your questions in one limited post, particularly in a subject as complex as airspace design, where the genuine and immutable need to ensure safety needs ALWAYS to be balanced against the cost-effectiveness of achieving that end – AND the need to ensure amenity [that is, access to the airspace by those who want, but perhaps inevitably won’t be able, to operate there].

The Visual Operations Panel to which we referred was challenged to address the legitimate concerns of IFR operators, who were operating increasingly complex and higher energy [higher performance] aircraft in proximity to increasing numbers of VFR flights. The target was to allow those VFR operations to continue with as few limitations as possible [it was, after all, a VISUAL operations panel] – BUT where necessary [Class A] exclude them.

We don’t know the specific mechanics of your airspace – but you are undoubtedly not unique – though we recognize that EVERY country has its unique characteristics. VFR aircraft operators around the world howl whenever their amenity is challenged – and many IFR pilots that you speak to would prefer Class A across the world [try the Russian Federation!].

There are four keys to [good] airspace design. The first is to determine the level of risk - not just across the whole environment [this can give mis-leading results] but also in individual environments – each has its own idiosyncrasies. You don’t need to apply high levels of science to do this – there are many methods for assessing risk – but you do need to be able to defend any risk assessment that you make - that necessarily means openness. That also does not mean that you need to ameliorate the concerns of all airspace users – BUT you must be able to demonstrate that you have [genuinely] listened to their concerns – AND sought to factor those concerns in your decision making processes.

The second is to find as uniform a set of airspace classifications as possible, that will “fit” the risk profiles. What we mean here is to choose as few rule sets as is feasible. Simply because there ARE seven airspace classes, does NOT mean you need to use them all. Our experience is that pilots and service provider staff like to keep things simple – safety thrives on simplicity.

The third step – and this is critical – is to test and evaluate the risk mitigations offered by the classification – e.g., will applying clearances to VFR flights mitigate the risk, will excluding VFR flights mitigate the risk, will it be an unnecessary impost to restrict VFR operations, and so on.

This will leave you, inevitably, with a patchwork quilt of airspace classes. So, your fourth step – and many countries [see the Eurocontrol web-site for diagrams of the biggest patchwork quilt of all] don’t take it – is to rationalize the mix of airspace classes, or procedures. So if you determine that you should have Class C in one area, Class D adjacent to that airspace, and then Class E adjacent to that airspace – AND it would cost you no more to make it all Class C – then that should be your decision. If there is no cost impact – and no demonstrable negative impact on amenity for a VFR flight – nothing in the “rule book” says you can’t exceed the “minimum requirement”. If you exclude a very small number of Class B airports in the United States, there are really only 4 of 7 classes applied. Do they need Class A above FL180 – in many cases no. If they had A, B and C, the rule set becomes too complex. Could the United States apply larger volumes of Class G – yes – but again the mix of rule sets would make it more complex.

It is interesting to note that in the Eurocontrol documentation, they have established a target of unifying airspace classifications across Europe into three by 2010 – in a framework of better efficiency and better access and equity – NOT in a framework of restrictive practices.

Before we close – a respondent made a reference to our organizational allegiance. We do not represent anyone or any organization. We are concerned that many decisions made not only in your country, but in many others, are based not only on [hopefully] mis-understanding – but also [hopefully not] on deliberate mis-interpretation. We are concerned about safety – and we are concerned that any money that is spent on airspace management is correctly applied to ensure safety, without unnecessarily restricting the amenity of any user.

[Voices of Reason]

To TOBZALP,

We have just re-read your intervention - and you are correct - having re-read our original post, we may not have been clear. Our apologies. There must be absolutely no misunderstanding that IFR to IFR operations deserve a constant level of protection - and a constant level of protection in relation to their interaction with VFR flights. The VOP intended that for Classes A, B, C, D and E, the levels of service to IFR aircraft in respect of other IFR aircraft is IDENTICAL. The varying classifications refer to the levels of interaction between IFR and VFR aircraft. In response to your comment about Class G above 18,000 feet - though not fully familiar with your airspace, we suspect that you are being facetious - we would expect that high performance IFR aircraft are likely to interact with other high performance IFR aircraft in that domain - clearly some level of control type services would be advocated.

In respect to your intervention on airborne collision systems, we would ask that you do access ICAO documentation - or at the very least access your officials in ICAO. ICAO is categoric in its views on the use of ACAS systems in airspace design. If we were less than clear in our statements, we apologize.

If our views are not helpful, we will, of course, withdraw from your forum. We seek only to offer the benefit of experience in these matters - and to offer sources of information which you may use to the benefit of aviation safety in your country. From what we have observed, you are fighting misinformation - skillfully manipulated - but incorrect, nonetheless. We can provide assistance to discredit such misinformation, and point you to correct source material.

[DirtyPierre]

Tobzalp et al.

Is it just me or does the "Voices of Reason" posts sound like the benevolent aliens (like the Asgards off Stagate SG1) have decided to help us mere mortals.

Sorry to sound cynical Voices of Reason, but we really could have used your help before the NAS mess started. Your reasoned argument and historical background make sense and its a pity some of it wasn't given to the ARG responsible for the airspace disaster we're in.

Maybe some of your posts and information could be given to ATSB and CASA so the airspace can be fixed.

Anyway, thanks for giving us the lowdown on airspace development history at the international level.

[Voices of Reason]

Dirty Pierre,

Points taken - and no, we are not "benevolent aliens" - we were pointed to your airspace debate by "interested parties" in your country who thought we might be able to offer assistance.

We have found that truth sometimes gets [deliberately or accidentally] covered-up, and buried in red-tape, so that untruths can flourish.

There is a powerful instrument used in the United States of America, and around the world, to cut through this "red tape subterfuge" - it is known as FREEDOM OF INFORMATION. It is usually relatively inexpensive to access any relevant information from government and semi-government organizations. BUT you must be specific in what you request.

Might we suggest that rather than exchange frustrations on this site - clearly not heeded by your airspace designers - that you access ALL of the information on which their decision making is based - you might be [very] surprised at what you uncover.

We would suggest two mechanisms. First, as we said - be very specific in your request. Do not simply ask for airspace documents - ask for documents relating to every name and iteration over the last several years. We think you have had NAS, Class G Demonstrations, LAMP, Airspace 2000 and so on. Make sure you ask for information at EVERY level in the organization - not just at senior executive level.

The second is to establish a credible [to you] framework in which to request and analyse the information - that could be done by partnering with an interested party - such as your aviation investigation body - or if you are serious, with a dedicated newspaper reporter. You might find that the latter is less manageble [obviously reporters have particular reasons for participating] - but might accelerate the process so that your aviation investigation body is DIRECTED to act [we suspect you will understand what we mean].

If we can be of assistance, please post accordingly.

[Voices of Reason]

We noticed that an exchange is taking place on a parallel site - dealing with proposed new radio procedures. We noted the detailed reference to incidents, and were surprised to see how many of those incidents were apparently resolved by ACAS systems - not design, and not procedures.

This is a very good example of mis-interpretation and mis-direction attempting to lead you AWAY from a point and not towards it.

As we indicated in previous postings, the use of ACAS systems as a system design tool is specifically and categorically discouraged - not only by the International Civil Aviation Organization - but also by ALL major States and Eurocontrol. Both the International Federation of AirLine Pilots Associations [IFALPA], and the International Federation of Air Traffic Controller Associations [IFATCA] have strong positions on the use of ACAS systems as anything other than last line of defence systems. Even the United States of America would not design a system that relies on ACAS systems. We suspect that a question to the right authority in the Federal Aviation Administration would validate this statement.

Your respondent cites numerous examples where the activation of ACAS systems - whilst preventing a collision - allowed aircraft to operate in dangerous proximity. ACAS systems can and do fail - witness the unfortunate accident at Uberlingen.

What we are saying is that you should NOT be bated by the seemingly "convincing" statistics - they are just that - statistics. We have looked at the web-site of your air investgaion body, and if we are correct, a classification of 4 or 5 means that your investigator was not overly concerned by the incidents.

And yet, in the same breath, your airspace design people are [seemingly] advocating a system that RELIES on ACAS systems to be effective.

We would play this straight back to your designers - challenge them to demonstrate how it can be a dangerous set of incidents on the one hand - yet a key safety design feature on the other.

[tobzalp]

Seriously. Who are/is WE?

What exactly are you trying to achieve?

[Voices of Reason]

Tobzalp,

WE work through every site in PPRuNe, from time to time, looking for areas where it is obvious that aviation safety is being challenged.

We change our "callsign" on each occasion - however, we maintain absolute consistency in our view that where safety is being challenged - OR where the industry is being subjected to excessive and unnecessary costs - OR where amenity or access is challenged unnecessarily - we will attempt to intervene.

We are located throughout the world - and we are of one mind - safety of aviation - but not at any cost. One life lost unnecessarily is one life too many. Aviation is an expensive business - but the consequences of mistakes in airspace design are very high.

[DirtyPierre]

Voices of Reason,

I like what you say and how you say it.

Maybe you could answer Dick Smith directly. Mind you he has been very slow in replying to any of your posts.

You still do really sound like the Asgards though. All very mysterious. Maybe you're the prophets from Deep Space Nine?

[Voices of Reason]

We have again been directed by respondents to certain sites, and have noted some of the debate over the re-classification of airspace – and the at times spurious arguments that are made for and against the proposed re-classifications. We would offer the following observations, based on ICAO processes, and based on “world best practice”.

Clearly, there is theoretically little or no difference in the levels of service provided between IFR aircraft operating in Airspace Classes A, B, C, D or E. We say theoretical, because in practice, there is a higher potential for tactical – rather than planned - response by IFR flights in relation to VFR flights in Class E airspace, which may impact the ability to offer, or the effectiveness of offered, separation services to IFR flights.

Where the differences occur, of course, is the interaction between IFR and VFR flights. By that, we mean that an IFR aircraft may require services more urgently [i.e., tactically rather than in a planned fashion] in Class E airspace because of the proximity of VFR flights, or may not be able to comply with a planned ATC instruction. This adds a level of complexity to the model – for both pilots and providers of services – something that needs to be factored in the holistic airspace design. That is not to say Class E should not be used – far from it – but it must be appreciated that Class E operates in a fundamentally different way than Classes A through D.

In any given volume of airspace, with the same number of IFR and VFR flights, the level of risk must increase when Class C airspace is changed to Class E [or Class D, or Class F or Class G for that matter]. Equally, a change upwards in classification, from Class C to Class B or Class A, for a given volume of airspace, with the same number of IFR and VFR flights, the level of risk is decreased.

As we have indicated before, the intent of the airspace classification system was to provide a menu of services whereby the levels of risk to all aircraft – but in particular IFR flights – could be maintained within an acceptable band – but without unduly restricting the amenity of VFR flights, and adding unnecessary expense to operators.

We do not dispute the fact that in many instances – and this has occurred around the globe – that the initial transition to the airspace classification system was done without conducting a risk analysis – or identifying what risks were being managed – before the “label” was assigned. This could, of course, result in levels of service that far exceed those truly required in a given volume of airspace. We suspect that this has happened in your country, as it has happened in others.

It will prove almost impossible to develop an airspace model where the level of risk to any particular aircraft or group of aircraft – IFR or VFR – is uniform. As we have mentioned in previous posts, having determined the risk levels, and appropriate classifications, you will need to “smooth” the model, by changing some classifications for the sake of simplicity and uniformity.

Now we need to clarify a point made direct to us by a respondent. We have indicated that the training material we have seen appears to hold ACAS systems and the use of transponders as an airspace design mitigation in Class E airspace. On further examination of the material, it would appear that there is no DIRECT statement to that effect, nor direct linkage – if we have misinterpreted the material, we apologize to the respondent and affected parties. We have noted, however, the consistent reference to the carriage and operation of transponders, and the illustrations of TCAS operation, and can only draw a strong inference that the intent is that aircraft carrying ACAS type equipment will be afforded some additional layer of protection in Class E airspace.

Let us be perfectly clear. There is no requirement in the ICAO airspace classification system for the carriage and operation of transponders, nor the use of ACAS type systems. The classifications stand or fall on their own merit. As we have pointed out previously, the operation of transponders within Class E airspace is only of use as a design tool where there is secondary radar coverage – to allow enhanced provision of traffic information by a third party. Transponder carriage and operation outside of radar coverage cannot possibly be used as a tool to enhance airspace design. Some States – such as the United States of America, and certain European States - have recognised that they have substantial secondary radar coverage, and have been able to factor that coverage, and widespread transponder carriage, in the assessment of risk, allowing Class E airspace to be used more widely.

We agree totally that it is of exceptional benefit, overall, to aviation safety, for aircraft to carry and operate transponders – but this is not to be used as a factor in the design of airspace, and may better have been omitted from your airspace debates, and implemented as a separate safety initiative.

[Capn Bloggs]

V of R:
We agree totally that it is of exceptional benefit, overall, to aviation safety, for aircraft to carry and operate transponders – but this is not to be used as a factor in the design of airspace, and may better have been omitted from your airspace debates, and implemented as a separate safety initiative.
Arrhh, yes. Had TCAS not been incorporated as a basic mitigator, we would not have AusNAS, at all. Even the fanatics (Dick Smith, Mike Smith, the two bills and boyd et al) would have conceded that. And therein is the problem.

[Voices of Reason]

Safety is complex - difficult in advance - so easy in hindsight!

We have been pointed to references in parallel posts about affordable safety. In the determination of appropriate airspace design, considerable weight needs to be placed on the cost, versus benefit, of any particular change. We note, with interest, that in most cases, the cost benefit analysis associated with the removal or reduction of service is substantially different from that where an increase in service is proposed. A good – and freely available – example of this is the United States of America Federal Aviation Administration’s document on tower establishment and discontinuance, where the presence of an existing service [a tower] makes it more difficult to discontinue or reduce a service.

It cannot be denied that whilst safety is an absolute imperative in aviation – it is not the only imperative, and needs to be balanced against a range of factors. Safety costs – and it needs to be paid for, most often by the users of the amenity themselves. So the notion of attributing resources to those areas where safety is most benefited is certainly supported. We must point out that in many legal cases, judges have found, in relation to safety, that where a safety action could have been undertaken at little or no cost, then such action should have been taken. Unfortunately, most of these observations are made post-factum. Many things are inexpensive with the benefit of hindsight.

We must also state that whilst attribution of safety resource for the protection of many should always be an objective, this should not come at the expense of those who, whilst choosing a knowingly or apparently dangerous activity, do not engage in that activity dangerously. By this we mean that the general aviation community does not believe that the activity it undertakes is inherently dangerous – no more than a motorist taking a “Sunday drive”. The belief by the general public that an activity is inherently less safe than any other activity should not be a reason for deliberately increasing levels of risk to that part of the aviation community. In short, achieving safety for the majority, at the inappropriate expense of a minority, should not be an airspace design outcome.

We have attached two relevant extracts, which may be of some interest. The first is an extract from “1997 WHITE HOUSE COMMSSION ON AVIATION SAFETY AND SECURITY THE DOT STATUS REPORT”

“...The Department of Transportation recognizes that in conducting benefit-cost analysis in aviation safety and security rulemakings, quite often there are both tangible and intangible benefits of a rule. It is also necessary to assess risks and examine potential mitigating measures. A key is not to wait for accidents to happen but to identify high-risk potential causes and act to address them before an accident occurs. The Department recognizes the importance of sound economic analysis when it comes to rulemakings, and that such an analysis includes taking into account both tangible and intangible benefits. Accordingly, the Department has instituted into its rulemaking practices a policy to ensure that costs alone are not dispositive in the rulemaking process....”

In responding to the challenge, the FAA sated: “...the Commission recommended that cost not always be the determining factor or basis for deciding whether to put new aviation safety and security rules into effect. Specifically, the Commission notes that the potential reduction in the fatal accident rate merits a careful weighing of the options for improving safety in terms of the benefits that go beyond those traditionally considered in benefit-cost analyses. However, we also believe that it is important to recognize that the recommendation (1) represents a significant departure from traditional processes, (2) could result in significant cost increases for relatively modest increases in the safety margin, and (3) could rest on a limited empirical justification. In effect, this recommendation may increase the number of instances in which the primary factor determining whether or not to go forward with a safety or security improvement is what might be referred to as a public policy imperative rather than the result of a benefit-cost analysis...”.

The second extract is from a New Zealand review report on the term “safety at reasonable cost”, which is a statement contained in New Zealand aviation legislation.

The Civil Aviation Act describes the Authority functions as "activities which promote safety in civil aviation at a reasonable cost". Reasonable cost is defined in the Civil Aviation Act 1990 as 'where the value of the cost to the nation is exceeded by the resulting benefit to the nation.' The provisions in the Act relating to "safety at reasonable cost", stem directly from the following Swedavia - McGregor recommendations:

"...The aviation safety goal is: that the civil aviation system takes all measures that would improve safety at reasonable cost, subject to the State meeting its minimum obligations under ICAO. Reasonable cost is interpreted as meaning that the cost to the nation is exceeded by the benefits to the nation. The aviation safety regulatory body should stop striving for improvement in safety at the point where the value of the next increment of safety is outweighed by the cost of achieving it...".

Implicit in these recommendations is a need to evaluate benefits and costs. In this context, Swedavia - McGregor recommended that:

"...Cost-benefit analysis should, whenever practicable, be a mandatory tool in the rulemaking process for discretionary areas...".

With respect to making of rules, the Act requires that the Minister or Director

"shall have regard to, and shall give such weight as he or she considers appropriate in each case to -
f.The costs of implementing aviation safety and security."

The Review observes that the CAA, in principle, applies the notion of safety at reasonable cost in assessing what it should do to achieve safety outcomes. CAA management understand, and are committed to, the concept of safety at reasonable cost. The CAA adopts a pragmatic approach. The CAA assesses suitability of the conduct of benefit/ cost analysis (BCA) where appropriate, and at other times aims to achieve safety at reasonable cost through the application of proven international best practice for safety standards and activities. The Review has referred already to the consultation processes in place to ensure that the views of industry participants are considered before decisions are made, particularly on Rules development.

Notwithstanding the above comments, the Review concludes that there is room for some improvement in the CAA's application of benefit/ cost analysis, particularly with regards to the conduct of benefit/ cost analysis during the development of Rules, and for other initiatives where this could be considered appropriate.

Where activities are mandatory, the issue becomes more one of cost effectiveness, that is, the achievement of outcomes at least cost. A full assessment of the management of CAA resources and costs is outside the scope of the current Review. However, some suggestions are made for some areas where the CAA might enhance its allocation of resources (see below).

While the Civil Aviation Act 1990 clearly refers to 'safety at reasonable cost', there is no requirement in the Act to complete a benefit/cost analysis. Even the development of cost data appears to be discretionary. Furthermore, it is unclear from the Act as to whether "the value of the cost to the nation is exceeded by the value of the resulting benefit to the nation" applies to the civil aviation regulatory function as a whole or to specific rules and activities, or both. There are both positive and negative aspects of conducting a benefit/ cost analysis.

On the positive side, a thorough benefit/ cost analysis requires the implications of a proposed rule to be assessed. It provides the decision maker with an objective tool. Once completed, it also provides a transparent basis for decision-making.

On the other hand, benefit/ cost analysis can be time-consuming and costly to undertake. A complex rule, for example, could involve several months' work and cost in the hundreds of thousands of dollars. A benefit/ cost analysis for a safety Rule also can generate high emotion, as it requires a value to be set for human life. The value for human life in aviation terms has not yet been established, and there are grounds for suggesting that the value of life used by other transport safety regulators (in particular Land Transport Safety Authority) may not be appropriate in the aviation sector.

The aviation community is very divided on the need for benefit/ cost analysis to be undertaken. Some claim that a benefit/ cost analysis should never be done, while others argue that a study should be done for every rule proposal. Most take a pragmatic middle-of-the road approach.

The Review supports a pragmatic approach to the use of formal benefit/ cost analysis. Major Rule changes that are expected to involve significant compliance costs should be subject to formal benefit/ cost analysis, to ensure that the requirement for benefits to exceed costs has been tested. However, minor changes may well not warrant a full analysis if the costs of undertaking the analysis would outweigh the benefits of the change or if the benefits of the change are readily apparent.

In other instances, if an ICAO standard leads to a rule change, under normal circumstances it would not be cost-effective to undertake a costly analysis given the provisions in the Act promoting harmonisation with ICAO. That said, however, it may be advisable for a benefit/ cost analysis to be undertaken for specific projects that result from a rule change, in order to determine options for compliance. An example of this is runway end safety area standards.

In order to determine the extent of analysis, including formal benefit/ cost analysis, that is required to evaluate a Rule change, an open and transparent rulemaking process is required that allows for discussion by interested parties. Recommendations can then be made to the Director who would then decide the scope of benefit/ cost analysis required.

Cost estimates for a new or changed rule are generally much easier than quantifying safety benefits. Therefore, it would be advisable to determine costs for all new rules. Industry can generally determine implications for respective sectors, whereas the CAA can complete cost estimates for regulatory implications.

[tobzalp]

Industry can generally determine implications for respective sectors, whereas the CAA can complete cost estimates for regulatory implications.

Which requires industry consultation ie the users. This did not occur in Australia.

[Voices of Reason]

We have noted responses – both on this site, and direct to us – regarding the use of airborne collision avoidance systems as airspace design mitigators, and have also been pointed to certain web-sites in your country – most notably a site hosted by your Department of Transport and Regional Services, for a project known as the National Airspace System. We were surprised to find the following relating to airspace design principles in documents on that site:



“…The following document was finalised on 14 December 2001 and details the original NAS Australia proposal. It was part of the report prepared by the ARG for the Minister for Transport and Regional Services in March 2002, which was considered and agreed to by the Government on 13 May 2002:

Airspace Architecture Design Principles [dated 14 December 2001]

The following principles provide the high level framework for the allocation of airspace classifications to Australian domestic and international airspace:

Situational awareness will be enhanced by third party traffic advice, by pilot reports or by electronic mean (a footnote explains that electronic means includes TCAS and ADS-B/CDTI);
…
Any safety analysis shall employ a methodology of comparative study of proven systems. Where this is not feasible, an ALARP/constrained cost – benefit methodology will be used;
…
In order to mitigate the risk of systemic (human) failure, airspace and procedures design must remain simple and logical, and must be supported by comprehensive training and education programmes.
…”



We have reviewed a number of ICAO documents, and provide the following extracts for clarification:



ICAO ANNEX 11:
SECTION 2.4: DETERMINATION OF THE NEED FOR AIR TRAFFIC SERVICES

2.4.1 The need for the provision of air traffic services shall be determined by consideration of the following:

a. the types of air traffic involved;
b. the density of air traffic;
c. the meteorological conditions;
d. such other factors as may be relevant.

Note:- due to the number of elements involved, it has not been possible to develop specific data to determine the need for air traffic services in a given area or at a given location. For example:

a. a mixture of types of aircraft of varying speed (conventional jet, etc) might necessitate the provision of air traffic services, whereas a relatively greater density of traffic where only one type of operation is involved would not;
b. meteorological conditions might have considerable effect in areas where there is a constant flow of air traffic (e.g., scheduled traffic), whereas similar or worse meteorological conditions might be relatively unimportant in an area where air traffic would be discontinued is such conditions (e.g., local VFR flights);
c. open stretches of water, mountainous, uninhabited or desert areas might necessitate the provision of air traffic services even though the frequency of operations is extremely low.

2.4.2 The carriage of airborne collision avoidance systems (ACAS) by aircraft in a given area shall not be a factor in determining the need for air traffic services in that area.



The words in paragraphs 2.4.1 and 2.4.2 of Annex 11 are “Standards” – standards employ the operative verb “shall”. A “standard” is defined by ICAO as “… any specification for physical characteristics, configuration, materiel, performance, personnel or procedure, the uniform application of which is recognised as necessary for the safety or regularity of international air navigation in accordance with the Convention; in the event of impossibility of compliance, notification to the Council is compulsory under Article 38.



ICAO DOCUMENT 9689 - MANUAL ON AIRSPACE PLANNING METHODOLOGY FOR THE DETERMINATION OF SEPARATION MINIMA
Aircraft equipped with airborne collision avoidance systems (ACAS)
3.8 It should be noted that, in accordance with the guidance given in Annex 11, the carriage of ACAS by aircraft within a region should not be used to justify a reduced separation minimum. However, the presence of such systems may be relevant when contemplating the application of reduced separations, as changes to the ACAS systems may be required in order to avoid an unacceptable rate of false alerts.



Whilst the use of ACAS systems as a design mitigator may be ambiguous in training material being distributed to pilots, there is clear reference to its use as a design tool in the design principles document. As we have stated on a number of previous occasions, under rules established by the International Civil Aviation Organization, such systems cannot be factored when designing airspace.

[Voices of Reason]

Members of our group have been engaged in airspace design work around the globe for many years, and whilst not experts, we have a reasonable amount of expertise in this area. Airspace design is an exceptionally complex discipline, and requires very careful analysis of all available data and information to form correct and sustainable technical outputs, and careful understanding of the operating environment in order to develop a socially and politically acceptable output.

In the course of reviewing material associated with our previous post to this site, we came across puzzling statements relating to the use of “reference systems” in airspace design. In the document on the Department of Transport and Regional Services website for the National Airspace System, entitled Airspace Architecture Design Principles (dated 14 December 2001), we found the following two statements:

“….The following principles provide the high level framework for the allocation of airspace classifications to Australian domestic and international airspace:
….Any safety analysis shall employ a methodology of comparative study of proven systems. Where this is not feasible, an ALARP/constrained cost – benefit methodology will be used…”.


And within the same document:


Safety Analysis
3.1 Methodology

ICAO provides two methodologies for “determining whether the system is acceptably safe”:
a. comparison to a reference system, and
b. evaluation of system risks against a threshold.

Comparison with a reference system is a relative method, i.e. all the relative characteristics of the proposed system are compared with the corresponding characteristics of a reference system, which has been judged to be safe. Provided that the proposed system can be demonstrated to be the same or better than the reference system in all safety aspects, then it may be assumed also to be safe…”

As the NAS draws on international best practice and the proven ATM system of North America, process a. above is the appropriate methodology.

3.2 Application

This “comparison with a reference system” process will be applied as follows:

REMOVAL OF DIRECTED FULL SAR TRAFFIC SERVICE IN CLASS G AIRSPACE. Primary reference: The existing Australian Class G system in the Northern Territory where IFR now operate on a self-announce basis in large CTAFs to 10,000’. Supportive reference: The USA FAA system where Class G extends to FL145 in low density traffic areas.
CLASS G TERMINAL AREAS. Primary reference: The existing Australian Class G system. Supportive reference: The Canadian Class G system in terminal areas.
CLASS E RADAR AND NON-RADAR ENROUTE AIRSPACE. Primary reference: The USA FAA system. Supportive reference: The existing Australian Class E airspace.
CLASS E RADAR AND NON-RADAR TERMINAL AIRSPACE: Primary reference: The USA FAA system. Supportive reference: The Canadian system.
CHANGE MBZ PROCEDURES TO CTAF/UNICOMS. Primary reference: The reference will be the USA FAA CTAF/UNICOM system. Supportive reference: The existing Australian CTAF system as used by scheduled services.




We believe that the basis for these statements in relation to ICAO and reference systems lies in out-of-context references to ICAO Document 9689 - Manual on Airspace Planning Methodology for the Determination of Separation Minima. That document was SPECIFICALLY DEVELOPED FOR USE IN THE DETERMINATION OF SEPARATION MINIMA IN CONTROLLED AIRSPACE, though it does also contain references to risk assessment methodologies outside of controlled airspace.


The NAS design principles document makes an assertion that “ICAO provides two methodologies for “…determining whether the system is acceptably safe - comparison to a reference system, and evaluation of system risks against a threshold…”. This is subtly out of context. ICAO Document 9689 actually states:

“….5.1 The safety of a system depends on a number of characteristics of the airspace (see chapter 3). When the relevant characteristics have been identified and quantified, there are two basic methods for determining whether the system is acceptably safe – comparison with a reference system; and evaluation of a system risk against a threshold.

5.2 Comparison with a reference system is a “relative” method, i.e., all the relevant characteristics of the proposed system are compared with the corresponding characteristics of a reference system which has been judged to be safe. Provided that the proposed system can be demonstrated to be similar to or better than the reference system in all safety-related aspects, then it may be assumed to be safe….”


Chapter 6 of ICAO Document 9689 specifically deals with the issue of comparison with a reference system. Paragraph 6.3 and 6.4 state:

“whatever reference system is chosen, it must bear a sufficiently close resemblance to the proposed system for any comparison with regard to safety to be valid. The levels of air traffic service provided in the reference and proposed airspaces, as defined by the ICAO airspace classifications, should be examined. The air traffic service in the proposed system should provide at least the same level of service as the reference system.

The minimum requirements for a reference system to be considered similar to a proposed system are:

a. Separation minima should not be less in the proposed system than in the reference system;
b. proposed means of communication and surveillance must be no worse in terms of accuracy, reliability, integrity and availability than those of the reference system;
c. frequency and duration of the application of minimum separation between aircraft must not be greater in the proposed system than in the reference system; and
d. navigation performance [typical and non-typical] of the population of aircraft in the proposed system should be no worse in its effect on collision risk, in any dimension, than that of aircraft in the reference system”.

Paragraph 6.8 then states:

“Once a reference system has been chosen, the airspace planner must perform the following steps to evaluate the relative safety of the two systems:

1. describe in detail the differences and similarities between the two systems. This must be done for all of the criteria in Chapter 3 [refer extract below];
2. For each criterion, assess how any differences between the systems would affect the risk. This can be done using mathematical techniques and/or using operational judgment. However, care must be taken to identify situations where the effect on collision risk is counter-intuitive. For example, an increase in lateral navigation accuracy, whilst decreasing collision risk in the lateral dimension, could actually increase the risk of a collision in the longitudinal or vertical dimensions. Furthermore, where risk is dominated by the occurrence of large operational errors, an increase in lateral navigation accuracy may even increase the lateral collision risk;
3. For each criterion, ensure that the proposed system is at least as safe as the reference system. Alternatively, a trade-off between factors, which are worse, and those which are better than the reference system, may be possible.


Chapter 3 of ICAO Document 9689 states, verbatim:

CHAPTER 3

DESCRIPTION OF THE CURRENT AIRSPACE AND THE CNS/ATM SYSTEMS

DETERMINING SEPARATION MINIMA

3.1 In determining appropriate separation minima, the airspace planner must have a thorough knowledge of the existing airspace, the CNS/ATM capabilities and the airspace characteristics, which may influence the safe separation minima. There are a number of factors that may influence the separation minima and these include:

3.2 Airspace structure:

a) route structure, e.g. the use of parallel or non-parallel ATS routes and whether they are bi-directional or unidirectional;

b) existing separation minima and how often values close to the separation minima are used in practice;

c) complexity of the airspace, including inter alia:

1) traffic demand pattern,

2) numbers and locations of crossing tracks,

3) amount of traffic operating on opposite direction tracks,

4) amount of traffic which is either climbing or descending,

5) nature of the aircraft population, i.e. the diversity of traffic with respect to aircraft performance and equipage (e.g. mix of various speeds, climb performance, desired optimal flight levels),

6) peak and average traffic demands versus system capacity,

7) runway capacities and the limitations of associated ground services,

8) any adjoining special-use airspace, airspace usage and types of activities including the civil/military mix, and

9) regional meteorological conditions (e.g. the prevalence of convective storms etc), and

d) designated airspace classifications.

3.3 Communication capability:

a) direct controller/pilot voice communication (VHF/HF/SATCOM);

b) indirect controller/pilot voice communication (HF);

c) controller/pilot data link communication (CPDLC);

d) controller/controller voice and automated data link communication, both inter and intra ATS unit(s);

e)data link between ground ATC automation systems and aircraft flight management computers; and

f)system availability, reliability and capacity;

3.4 Surveillance capability:

a) procedural dependent surveillance:
1)content of pilot position reports, and
2)reporting intervals;

b) automatic dependent surveillance (ADS):
1) basic update rate,
2) display accuracy,
3) ADS contract (e.g. events triggering increased reporting rate),
4) sensor accuracy,
5) system reliability, and
6) end-to-end communications time capabilities; and

c) independent surveillance (radar):
1) type of sensor (primary or secondary),
2)coverage area,
3)processing and associated delays,
4)accuracy of measured position after processing,
5)update rate,
6)display accuracy, and
7)system reliability.

3.5 Aircraft navigation performance:

a)required navigation performance (RNP);
b)typical and non-typical performance (e.g. MASPS/MOPS), (RTCA SC181 documents refer); and
c)time-keeping accuracy.

3.6 Flow management capability (ability to control traffic input to ATC):

a) strategic air traffic flow management;
b) tactical air traffic flow management;
c) ad hoc ATC “in trail” restrictions or enhancements; and
d) procedural restrictions (e.g. through local operating procedures).

3.7 Air traffic management tools to reduce controller workload or improve controller intervention capability:

a)automated controller planning tools, including conflict prediction and resolution;

b)controller displays; and

c)out-of-conformance alerts (3-D) (i.e. automatic systems which alert ATC to any deviation of an aircraft from its nominal path).




The Department of Transport and Regional Services web-site makes the following statement in relation to the design principles document:


“…The following document was finalised on 14 December 2001 and details the original NAS Australia proposal. It was part of the report prepared by the ARG for the Minister for Transport and Regional Services in March 2002, which was considered and agreed to by the Government on 13 May 2002…”


We have not seen any evidence in publicly available material that any such detailed comparative analysis had been carried out in providing advice to your airspace administrators.


If this is the case, then it is entirely possible that misleading or incorrect information may have been provided to your Minister for Transport and Regional Services, and that may have prompted incorrect decision making processes.

[Voices of Reason]

We have seen repeated reference to airspace management based on world’s best practice, and the use of an airspace system based on practices in North America – notably the United States of America and Canada.

There are a number of technical publications which outline the principles and processes for airspace design and management used by the Federal Aviation Administration of the United States of America. These are freely available, both on the internet and direct from the address at the end of this post. We have reproduced below a [relatively] short description of the airspace management process used by the Federal Aviation Administration, as published in the Airspace Management Handbook.


THE AIRSPACE MANAGEMENT HANDBOOK

The Airspace Management Handbook has been prepared primarily for the specialists in the field who may have to initiate or participate in the process of making changes to the airspace structure. …….. Included in the guidelines are references to other, more-detailed documents that provide even more amplification on some elements of the airspace management process.

OUTLINE FOR HANDBOOK

1. CHARACTERIZE PROBLEM
Problems with airspace design or structure are often identified internally from within the Federal Aviation Administration (FAA) or by sources external to the FAA such as National Airspace System (NAS) users, airport authorities, or communities. In most cases, the FAA field facility that is affected by a problem or its solution will have primary responsibility for examining the issues. FAA Headquarters will probably be responsible for issues that involve multiple regions or national airspace. Characterization of the problem is crucial since it sets the stage for the subsequent phases of study. It is important to ensure that problem characterization does not repackage the original issue, but rather determines the true nature of the problem and extracts the root cause. The approach for characterizing a problem should be tailored to fit the situation. The approach can be very simple, relying heavily on anecdotes and judgment, or it can be a sophisticated application of tools to analyze data. In all cases, some analysis will be required along the lines of the basic principals of the scientific method. Problem characterization can be an iterative process, with the possibility that any new investigation could open additional questions about the nature and extent of the problem. Step 1 can also be interactive with Step 2, Initial Evaluation. See the Guidelines, Step 1, for a more detailed discussion of problem characterization.

2. PERFORM INITIAL EVALUATION
Not all problems or issues identified with the use of the NAS need to be resolved through a change in the airspace structure. As described in Step 1, the characterization of some perceived problems shows that they are not problems at all. Many real problems can be resolved without resorting to changes in the airspace structure. As with all problems, NAS problems should be resolved in an expeditious manner with the least amount of effort and resources expended. Only when it is clearly indicated should changes to the airspace structure be considered. Initial evaluation is performed to develop various alternatives to solve the problems and to support (justify) necessary action. The initial evaluation process usually begins at the field facility where the problem is perceived to exist, or where the proposed operational change would have the greatest impact. The initial evaluation, and possibly the resolution, can sometimes be conducted by a small group of people, based on their expert judgment and knowledge of the circumstances. See the Guidelines, Step 2, for a more detailed discussion of the initial evaluation process.

3. INITIATE AIRSPACE STUDY
If an airspace study is to be performed, then an airspace design team must be formed. The airspace design team is named by the cognizant regional airspace manager, or the lead organization for the airspace analysis. The airspace design team drafts the charter for the proposed study. Charter development assists the airspace design team in determining if additional membership is needed, including outside stakeholders. The draft charter for the airspace study will be provided to FAA Headquarters for review and coordination. The first task of the expanded airspace design team (which may now include stakeholder representatives, members from other regions, and perhaps a member from ATA-200 as well as other FAA Headquarters organizations), is to develop a comprehensive study plan. The scope of the study should generally correspond to the complexity of the proposed change, the number of facilities involved, and the potential impact of the proposed changes. See the Guidelines, Step 3, for a more detailed discussion of how to initiate an airspace study.

4. CONDUCT AIRSPACE STUDY
Every study should begin with a re-statement of the problem. This statement must be able to be clearly understood by all. The study team should be specific when documenting the issues. A specific statement of the primary issues is easier to understand, and makes it easier to plan subsequent analyses. A formal written statement of the problem is required. The most important ingredient to the successful airspace study is the appointment of a single, capable study manager to ensure all the study goals are met. If there are complicated and unique issues surrounding a study, the study team should take advantage of ATA-200 or the National Airspace Laboratory for assistance in the development of assumptions or alternatives, collection of data, or determination of metrics.

a. revalidate problem statement
b. select and define metrics
c. identify alternatives
d. determine type of analysis
e. select tool(s)
f. obtain input data
g. define baseline and alternative scenarios
h. adapt, calibrate, and validate model
i. make production runs
j. analyze model output
k. perform sensitivity analysis
l. conduct human-in-the-loop testing and evaluation

5. SUMMARIZE AND PRESENT RESULTS
The analyses performed, and the conclusions and recommendations derived from those analyses, should be documented in a formal study report. The formal study report should specify recommended airspace actions, sector realignments, route adjustments, and procedural changes necessary to implement the recommendations. An example outline for the study report is included in the guidelines. A formal study report is important because it conveys the key findings of the study to decision makers and stakeholders. A study report also documents the analysis and recommendations for historical reference. See the Guidelines, Step 5, for a more detailed discussion of preparing the final study report.

6. PLAN IMPLEMENTATION AT FIELD FACILITY
Careful consideration of actions necessary to implement recommended airspace changes should be a part of the overall planning process. Although implementation issues ought to be considered throughout the study process, detailed implementation planning should begin immediately after approval for the airspace change. Careful implementation planning is necessary for airspace changes to avoid any interruption of air traffic services, to minimize any disruption of air traffic, and to communicate what airspace changes are to occur. Facilities implementing an airspace change should develop an Implementation Plan and a Transition Plan, which should together lay out an achievable schedule and describe the steps required to successfully coordinate and enact the change. Involvement of the users is imperative in developing the Implementation and Transition Plans, and in actually implementing the airspace changes. See the Guidelines, Step 6, for a more detailed discussion of planning the implementation of airspace changes at the field facility.

7. EVALUATE IMPLEMENTATION
Airspace changes should be evaluated after implementation to measure their success. Once in place, changes to the National Airspace System should be assessed to verify that the objectives specified in the Implementation Plan are achieved, to provide lessons learned concerning the process, and to ensure improved service to users of the National Airspace System. See the Guidelines, Step 7, for a more detailed discussion of post-implementation evaluation of the impact of changes.

Further information can be obtained from:

FEDERAL AVIATION ADMINISTRATION
OFFICE OF AIR TRAFFIC AIRSPACE MANAGEMENT
PLANNING AND ANALYSIS DIVISION (ATA-200)
800 INDEPENDENCE AVENUE, SW
WASHINGTON, DC 20591

[Woomera]

Voices of Reason

Thanks for spending the time and keep it coming, it is great to see professional reason in the face of amateur rhetoric.

[Voices of Reason]

Woomera,

Thank you.

Without wishing in any way to insult or discourage participants in this forum, we have found that whilst subjects such as airspace design can become extremely emotive and at times personal, that emotive argument is next to useless when trying to influence the changes that caused the emotional responses. It would appear that the emotive arguments in other threads on this site, whilst passionate, are having little or no effect.

We find it far better to [try to] remain dispassionate, and to use facts and the truth to achieve our ends. That is why we have placed so much information at your respondents' disposal.

We hope that in the posts that we have made, your respondents will have seen how (relatively) easy it is to find factual information - and to use that information to argue their case. In dealing with Government and its agencies, what is not available in the public domain can be easily obtained through access legislation, such as Freedom of Information.

Let us be clear - we support airspace reform wherever it will derive benefits to the user community - without compromising safety, and without unnecessarily impacting user amenity. Such reforms must, however, be done in an open and inclusive manner, to ensure that they can be implemented safety and effectively.

[DirtyPierre]

Let it be made clear to all those who think that Australian ATCs are opposed to NAS because we are trying to save jobs that this is utter bull!

Australian ATCs have worked on all the airspace reform projects, AMATS, Airspace 2000, G Demo, NAS, etc. Australian ATCs have a clear, and deep understanding of the implications of any airspace or procedure change.

Australian ATCs are not opposed to airspace reform where it is a clear benefit to the the Australian community, "without compromising safety and without impacting user amenity".

Perhaps those that continually use emotive or dismissive arguments should also stick to the facts.

Et tu Brute.

[Capcom]

Thankyou (Whoever you are)!;)

All the processes we knew were required, none of which have been undertaken!:hmm:

What if any power does ICAO hold to lobby/recommend for corrective action as Australia is a signatory to the convention?:E

[Voices of Reason]

Dirty Pierre et al,

We suspect that you may have misinterpreted our comments – and if we have offended, we apologize. In the course of this thread, we have accessed or have been provided with access to material that clearly indicates that service provider readiness for all airspace changes that have occurred in your country has been exemplary. That means that training material has been readied, delivered, and received well in advance of implementations, and that ATS staff have been operationally – if not emotionally – supportive of all changes. That is clearly evidenced in reports from your Air Transportation Safety Board and its predecessor [we assume] the Bureau of Air Safety Investigation – in particular a report we found on the Class G Demonstration. Such levels of readiness could not, in our experience, be achieved without a great deal of cooperation and collaboration from ATC and support staff.

The points that we were trying to make were simple. We have watched countless responses posted on PPRuNe – not simply in the Australian airspace debate, but on other controversial issues in many countries – where respondents have bemoaned the fact of a change that they do not support and have expected that that would precipitate a return to past practice.

More often than not, assembly of a succinct but factual argument, well presented and well supported, will achieve far more.

In reviewing threads in this site over the last 12-18 months, we have seen pieces of information that, if properly assembled, and placed in correct context, may have achieved your desired outcome.

Unless there is an imminent safety risk [and despite the rhetoric, we do not believe such a risk currently exists], we do not – and cannot – intervene directly. We can provide you with sufficient background material to allow you to assemble your own arguments, and submit those to appropriate authorities.


CapCom,

Despite its aura, the International Civil Aviation Organization hold power only by right of member States - that is, States decide to adopt, or otherwise, ICAO Standards. In that sense, ICAO is powerless. Article 1 of the Chicago Convention states: "The contracting States recognize that every State has complete and
exclusive sovereignty over the airspace above its territory". That effectively allows a State to determine its own rules, should it so choose. Article 38 of the Convention requires States that choose to implement Standards that differ from ICAO, to notify those differences.

The United States, for example, has notified ICAO that the levels of service provided in Class G airspace are different to those specified in ICAO Annex 11 - in particular, they have notified that they do not provide certain services to IFR flights as required by ICAO standards. The supplements to Annexes report all of the differences notified to ICAO - it is interesting just how many States do not follow ICAO fully - and do not practice "world's best practice". We are sure that there is an appropriately stocked aviation library in your country that would be able to provide this information to you.




On another matter, we noted in documents accessed from the web-site of the Department of Transport and Regional Services, that statements are made in relation to "harmonisation" of procedures between the United States and Canada. In fact, examination of the airspace management rules of both countries shows that there are substantial differences in application of airspace classifications and procedures between the countries - to the point where special procedures needed to be developed to allow the handling of air traffic in the cross-border regions between the United States and Canada. Effectively, between them, the two countries apply three sets of airspace management procedures.

[Capcom]

Da’ Voice’s

I should have explained the rhetorical nature of the question i.e.
They claim that AusNAS is “worlds best practice” and in line with “international standards”, yet it is clear that the proponents claim to ICAO commonality (Legitimacy) is scurrilous at best!Unless there is an imminent safety risk [and despite the rhetoric, we do not believe such a risk currently exists], we do not – and cannot – intervene directly.That surprises me!
You seem aware that due safety analysis of volumes has not been undertaken yet “believe” such a risk does not exist. Try as I might, I cannot reconcile that one!:uhoh:

If an imminent safety risk is proven i.e. ATSB report 200305235 Launceston and others, then what action should you take or does that not qualify as an “imminent safety risk”?.:rolleyes:

We can educate Pilots and Air Traffic Controllers till the cows come home, it will not change a thing, in so far as has been pointed out numerous times, everyone can be doing the right thing and a collision (Including RPT) can still result within volumes of airspace that was "C" (positive clearances and separation) now non- analysed “E”!
An imminent safety risk if ever there was one don’t you think?:hmm:

Edited to better explain where the risk exists!

[Voices of Reason]

The United States Aircraft Owners and Pilots Association – US AOPA – represents more that 400,000 pilots. Their web-site is easily located: www.aopa.org. On that website, member or not, you may access a range of interesting material. One sub-site that may be accessed from the main AOPA site is the AOPA Air Safety Foundation. The AOPA Air Safety Foundation is a “ …non-profit, tax exempt organization promoting safety and pilot proficiency in general aviation through quality training, education, research, analysis, and the dissemination of information…”.

The Air Safety Foundation site contains a range of excellent material, including on-line courses, safety topics, and accident analysis.

In the Airport Operations section of that site, you may freely access a document entitled “Operations at Non-Towered Airports”. This is a 16 page document that describes how pilots – IFR and VFR – should operate at the 12,000 non-towered airports in the United States. It is highly recommended that you access that site and document, and read the entire publication. Following are extracts that may encourage you, in the interests of safety, to access the site:




“….Nontowered airports—it’s a shorthand way to refer to airports not served by operating air traffic control towers, and that includes most of the airports in the United States. At present, some 12,000 airports are nontowered, compared to approximately 400 that have FAA towers. Millions of safe operations in all types of aircraft are conducted at nontowered airports in a variety of weather conditions. It works because pilots put safety first and use commonly known procedures….

….Right-of-way rules, and nontowered airport traffic patterns and procedures, exist for only one purpose—to prevent collisions in the air and on the ground. There are other benefits to adhering to the rules, such as an orderly traffic flow, noise abatement, and defusing potential right-of-way conflicts, but traffic separation is the prime concern…..

….Communication: VFR charts depict towered airports in blue, and nontowered airports are shown in magenta. The basic difference between operating at a tower-controlled airport and one without an operating control tower is the difference between instructions and advisories. Tower controllers issue taxi, departure, and arrival instructions for pilots to follow on specific air traffic control frequencies. At nontowered airports, you will hear advisories on a CTAF, but the responsibility for collision avoidance, sequencing, and knowing the local procedures lies solely with the pilot…..

….Safety Tip: All aircraft should monitor the CTAF when operating in the vicinity of nontowered airports…..

….Nontowered airports without a flight service station (FSS) generally will have a unicom frequency. These usually are staffed by fixed-base operation (FBO) employees who provide airport information. The unicom is usually the CTAF…..….Note: Unicom operators are not required to communicate with pilots, and if they do, there are no standards for the information conveyed…..

….Nontowered communication is not always easy, though, especially in metropolitan areas where there never seem to be enough frequencies to go around. It’s not unusual for several airports within radio range to share the same CTAF. The result is an aeronautical party line traveling at more than 100 knots…..

….Safety Tip: The CTAF should be used for two reasons only: Collision Avoidance, Airport Advisory…..

….Listening to a busy CTAF for only a few minutes will reveal too many long-winded conversationalists. Don’t use this vital collision-avoidance resource for aircraft or lunch scheduling, formation flying, saying hello to old friends on the ground, discussing sports scores, or expressing your displeasure at the guy who just pulled out on the runway while you were on short final…..

….Safety Tip: ASF recommends that pilots of no-radio aircraft use a hand-held transceiver at busy nontowered airports. This is an essential piece of safety gear…..

…..Collision Avoidance: At nontowered fields, it’s possible that pilots in noradio aircraft are shooting landings, IFR students and their instructors are practicing instrument approaches, helicopter pilots are perfecting their autorotation skills, or sailplanes are floating overhead. Not all pilots in the area are announcing their positions and intentions on the CTAF, or even looking out the window!.....

…..Midair collisions are the primary hazard associated with flying at nontowered airports. Most midair collisions occur in clear weather within 5 miles of an airport and below 3,000 feet, which is where aircraft congregate. Most collisions occur on final approach, generally with a faster aircraft overtaking a slower one. See ASF’s safety advisor on Collision Avoidance, www.aopa.org/asf/publications/sa15.pdf/.......

…..Safety Tip: An aircraft on a collision course will have no apparent movement relative to you, and the target will “blossom” just a few seconds before impact. Survivors of midair collisions frequently have no recollection of seeing the other aircraft. It is easy to lose a target in the ground clutter—be at pattern altitude before entering the pattern……

…..Collisions also occur on the ground, both on taxiways and runways. This is a problem at dusk, night, or during periods of low visibility. In calm or nearly calm wind conditions, be especially cautious. Another pilot may choose a different runway from the one you have selected. If the runway has a blind intersection or you cannot see the opposite end, be prepared. Remember that not everyone is on the CTAF……

…..Departing the Airport: When departing a nontowered airport, monitor and communicate on the CTAF from engine start until you’re 10 miles from the airport, so you’ll be aware of other traffic that could conflict with your route. The exception is if you need to switch frequencies after departure to talk to ATC or an FSS specialist……

…..Safety Tip: Remember to scan for traffic while talking on the radio……

…..Safety Tip: Air carrier aircraft and many larger aircraft seem to make more straight-in approaches than light singles. In many cases, they cannot fly a pattern much slower than 120 knots, which is faster than the cruise speed of most trainers. They might not see you, and although there may be cases where they should yield right of way, they sometimes don’t. Pursue the discussion on the ground, not on the radio……

…..A situation that poses special risks is when a nontowered airport is blanketed by a broken or overcast cloud ceiling or visibility is reduced—due to haze, for example—yet VFR conditions exist below the cloud layer. In that case, it’s possible for a pilot flying an actual IFR approach in the clouds to break out below the ceiling and suddenly encounter a VFR pilot turning base for a practice touch and go. It helps if both pilots are diligent in communicating on the CTAF, but even that doesn’t guarantee against a conflict on the final approach, because they can’t see each other until the IFR aircraft has descended below the cloud layer…..

…..Safety Tip: If possible, monitor the IFR approach frequency simultaneously with the CTAF, if your aircraft has more than one radio. It can provide valuable warning as to when an IFR inbound is about to pop out of the clouds…..

….The way to fly safely at nontowered airports is to REACT:

Radio - Listen to the automated weather observations, if available, and the common traffic advisory frequency (CTAF) for airport information and traffic advisories.

Eyes - Use them! Look for other traffic. This is the top priority when operating in the vicinity of a nontowered airport. Use landing lights so other pilots can see you more easily.

Announce - Report your position and intentions using standard phraseology.

Courtesy - A little courtesy will smooth out most problems. The “me first” attitude can be dangerous and rude.

Traffic Pattern - Follow the recommended procedures. before you fly. Research the necessary information about your departure and destination airports.




There are many other valuable documents which may be of interest – in particular a document entitled: “Collision Avoidance – Strategies and Tactics”. It contains, amongst other tactics, the following statement:

“…Become a target: If you operate an aircraft without radios or transponders, consider installing them….”

“HEAD TO HEAD” by Bruce Landsberg (From AOPA Pilot, January 2000.)

Midair collisions are one of the few types of accidents where seconds of inattention can lead to disaster. Everything is normal and then, in a split second, one or both aircraft may be out of control and spinning earthward. Fortunately, these collisions are relatively rare. In 1998 there were 14. Small details play significant roles in the accident chain, and in the case below, a transponder figures prominently.

On April 4, 1998, at about 10:34 a.m. Eastern Standard Time (EST), a Cessna 525 (CitationJet or CJ) and a Cessna 172 collided over a residential area in Marietta, Georgia. The CJ had departed from the Dekalb-Peachtree Airport at about 10:30 on an instrument flight plan to Harrisburg, Pennsylvania. According to radar data, the 172 departed Mathis Airfield, near Cumming, Georgia, at about 10:25. The 172 was on a power line patrol and did not file a flight plan.

Visual meteorological conditions prevailed at the time of the accident. The visibility at nearby reporting stations ranged from seven to 10 miles, with broken to overcast skies varying from 2,800 to 3,100 feet agl. Radar information showed that the collision occurred at 3,425 feet msl. This was approximately 2,400 feet agl or just about 500 feet below the clouds.

After takeoff, ATC assigned the CJ 3,000 feet and a heading of 280 degrees. At 10:33:01, ATC cleared the jet to a heading of 360 degrees with a climb clearance to 14,000 feet. According to radar data, the CJ had just vacated 3,000 feet msl and was passing 3,400 feet msl when a primary target merged with the radar target of the jet. The CJ pilot’s acknowledgment of the climb clearance was interrupted at about 10:34.

The Atlanta ATC radar showed a primary target (radar energy reflected from the skin of the airplane without electronic enhancement; i.e., no transponder) beginning at 10:25:07. The target appeared approximately two miles southwest of Mathis Airport and traveled to the southwest, intersecting the flight path of the CJ at the collision site.

At about 10:34, the 172 contacted the Dobbins Air Force Base Tower and identified itself as Seven-Whiskey-Delta. The controller responded, "Seven-Whiskey-Delta, Dobbins Tower." The aircraft replied, "Good morning, sir, Seven-Whiskey-Delta, Cessna One-Seventy…." The controller stated, "Seven-Whiskey- Delta, you were cut out." No further transmissions were received from the airplane, and the controller was unable to reestablish contact.

A reconstruction of the accident sequence based upon radar data showed that the CJ was tracking north, while the primary target that merged with the CJ target exhibited a southerly track with an approximate closure rate of 300 knots. A study was done to determine how long each pilot might have had the other aircraft in sight, based on radar data.

The data plots indicated that the 172 was either behind the CJ’s center windshield post or may have been visible to the right of the center windshield post for 35 seconds prior to collision. The plots indicate that the CJ would have been visible to the 172 pilot in the lower left quadrant of the pilot’s windshield somewhere be-tween 35 to five seconds before impact. The 172 was in level flight and collided with the climbing jet at an angle of about 52 degrees to the left of head-on.

The CJ came to rest inverted in the rear of a residence, and the 172 crashed inverted about a half-mile away. The commercial pilot of the 172, the airline transport pilot of the CJ, and the CJ’s three passengers were killed.

The wreckage of the CJ was scattered over an area of approximately 1.5 square miles. The horizontal stabilizer, elevators, and the top one-quarter of the vertical stabilizer separated from the airplane. Black tire marks were found on the vertical stabilizer leading edge. A small five-inch-long section, separated from the outboard end of the left horizontal stabilizer leading edge, was crushed aft, forming a tight three-inch-diameter U shape. This section was among the first debris located on the wreckage path. Additionally, blue paint that was similar to the blue paint of the 172 was found on the leading edge of the horizontal stabilizer. All of the fractures to the empennage exhibited overload failures.

The 172 wreckage was also scattered over an area of approximately 1.5 square miles. Witnesses observed the aircraft hit trees before reaching the ground. The wreckage burned in a post-impact fire. There was evidence of metal scrape marks on the underside of the tail cone. The nose landing gear, which was found with the main wreckage, exhibited fire damage. The upper strut housing evidenced an indentation between five and seven inches below the upper end of the strut. The indentation on the outboard left horizontal stabilizer leading edge of the CJ matched the indentation on the nose landing gear strut housing of the 172.

The CJ pilot held a type rating for single-pilot operation of the jet with 1,825 hours’ total flight time and 86 hours in the CitationJet. He had learned to fly in 1994 and moved rapidly through a series of high-performance aircraft, including a Beech 60 Duke and a Beech 90-series King Air. The pilot’s instructor, who had trained him from the beginning and attended FlightSafety International CJ training with him, described the pilot as highly qualified, competent, and detail-oriented. The pilot had enrolled in a CJ proficiency course that required attendance every three months.

The pilot of the 172 held commercial pilot and flight instructor certificates, as well as a mechanic’s certificate with airframe and powerplant ratings. He had logged almost 14,000 hours and in August 1997 had completed a flight review in the accident aircraft. FAA records indicated that the pilot’s certificate had been suspended on three occasions. In 1987, he received a 30-day suspension for a violation involving minimum safe altitudes. He received another 45-day suspension in 1990 regarding an ATC clearance for operations in Class B airspace.

In 1993, a 60-day suspension was given for violation of various sections of FAR Parts 23 and 91 that dealt with miscellaneous markings and placards on the airplane, airman certificate requirements, careless operation, and airworthiness of the airplane.

The 172 pilot’s power line patrol contract required that the pilot adhere to FAA regulations on certification of aircraft, special permits, etc., and that the surveillance aircraft must have an observer on board at all times. The observer’s job was to look at the lines while the pilot flew the airplane. According to the power company maintenance manager, who maintains the lines, if a pilot were discovered conducting surveillance flights without an observer, he would be counseled first and possibly terminated from employment if the action were repeated.

The pilot’s power line patrol records, however, showed multiple flights that did not reflect an observer, or "self" was recorded in the observer block.

The accident investigation team determined that the 172’s transponder function switch was in the Off position. The unit was returned to the manufacturer for testing. The ATC code switch wafers were burned but readable. The wafers and the function switch were compared to an undamaged unit that corresponded to a VFR code of 1200 and Off.

The pilot’s son, who had flown often with his father, stated that because of the type of flying involved, his father would leave the transponder in the Off position during normal flight until he approached airspace in which he needed the transponder. At that point, he would turn on the transponder before entering the airspace. According to FAR 91.215, the Cessna 172 was required to have an operating transponder while flying within the "Mode-C veil" extending 30 nautical miles from the Atlanta Hartsfield International Airport—and the accident occurred within this veil.

During interviews, the air traffic controllers stated that they did not observe the primary target associated with the 172 and therefore did not provide advisories to the CJ pilot. As mentioned earlier, the 172 was not in contact with ATC despite a call just before the collision occurred. In visual conditions, ATC will call observed traffic on a time-permitting basis to aircraft for which it is providing radar service, but that is not guaranteed. The controller’s handbook states, "Additional services are provided to the extent possible contingent only upon the controller’s capability to fit them into the performance of higher-priority duties and on the basis of limitations of the radar, volume of traffic, frequency congestion, and controller workload."

The workload in a single-pilot cockpit, regardless of aircraft type, can be significant. Even momentary and necessary distractions such as tuning a radio or programming the autopilot may mean less time for looking outside. The CJ pilot’s instructor reported that the FlightSafety training course recommended the use of the autopilot as soon as possible after takeoff, to reduce the workload (wheels up, flaps up, autopilot on). According to the instructor, to initiate a climb in the CJ with the autopilot engaged involves looking down, locating and turning the altitude select knob, checking the readout on the electronic attitude primary flight display, and then rotating the pitch wheel to begin the climb.

A pilot familiar with the aircraft can do this by feel, since the controls are differentiated by feel and the EADI altitude readout is just below the glareshield. The distraction, by design, is minimal to enhance single-pilot operation. FlightSafety also recommended that the aircraft recognition lights be illuminated below FL180. It is not clear from the accident report whether they were in use.

When on a collision course, the target aircraft with which you are converging will appear to remain stationary. It just "blossoms" suddenly in the windshield, assuming the pilot is in a position to see it at all. A closure speed of 300 kt equates to five miles per minute and allows little time to identify a threat and react.

This accident chain involved failure to follow procedures requiring an observer, high closure speeds, operation without a transponder, not using VFR flight following, and aircraft structure that may have blocked the other airplane from the pilot’s vision. An aircraft operating without a transponder in high-density airspace may not only be illegal, but it may also deprive the ATC system of an opportunity to spot a threat that the pilots involved could not.

Talking and squawking will help when scanning alone may not do the job.

[Voices of Reason]

One of the respondents to a parallel thread on this site has cited a number of statistics and incident reports to demonstrate a point. We have previously cautioned against the validity of these arguments, as it is exceptionally difficult to place these incidents and causal factors in context. Statistics can be used to tell many different stories. As a very simplistic example, we provide the following:

The US AOPA Air Safety Forum site contains a collaborative link to the United States National Transportation Safety Board database, and enables viewers to access accident data tracking back to 1983.

The ASF data relates strictly to ACCIDENTS involving FIXED WING AIRCRAFT OF 12,500 POUNDS [5,700 KILOGRAMS] OR LESS in the United States of America.

A basic search of that database for the LAST TEN (10) YEARS found the following statistics:

Accidents where there were no injuries: 8818
Accidents where there were minor injuries (as the highest outcome): 2540
Accidents where there were serious injuries (as the highest outcome): 1724
Accidents involving fatalities (as the highest outcome): 3432

Total accidents: 16,514

This means that on average, there are 1,652 accidents per year in the United States, involving fixed wing aircraft of 5700 kilograms or less. On average, there are 343 fatal accidents involving fixed wing aircraft of 5700 kilograms or less per year.

A claim that has been made in your airspace design debate is that the United States represents best practice. This would seem to indicate that by the logic of your NAS architects, US accident rates of 1652 per year, and fatal accident rates of 343 per year are acceptable.

In (very) simplistic terms, if, as has been stated in documentation relating to your airspace debate, the amount of traffic in the United States is 20 times that of Australia, then using the logic of a proponent of airspace change in your country, an accident rate of 1652 divided by 20 – or 83 accidents per year - would be an acceptable safety target in Australia. That would translate to 17 being an acceptable target number of fatal accidents (involving light [GA and commuter] aircraft) per year.

Now, it is reasonable to assume that a fatal accident involves at least one fatality. So at least 17 deaths is acceptable. On reviewing statistics on fatal accident in the US over one recent month in last year (December 2003) it was found that out of 29 fatal accidents, there were 47 fatalities – so, on average, each fatal accident involved 1.6 fatalities.

This would seem to indicate, by the logic of your NAS architects, that 27 fatalities per year in light GA and commuter aircraft is an acceptable annual fatality rate in Australia.

This does not, of course, include statistics on accidents involving helicopters, and accidents involving aircraft at weights greater than 5700 kilograms.

Accessing the US NTSB site direct, it is possible to determine the total number of accidents that have occurred [as far back as the 1960’s] – including helicopters and aircraft heavier than 5700 kilograms. In 2003, there were 377 FATAL accidents in total in the United States – this includes all air operations, including Part 135 Air Taxi and Commuter Operations, and Part 121 Scheduled Operations.

Those 377 accidents resulted in 703 fatalities, at an average of almost 2 (1.9) per accident.

There were 2 fatal accidents involving Scheduled Operations, and 14 fatal accidents involving Air Taxi – Commuter Operations, for a total of 45 (fare paying passenger) fatalities – at an average of around 4 (4.2) per accident.

Using the “5% of the traffic” argument, and the suggestion that you should move to so-called best (United States) practice, it would appear that in Australia, you should be prepared to accept air accident fatalities at a rate of 35 DEATHS PER YEAR, with fare paying passenger fatalities at a rate of 2 DEATHS PER YEAR.



We must state that whilst the US ASF and NTSB statistics are accurate, the simplistic logic applied here in interpolating to Australia would NOT stand proper mathematical scrutiny – but then neither would the simplistic comparisons being done in other threads.

Given the amount of experience that the NTSB must have (over 1600 accidents per year), might it not be proper for them to examine your safety record, and operating conditions, carry out a proper comparative analysis, and suggest acceptable safety targets, or measure whether or not the safety levels apparently being achieved now in Australia are, perhaps, a better measure of “best practice”.

[Voices of Reason]

We accessed the databases for the Australian Transportation Safety Board (ATSB), and found the following aviation statistics, which may be useful in comparing the data presented in a previous post.

Fatalities in Australian aviation accidents in the 10-year period from 1993 to 2002 (inclusive):

High Capacity Air Transport: 0
Low Capacity Air Transport: 17
General Aviation – Agriculture: 23
General Aviation – Charter: 105
General Aviation – Flying Training: 11
General Aviation – Other Aerial Work: 46
General Aviation – Private/Business: 384

TOTAL: 586


That would provide an average of 58.6 fatalities per year total (compared to the US Best Practice prediction of 35 per year), and 1.7 fatalities per year in fare paying passenger type operations (compared to US Best Practice prediction of 1.9 per year).

You MIGHT interpret this to mean that you do NOT have a safety issue related to passenger carrying operations that needs to be remedied immediately – that is, it would appear that current practice is achieving satisfactory results.

What the statistics MIGHT be interpreted as saying is that you might better focus resource on looking at means to INCREASE SAFETY LEVELS FOR GENERAL AVIATION AIRCRAFT OPERATIONS.

[Voices of Reason]

There has been considerable debate in threads on this site about the motivation for moving ahead with an airspace reform program in your country. The web-site of the Department of Transport and Regional Services makes reference to a report to your Minister Anderson entitled “Review of the National Airspace System and Competition for Airport Related Services Report”. Minister Anderson tabled this report, prepared by Wes Willoughby and Associates, in the House of Representatives on 28 May 2003.

One of our team accessed a copy of that report and found a number of statements relating to air traffic control efficiency as being a substantial justification for proceeding with the National Airspace System.

We were also easily able to access the following document on the web, produced by your ATC service provider, Airservices Australia.


BENCHMARKING BROAD PARAMETERS ACROSS SERVICE PROVIDERS

The following table provides a high level comparison of broad parameters across the ATNS providers of the United States, Europe and Australia during the year 2000. This table was compiled by Airservices Australia utilising benchmarking data provided by the European Organisation for the Safety of Air Navigation (EUROCONTROL) in its Performance Review Report – An Assessment of Air Traffic Management in Europe during the Calendar Year 2000. The 2003 Performance Review Report (due in April 2003) will, for the first time, also include Australian data in its assessment. For further information please refer to the Performance Review System of the EUROCONTROL at its website - http://www.eurocontrol.int/prc/index.html.

HIGH LEVEL COMPARISON FAA / EUROCONTROL / AIRSERVICES

Passenger departures (million) 641 / 450 / 41

Number of major hub airports 31 / 27 / 8

Size of en-route 9,820,000 / 10,545,000 / 11,830,000
controlled airspace (km2)

Size of core area (km2) 2,563,000 / 1,485,000 / 2,184,000
(high density traffic)

Number of en-route 9 / 17 / 2
centres in core area

Average number of sectors 37 / 8 / 36
per en-route centre

Average kilometres per flight 772 / 795 / 824

Average flight hours per flight 1.4 / 1.3 / 1.2

Total ANS costs (AUD) per IFR flight 590 / 1,126 / 347

Total ANS costs (AUD) per 1000km 763 / 1,416 / 421

ANS costs (AUD) per ATCO 530,844 /540,698 / 384,737

En-route ATCO/sector working position 9.8 / 17.9 / 6.1

IFR km flown/sector working position 15,908,254 / 14,091,342 / 12,231,662

IFR flights/total ATC’s 900 / 480 / 1,109

IFR km flown/total ATC’s 695,349 /381,747 / 914,156

Flight hours controlled/total controllers 1,254 / 621 / 1,331


By our assessment of this data, and with the benefit of some experience of current performance enhancement initiatives both in the United States and Europe, we would argue that the ATC efficiency of Airservices Australia is better, in all respects, that the so-called best practices of the United States, and substantially better than European practices. That is not to say that further efficiencies can’t – and should not – be pursued – but it is not a compelling argument for change in a hurried and unsafe manner.

In summary, and using the arguments and data we have provided previously, it is possible to draw the following conclusions:

1. SAFETY: The safety of your system, based purely on an analysis of incident and accident reports and statistics would appear to indicate that the current system of operation provides better levels of safety protection to fare-paying passenger operations, but exposes general aviation activity to higher levels of risk that those in the United States. This would prompt us to suggest a program to reduce risk to general aviation aircraft would better serve aviation in Australia.

2. PROCESS: From what we have been able to freely access on the web, and through your posts, the airspace design and implementation management process has been mishandled, and certain assumptions that have been used to underpin decisions in relation to the National Airspace System may be wrong. It would also appear that the comparative or reference system argument may not have been correctly applied.

3. COSTS AND EFFICIENCY: Comparative analysis – again freely available on the web – would appear to indicate that ATC service provision in your country is, at worst, as good as that in the United States, and most certainly better in many respects. It is also substantially better than European practice.

In short, there appears no safety or efficiency justification to have pursued the reform program and to have subjected your system to unnecessarily high levels of risk.

We must stress that we have formed these opinions on a limited source of information – but we are confident that a considered effort by participants in this forum to access more complete data would bear out our conclusions.

[Kaptin M]

It would seem that Voices of Reason understands the pilot psyche perfectly - almost all of us need spoon-feeding.

We have all been extremely well tutored by VoR on this thread as to HOW to methodically and diligently research the subject to make a PROFESSIONAL presentation - even to the point where VoR has SUPPLIED us with the material.
Obviously it has been no small project for our benefactor who has spent not an inconsiderable amount of time gleaning the subject matter.

It is now up to US (Australians) to take advantage of VoR's tuition and use it as the backbone of a Safety campaign.

It has been humbling to read your posts, VoR - Thank you (one/all) and Thank Heavens we still have PROFESSIONALS to give assistance to other professionals.

Thank you.

[Woomera]

Hiya Kaptin.:ok:

Amen to that.

[Voices of Reason]

****su-Tonka,

Please forgive us for being blunt - your "government safety authorities" ALREADDY HAVE all of this information - they CANNOT but have it! We have accessed this information from open sources - easily. We are not trying to partonise the readers and participants on this site - we are trying to say that if it is so obvious to us that something untoward is "going on" - then it MUST be obvious to intelligent people in your safety and service provider organisations.

We have little or no ability to access the behind the scenes discussions that have either deliberately ignored it, chosen deliberately to misinterpret it, or, God forbid, have been directed to ignore it.

We cannot be more direct - use the information we have supplied as a means of building a legitimate case to access the "behind the scenes" information through Freedom of Information legislation.

Then ALL will know the truth.

[Voices of Reason]

****zu-Tonka,

You are getting dangerously close to the truth.

What we are about to say will compromise our position, and make it impossible for us to continue further in this particular forum under this particular bi-line. We also need to be exceptionally careful that we do not inappropriately malign any particular person and run the risk of legal action.

We were shown information which prompted our participation in this forum. That information outlines a complex matrix of interactions between senior airspace management personnel in your country, leading to the highest levels. It is possible to interpret how and why certain airlines have taken certain positions to protect other initiatives - how certain senior airspace management staff have been influenced to adjust or re-interpret their positions, and how certain infuences have been brought to bear to ensure certain outcomes. That is why we have suggested that you attempt to access all of the relevant documentation through legal process.

You will immediately respond conspiracy - that is not, we believe, the case - though you may prove differently. We believe that the proponent(s) of change are not that clever, and that is not their motivation. This is being driven by a few people with sufficient aura or position to directly influence - by reason of that aura - the normal checks and balances. We believe that this process has developed such momentum that it will be impossible to stop cleanly - hopefully it will stop without an accident.

Let us be clear - we are NOT accusing anyone of deliberately seeking to undermine safety levels in your country. We believe that the proponents of change genuinely believe that the outcome of their process will be better than your current system.

We have provided factual evidence that challenges this assumption. We have also provided factual evidence that the process is incorrect.

We have enjoyed participating in this forum - we hope you have success in your endeavours.

WE NOW RELUSE OURSELVES.


Woomera - if you believe what we have written in this message could in any way be interpreted as identifying and maligning any individual(s), please delete it immediately. Our thanks for your support.

[WALLEY2]

VoR

Dear sir,

I am amazed at your volume of information, on another thread "No Radio Dick" I have writen a post which I would seek your comment on.

Our independent consultants are currently completing a design safety case for terminal airspace at Broome International Airport Australia's busiest uncontrolled regional airport with medium sized RPT aircraft.Namely 737 300,400,800 Bae146 Braziliers Metroliners.

Current total movements 25,000pa. In 1998/9 we found our MBZ procedures were not working 5 incidents in 6 weeks involving RPT aircraft after discusion with CASA we increased the MBZ to 30nm and installed a CAGRS equivalent to an ASS in USA: dedicated and manned in a tower by exFSS or ATC personnel and auditored yearly by CASA.

We have placed a FOI on all gov departments re 2c and now placed the matter in our lawyers hands as they have exceeded the regulated information supply date.

We are cosidering all avenues available to us, would you know of an international person willing to discuss this further? My email is [email protected] our web site is www.broomeair.com.au

I will bring this thread to the attention of our study team who include two of Australia's most qualified persons as well as universtity statisticians. We would gladly pay for a review by your nominated expert.

There are at least five other airports within 20% of our usage also servicing a/c upto 737 800, our sole aim is to avoid a disaster, unfortunately our airlines and authorities have been placed under pressure to implement NAS, I refer to to the Ministers "letter of charter" to the new CASA CEO which is on the CASA site.

I had discussed our concerns with the former CEO of CASA the last time being 48hrs before his resignation which he did not mention to me or his senoir staff before it was submitted. This occurred just after the change of legislation that placed the CEO under ministerial control and the axing of the CASA board.

The public is hard to convince while our major airlines accept the change and the airlines need ministerial approvals for route expansion so there is a deafening silence.

Complaints from professional pilots asociations and ATC are publically dismissed as self interest scare mungering. We can't raise a legal case due to our laws protecting the minister so we can't get it into a court and have the NAS methodology exposed on an even playing field untill there is an accident.

Even our state government Western Australia and the Australian Transport Council a coucil of all state ministers of transport are being stymied. The Council demand for a design case is being challenged as the Federal Minister, the Chair of the council was not at the meeting when this resolution was passed.

We have advised the Australian Senate subcommittee of misleading information given to it by NASIG. It is chaired by a Gov Senator and the subcommitte has not been reconvened since our letter some 2 months ago.

I am the Chairman of Broome Inernational Airport and am willing to state the above as I would welcome a slander case so we could be in court before the feared loss of life.

These facts I place before as they show the difficult task we have in using data analysis mathmatical modelling and risk and safety assessment to stop 2c being implimented.

In other words this is a plea for further professional consultancy to help us try to present the best case to the current NPRM which has to be answered by CASA. In such a determination by CASA the minister is not supposed to be able to direct the CEO either on its findings or decision.

regards Mike Caplehorn
Chairman Broome International Airport Group

[triadic]

We (!) continue to be enlightened by the discussion on this thread. Whilst the post by VoR on the above topic (like the others) is comprehensive, it should be noted that the numbers quoted are in relation to all accidents and not to airspace only related accidents.

The level of safety can be gauged in many ways and reducing occurrences by using establish risk management methodology is (and must be) common practice.

An activity is often referred to as “ultra-safe” if the number of occurrences is less than one per million. In aviation this is usually per sectors or departures. World-wide the number of fatal accidents in the airlines is less than 1 per million departures, however in Australia it is 0 and tragically in Africa it is over 10. Using the similar guidelines it would be interesting to compare the GA rate of fatal accidents (worldwide estimate or domestic) against this or a similar benchmark. And more to the point, the number of airspace related occurrences?

Of course it means that an activity that is ultra safe may have occurrences which involve fatalities. Like everything we do, the application of appropriate risk management techniques is/should be normal practice, however often we don’t even think about it (like crossing the street). In airspace management, it is procedures and education that are the major risk mitigators. It would be good if the proponents of NAS understood this.

The political interference (because that is what it is) in the NAS project has been and will be its downfall. This is especially so, when there are no proven benefits and the truth is not a priority.

I have expanded some of my own views on the “rollback” thread as I believe it appropriate that this one remain on topic.

VoR… keep up the good work....and don't bail out! Your words of advice and wisdom are needed.

[Chimbu chuckles]

Voice of reason,

Let me add my voice (sic) to those thanking you for this information.

The ATSB statistics are particularly interesting in light of the general feeling that standards having been slipping for many years in Australian GA.

It has been said, by more than one participant in this forum, that the practical standards of licence applicants for CPL in the last few years, say 10, wouldn't have seen them pass a PPL flight test 20+ years ago. As someone who has done my fair share of training in the Charter/Supplemental airline/Corporate jet areas of the industry I can only agree.

I have stated recently, in this forum, that if the 'influential individual' who has been so instrumental in airspace reform had placed his influence behind a drive to raise standards I might begin to respect him.

The likelyhood of that is, in my opinion, very low as this individual was the head of CASA when that body saw fit, undoubtedly driven by political issues, to outsource most of the standards oversight to industry. This led to our present system of Authorised Testing Officers who replaced, in large part, the previous Departmental Examiners of Airmen. the few Examiners who remained within CASA became Flying Ops Inspectors and spend an inordinate amount of their time in the office doing paperwork. A discouragingly large % of FOIs, but not all by any means, are essentially individuals who 'could not make it' in industry and retreated to CASA. From discussions I have had with peers this is not an unknown problem in most western aviation regulatory bodies.

It doesn't take a brain surgeon to see that an ATO who applies 'too high a standard' on licence skills tests won't be asked back to that training facility in the future....as the ATOs income depends on how many tests he conducts per annum the pressure is obvious. The stories I have heard from an ATO friend would make your hair stand on end!!

I have also stated on this forum that airspace reform, particularly the kind we have had in the last 10+ years, is fiddling while rome burns. As you have suggested we already equal or better worlds best practice in airspace utilisation etc.....something those of us who spend our working lives crewing internationally already knew....what we need is a drive towards higher standards.

Unfortunately that requires money that succesive Australian Govts have proved they are not prepared to spend.

Much better to waste tens of millions of dollars of taxpayers money on ill advised airspace tinkering, driven largely by one idiot (yes emotional...I know), than spend a fraction of that money on striving for worlds best practice in pilot skill/knowledge standards.

:mad: :mad:

Chuck.

[Woomera]

WALLEY2.

The wheels have fallen off your email address.

"...refused (blackholed by bl.spamcop.net); Blocked..."

No good posting uncontactable email addresses in PPRuNe! :{

Woomera

[DownDraught]

Well Dick, what are your "feelings" on this information, care to explain anything????

[WALLEY2]

VoR, Woomera,

My apologies left off the "au"

My email is [email protected] thx

[SM4 Pirate]

Is it just me or have we suddenly lost the pro NAS voice?

Additional Safety Enhancements... C Everywhere over terminal areas D&C; elsewhere C above FL125 (in radar J curve); C above FL180 (in "non radar" areas).

70 Sydney mile circle; 40 miles at CB (higher needs less distance on 3 degrees); 50 miles at BN, CG, AD, PH, CS; PRE 27 November C steps back into D tower airspace... All to caputre the FL125 at three degrees; so some extra C steps to some D towers... Generally RPT protection; fantastic!

E space corridors, might come back to DU and MIA. It's all about reducing risk to pre 27/11 levels.

All in all it looks like rollback to me; sorry "Additional Safety Enhancements."

Additonally, isn't this what was suggested by Civil Air, the union that allegedly doesn't support me professionally just industrially, right from the start.

Does it look similar to LLAMP??? It was so long ago...

Bottle of Rum

[tobzalp]

This is beyond rollback. It is more like the airspace setup right after G demo and at the start ot the E airspace 'trial'. Plus some additional 2000' of Controlled Airspace over the GAFA.

Some people should dead set lose jobs over this one.

I await the apologies to Ted Lang personally from the many who slandered him and to Civil Air as a whole with respect to the Scaremongering claims. Additionally the Major Airlines QA departments should have a good look at themselves for being so quiet for so long especially since I am aware of what some within actually thought but would not come forward with.

ATC and pilots have been pointing out this risk for ages now and the people who assess risk ie the insurers, finally stepped in and put some what of a stop to the idiocy.

Alot of people did alot of work on this one and should be recognised for the effort. Unfortunately they were carrying an ever decaying can.

[Baileys]

Amazing. Can hear a feather drop.

[QSK?]

SM4 Pirate:

What about ATS frequencies and boundaries back on the charts? Are they proposed for a return?

[SM4 Pirate]

QSK? The short answer is no...

A FIS/COM chart is to be made; but not superimposed on the charts in the interim.

I think long term, i.e. next MAP cyle, this may get a gig, but not right now...

I've seen the draft FIS/COM; it's a help but not really very detailed as on one slightly smaller than an A3 page was all Australia. Lots of lines lots of frequencies.

Zoomed in model on the back perhaps for appropriate regional area.

This is all together with advice about frequency monitoring... (like it used to be)

[Woomera]

Seems like everything changes but really stays the same.

:rolleyes:

FISCOM ??? now that rings a bell. :{

[CaptainMidnight]

FISCOM???

Good Grief - those of us old enough to remember :) They rehashed it and named it the Planning Chart I think.
I might even have one stashed somewhere - along with a VEC (not a particularly useful chart, that one). Now the best chart I ever saw was a standard VNC with the ERC low routes overlaid along with the navaids, tracks & distances. It was a raw data proof that Airservices never went ahead with.

And on NAS: there is a lot of backroom lobbying and talking going on, I hear ;)

[Woomera]

CaptainMidnight

Cap'n, trouble is, those of us old enough to remember are having trouble remembering anyway.:*

And the youngsters and/or new pilots never knew what they don't have.:sad:

I'm think I'm coming down with a bad case of deja vu.:confused:

[tobzalp]

Wait a fortnight and the airspace will give you anothe shot of it W

[Tinstaafl]

I miss the VEC. It was a pain in the backside when the twits did away with it. It wasn't ideal but a damn sight better than using an ERC for VFR ops. Or even middle-of-nowhere IFR ops.

What I'd have liked is a combined FISCOM, VEC & ERC (with frequencies & boundaries). Considering how little was on the FISCOM/PCA I'm reasonably confident it's information could be included without unacceptable clutter. Use very light shading for reception ranges etc.

[DirtyPierre]

It's a pity that those that make the charts aren't accessible to those that use them, ie. pilots.

On our ATC consoles we use our own personalised charts. For instance, a WAC with an overlay of airspace boundaries, low or high level routes as appropriate, frequencies, and sector boundaries. Others are VNCs with similar overlays.

It seems that these sort of charts might be very useful to pilots. Maybe AOPA could lobby AsA to provide these sort of charts to their members in the interest of serving their members needs?

Just a thought.

[RTB RFN]

and what of the organisation that is required to monitor these issues with vigilance and neutrality and intervene to assure safety for flying operations.

What of CASA as an organisation and the the senior CASA public servant or servants who actively supprted this.

Are they sitting at their desks today watching the back of their office doors waiting for them to open to allow them to find a more appropriate place of employment?

Damn well should be.

You know who you are and democracy, not your presumed expertise, has won over.

Ethics and integrity - don't live here no more!

[QSK?]

SM4 Pirate:

thanks for the reply. At least the production of a new FISCOM is still an improvement on what we have today under NAS.

I've still got a copy of an old FISCOM chart (1984) in case anyone is having trouble remembering what they look like.

[swh]

I would be more than happy to go forward with NAS if the following were applied :

1) For each VHF centre/control freq "Airservices" provided a "flight service" frequency at the same transmitter (not req when there would be a geographic overlap). This would give everyone equal "access" to "flight service".

2) Aerodromes that are MBZ's have an ADSB receiver to link Mode S transponder output and GPS position into TAAATS. This would provide pseudo radar service to MBZs. Could be expanded to proivde a DGPS facility in this airspace as the MBZ receiver location could be fixed providing an accurate DGPS position.

3) Fitting of a Mode S transponder and GPS position output to each aircraft that will transmit the unique 12 bit aircraft code that is assigned to a mode S transponder at all times irrespective of the position of the "OFF-STBY-ON-ALT-TEST" switch.

Cost recovery : IMHO the cost recovery for this technology could easly be recovered by Airservices with the next phase of the SSR replacement. Its much cheaper to add radio re-transmitters and to equip all aircraft with Mode S/GPS then to install a new radar mast.

Why Mode S transponders : they have a datalink facility in the transponder that can be used for ADSB and TCAS II uses Mode S transponders for better RA/TA's.

In the UK they are making everyone now install a Mode S transponder.

[tobzalp]

Huh

1) But under NAS how would you know where the frequency was transmitting receiving. Access Flight Service all you want. there will be noone sitting on the other end of the radio. Your mate Dick has aleady seen to that.

2)Who will do this radar service in the MBZ? Controllers? Homey don't think so. Who is gunna pay that bill year in year out?

3)The govermen/Airservces are not going to pay to fit TCAS/Datalink/Transponers to your aircraft. They wont pay to fit an airbag to my kingswood so why should they put something in you aircraft.

Make mode S compulsory if you want. Sounds good but I think that you are off with the elves in lala land if you think that it will be free.

[NAMPS]

All I can say is that I'm thankful that I've heeded the warning issued by Jeppesen to keep the old charts - I just hope that a rollback is on the cards...:D

Although the spin doctors may have something to say about it. :{

[Dick Smith]

DownDraught, I find that Voices of Reason is a breath of fresh air. As you would know, I believe that the ICAO airspace classifications should be allocated to reflect risk levels. Because of this, it is extraordinary that Class C airspace is deemed necessary in link airspace above Launceston, however Class G airspace is acceptable at places like Ayers Rock - with twice as many jet movements.

Professionalism requires objective judgement. Using any reasonable logic it is obvious Australia has misallocated airspace categories. Even if you believe that Class C airspace is required above Launceston, that surely must mean that Class B airspace is required in the Launceston terminal area – i.e. where the risk is many times higher, you place a higher category of airspace.

I support what Voices of Reason says, as that organisation explains that airspace should be allocated in relation to objective risk assessment. I particularly agree with Voices of Reason that there is no present safety risk that would require the reversal of the 27 November 2003 changes:

Unless there is an imminent safety risk (and despite the rhetoric, we do not believe such a risk currently exists) we do not - and cannot - intervene directly. It’s great to see that so many others support Voices of Reason on this.

I find that many postings on this thread – which come from air traffic controllers and some pilots – mainly tend towards the status quo.

How can Airservices justify Class D airspace at Albury, with a few turbo-props, but Class G airspace at Ayers Rock, with 16 jet movements per day and loads of VFR traffic? I’ve been told it is because air traffic controllers like to live at Albury, but would not like to live at Ayers Rock. Does anyone have any other suggestions?

By the way, most posters on this thread rave about how wonderful Voices of Reason is. Do I then dare point out that the Voices of Reason posting of 3 February 2004 at 22:05 clearly explains my views in relation to the affordability of safety – Swedavia - McGregor were my mentors!

[CaptainMidnight]

Was told the other day;

Must not say "Rollback"
Must say "airspace enhancements and fine tuning"

[Howard Hughes]

Well we seem to have adapted a lot of things from the states.

Why could'nt we have their WAC charts, which include topographical info, frequencies and boundaries, airspace, PRD's but cant quite remember if they had airways on them!!

Sounds like a great idea to me, everything on one chart!!
Anyone, Anyone?

Cheers, HH. :ok:

[Woomera]

Howard Hughes

Part of the friendly Woomera service for you.

FAA Airmans Manual

9-1-4. General Description of each Chart Series

a. VFR Navigation Charts.

1. Sectional Aeronautical Charts. Sectional Charts are designed for visual navigation of slow to medium speed aircraft. The topographic information consists of contour lines, shaded relief, drainage patterns, and an extensive selection of visual checkpoints and landmarks used for flight under VFR. Cultural features include cities and towns, roads, railroads, and other distinct landmarks. The aeronautical information includes visual and radio aids to navigation, airports, controlled airspace, special-use airspace, obstructions, and related data. Scale 1 inch = 6.86nm/1:500,000. 60 x 20 inches folded to 5 x 10 inches. Revised semiannually, except most Alaskan charts are revised annually.
(See FIG 9-1-1 and FIG 9-1-11.)

2. VFR Terminal Area Charts (TAC). TAC's depict the airspace designated as Class B airspace. While similar to sectional charts, TAC's have more detail because the scale is larger. The TAC should be used by pilots intending to operate to or from airfields within or near Class B or Class C airspace. Areas with TAC coverage are indicated by a · on the Sectional Chart indexes. Scale 1 inch = 3.43nm/1:250,000. Charts are revised semiannually, except Puerto Rico-Virgin Islands revised annually. (See FIG 9-1-1 and FIG 9-1-11.)

3. World Aeronautical Chart (WAC).
WAC's cover land areas for navigation by moderate speed aircraft operating at high altitudes. Included are city tints, principal roads, railroads, distinctive landmarks, drainage patterns, and relief. Aeronautical information includes visual and radio aids to navigation, airports, airways, special-use airspace, and obstructions. Because of a smaller scale, WAC's do not show as much detail as sectional or TAC's, and; therefore, are not recommended for exclusive use by pilots of low speed, low altitude aircraft. Scale 1 inch = 13.7nm/1:1,000,000. 60 x 20 inches folded to 5 x 10 inches. WAC's are revised annually, except for a few in Alaska and the Caribbean, which are revised biennially. (See FIG 9-1-12 and FIG 9-1-13.)

:D

Is this perhaps the missing link in all of this.

If we going to have US airspace then should we not have the complete nav package???

The rest is here FYI;

FAA Airmans Information Manual (http://www2.faa.gov/atpubs/AIM/index.htm)

[R4+Z]

Dick

does this mean you agree with this quote from VoR

You will immediately respond conspiracy - that is not, we believe, the case - though you may prove differently. We believe that the proponent(s) of change are not that clever, and that is not their motivation. This is being driven by a few people with sufficient aura or position to directly influence - by reason of that aura - the normal checks and balances. We believe that this process has developed such momentum that it will be impossible to stop cleanly - hopefully it will stop without an accident.

Let us be clear - we are NOT accusing anyone of deliberately seeking to undermine safety levels in your country. We believe that the proponents of change genuinely believe that the outcome of their process will be better than your current system.

We have provided factual evidence that challenges this assumption. We have also provided factual evidence that the process is incorrect.


Or are you going to be selective about what you agree with, or will you now accept that we should never have got into this position in the first place.

If the latter are you acknowledging any liability for any of the possibly dire outcomes suggested by VoR.

and since you are now posting on this thread can you cofirm or deny the existence of the documentation which VoR referrs to here

We were shown information which prompted our participation in this forum. That information outlines a complex matrix of interactions between senior airspace management personnel in your country, leading to the highest levels. It is possible to interpret how and why certain airlines have taken certain positions to protect other initiatives - how certain senior airspace management staff have been influenced to adjust or re-interpret their positions, and how certain infuences have been brought to bear to ensure certain outcomes. That is why we have suggested that you attempt to access all of the relevant documentation through legal process.

I won't hold my breath

R4+Z


I think I posted this mid merge ??????

:confused: :confused:

[Woomera]

Just for the record I've merged the other NAS thread here and closed the Radio Dick thread, for housekeeping purposes only.

Lets keep this one at the high tenor set by the V's of R eh.:cool:

W :ok:

[SM4 Pirate]

Hot rumour at work is John Forsyth has fallen on his sword over this debacle.

Dick, just look at you, trying to save face...

Call me a cynic; but I believe the ARGs (your) ultimate agenda is to remove ATCs as far as practicable, it always has been. GNAF etc.

It was you that flogged (to death, $50M+) the cost benefits of proceeding with NAS even well after they were disputed by the provider in Senate Estimates; face some facts Dick, one ARG member has quit, it's time for another.

Consultation is required next time; how much Tax payer money have you, directly or indirectly, been responsible for wasting, enough is enough.

Bottle of Rum

[Clothears]

This from ABC news online:

-----------------------------------------------------------------------

Last Update: Thursday, February 12, 2004. 9:00pm (AEDT)
ASA chairman resigns
Air Services Australia (ASA) chairman John Forsyth has resigned.

Mr Forsyth has been in the position for the last eight years and has been in charge of the current review of Australia's air space rules.

Proposed changes to air space regulations are due to be presented to Transport Minister John Anderson within a week.

No explanation has so far been provided for Mr Forsyth's resignation.

------------------------------------------------------------------------


Did he jump or was he pushed? And which prominent aviation "expert" (as viewed by Anderson) will replace him? Who's next to go?


:confused:

[Douglas Mcdonnell]

Mr Smith. I find your posts to be quite scary. Your lack of understanding of what acually happens in the daily operations of a professional pilot is obvious. I first experienced your "reforms" back in the Class G debacle. After much frustration and a very near miss under that system, which you backed to the hilt at the time, I find your credability on this issue to be a bit lacking.

Sure posting lots of incidents on another thread shows your involvement but not an understanding.

The NAS has taken Australian airspace backwards 40 years. I know because I operate in it on a daily basis. Like most of my profession, I am left shaking my head at the glaring holes in the NAS.

For example. The see and avoid advice is nice if you are in a light a/c. How ever, jet transports that cruise around 480kts tas, head to head with a lightie that is doing 110kts tas makes for nearly 600kts closure. I would put it to you that by the time you have seen the target at that speed it is probably to late.

The most negligant thing in the NAS, i feel, is encouraging smaller aircraft not to use the radio. The radio is of ut most importance to separation issues and is not just a distraction.

The NAS, unfortunately, is part of our lives at the moment. This will change.

Professional aviators need professional airspace to work in. Its not a request its a requirement.

DM

[DirtyPierre]

Dick,

You still don't get it. Controllers would gladly upgrade the airspace around Ayers Rock, but don't have the authority or power. We're happy to have a tower at Broome, but we have no say in that either.

Just like Ayers Rock, Broome, or NAS, controllers have no say on airspace. We merely advise and when directed, design and operate.

Stop waving the controller saving jobs whodo voodoo doll and start listening to posters like VoR et.al.

There are none so blind as those who will not see.

[Howard Hughes]

Thanks for that Woomera, could'nt quite remember all the relevant names of the charts.
But do remember criss crossing the states with one chart in hand, with everything on it!!
All the while with the reassuring chatter from the controller providing VFR flight following!!
"Cessna XXXXX traffic is 1 o'clock and four miles four F-15's" and before I had even looked "traffic no longer a problem".
Ahhh the memories of it all.

Perhaps the other missing link, RADAR!!

Now you, me and so many others can see the problems, why cant those with the power to do something?

Cheers, HH.
:ok: :ok:

[Douglas Mcdonnell]

It just dosent make sence. I cant actually understand why Mr Smith is involved with all of this.

In what other country is major airspace reform pushed ahead by a biscuit magnate who does a bit of private flying?

What a disgrace.

To keep it interesting, could we run a tab as to when Mr smith starts to distance him self with this project. Id reckon about 8 weeks.

[Capcom]

Douglas McdonnellTo keep it interesting, could we run a tab as to when Mr smith starts to distance him self with this project. Id reckon about 8 weeks.He has already started building firewalls around himself, I guess he will be helped/protected by JA and JH otherwise he might just take them down with him. You can bet they are very worried about that!.:rolleyes:

Bet they are all praying no one is killed before the "fine tuning" is put into play!:hmm:

The cleaners are going to have a hell of a time cleaning up the fur when this is all over!:*

[Four Seven Eleven]

Dick Smith wrote;
How can Airservices justify Class D airspace at Albury, with a few turbo-props, but Class G airspace at Ayers Rock, with 16 jet movements per day and loads of VFR traffic? I’ve been told it is because air traffic controllers like to live at Albury, but would not like to live at Ayers Rock. Does anyone have any other suggestions?

I certaibly have a suggestion. I suggest you ask Airservices how they justify it. perhaps their justification will not stand up to a proper risk/cost benefit analysis and a review might be warranted.

I am staggered that you seem to infer that Airservices bases its decision on airspace classification in accordance with my and my colleagues' personal preferences. Oh, would but it were so.:rolleyes:

Did the same person who 'told' you this also tell you that NAS was a safer system? Perhaps you need some new advisers.

Professionalism requires objective judgement.
Does this mean that you will now support an objective analysis of whether or not NAS is going to be safer than the previous system?

I find that many postings on this thread – which come from air traffic controllers and some pilots – mainly tend towards the status quo.
Could you point those out to us please. I think you are wrong.

[AirNoServicesAustralia]

Dick Smith continues to miss the point, that being that because there are inadequacies in some areas in service provided, that justifies reducing services in other areas. It has long been known by controllers in and around the Alice Springs/Ayers Rock area that an upgrade in facilities (ie. RADAR!!!) and airspace (ie. Class E if not C further down into Ayers Rock) is desperately needed. So to say that the lack of service around these areas justifies a reduction is service in others is just a nonsense. The fact is a radar head at Alice Springs has been needed for a long long time and there have been a number of feasiblity studies done, but nothing has ever came of it, because of the mighty dollar.

All this is not to say that the service provided by my very talented and motivated ex-colleagues on what used to be known as Sector 1/5 is anything other than top notch, its just that a radar is well overdue, and I'm sure they would welcome it (if only to get that radar rating to go with all those procedural ratings, poor guys!).

[Adamastor]

The silliest part is, ANSA, that the money senselessly wasted on this debacle could have purchased TEN radar heads, any one of which could have served Alice admirably...(angry sigh!)

[tobzalp]

That is quite a good way to look at it Adamastor. I vote that Dick buys them one to make up for it.

[Dick Smith]

Four Seven Eleven, re objective judgement, you asked me:

Does this mean that you will now support an objective analysis of whether or not NAS is going to be safer than the previous system? As I’ve stated consistently for my 15 years of involvement in airspace changes, everything should be based on objective analysis. That is, ICAO airspace classifications should be allocated commensurate with risk. I have never changed my view on this. I am a co-founder of a prestigious organisation called the “Australian Skeptics”, which examines all subjective claims on an objective basis.

There is little doubt in my mind that if Class C airspace is required in the link airspace above Launceston, then Class B airspace would be required where the collision risk is far greater in the area close to the runway.

If you take a close look at the American airspace ICAO classification diagram that I posted on a previous thread, you will see that the airspace consistently moves up, as traffic density and mix changes, in classification from Class G to Class B.

This has been my aim for the last 15 years, and I’m pleased to say that we are gradually moving in this direction. Part of the NAS plan is to put Class E airspace into places like Ayers Rock and Broome, however it was only 5 years ago that I introduced the first Class E into Australia. That was between Canberra and Ballina, Dubbo and Broken Hill, and Mildura and Melbourne. At the time it was resisted in every way possible – I still have my newspaper cuttings. Gradually, Class E airspace is being better understood, and deemed to be more acceptable – even by professional pilots.

Despite some criticism, the reason I support Voices of Reason is because that organisation clearly understands what I understand – airspace should be allocated objectively in relation to risk. I’ve always been consistent on this, and I will always be, as this is the best way of reducing aviation fatalities.

[DirtyPierre]

Dick,
You said,

"Despite some criticism, the reason I support Voices of Reason is because that organisation clearly understands what I understand – airspace should be allocated objectively in relation to risk. I’ve always been consistent on this, and I will always be, as this is the best way of reducing aviation fatalities.

Sorry, mattey, but it has already been shown (by ATSB, CASA et.al) that mixing high performance RPT turbo and jet aircraft with unreported, and uncommunicative VFR aircraft is not safe. Read the report by the ATSB on the Launy incident.

So by your own admission, you would have to agree that class C airspace is required at places where RPT turbo and jet traffic mix with VFR traffic ie. where there is significant risk of fatalities.

I still stand by my statement that you DON'T understand how airspace should be allocated.

[Sterner Stuff]

Dick my benevolent dictator "friend",

Pleased that you managed to tear yourself away from the great Ugg Boot debate long enough to break out the fiddle whilst Rome burns.

Read the Voices of Reason thread in toto rather than cherry pick the bits that distance you from the sh!tfight and try to make it look like everyone else's fault that this is going belly up. Stop throwing non-sequiturs about staffing Uluru tower and play the main game. NAS is dying and you put your personal reputation on the line for this. YOU MUST TAKE SOME OF THE FALL-OUT. You stated categorically that "...we [ATC, professional pilots and operations procedures specialists from the heavy metal customers and Airservices] just don't get it." as early as 30 November last year only days after the 2B debacle rolled-out just as you wanted it.

Dick you've been trying to get your vision across for 15 years and no-one else can see the fairies at the end of the garden despite everyone scrutinising every damn thing with a very big scrute indeed. Given that hundreds of people have been involved in your various iterations of flights of fancy for airspace reform how is it that they still keep falling over? 11/11, Airspace 2000, The "G" trial, LLAMP, and now NAS, there are three common factors in every one of them:

1. You
2. They all seems to cost more than we gain
3. They aren't safer than what we were doing anyway

I'll go further - some of them are demonstrably dangerous (the G trial in Northern NSW springs to mind). You can't explain it all away with conspiracy theories. I've been here for the duration, don't have the benefit of a Citation and millions in personal wealth to allow me to examine the world in detail, but I am a professional, have plenty of experience, read a sh!tload about what's happening OS and keep in contact with the people that are managing these processes out there, and yes, I still want the industry to be efficient. My opinion seems to be worth nothing. A lot of people both sides of the air-ground set-up feel the same.

You are good at business, you've proved that both personally and when you oversaw the painful cuts that yielded one of the most efficient air traffic service providers in the world but this just seems to be out of your reach. This could have worked, had it been approached in the responsible manner that the aviation world has learnt by way of many very hard lessons:

- CONSULT
- DESIGN and test exhaustively
- CONSULT
- INVITE PEER REVIEW
- BE PREPARED TO DEFER IF THINGS LOOK BAD
- DON'T SHOOT THE MESSENGER IF SOMEONE SPOTS A HOLE IN THE PLAN
- KEEP AT IT UNTIL THERE ARE NO HOLES LEFT; THEN
- IMPLEMENT OVER A REALISTIC TIME FRAME

Remember the thing about old and bold pilots? There's a reason why every pilot gets told it. Look through the old crash comics for hundreds of tales about what happens when you press ahead regardless. Full speed ahead and damn the torpedoes simply isn't appropriate in this day and age.

Even your mate John Howard is going to back away from this one. Given that Voices of Reason and virtually every amateur airspace reformer is spotting the significant flaws in this latest debacle, how about me agreeing not to attack you personally if you stop pushing personal agendas that are unsafe, cost the country a fortune and benefit no-one and nothing except your column inches?

[themwasthe days]

Voice of Reason:

I do appreciate your comments, and agree with most, however your quote:

Your respondent cites numerous examples where the activation of ACAS systems - whilst preventing a collision - allowed aircraft to operate in dangerous proximity. ACAS systems can and do fail - witness the unfortunate accident at Uberlingen.


raises another issue.

Is this a correct statement? As I understand the issues, it was the failure of one of the pilots to follow the RA that resulted in the collision. This should then raise alarm bells, as to why such a "mitigation" is not INCLUDED in any risk management process, as it is clear that the system design is fallible, and such input could affect any safety assessment outcome.

[DirtyPierre]

Sterner Stuff,

Good post but I must correct you on one point.

LAMP was nothing to do with Dick Smith...he was the one that shafted it days prior to implementation. In fact LAMP did

- CONSULT
- DESIGN and test exhaustively
- CONSULT
- INVITE PEER REVIEW
- BE PREPARED TO DEFER IF THINGS LOOK BAD
- DON'T SHOOT THE MESSENGER IF SOMEONE SPOTS A HOLE IN THE PLAN
- KEEP AT IT UNTIL THERE ARE NO HOLES LEFT; THEN
- IMPLEMENT OVER A REALISTIC TIME FRAME

Iwent to about a dozen meetings with industry in the 12 months I was associated with the LAMP. And guess what, there were cost savings for the industry. Cancelling LAMP meant that AsA suddenly had a staffing crisis on their hands as they had to begin recruiting for all the ATC staff cutbacks they were going to have by natural attrition (eg. retirements, resignations, etc).

Dick has cost the Australian Aviation industry in money, reputation and consumer confidence. If their is a villian in this sad and sorry tale, its Dick Smith.

[Four Seven Eleven]

Mr Smith

So, was that a yes or a no?

Many words, but you fail to answer the question which you quoted. I ask again, will you support an objective analysis of whether or not NAS (or any new system) is safer than the system it replaces?

It has been argued on these forums that NAS, whatever its merits, is not as safe as the previous system. It is incumbent therefore on those entrusted with air safety to justify the reduction in safety with tangible benefits. Merely waffling on about how the US has certain traffic levels and is ‘safe’ is not enough. We need to know if we are moving towards a safer or less safe system and understand the reasons why.

Given that the empirical data suggests that the US system is both more expensive and less safe than the pre-NAS2B airspace, why do you continue to evade the basic questions as to relative safety? Is it because you know that the relative safety and cost of NAS is indefensible by facts?

[DirtyPierre]

4 7 11,

So far the silence is deafening!!!!


Com'on Dick. Answer the f...ing question.

[SM4 Pirate]

From yesterdays Hansard Transport: National Airspace System

Mr MARTIN FERGUSON (3.52 p.m.)—I can assure you that no-one owns me; I am not sure about
those on the other side of the House. My question is to the Deputy Prime Minister and Minister for Transport and Regional Services. Does the minister stand by his statement in this House of 27 November last that the National Airspace System is a ‘safer, more productive and efficient system’?

Mr ANDERSON—I thank the honourable member for his question and trust that he is feeling better. We are in the process of reforming airspace in Australia.

Opposition members—Ha, ha!

Mr ANDERSON—As a matter of fact, we are. We are on the way to international harmonisation. There are something like 50-odd steps in that process, of which only a limited number have been completed. I stand completely by the view expressed to me by people who are expert in this area—
Mr Martin Ferguson interjecting—

The SPEAKER—The member for Batman has asked a question!

Mr ANDERSON—and I stand by my own conviction—

Ms O’Byrne interjecting—

The SPEAKER—I warn the member for Bass!

Mr ANDERSON—that the National Airspace System will produce better safety outcomes for the traveling public in this country and will allow for a more relevant concentration of finite safety resources in the areas of greatest safety risk. The proposition that, somehow or other, a proven international aviation airspace management system—which is used in a country where there are four times the levels of aviation activity as there are in Australia—

Ms O’Byrne interjecting—

The SPEAKER—The member for Bass will excuse herself from the House! The member for Bass then left the chamber.

Mr ANDERSON—where the weather is less clement than it is in Australia, and where the aviation safety record is outstanding—is somehow not safe or is less safe than what we have now is palpably nonsense. I remain absolutely consistent in my view that moving to NAS is in the interests of the travelling public of Australia.

So does this mean nothing will change?

[Four Seven Eleven]

The proposition that, somehow or other, a proven international aviation airspace management system—which is used in a country where there are four times the levels of aviation activity as there are in Australia, where the weather is less clement than it is in Australia, and where the aviation safety record is outstanding—is somehow not safe or is less safe than what we have now is palpably nonsense. I remain absolutely consistent in my view that moving to NAS is in the interests of the travelling public of Australia.
So, the goal posts are gradually shifting. The same minister who claimed that NAS would make aviation in Australia safer, is now reducing his argument to weasel-words such as those above.

No one is suggesting it is ‘not safe’ in the absolute sense. What many (including myself) are suggesting, Minister, is that it is ‘less safe’. You, Dick Smith and the others who perpetrated NAS have provided not one iota of evidence to show that you even bothered to find out whether or not it was.

If I were to say that ” The proposition that, somehow or other, a proven international automotive system—which is used in a country where there are four times the levels of automotive activity as there are in Australia, where the weather is less clement than it is in Australia, and where the automotive safety record is outstanding—is somehow not safe or is less safe than what we have now is palpably nonsense”, many would be quick to point out that the US:

a) Does not mandate seat-belts in all jurisdictions.
b) Has experienced child deaths in vehicles caused by air-bag deployment in light collisions
c) That these child deaths would not occur in Australia because our air-bags are ‘low-impact’ types, designed to be used in conjunction with seat-belts.

Only someone who had a pre-determined agenda would consider scrapping the Australian Design Rules in relation to air-bag deployment, in favour of the US rules without considering the legislative and other differences between the two countries. It would be a foolish minister indeed who accepted the argument that “it works in the US, therefore it is safe.” A wise member of a theoretical “Automotive Reform Group” would be aware of these differences and would want safety to be analysed before adopting any changes.

The simple fact is that the US, being a strong and free country accepts certain risks in exchange for those freedoms. It also is willing to pay the financial costs of ameliorating those risks.

In the case of motor vehicles, drivers’ groups have lobbied to avoid compulsory seat-belt laws. They see this as a basic freedom. In Australia, we have gone the other way, mandating seat-belt laws. Which approach is better is a moot point.

The important point is that:
1) A car manufactured for US conditions will be more dangerous in Australia than one manufactured for Australian conditions.
2) A car manufactured for Australian conditions will be more dangerous in the US than one manufactured for US conditions.

Perhaps all involved in this sad debacle are coming to realise that:

1)NAS reduces safety. The available facts support this proposition. If confirmation was needed, Dick Smith’s silence and evasiveness on the question provide ample evidence.

2)NAS has cost over $50,000,000, only to now require ‘enhancements’. Who knows what this will eventually cost.

3) NAS has harmed Australia’s reputation as a safe aviation climate. This will jeopardise the aviation industry in its attempts to attract foreign business for the GA industry.

Why, Mr Smith, if you care about the aviation industry, are you not willing to prove that NAS is safer? What is there in the evidence that you are unwilling to let us know? Or did you just not even bother about safety, relying on "it works in the US' as your only safety 'analysis'?

[missy]

4711, I was thinking of introducing the automotive comparison myself...

Hey Dick, why don't we drive on the right hand side of the road, after all it's gotta be safer, oops, sorry, for the overall benefit of the Australian travelling public.

The US has more vehicular traffic, better roads, harsher weather but let's give it a go. No need for a design safety case and the implementation should be as simple as one, two, three. Certainly now where near the 50 elements of the NAS plan.

[Desert Dingo]

http://members.optusnet.com.au/~d.dingo/DS-minister.jpg
"NAS is working perfectly."
"I have detailed information about the situation...which completely proves that what they allege are illusions . . .
They lie every day."
(With apologies to Muhammed Saeed al-Sahaf, the Iraqi Information Minister)


http://members.optusnet.com.au/~d.dingo/JA-minister.jpg
Mr Anderson says the new system is being introduced progressively and will not be abandoned.
"The National Airspace System (NAS) will produce better safety outcomes for the travelling public in the country," he said.
"It will allow for a more relevent concentration of finite safety resources in areas of greatest safety risk.
"I remain absolutely consistent in my view that moving to NAS is in the interests of the travelling public of Australia

[Woomera]

Mr D Dingo

Love em or hate em I just love your work, needed a good belly laugh.

I thought Muhammed Saeed al-Sahaf should have got an Oscar that year for best stand up comedy routine.
I used to look forward to his press conferences the same way I look forward to the cartoon in the morning papers. :D
I always had that sneaking suspicion that he was really just playing the game all along.

[Voices of Reason]

We have been encouraged to re-enter this discussion, and to provide further information.

We have been pointed to transcripts of your senate estimates committee in which testimony was provided by representatives from various organisations involved in the airspace reform debate. We found the responses both amusing on the one hand, and deeply disturbing on the other.

One point that appears to have been lost totally on your regulator – and we would argue that this is significant enough to call into question the integrity of your regulator as a whole – is the set of statements relating to the use of training and education as a major safety mitigation.

In and of itself, training and education IS a very good safety mitigator – but ONLY if it can be demonstrated to be effective.

We understand that the safety regulator has examined implementation safety cases provided by your service provider and airspace change proponents which contain such education and training requirements – and has actually sighted the training material has sighted and noted the training schedule for affected controllers, and has witnessed the delivery of that training, and has sighted the assessment material that demonstrates competence – that is, demonstrates that the training and education material has been delivered effectively, and has achieved the desired safety mitigation.

It is therefore reasonable to say that all of the safety obligations within the implementation safety case have been effectively discharged – BY YOUR SERVICE PROVIDER.

However, the service provider is but one element of the safety equation. Pilots are the other. Clearly, from the material we have seen, and from transcript evidence presented to your Senate committee, whilst several people – including a senior representative from your Department of Transport and Regional Services undertook to ensure training material was created and distributed – there is ABSOLUTELY NO EVIDENCE that the safety requirement for effective training and education – the CORE safety mitigator - has been met.

Has your regulator examined airline training records to ensure that the training material was appropriately tailored for their operations, delivered effectively, and that delivery recorded? Has your safety regulator examined the training records associated with charter operations, aerial work operations and general aviation operations to ensure that the training material was effectively delivered and understood? Has your regulator examined the training records of the Defence establishments in your country to ensure that training material was effectively delivered and understood and tested?

If the airline certification process in Australia is similar to other major countries, there should be a process that requires a proper “check and training organisation” within the airlines. BEFORE the changes were committed – as appears to have been the case in relation to a Sunday evening meeting referred to in the transcripts, your regulator should have been able to demonstrate – in fact should have required your airspace reform program managers to demonstrate – that airlines and other operators could effectively deliver training in the required time.

You CANNOT create a Safety Case that requires safety mitigation from ALL parties – and then measure its effectiveness by the compliance of one party. Neither can you say that simply putting the training material “in the post” satisfies a safety obligation.

We have to question the competence of your regulator. This is a fundamental failing and calls into question the whole safety case process for your airspace reform.

[Wirraway]

Qantas endorses air traffic control system PM - Thursday, 19 February , 2004 18:38:00
Reporter: Alison Caldwell

MARK COLVIN: But what does Australia's leading airline think about the airspace reforms introduced in November last year?

Qantas' Chief Pilot is Captain Chris Manning. He says the airline has recorded no incidents as a result of the changes, and apart from a few minor concerns, Qantas is happy with the system as it stands.

Captain Chris Manning spoke to Alison Caldwell.

CHRIS MANNING: As we currently know it we have issues, they are small, they're called fine-tuning. But we consider the air space system safe, otherwise we wouldn't be flying in it.

ALISON CALDWELL: What are your issues?

CHRIS MANNING: The issues we have are a couple of issues around charting, that is, how the charts are presented. Those issues have been accepted by the NAS (National Air Services) implementation group, and a couple of issues of airspace, and they are being accepted. So we have no problem with the way it's being conducted at the moment.

ALISON CALDWELL: What's your view of the call from some pilots to immediately introduced controlled airspace to cover all regular public transport areas near major airports in Australia?

CHRIS MANNING: You'd have to ask pilots who said that why they want it. Our issue is we would not allow the aircraft, Qantas aircraft to fly in airspace that wasn't safe. The current system is safe.

We have had no incidents involving a breakdown of separation attributable to the National Airspace System. I will say that there will always be errors when human beings are involved – they occurred under the old system, they will occur under the new system. What we have to do is mitigate those errors and they are mitigated.

ALISON CALDWELL: So you don't agree that it's an inherently flawed system?

CHRIS MANNING: We are very happy to fly within the current airspace system.

ALISON CALDWELL: What did you make though, the other day, of the Minister for Transport, John Anderson, expressing complete confidence in the system, yet on the other hand within a few hours, the Chief of Airservices Australia announced a full and comprehensive review into this system and a complete risk analysis of the system, and admitted that it had acted illegally in its implementation of the system?

CHRIS MANNING: I think you'd probably have to talk to those two gentlemen who would doubtless explain, or, as I said before, we are happy to fly within the current airspace system.

We have not been told of any review formally, we've only read about it like you've read about it. But as I said before we are happy with the current airspace system, we were happy with the previous one, we'll probably be happy with the next one.

All I can say is we've now been operating for the best part of three months with not an incident of breakdown of separation. When our pilots have sighted other aircraft the National Airspace System has worked as planned.

ALISON CALDWELL: But yet it's under review now.

CHRIS MANNING: Well, you'll have to ask the regulator why it's under review. I'm sure they'll tell you.

ALISON CALDWELL: If we could interview them we would, believe me. Look, air traffic controllers also don't like this, their union says that change is needed; do you think that they're just crying wolf?

CHRIS MANNING: No, I don't. I mean, you would have to see their union, and I'm sure they'll be very happy to explain why it's wrong, and what's wrong, what incidents have occurred.

But I just speak for the airline and we have had no incidents. And we are very happy, we do risk analysis on these changes, we are very happy that we have continue to operate very safely.

MARK COLVIN: Qantas' Chief Pilot, Captain Chris Manning, speaking to Alison Caldwell.

============================================

[Niles Crane]

Voices,

You have brought up a very good point!

When the training material arrived on my desk 6 days before "The Date", I showed the video and training material to a number of our pilots and they asked more questions then the video and training packed answered.

I then deduced that we would have to rewrite the material for training our regional airline pilots as the material was written for private pilots.

My next action was to get onto CASA and notify them that training would not be conducted in time!

There answer was "no problem, you do not have to do anything as Airservices has passed the training package and no further training is required"

Casa was not prepared to "Buck Dick"!!

[WhatWasThat]

"We are happy with the current airspace system"

Joe Public takes this statement from the "chief pilot" of Qantas as an endorsement by ALL Qantas pilots!

I really don't think this is the case, I have not personally heard a single heavy metal pilot with anything even slightly positive to say about NAS 2biscuit. Perhaps the Qantas pilot community might like to ensure that this does not go unchallenged.

[Philthy]

Below are the recommendations made by the French Bureau Enquetes-Accidents (BEA - equivalent to the ATSB) following their investigation into the mid-air collision between Airbus A320 F-GJVG and Grob 103 F-GCXB on 12 February 1999. The translation from the French is mine so there may be some detail inaccuracies, however I believe that the substance of the recommendations has been rendered into English accurately.

To set the scene, this accident occurred while the A320 was following a STAR in Class G airspace on arrival into a Class D CTR at Montpellier Mediterranee, France, in VMC. Although warned of the presence of glider activity (OCTA) by a broadcast on the ATIS, the crew of the A320 did not see the other aircraft until too late. Neither did the crew of the glider see the A320 until too late. Naturellement, the glider was not transponder equipped.

Although both aircraft took avoiding action, a collision occurred. By great good fortune, although both aircraft were damaged they were both landed safely without further incident.

This was the second mid-air collision in France within six months between an RPT aircraft and a VFR aircraft, in VMC in Class G airspace. Of course, Class E airspace would have made no difference.


Recommendations of the Bureau Enquetes-Accidents following the mid-air collision between Airbus A320 F-GJVG and Grob 103 glider F-CGXB near Grenouillet, France, on 12 February 1999.

Several measures were taken following the accident:
- the center of gliding of Montpellier Pic Saint Loup will temporarily maintain all of its activity at an altitude lower than 4 500 feet.
- During a meeting held on March 16, 1999, the director of airspace decided to change the limits and the classification of the airspace relating to the airport of Montpellier Mediterranee. These modifications, which came into force on May 20, 1999, will be published to users by way of the aeronautical information service.

Lastly, it is expected that new agreements will be negotiated in order to integrate the gliding activity of Saint Martin de Londres in the airspace thus modified. Taking note of these measures, the BEA:

4.1. Makes again the following recommendation, put forth on February 24, 1999 within the framework of the investigation into the mid-air collision which occurred on July 30, 1998 in the Bay of Quiberon between Beech 1900 D registered F-GSJM and Cessna 177 registered F-GAJE:
- that within the shortest time, the DGAC makes provisions so that the crew of any aircraft involved in the public transport of passengers, under the IFR, can be informed of any aircraft representing a potential risk of collision. This objective could be met by the three following complementary strategies:
1) the designation of classes of adapted airspaces, or specific airspace, ensuring the protection of published IFR routes;
2) the equipment of aircraft carrying out the public transport of passengers with TCAS, without awaiting the limiting date fixed by regulation;
3) requirement for the use of transponders with altitude reporting for any aircraft operating above revised reference levels.

4.2. Recommends:
- that the DGAC makes, on a purely transitional basis, provisions so that, except in the event of operational need or reasons related to safety, aircraft on an IFR flight plan do not receive clearances to deviate from a published route when this is likely to lead them to be operated in airspace where the knowledge of any aircraft presenting a potential risk of collision is not guaranteed.

4.3. Recommends:
- that, when portions of airspace managed by the Defence organization and crossings by arrival and departure routes are not active any more, they can be used by Civil aviation in order to protect these routes and to allow continuity in the application of the supervising authority.

4.4. Recommends:
- that meetings are regularly organized by the services of the Civil aviation authority at general aviation aerodromes in order to discuss with users questions relating to their activity, in particular when changes are brought in the organization of the airspace and that if need be, draft agreements binding the users to the Civil aviation authority and with the Defense authorities are amended.

4.5. Note that, contrary to the aeroplane flight guide, the existence of traffic IFR in class G airspace does not appear explicitly in the gliding flight guide. This gap was not identified as being contributory to the accident, the two occupants of the sailplane being also powered aeroplane pilots, but it represents a potential weakness of the safety system. It was also raised in the ultralight flight guide. Even if the taking into account of the first three recommendations decreases the probability of the presence of IFR traffic in class G airspace, this remains possible. Consequently, the BEA recommends:
- that theoretical training manuals for glider and ultralight pilots are amended in order to bring to pilots knowledge of IFR flights in class G airspace.

[ferris]

Voices of Reason.
What test is applied to any mitigation in relation to a safety case? Who says that just because "adequate training" is listed as a mitigator, even if "adequate training " is then conducted, that it is an adequate mitigation?

Good to see the QF chief pilot standing up to be counted when required. :hmm: The politics are mind-boggling.

[Voices of Reason]

Ferris,

Thank you for your question. We don’t mean to lecture here – neither be patronizing - but the background below may help you and other readers to better understand the true nature of safety case and hazard identification and management.

A safety case is, in its most simplistic form, the recording of a number of structured actions that have been taken to provide assurance as to the safety of a design or a model or the implementation thereof. A safety case is – or should be - a clear demonstration of a robust process of risk assessment and treatment strategies. It may not – and most often does not – identify all of the risks associated with a project – but well conducted, with appropriately qualified people participating in the hazard identification process, it will identify those risks that are most likely to be present in the system. The ongoing nature of a safety case means that once identified and recorded, hazards must be regularly reviewed, the effectiveness of the hazard treatments examined, hazards removed as they are superceded, and other hazards added and treated as they arise.

What is more relevant to your question is the effectiveness of the determination of hazards that may contribute to, or increase the levels of, risk associated with the project – and then determination and assessment of the available options for reducing those risks to “as low as reasonably practicable – ALARP”.

First, the hazard identification process needs to be carried out “without fear or favour”. That is, the participants within any group examining risks should be free to identify and record ANY hazard that they feel is appropriate. That said, the hazards must be able to be clearly linked to the major hazard, which, in the case of aviation, is most likely the “potential for a collision between aircraft”.

So the process must be one that says: “event x could occur, which would lead to an increase in the potential for a collision between two aircraft” – not “event x could happen which I don’t like”, or "event x could happen which would increase our charges", etc.

It is desirable - but not essential – that the identifiers of a hazard then identify activities or actions, which – in their opinion – may bring about a reduction in that hazard. Here again, such mitigators should be suggested without fear or favour. It is not appropriate to dismiss any mitigation at this point – even if it is obviously unlikely to be implemented. In some cases, it may not be possible for the parties present to develop a mitigation. If other parties determine the mitigators independent of the hazard jury, the hazard jury should be given the opportunity to examine the mitigators, and comment on their suitability.

At this point, the suggested mitigators can be evaluated to determine both their cost, and benefit. Most certainly, if a mitigator can be introduced at relatively low cost, WITHOUT substantially altering the characteristics of the change proposed, then it should. If a mitigator is expensive, and the cost would be disproportionate to the benefit – AND the residual risk is within the ALARP range – AND the responsible authorities are prepared to accept the risk – then the mitigator may be discarded – BUT the it must be stated within the safety case that a mitigation was considered and abandoned. In fact the reason for not applying any particular mitigation MUST be recorded.

It is NOT appropriate that hazard mitigations be limited by the convenors of the hazard identification process – even if it is clear that only certain options may be available.

Now to your question regarding effectiveness.

Having identified a mitigator, a process must be put in place – and its effect measured – preferably BEFORE – but most certainly immediately after implementation. That is why we made the point that simply identifying training and education as a mitigator – and apparently a primary mitigator at that – and then dispatching the material – does NOT fulfill the obligations of the safety case. The authors of the safety case MUST be able to demonstrate that the training and education material ACHIEVED THE DESIRED EFFECT.

How is that measured? In the identification of the hazard, it is important that the hazard is correctly specified, so that the causal chain can be seen, and the expected effect of the mitigation seen and recorded. So “event x could happen, …- if we educate the pilot about the hazard and its impacts, then educate the pilot about actions that would reduce the likelihood, then the potential for this hazard reduces”.

This allows two things to occur. First, it is possible to tell the training specialists exactly the event for which the training material is required – i.e., specific hazard related training rather than glib PR material.

Second, it is possible to test the effectiveness of the material by examining pilots, checking their responses, and determining if the education material is “fit for purpose”. This is usually done with a pilot study, or with a sample group of affected staff before material is released into the public domain.

In all, even for a relatively minor change, we believe that with over 50,000 pilots in Australia, you would need at least to 3 months to develop, test and evaluate, and then deliver training material – AND examine and record IN THE SAFETY CASE that it has been delivered effectively. Adjustments to training material for major change may require the training period to be extended to 6 months or more. Your regulator should only allow a go/no go decision date to be passed ONLY if there is evidence that training and education has been delivered and recorded – or can be delivered and recorded before the start date. This latter situation would probably only occur if there was evidence of prior compliance.

We hope this helps.

[ftrplt]

Dick Smith said:

There is little doubt in my mind that if Class C airspace is required in the link airspace above Launceston, then Class B airspace would be required where the collision risk is far greater in the area close to the runway.

This is the basis behind all of your reasoning for the airspace class changes, however it highlights totally your flawed logic.

- 'There is little doubt in my mind'; to me implies you have based your belief on opinion only and not backed by facts

- It is nonsense to assume that just because Class C may be justified for an arrival area, then Class B is automatically required in the terminal area. Who says the collision risk automatically increases?

If what you say is true, then the risk of collision in the SYD apt terminal zone in the Director radar pattern must be automatically higher than in the terminal arrival airspace where there are three airports and a couple of VFR lanes as well as mixing it with PJR ops.

How about a mythical piece of arrival airspace that services 3 or 4 large airports in close proximity, are you saying that the terminal airspace of each individual airport is automatically riskier than the arrival airspace where traffic for all airports is mixing??

It is easy to see that Class C arrival airspace automatically requiring Class B terminal airspace is silly. It is entirely sensible that Class C arrival AND Class C terminal airspace may be entirely justifiable.

[4Greens]

We are now entering a very dangerous stage in the airspace problems. Changes to changes are a prescription for real trouble. Any variations to procedures should be incremental and slowly and carefully implemented.

[ferris]

VoR.
Thanks for the response. I'm still troubled byHow is that measured? In the identification of the hazard, it is important that the hazard is correctly specified, so that the causal chain can be seen, and the expected effect of the mitigation seen and recorded What level of mitigation is being offered? Are the same people responsible for determining "expected effect"? eg. If see and avoid between jets and C172s is identified as a hazard, and the mitigation offered is 'switch on your lights', at what point is that mitigation measured for effectiveness ie. will switching on lights adequately mitigate? If it is determined afterwards that it happens to be a piss-poor mitigator, what happens- everyone just shrugs and says "the safety case wasn't very good"?

Second, it is possible to test the effectiveness of the material by examining pilots Education may reduce the hazard, but maybe only by an infinitely small amount. How will we know? Is that adequate? Given that the error event is catastrophic, is it worth finding out the 'hard way'?

All this assumes a safety case is even attempted.:hmm: Here I was thinking safety cases were just hastily cobbled-together shams written to achieve a set objective. Cynical?

ftrplt. Too right. You'll only get emotive argument out of Dick.

[Voices of Reason]

Ferris,

Perhaps an example of how we might approach a change, similar to one enunciated in your latest reform efforts:

Proposed design change: Class C in the terminal transition airspace to Class E.

BENEFITS

Benefit and Value 1. Reduced separation responsibility for air traffic control potentially translates to reduced workload to controller potentially reduces staffing requirement. If tower and approach function integrated and one man tower – net benefit zero.

Benefit and Value 2: Greater freedom of access for VFR aircraft. If VFR aircraft regularly diverting around controlled airspace, or delayed in obtaining clearance or subject to restrictive clearances, potential fuel and time cost. For small and quiet tower, assume minimal disruption to VFR operations, assume cost to VFR at $200 per day times 365 days equals $75k per year.

Benefit and Value 3: Better relationship between levels of risk and services provided to mitigate risk – i.e., best practice. Value – cultural not directly monetary.

Net potential benefit: $75,000.00

RISKS

Primary Hazard: Inability to communicate with, control, or manage VFR flights in relation to IFR flights increases to potential for collision in terminal transition airspace. Class C risk calculated/estimated at [say one accident per 200 years(not validated – example only)]. Risk in Class E calculated/estimated at [say one accident per 100 years (not validated – example only)]. Cost of a hull loss equals $50M plus passenger value at $2M times 75 equals total $200M amortized over the change in risk years [$200M/100years] equals $2M per year.

RISK MITIGATION

In order for this equation to make sense, one of two things needs to happen.

1. An authority needs to state that a change in risk of this magnitude is acceptable.
2. Risk needs to be managed so that the differential between cost and benefit is reduced to a more reasonable ratio.

Examining risk mitigations:

1. Primary radar – cost $5M plus annual maintenance - unacceptable
2. Secondary radar plus transponder carriage and activation - $5M plus maintenance – unacceptable
3. Reliance on TCAS – not permitted
4. enhanced see and avoid – minimal cost [but refer 6 below]
5. training and education – cost at, say, $100,000 one off.
6. etc

Enhanced see and avoid, from what we have seen and read, means training in scanning, and activation of lights. A search of the web will immediately turn up more than a dozen studies that argue that scanning and lights are of somewhat limited value [refer previous posts]. If this means is to be pursued, the proponents of change would need to do and record substantial studies on the subject, and specifically tailor training and education to that subject.

Training and education would probably concentrate on avoidance techniques – i.e., ways to avoid the flight paths of IFR aircraft and so on [but refer the benefit argument above].

…etc…

We think you see where we are heading here.

There is little or no benefit, for a substantial initial cost, AND a substantial risk increase.

One thing that should be noted is that safety cases do not just show when it’s “safe” to do something. They are also used to tell you when you shouldn’t do something. This is a classic case where there is no benefit in a change, other than the potential cultural shift.

[DirtyPierre]

Voices of Reason,

WOW!

That last post postively demonstrates how our airspace reform should proceed. Not the Australian, "she'll be right, they do it overseas mate!"

Thank you for your objective and logical dissertion on this very important topic.

Thanks mate!

[AirNoServicesAustralia]

Sorry Voice of Reason, but as an ATC I can't stomach the whole idea of crunching numbers (involving hull losses and peoples lives being lost) and deciding based on economics if a change to procedures/airspace is acceptable or not.

It reminds me of the big US car companies who on finding a defect in their cars, don't automatically recall the car, but first do an analysis of how many people the defect will kill, and then based on the litigation costs from those peoples families versus the cost of a total recall, it is decided whether or not those faulty cars are left on the road or not. That whole process makes me sick.

As a controller, my decider on whether a change to airspace/procedures is acceptable is the same as used when deciding whether or not to validate a new controller, that being "would I be happy to have my family fly with this controller" (in this case in this airspace). I know economic rationalism has taken over the world and my "voice" may be old fashioned and out of date, but I still feel that one hull loss and one life (who may be my son, or mother, or father) lost is one too many, and in Australia at least we have always achieved a perfect record when it comes to RPT jets getting safely around the country, so lets keep that.

Let the economists crunch the numbers all day long, but I know without the figures, that E airspace is less safe than C and it does not reduce controller workload (hence doesn't reduce controller numbers, hence where is the saving coming from???), so the changes have and always will be unwarranted.

[Chris Higgins]

Alright, enough beating up on Dick! At least he's got balls enough to come on line in his own name and defend his ideas. Don't back him into a corner, let's help him find a solution.

Mr Smith, no matter how you you cut it, the present system just won't fly: get over it!

I am a domestic and international charter jet captain who flies 700 hours a year on average. I am based in Pittsburgh, but learned to fly in Port Macquarie, under Bob Needham, who has since retired. I used to live in Alice Springs, then Mt Isa, Townsville and Sydney. I did a short stint in New Zealand before meeting my American bride and have been living Stateside for fourteen years.

Mr Smith, you are forgetting one thing when you fly around Australia in your Citation...how few tax payers there really are!

It is true that less than nine million people in Australia pay their full burden of income tax. With that, we build roads, educate children, run a skeleton military and among other things, support a NAS. In the US there are more than 200 million workers with tax withdrawals coming from their pay cheques every other Friday. This means they can build roads, educate children, bomb the sh!t out of people and HAVE NATIONWIDE RADAR COVERAGE.

In 1990, when I first married, I read a commercial brochure for the Pittsburgh International Airport. It states, "Pittsburgh is within 90 minutes flying time by commercial jet of 50% of the US population and 50% of the Canadian population". It would certainly make sense than, that the busiest "center"(centre) in the world is now Cleveland. It would also make sense that the load is so high that you must program at least a dozen communication frequencies to complete a one hour flight anywhere.

How does this relate to Australia? IT DOESN'T!

Australia has neither the resources, trained staff, nor the willingness of the industry to participate in such a needless process. It doesn't have the weather to require it either. I have frequently departed in less than 600 feet of forward visibility this last winter, I doubt we do that too much in Port Macquarie or even Melbourne.

VFR flying cannot be considered an excuse to not participate in a reportable, accountable and completely identifiable flying transaction. It used to be...it was called FULL-SAR, FULL Details.

Remember that Dick? It was one of the first things you stopped when you came up with that new idea of changing the safest airspace system in the world. Now VFR guys leave a note with mum.

Admit you screwed up and bring it back!

Next, fix the bloody exams. They are completely corrupted now. Any parrot could recite the answers and now you have pilots with alarmingly low intelligence operating in the airspace system.

Charles Dickens had many themes in his writings. One is that you become what you hate. It seems that at times you have shown disdain for things from foreign countries, yet it is America that you seem to be trying to turn Australia into. Australia will always be Australia, and I will always be Australian. How 'bout you Dick? Are you content with "affordable safety"? Do you want someone with very little experience and/or low academic achievement becoming an "airline captain". Do you really want to live through the dark days of USAir, where they had five fatal crashes in five years before anybody raised their hands to ask a friggin' question? What is your end game? What do you want exactly?

[Capcom]

VoR

http://www.stopstart.freeserve.co.uk/smilie/clap.gif

One of the NEW hazards in changing C to E was of unannounced, uncontactable and perhaps unseen VFR and the resultant consequential potential for collisions with IFR and other VFR.
It was raised by field Controllers repeatedly only to be told that it was an inherent risk in E and that because it was an accepted risk in the US that it was OK here without local analysis. No aeronautical studies with respect to local traffic densities, mix, terrain , meteorology etc.

The fact that was it was not previously a hazard in C in the context of normal system operation did not trigger an analysis (aeronautical study) for change to E i.e. In C the hazard only existed if the result of a VCA or ATC/Pilot error. Clearly the Increase in MAC opportunity in E would under any objective analysis be unacceptable when as indicated above it does not require a system fault to create a risk and not withstanding there is not an identified cost benefit to offset the identified increased risk.

Add to that another fundamental flaw i.e. The US consider VFR conducting instrument training in E will as a natural consequence of "head down" necessity, be treated as "IFR" and separated. It too was completely left out although it to was raised repeatedly. A known "US" mitigator left out of AusNAS.

That said, it is clear that if and when these analysis are carried out it will likely support a return to C when it is clear NO overall safety or cost benefit is gained by E.
Until then we are operating with untested and arguably “demonstrably” less safe airspace (See ATSB 200305235 Launceston). Criminal!

VoR et al, In advance of the following, I do not wish to detract from the very erudite discussion of these matters.
It is however, frustrating in the extreme to be discussing the very concerns that were raised and glossed over/ignored before 27 Nov. Clearly our concerns/questions were valid.
I cannot help being very bent outa shape over this whole mess. Those responsible seem blissfully uninterested in the problems it has caused.
This Industry has given me much over the years, and I am personally very angry at the systematic damage being caused by a handful of self-interested Pro-NAS dills.

RANT – select – ON (Full)
EMOTION – select – ON (Genuine, MAX)

So Dick, this is what your AusNAS 2b has delivered us:-

Negative effects:-

- VFR are NOT charged for en-route ATS, so there is No cost benefit C to E
- In the context of IFR to VFR, there is no longer 3rd party separation services - An Increase in risk for no cost or safety benefit
- Possibility for frequency congestion (Mutual Traffic ATC to Pilot - Pilot to Pilot). Increase in risk for no cost or safety benefit
- Less ability to plan separation sequencing into terminal areas - Increase in risk for no cost or safety benefit.
- Less SA for both Pilots and ATC - No cost or safety benefit
- VFR diversions from direct track to avoid IFR routes - No cost or safety benefit, especially considering there were very few delays for VFR in CTA prior to 2b
- VFR now need to know IFR tracks and APP/DEP routes etc in order to remain clear of them - No cost or safety benefit
- There are others but those above seem the most compelling

Positive effects:-

- VFR do not have to use a pesky radio- No cost and one could argue NO safety benefit (Not having to use a radio and look-out offset against the lack of separation services would seem to be a net negative safety effect. Certainly in the context of IFR conflict possibility)

Yep, AusNAS 2b, what a winner!! http://www.stopstart.freeserve.co.uk/smilie/cussing.gif

With the money wasted on AusNAS (Probably over A$100mil when all is said and done), imagine how much good could have been invested into industry via training, education and infrastructure that would have enhanced all sectors including VFR (GA in particular). Another opportunity down the dunny. Things such as:-

Every VFR (GA) Pilot could have had a 2-3 day course on:-

- Use of the radio and interaction with the ATS system
- How to use the ATS system safety to their advantage
- Famil visits to ATS operations, awareness opportunities

As well as things like:-

- An Online and or Operations operator Q&A for operational questions and feedback
- ATS established after analysis where a need "probably exist" i.e. AYE, Broome etc
- FSS Briefing and SAR
- Infrastructure to support enhanced Pilot SA (ADS-B subsidised introduction to supplement ATS in a similar fashion to TCAS)
- Reduced costs to industry (Subsidised services to regional and GA aerodromes provided by a re-investment of the profit dividend given to the Fed Gov't each year)
- Scholarships in ATS, Engineering, Operations etc

The list goes on, what’s more it is all achievable if only the "rudders" in CB would take the view that the industry needs support now more than ever, not screwing it for greater profits to Gov't. Bean counters have their place but should not be in the drivers seats.

Higher costs and less service, which we have seen in recent years just leads to de-skilling of pilots in ATS procedures and a reluctance on their part to utilise/participate in the very tangible benefits ATS can provide. Their fear of appearing amateurish due lack of familiarity or being ESIR'd for inadvertent transgression’s would seem to be a result of their ongoing exclusion from the ATS system. Those who grow up in the system do not fear it! Fact!

Nothing will improve for our industry until these fundamentals are addressed!

All in all an unmitigated disaster!

EMOTION – Select – OFF
RANT – Select- OFF




Nurse……..Nurse……….http://www.stopstart.freeserve.co.uk/smilie/explode.gif

[ferris]

VoR.
Thanks, it took a while, but we finally got there........There is little or no benefit, for a substantial initial cost, AND a substantial risk increase

Note to all: Dick Smith has stated on this very thread that he agrees with Voices of Reason. I expect he will immediately begin "lobbying":hmm: the Minister for Foot-in-Mouth, DSC (Distinguished Spin Cross) with bar, to halt this farce.

You will, won't you Dick? After all, it's a matter of personal integrity.

ANSA. Welcome to the 'brave new world' (best practice, that is).

Capcom. It's hard to check the emotions at times. Keep fighting the good fight.



Why are all the NASites so quiet? Busy eating crow? Back-peddling, arse-covering excuses for men.:mad:

[Adamastor]

I just wish Chris Manning had been as quiet as the rest of them - reading the transcript of his interview made me physically ill!!!

I wonder whether his self-promoting lies will get him his coveted position outside line management, or perhaps its the political arena he's been promised like Uncle Dick?! How does a person like that make those sort of statements and then sleep soundly at night?! Just disgusting.

[OverRun]

Let me come to the defence of Capt Chris Manning. I am quite outside of Qantas, although I have interviewed Capt Manning in a closed and confidential meeting with respect to safety issues around NAS.

He is sitting in an extraordinarily difficult position and has many stakeholders to satisfy. His job is to be Chief Pilot of Qantas, not to design airspace or work for the Government doing their air safety, or audit a safety case. His words in the interview were chosen, as carefully as ever, to discharge the requirements of his job and that is as much as he can be expected to publicly do.

If you are looking for people to criticise, what about the ones who are being paid to design the airspace, being paid to do the safety cases, and being paid to audit the safety cases? And the people who are being paid to sit above them and manage the process, and the board who sits above them and gets paid to make sure the job is being done properly.

None of those are Qantas or Capt Manning. In fact what I've seen from Qantas and many other airlines is a lot of contribution behind the scenes, to try and help the airspace changes so that they will work. Unpaid, of course.

I suggest that if individuals want to express their concerns about NAS, the door has been opened to all of us with the NPRM on Stage 2c. Please remember that the closing date for submissions is 12th of March. I urge you all to make a submission, however brief. It will help to inform CASA that such a change will benefit very few, but significantly increase the danger to many. The link to the NPRM is http://rrp.casa.gov.au/download/04_nprm.asp

While I'm on my soapbox, I want to draw everyone's attention to the persons who have done more to help us try and tackle this NAS debacle then even the eloquent and valuable contributions of Voices of Reason.

Danny Fyne, Woomera and the rest of the team at PPRUNE. Imagine how far in the dark we'd be without them. Go up D&G to the announcement on 'chat choking' and make a contribution. I have just done so. So can you.

[SM4 Pirate]

Mr Manning can hardly come out and say, "it's not safe, I thought so from the start", can he?

Although he might even think that.

Think of the tickets cancelled and subsequent bankrupt airlines in a very short period of time; not to mention most of us 'professionals' out of work.

Launceston has got the 'portable radar' nod; despite three other locations being preferred by the HATC and other operational types. Go figure, the bureaucrats and contract managers making a face saving decision against (over) operational advice. These clowns should be hanging from the highest rafter.

Anderson you are obviously not going to go (or do the right thing without being pushed into it), please sweep out all the dead wood that might have cost you your seat.

Bottle of Rum

[WALLEY2]

VoR Sir,

Our consultants are finishing "The design Aeronautical Study for Broome International Airport Terminal Airspace"

They have been thorough and because we requested an independent technical audit, it has taken 7 months and $60,000 to complete. It is the only design study carried out on 2c. This we have determined even though AA has rejected our FOI stating "public interest would not be served" we are challenging this decision but it will take months.

I find it amazing that an NPRM on parts of 2c is issued when there has been no baseline data gathering or attempt at analysis or design study for the rule changes. This we know as NASIG CASA and DoTRS say the documentation on 2c is minimal but at least they will release it (some 6-8weeks past the statuary release by date). Is this not putting the cart before the horse?

It has left us with nothing to compare our study with or any chance to compare risk parameters, mitigators, data etc.

My next question to you is that considering the site specific nature of many of the parameters in a terminal airspace study surely this means that if crude modeling (say on a/c movements p.a.) shows you are near the ALARP zone or if you are dealing with catastrophic events (mid air of a medium sized RPT jet) - then you need to do a series of terminal airspace Design Aeronautical Studies?

Now Airservices have undertaken to do the design Studies they neglected to do for 2b, would you consider it necessary that they do Terminal Airspace Design Studies for most of our major regional airports(typically 150,000 pax p/a and 737 ops down to 100,000pax p/a 146 or 717 ops)?


To all pprune users, FYI we don't feel it is in the public interest that the study on BIA be witheld from the public. It will be posted on our or our consultants web site within 1 week of its completion. cheers

[Woomera]

WALLEY2

Thank you.

If you would be so kind we would be delighted to provide a link to your generous offer from here.


W

[Capcom]

Walley2

Bravo!:cool:

Transparency and accountability, your leadership by example is to be applauded.

All the Best


Ferris
Damn hard to stay calm given what has happened and why! :mad:

The pills seem to be working though:ooh: ……...... for now! …..:E

[Dick Smith]

Four Seven Eleven, sorry, I thought I had answered your question in relation to objective analysis. Yes, I will certainly support an objective analysis of whether the NAS changes result in higher safety than the previous system. I have no doubt that they do.

The US FAA air traffic control specialists that were flown out at great expense from the United States both stated that the Australian NAS plan of placing airspace classifications to more effectively reflect the risk at that location was a better and safer way to go. They stated categorically to the Department and the Minister that the changes of 27 November 2003 would increase safety and that the final Australian NAS plan would lead to further safety improvement.

By the way, if you really believed in what you posted on this thread, I believe you would do it under your own name. For what other reason can your anonymity reflect other than a lack of confidence in your beliefs? If you genuinely believe that safety has been reduced with the NAS changes, I suggest you go public under your own name, and use your persuasive powers to convince the Australian people of this. I’m sure you will agree that it is almost impossible to do this when you are anonymous. I’m fascinated that someone could spend as much time as you do on this issue, and not be proud to put your name beside your beliefs.

[Chris Higgins]

Well, here we go...

Let's see Dick, highly paid Americans? Did that guarantee value for money, or just buy another donut franchise?

I went to Sydney Tech in 1986. We spent over a year on the commercial, flight engineer written, seniors..which became ATPL. Did courses on high speed flight, human factors and flight deck management. The exams were scheduled months in advance, many people didn't prepare, and they failed and quit completely.

Some of us missed the odd one,(for me it was Flight Planning at ATPL level using the 727-200 handbook), and we soldiered on.

When I got the States, I sat all exams in five days and passed with a 90 percent or better, no preparation. I was introduced to test prep books that even gave the answers to the exams before we went in. I instructed and flew air-ambulance for three and a half years. I was at first shocked at the low standards of secondary education and even more amazed at the standards promoted by the designated (ATO) examiners in their testing process.

I did a "degree", in fact a Bachelor's Degree in business, which included courses on American Modern History. One girl thought Pearl Harbor was in Florida, another said that she thought there had been, "like...three or four world wars?"

My observation of America is this: anyone can learn to fly and call themselves an expert. Anyone with a taste for caffiene and cigarettes can pretty much become a contoller, then call themselves an expert too!

You do not need to, "Come to America", as Neil Diamond would sing. You should look closer to home to find "experts". Their address is 203 Coward Street Mascot, and they are commonly referred to as "QANTAS Pilots".

Qantas flies into New York and Los Angeles, they don't just fly the oceanic feeds into coastal airports. I have seen them fly beneath me at FL350 through Denver Center Airspace, and they seemed to be going the right way!

Dick, while we're at it. When you analyze the weather of the United States and you look at the amount of flying done VFR by private pilots, it's actually one of the lowest proportions in the world. My money as an instructor was not made teaching primary students, it was made going straight from there into the teaching of instrument ratings, in a city that only gets 60 sunny days a year.

Why aren't I flying for Qantas? I interviewed there three times and somewhere between the fantasy point of flying for Qantas and the thought of sitting still for up to fourteen hours through ten time zones and relocating an American wife with young children to Australia, it didn't work out. I don't have a problem with that at all, in fact I had a wonderful time down in Sydney all three times. I don't see what all the gripes are with Qantas, they seem like a truly world class airline.

I instructed the Boeing 757 and 767 here in the States for a major airline and it was shocking to see the differences in piloting proficiency, self-discipline, mechanical aptitude and educational background. This is not the inconcistency that I ever observed during my short tenure as a commercial pilot in Australia.

My real fear Dick is this:

If I ever go back to Australia to escape this craziness, will it be even worse there than it is here?

Perhaps it's time for a fresh outlook. Perhaps it's time to find Australians that have solutions to the problems that are uniquely Australian. If you need me, send me a private mail. I go back to Australia at least twice a year. I'll do it for bloody free!!

[Paul Considine]

OK Dick, I'll bite!

1. I am posting in my own name because you seem to believe that peoples desire to use a psuedonym makes their point of view irrelevant.

2. feel free to PM me and I'll give you my phone number - you are a millionaire you can run your phone bill up!

3. I have had an absolute gutful of you telling everybody that NAS is SAFER!.

4. explain to us all - without use of the phrase "I believe" where the cost savings are

5. explain to me - a 737 Captain - how my operations in E are safer when you actively discourage VFR pilots from talking unless THEY believe a collision risk exists - and you complicate the issue by removing frequencies off charts, so if they determine a risk exists visually they need to hunt down the appropriate frequency

you have made my job infinetely more difficult, and far more dangerous - thanks heaps!

[Creampuff]

I am disturbed at the way in which you appear to analyse these issues, Dick.

4711 chooses to post anonymously, and that somehow affects the objective risk in Australian airspace, pre- and post-NAS 2b, does it?

The number of people you and he can convince one way or the other as to the objective risk in Australian airspace, pre- and post-NAS 2b, somehow affects that risk, does it?

MARTHA (737 passenger): Look Arthur, there’s a Tobago.

ARTHUR: Don’t worry Martha, a majority of the public including that nice Mr Smith are of the opinion that we’re safer than we would have been last month.

MARTHA: But Arthur, wouldn’t the Tobago have needed an airways clearance last month?

ARTHUR: Don’t worry Martha, a majority of the public including that nice Mr Smith are of the opinion that we’re safer than we would have been last month.

MARTHA: But Arthur, wouldn’t they have kept us a little further apart last month?

ARTHUR Don’t worry Martha, a majority of the public including that nice Mr Smith are of the opinion that we’re safer than we would have been last month.

MARTHA: But Arthur, was it safe to be that close?

ARTHUR: Of course: only people who post anonymously on PPRuNe think it isn’t.

MARTHA: I see ….. I think.

This is madness, Dick.

You support an objective analysis of whether NAS results in a comparatively less safe or more safe system than its predecessor. That’s a relief. If only the analysis had been done before the unwitting public was let loose in it.

You have “no doubt” that post-2b is safer than pre-2b. So what? I know some people who have “no doubt” that the moon missions were a hoax. I also know some people who have “no doubt” that the specific gravity of AVGAS is approximately 0.7 at 15 degrees celsius. Before acting in reliance upon their respective opinions, I ask to see the evidence upon which those opinions are based.

I don’t care what you doubt or don’t doubt Dick. Nor do I care what 4711 doubts or doesn’t doubt. All I want to know is: where is the evidence?

You say some FAA ATC experts were flown out and that:[Those experts] stated categorically … that the changes of 27 November 2003 would increase safety.You have got to be joking. No really Dick: you have got to be joking. No competent expert on this planet would be prepared to make a categorical statement like that about any complex system, airspace or otherwise. No competent expert would put their name to an opinion about safety, without setting out the assumptions, limitations and qualifications upon which the opinion was based.

But I’m happy to be convinced otherwise. I’m happy to consider the evidence as to who said what and on what basis. Could you post the experts’ report in its entirety, or a link to a copy, please.

[edited to correct two typos]

[Dick Smith]

Paul Considine, the facts are this. Now that fewer VFR aircraft are making self-announcements on ATC frequencies, Australian airspace will be able to be operated with fewer sectors. Not so long ago on this site, an air traffic controller stated that the only reason an additional low-level sector was turned on – with additional ATC staff – during the day was that VFR aircraft started making self-announcements on the frequency when their flying school operations began for the day.

Pilots who have flown in the system since 27 November will notice that it is considerably quieter. This means fewer sectors and cost savings

Paul, I would have difficulty in convincing you that your operations in Class E are safer, however you have to look at the complete airspace system. If you fly an aircraft from Sydney to Launceston, you no only go through Class E airspace, but you also enter Class D airspace where the collision risk is higher. Before 27 November 2003, the controllers at Launceston were responsible for airspace of very large dimensions. Separating IFR and VFR aircraft in Class C without radar is extremely complicated, and I’m told (by controllers) requires a high workload. This obviously means that the controller could be concentrating on separating IFR and VFR aircraft well away from the field, whilst at the same time the controller has responsibility for the separation of circuit traffic.

I am told that the reason the American system gives such high levels of safety is that they concentrate the ICAO airspace classifications to reflect the degree of risk. They do this in a totally objective way.

The reason the frequency boundaries have been removed from the charts is so that we can copy the international system where small aircraft with less experienced pilots can concentrate monitoring the aerodrome frequency when in the approach and departure airspace.

I’m sure you would agree that when you are flying at FL350, it is not important for a VFR aircraft below you at 5,500’ to be listening to your calls to air traffic control. The problem is that with the previous system, after 2 or 3 hours of listening to these calls (all of which were irrelevant in relation to traffic avoidance to the small aircraft) when then in the approach and departure airspace of an MBZ or a CTAF, quite often the VFR aircraft was either still on the ATC area frequency, or the pilot had simply given up and turned the volume down.

The plan of the ARG is to decrease the number of unalerted see and avoid incidents. An unalerted see and avoid incident is more likely to happen when close to an aerodrome. I understand that already these incidents are reducing.

Chris Higgins, you are correct. Qantas flies passengers across the United States every day – in Class A airspace enroute and approaches through Class E airspace at Los Angeles and JFK. Qantas passengers then move on to other airlines and fly regularly through non-radar Class E airspace into Class D towers. If Qantas for one second thought that the procedures the Americans use in radar airspace, and the procedures the Americans use in non-radar airspace were not safe, they would inform their passengers. Considering the enormous amount of traffic in the USA, it is obvious that their airspace system provides very high levels of safety. This is not a belief of mine, it is a fact supported by 50 years of statistics.

[ferris]

Good to see you are getting to the core issues, Mr. Smith. You are doing a damn fine job convincing the professionals your "beliefs" are the way to go. I mean, it's much more important to try and get an opponent to reveal his identity, than answer any criticisms, or defend the indefensible, right? I'm sure your interest in this person's identity is purely magnanamous- just want to send him a 'good work' note? Who do you think you are kidding?
Yes, I will certainly support an objective analysis of whether the NAS changes result in higher safety than the previous system. I have no doubt that they do Then why didn't you/ARG commission such an analysis before you began the changes? BTW, I and at least 3 other 'international air traffic control specialists' have flown to Australia 'at great expense', and we agree that AusNAS is not a better and safer way to go. So, I see your two ATC's, and raise you two (do you see how stupid your arguments sound?).

The wings have fallen off (AGAIN), your cohorts are all reaching for the parachutes- are you going to ride with it into the ground? Please do, Australia can ill afford to waste any more money on your 'aviation adventures'. It's high time your reputation got down to where it should be (and not just for those within the industry).


edited to reflect the last post- posted while I was posting mine.
in the USA, it is obvious that their airspace system provides very high levels of safety. This is not a belief of mine, it is a fact supported by 50 years of statistics You are very careful choosing your words, but you're still not fooling everyone. You see, I happen to think that 'very high' levels of safety may not be good enough, especially when the system YOU changed had EVEN HIGHER LEVELS OF SAFETY- as supported by 50 years of statistics.
Your other points have all been addressed before- frequency combining was a child of 'efficiency', something I thought you would have approved of- in fact, making Aus MORE EFFICIENT in providing ATS than the US. It allowed you to sack all those FSOs- you know the ones they have in the US SYSTEM? (BTW- if a VFR pilot 'gets bored' listening to the radio so turns it off, maybe one should question whether that person is fit to hold a license, not whether the radio should be made silent? What do we do about pilots who get bored looking out of the window for traffic? Put them in charge of airspace reform and see what they 'believe'?). And the furphy about more classC somehow 'distracting' the controller from 'closer to the airport', etc. etc. Done to death, Dick.

Something about a drowning man and straws comes to mind.

[Paul Considine]

Dick,

Thanks for the response.

Firstly can you quantify the savings? I am not convinced that the savings are there - I don't see AsA offering redundancies to controllers as a result of the 2b changes.

You say that I have to look at the whole system - so are you admitting that the E is LESS safe than what was previously in place? This is certainly the implication that can be drawn from your statements.

The shrinking of the D steps into Launceston makes my workload higher and also complicates the life of the controller because he can't assign me descent below 15000 into Launy on the Sydney track until about 30 DME which puts us very high.

This has the effect of transferring our attention from looking out the window to managing the aeroplane. We are also high requiring extra track miles within the D controllers airspace which makes his/her life more complicated.

you and the rest of the ARG are NOT professional AIRLINE pilots and you don't look at the airspace from the perspective of the professional airline pilot - that is - the USERS.

The VFR lobby have too much pull politically in my opinion.

The entire system is less safe as a result of your reforms and you should be ashamed of yourself - your inability to listen - and I mean LISTEN to differing opinions was the cause of your undoing at CAA and CASA and will be the undoing of you here.

[Dehavillanddriver]

amazing how things change!

Airspace changes will be safely, efficiently and professionally introduced on 27 November 2003
Aviation Reform Group (ARG) Chairman and Secretary of the Department of Transport and Regional Services, Ken Matthews, Airservices Australia Chief Executive and Managing Director, Bernie Smith and Civil Aviation Safety Authority (CASA) Acting Director of Aviation Safety, Bruce Gemmell, today jointly announced the next planned changes under the National Airspace System (NAS) reforms, will proceed on 27 November 2003.

The decision follows exhaustive safety analysis of all issues raised, including those made by pilot and air traffic control unions, in relation to the proposed changes.

CASA Acting Director of Aviation Safety, Bruce Gemmell said the Authority has accepted the safety cases prepared by the NAS Implementation Group, which allows the introduction of the new changes.

“ Our acceptance follows the incorporation of changes in updated pilot and air traffic controller training and education material, regarding radio use, operations in non-controlled airspace, and the inclusion of additional safety mitigators,” Mr Gemmell said.

Airservices Australia CEO, Bernie Smith said as a result of the CASA acceptance, the Board of Airservices Australia approved the immediate distribution of pilot documentation including charts to give effect to the airspace reforms.

“ The distribution of pilot documentation including charts and training materials is a key milestone in the safe implementation of the changes which come into force on 27 November 2003.

“ The Airservices Australia Board and Management are satisfied that the safe implementation of the changes can proceed following appropriate safety analysis and final CASA acceptance,” Mr Smith said.

ARG Chairman, Ken Matthews, said that he was satisfied that due process had been followed to achieve the final approvals.

“ The various agencies involved in airspace reform each have certain parts to play in the process and legal obligations to discharge. It is gratifying that Airservices Australia, CASA, Defence, the Department of Transport and Regional Services and the NAS Implementation Group have been able to work together constructively and complete their work on time.”

Contacts
All inquiries of a technical nature should be directed to the NAS IG - the group responsible for implementing the new system.

Colin Blair, NAS IG, 02 6287 6978 / 0416 266 843
Kate Robinson, Department of Transport and Regional Services, 02 6274 8059 / 0438 288 105
Richard Dudley, Airservices Australia, 02 6268 4479 / 0412 146 828
Peter Gibson, Civil Aviation Safety Authority, 02 6217 1015 / 0419 296 446

[ftrplt]

The reason the frequency boundaries have been removed from the charts is so that we can copy the international system where small aircraft with less experienced pilots can concentrate monitoring the aerodrome frequency when in the approach and departure airspace.

OK Dick,

just which 'aerodrome frequency' do these VFR's monitor 45nm west of Sydney, Cairns or 45 north of Brisbane or Melbourne?? Which frequency is appropriate?? Where do they find them??

Do you believe that Class C approach airspace AUTOMATICALLY requires Class B terminal airspace because it is 'much riskier'?

[Four Seven Eleven]

Mr Smith

By the way, if you really believed in what you posted on this thread, I believe you would do it under your own name. For what other reason can your anonymity reflect other than a lack of confidence in your beliefs? If you genuinely believe that safety has been reduced with the NAS changes, I suggest you go public under your own name, and use your persuasive powers to convince the Australian people of this.

Oh, not that tired old saw, again, and again, and again........ When you run out of answers, you drag this one out - every time. Let me repeat for what seems like the thousandth time. The reasons for my anonymity on these forums is covered very adequately on the "Dicksmithflyer" website. If you now believe that what you say on your own website is a lie, I suggest you make a public retraction. If, as you say, you 'believe' I will reveal my name on this forum, then - once again - your 'beliefs' are wrong. Not everything you 'believe' is necessarily true.

I have never said, here or elsewhere, that I do not advocate, under my own name, for air safety in Australia. I do so on a regular basis. In fact, I am paid to do so. That advocacy - or more accurately the advocacy of many professionals including myself - is finally starting to bear fruit. The Airservices board will shortly be considering air safety improvements to counter the effects of NAS2B in particular. Despite your efforts, air safety will hopefully now be subject to stringent analysis before implementation of further changes.

If we can avoid the self-serving political manipulation of the last few years, we might be able to overturn the economic and safety debacle that NAS has caused so far and advance the cause of aviation reform. Personal crusades and sectional intersts have held sway for too long. It should now be the turn of those who have the interests of the aviation industry at heart.

I am glad to hear that you finally support objective safety analysis of NAS and relative safety. I am appalled that it has taken this long for you to do so and at great financial and safety cost. Why did you not support it - in fact insist on it - before the untested system allowed a jet and a Tobago to get so close to each other near Launceston? Not to mention the Darwin, Melbourne and other incidents. How do you justify that increased risk to those passengers -a risk that was not present before 27 November?

Pilots who have flown in the system since 27 November will notice that it is considerably quieter. This means fewer sectors and cost savings
Once again you demonstrate an abject and wilful ignorance of air traffic management. If you believe this to be true, I suggest that you contact Airservices Australia to find out the real costs.

With all due respect, do you not feel that it is either time for you to start educating yourself on air safety and airspace management issues, or allow those who have professional expertise in this field to do their job in the interests of the Australian public?

Separating IFR and VFR aircraft in Class C without radar is extremely complicated, and I’m told (by controllers) requires a high workload. This obviously means that the controller could be concentrating on separating IFR and VFR aircraft well away from the field, whilst at the same time the controller has responsibility for the separation of circuit traffic.

And what happens under NAS? The controller continues to do the job of separating close to the aerodrome, and no-one separates IFR from VFR further afield. In fact no-one provides traffic information. So, by the stroke of a pen, we just tell pilots that they will be 'safer' if they make it to the circuit area.

Forget about what a controller 'could be' doing, Mr Smith. You are paid to determine not what 'could be' happening, but what in fact really happens. Suppositions, "could be's" and your beliefs have no place in being a paid public servant entrusted with the safety of the flying public. If you are unwilling to let objective analysis, rather than supposition and guess work, form the basis for airspace reform, then I suggest that we need someone who will.

[Those experts] stated categorically … that the changes of 27 November 2003 would increase safety.

I suppport Creampuff's request that you provide us the evidence of this statement. Show us that you are telling the truth about this statement.

[Four Seven Eleven]

****su

As to your summary of the cost savings - less sectors because of less radio transmissions - please tell me you have got more than that.
Of course he has. Remember, he got paid to assess "the cost effectiveness of each of the competing proposals" (LLAMP vs NAS). This could not have been done without empirical data. So not only would he have the detailed cost/benefit anlaysis for NAS, but also the same data for LLAMP. The ARG were not paid 'handsomely' to tell us what they 'believed - in their 'heart of hearts - could be' better. They were public servants paid to do a job.

So, Mr Smith, you have the data. Why not release it? It must be contained in the written report that the Minister paid you to produce. Surely the hard facts will prove that NAS is cost effective, rather than relying on some silly 'silence is golden' theory of air traffic management. The figures will no doubt prove that the rumoured extra $53,000,000 that our customers will have to pay for the costs so far will be but a mere bagatelle when the costs benefits come to fruition. Surely, even now, GA and airline operators around the land are wondering what to do with all of the cost savings flowing into their bulging coffers.

So, the evidence you used to do your paid ARG job, and the evidence you mentioned in relation to NAS2B and NAS generally being quantifiably safer than the pre 27 November airspace will go a long way to advancing your cause.

We await the production of these facts with breathless anticipation. It will certainly silence those who have claimed that Australian airspace management is being done in anything other than the finest traditions of professional safety management.

The Virgin passengers who became so unexpectedly familiar with the sleek lines of a Tobago would no doubt feel somewhat reassured to know that you did not abandon their fate to the vagaries of chance, but acquitted your paid responsibilities in a 'professional' manner, with nothing but good solid hard facts to back you up.

Tell us it is so. No, don't tell us.......... show us.

[Chris Higgins]

Mr Smith, Qantas does an arrival in New York that descends from Class A airspace over the top of La Guardia and into Class B airspace at JFK. They never fly through Class E Airspace in the Northeast. The arrival is called the "Lindy Five Arrival", you surely have Jepp view?

I was the union safety chairman based in JFK for almost three years. They tried "turbo-prop" routing through Class E airspace with full radar coverage to mitigate arrival delays. Our operations averaged four (4) resolution advisories per week between Allentown Pennsylvania and the Colts Neck VOR. Thank God for TCAS! This was in a full radar environment with a completely overworked approach facility. The only time is was remotely safe was when it was socked in, and preferably in icing conditions.

I spent over 4 1/2 hours of my unions telephone money on conference calls with New York, Washington and Boston Centers and finally came up with Northern routing over more sparsley concentrated traffic and in mostly Class A and B airspace. The result was that the TCAS resolution reports dropped to zero for an almost three month period straight. We ran 125 departures a day.

I was so involved in the problems with the routing that my wife and I were finally burned out on the whole process and that's why I quit and tried the training department at a major airline. I actually needed a break from the airspace. I flew 987 hours out of the JFK hub in 1997. It was absolutely exhausting. To have to continue to cope with Class E airspace with non-reporting VFR traffic would have made it extremely dangerous.

Dick, you are an admirable man who has shown great leadership in Australia. I still have the first Australian Geographic with the finely penned drawing of dingoes on the front and a bunch since then. I have admired your adventures in VH-DIK and watched your North-South circumnavigation of the globe in a Twin Otter. You built an advanced electronics empire from scratch and tried your best to mitigate the waste of government as chairman of the CAA...CASA. You're a smart man!

What you are forgetting though is that we are too!

As an entrepreneur, you have had to stand alone and sometimes take a gamble. That's not appropriate here. I now have fourteen years in the American system. It works here because the yanks have put there own local spin on things, which is what the Australians should be doing too.

I flew a celebrity in from Bermuda the other evening. As we approached New York to land in La Guardia, we were given a VFR arrival, in Class B airspace, that constituted several local landmarks. The co-pilot had never seen it before and I briefed it thoroughly. It was only with his concurrence that I accepted the approach.

He is not "just along for the ride". He is an extremely necessary part of my life.

The Australian Airspace user is a very necessary part of your life too!

You may feel victimized a bit by now, and you have certainly been a victim of some of the "tall poppy syndrome" but this goes beyond this. Every good leader should accept advice from their subordinates. My father fought and died in 1971. I was raised in a democracy by a single mum who fit the best description of the Aussie battler. I think you owe to us all to observe these basic Australian democratic ideals.

Dick, remember the last time everyone agreed? It was Germany in 1931. History shows us that wasn't such a good idea!

[DownDraught]

The methadology they used for safty case was given in the Senate Estamates




Senator O’BRIEN—Can you give me an explanation of how CASA made the assessment that the US FAA NAS system was safer than the existing airspace system and what that was based on?

Mr Gemmell—It is really summarised in appendix 1 to that document that you have where we actually go through—

Senator O’BRIEN—We did receive it quite late. So having a look at it, it is not an easily understood set of explanations, if I can put it that way.

Mr Gemmell—I would have to sympathise and agree. It is not easy to go through, but it is there. It is under the heading ‘Safety Regulations, Existing Australian Practice in the US FAA NAS’.

Senator O’BRIEN—Is it based on accident and incident numbers?

Mr Gemmell—Essentially, it is looking at collision risks compared to traffic densities and saying, ‘What results are you getting in one system versus what results are you getting in another system?’—what you would expect to get.


EVIDENCE???
So I read from that there cannot be any imperical data that dick can produce, or is that wrong dick, or is it a task of "creating a safety formula" to "what you would expect to get", whatever that may be?



And



Senator O’BRIEN—Thanks for that. Just looking at appendix 1 that we were talking about earlier, the conclusion is that the US FAA NAS system is different to Australia. It says— Apparent more en-route risk and less terminal risk. What does ‘terminal risk’ mean?

Mr Byron—‘Terminal’ refers to that airspace surrounding an airport. It is not specifically defined as a standard figure for every airport, but it is where the traffic congregates close to the airport on departure and arrival.

Senator O’BRIEN—So we have a greater risk under the proposed system en route?

Mr Byron—My understanding of the whole concept—and I have operated in the United States—is that there is a large allocation of resources to where there is the concentration of traffic, which is in the terminal area, because statistically that is where the risk is greatest. So the mitigator is to deal with it slightly differently from the way one does on the en-route areas where there is less concentration of traffic and the mitigators are different. So there are differences in the two types of airspace. As a practising pilot operating various types of aircraft for the last 40 years and certainly in Australian airspace at different parts of the country in the last 15 years, I think that is a practical position that I would agree with.

And......................



CHAIR—Thank you very much to Airservices Australia. I understand someone may want to make an opening statement. Is that correct?

Mr Bernie Smith—Yes. I thought that perhaps, given the interest in the NAS and what is going on, it might be worth while making a statement clarifying a few issues to begin with. The committee would be aware from a media statement by Airservices Australia that it has found a problem with the process used to put in place the changes to airspace implemented on 27 November 2003. Airservices wishes to put the following information on the record for this committee in order to clarify issues which we expect are of interest to it. Airservices has a statutory responsibility to consider and approve changes to airspace design and management. In managing change, either on a day-to-day basis or in relation to reforms such as NAS, Airservices is always in a position where risks exist and need to be managed. This is clearly an integral part of the business that we are in. In considering such changes, Airservices takes very seriously its obligation in regard to safety as the primary consideration. Airservices has recently formed the view that its process for considering the changes on 27 November 2003 may not have properly discharged all its responsibilities under the act. The nature of the gap in our process relates, firstly, to the extent to which Airservices may have relied on the work of other parties—the Civil Aviation Safety Authority, the Aviation Reform Group, the National Air Space Implementation Group as examples—rather than its own comprehensive research and analysis. And Tuesday, 17 February 2004 Senate—Legislation RRA&T 73 secondly, to the way in which we chose to manage an identified risk related to the implementation of class E airspace. The first issue is now being addressed by Airservices commissioning a full and comprehensive review and validation of the safety premises which underpin the NAS reform. This will take the form of a design safety case of the full NAS reform program. The second matter involves undertaking a more extensive risk analysis of the changes implemented last year. This review, which will be undertaken over the next three months, needs to be seen in the context of the Australian Transport Safety Bureau recommendations on the Launceston incident. At that point the board will decide the extent and the need for any change to the current E airspace. Despite media speculation, Airservices continues to have insurance policies in place and there are no new operational risks that were not known when the decision to implement the changes was taken. The sorts of enhancements the board will be asked to consider after a full safety assessment involve changing certain portions of E airspace. The calls for reversal of some of the reforms implemented last November must be seen in the context that any change, even going back, carries risks. Airservices must properly assess all of this before making a final decision on the most appropriate way forward. That completes my statement.

[Chimbu chuckles]

I'm actually getting a bit sick of Dick's line of BS.

Please Dick....just go away and let people who actually KNOW of what they speak fix the problems caused by your beliefs.

I do not want to hear anymore of your beliefs or economic rationalism...it sickens me!!!

I've spent 23 years in this industry and, more often than not, it has been a battle against beancounters and self appointed, know all, f*ckwits to try and keep it all as safe as humanly possible.

We have a system groaning from the burden of incompetence.

It is completely obvious to anyone with a brain that this latest airspace/aviation debacle has been driven through without even the SLIGHTEST hint of 'worlds best practice' within the responsible govt departments....hardly surprising!!!

Anyone who has been involved in aviation in Australia, for more than a few years, knows at least one career failure who ended up in CASA. The good ones leave in disgust after a time and the extra cunning dumbarses end up in positions of increased power purely by the wick effect.

I'm sick of it...and I'm sick of listening to what you 'believe'.

Do you really think we give a rat's what 2, yes a whole TWO!!!, alledged US airspace experts think..or 4 or 6?

You expect, it seems, for this earth shattering 'fact' to make us all feel better and finally see the genius of NAS.

Gee, EVERY single professional pilot I know, all their peers and the Professional ATC Association disagrees with your two deadbeats and you still aren't listening to US!!!

No-one thinks 2b is a good idea Dick...well except the weekend warriors, the aviation minister and a bunch of yes men straight out of 'Yes Minister'!!!

Dick it is a constitutional responsibility of govt to provide the infrastructure that allows free enterprise to flourish safely. For f**ks sake Dick...Japanese car manufacturers get more support, from the Australian govt, than the Australian aviation industry!!!!!

The reason US aviation is so healthy has nought to do with it's airspace design and all to do with the fact that it (aviation) is valued. That and the shear economies of scale that the population of North America allow.

When Australia starts putting a value on a healthy aviation industry and we start getting some level of truly competent regulatory oversight there might be a chance...I don't hold my breath waiting...just one reason why my professional life is spent almost exclusively as an expat.

A very small step in the right direction would be for you to just go off and play with your aircraft and leave airspace reform to the professionals....please!!!

Chuck.

[Capcom]

Mr Smith

You are incredible!. We have been over the technical, safety and for that matter the cultural and political issues SO MANY TIMES!.

I am not going to go around in circles again when clearly you are incapable of listening!

If any one is interested, once Danny has restored the search function, Do a search on NAS and or Dick Smith, the 100's of thousands of words are there for all to see.

Do you remember the conversation you had with line controllers in YSTW TWR during the country music festival in January of this year?

Perhaps you might reproduce your statements here about the facts relating to your E airspace!

How bout I refresh your memory on one of those points:-

You signed a piece of paper confirming that YOU agree that RPT traffic should NOT have Unalerted See and Avoid

That said can you show us how changing C to E conforms to that principle?

I'll look forward to your advice, beliefs, gut feelings, and empirical waffle!..........NOT!:yuk:

[Four Seven Eleven]

Four Seven Eleven, sorry, I thought I had answered your question in relation to objective analysis. Yes, I will certainly support an objective analysis of whether the NAS changes result in higher safety than the previous system. I have no doubt that they do.
Very good. What process will you be initiating prior to the introduction of NAS 2C and later NAS stages which will objectively analyse whether or not these changes result in a higher level of safety than the previous/current system?
When will this analysis be publicly announced?
Which independent authority do you recommend to do this analysis?
Given that NAS2C is scheduled for later this year, by what time do you anticipate that this analysis, which you now support, will be completed?
Will NAS2B be (belatedly) subject to the same analysis?
Why has it taken this long for you to support a safety analysis?

[SM4 Pirate]

Dick A+B=An apple.

You have an interesting view on logic.

Pilots who have flown in the system since 27 November will notice that it is considerably quieter. This means fewer sectors and cost savings No it doesn't; you increased levels of risk in enroute, so you could devote resources to the higher level of risk, without devoting any more resources to the supposed higher risk environments. You introduced a higher level of risk to all the enroute airspace, fact. We have attempted to compensate for this increased level of risk, by having more sectors open than pre 27 November 2003, fact.

It is harder to control class E than Class C in a radar environment, why don't you listen... In class C everything is known so every decision taken is reflective of known elements, and you can say no if it is needed for safety; sure in a procedural environment it could be complex; but now you need to continually monitor every piece of IFR traffic; yes we used to do that anyway, but now we have a legal and moral obligation to increase this monitoring, vigilance. You used to monitor for potential unknown traffic, which effectively was rarer than hens teeth, now the unknowns are there constantly. This increased monitoring has resulted in more opening hours of the low level positions; it's a joke if you think it's any other way.

.. would have difficulty in convincing you that your operations in Class E are safer... If you fly an aircraft from Sydney to Launceston, you no only go through Class E airspace, but you also enter Class D airspace where the collision risk is higher. Before 27 November 2003, the controllers at Launceston were responsible for airspace of very large dimensions. Separating IFR and VFR aircraft in Class C without radar is extremely complicated, and I’m told (by controllers) requires a high workload. This obviously means that the controller could be concentrating on separating IFR and VFR aircraft well away from the field, whilst at the same time the controller has responsibility for the separation of circuit traffic. And the controller could say no at anytime for safety. VFRs did used to cop that from time to time, now VFRs come in unannounced, do what they want and no one knows they are there until the pesky little TCAS screams. This is not a safety enhancement. It's different task allocation. Managing the circuit traffic at LT is not a difficult job; you have saved no resources at LT, because there are less than 6 on station, which now only have to concentrate on the circuit traffic... No point having a circuit if no one can get to it safely.

In the USA, some of the resources which compensate for this lack of safety is radar, yes I acknowledge that there are some locations that don't have radar, and they also don't have very much VFR traffic, due to altitude or inclement locations, such as Steam boat springs, or Alaska locations. Steam Boat has radar coverage to the circuit, provided by centre radar, which separates and sequences (essentially) all IFRs inbound.

Dick you have good intent, but again you've biiggered it up. The ARG member, who just resigned, your good friend, should be able to explain to you why this went wrong. Known levels of risk, replaced by hope and maybes, shoulds, coulds and I believes; not knowns.

Please admit defeat and leave it to the professionals to sort out your mess, again.

Bottle of Rum

[PPRuNe Towers]

By the way, if you really believed in what you posted on this thread, I believe you would do it under your own name. For what other reason can your anonymity reflect other than a lack of confidence in your beliefs? If you genuinely believe that safety has been reduced with the NAS changes, I suggest you go public under your own name, and use your persuasive powers to convince the Australian people of this.

But Dick, at least our members found the time, the ability and the mental capacity to register.

You however found the experience so bloody baffling it took three weeks, the apparent full time efforts of your secretary, multiple phone calls to our Oz based helpers and nearly 20 e-mails to me in the UK.

In the way of contrast, more than 80,000 people have successfully registered themselves on this website over the last 7 years. Alone, solo, without assistance. Here in the UK our views are coloured by your total inability to even register yourself on such a stupid thing as a website let alone be expected to answer basic, simply phrased questions about airspace.

I suspect that someone who set themself up as an outsider asking tough questions, a visionary, a blue skies thinker, someone outside the establishment getting things done in aviation is actually struggling to cope with this medium where anyone, irrespective of status or education, stands or falls by the quality and content of their posts.

Rob Lloyd

PS I sign with my real name. This is absolutely immaterial to the readers of this site. They determine whether my thoughts are cogent or those of a publicity seeking ****wit by reading my words not my name.

Personally I suspect you err more towards this philosophy:

"Words can only hurt if you try to read them. Don't play their game."
Derek Zoolander

[Chimbu chuckles]

:ok: :E :}

Chuckles

[Dehavillanddriver]

well done Rob!!

I thought that there was a remarkable likeness - Dick and Zoolander!

[Dick Smith]

Chris Higgins, I note your comment:

Qantas does an arrival in New York that descends from Class A airspace over the top of La Guardia and into Class B airspace at JFK. They never fly through Class E airspace in the Northeast. The arrival is called the “Lindy Five Arrival”, you surely have Jepp view? I was the union safety chairman based in JFK for almost three years. Chris, your comments really worry me. You spent almost 3 years at JFK, and were a union safety chairman, yet you didn’t know that your aircraft were always descending and climbing through large amounts of Class E airspace. It certainly confirms what a non safety issue it is. I suggest you check your charts again and then correct your post.

[Hempy]

This thread is getting nowhere fast. Dick firmly believes one thing, professionals from the Australian aviation community with no agenda other than getting home safely to the wife and kids each night believe another, and never the twain shall meet.

The reality is that NAS will go ahead, eventually, when Airservices actually follow legal procedure (for a change) and rubber stamp their safety case. A few band-aid measures (a mobile radar that doesn't comply with TAAATS) and it's presented to the fare paying public as "fixed".

Dick has been ridiculed by aviation professionals in Australia for years. This hurts his ego because he believes that he hasn't been given due credit for his own aviation expertise. After all, he flew his JetRanger "solo*" around the world, and "solo*" to the North Pole. He's certain that he has forgotten more about aviation in this country than most of you will ever learn. If you think NAS is bad, of course it must be good. How can an aviator who's been compared (http://www.phm.gov.au/scripts/webdbs/opac.idc?id=116) with Hinkler and Mollison be wrong? I'm sure that if all the NAS nay-sayers said the sky was blue, Dick would have the Minister for Big Skies (or at least the Minister for the Big Sky Theory) propose a colour change to pink.


*I do not use the word solo in the same context as the Oxford Concise English Dictionary

[Paul Wolfe]

Dick,

Please explain the basis of your statement ¡°I agree with the Voices of Reason¡±.

Understand this:

Reason is man's ONLY means of knowledge and is based on fact.

The facts of reality are knowable through a process of objective reasoning that begins with sensory perception and follows the laws of logic.

Logic is the method by which we reach conclusions about reality based on the evidence of the senses and begins with the evidence provided by the senses.

Identification is the primary goal of our conceptual faculty. Our brains are put there to identify---to grasp in conceptual terms---what is out there in reality.

Non-contradictory refers to the primary rule of logic: contradictions do not exist. If one arrives at the conclusion that a ball is both solid gold and solid lead then one has made an error.

All errors in logic ultimately manifest themselves as contradictory identifications, without exception.

A process of thought based on arbitrary premises or ¡°beliefs¡± is not logic.

Although the technical details may vary among fields of knowledge and among forms of reasoning, the basic rule of logic is that contradictions do not exist.

Every logical conclusion can be traced back to an ultimate grounding in observation.

Logic dictates that each man use his own independent, rational judgement as is his only guide to action and reject "beliefs" such as yours; that knowledge is a matter of opinion; the belief that knowledge is a product of revelations or insights.

As a rational being, I possess inalienable rights. As these rights can only be violated by force, you, through NASIG are instituted to hold a monopoly on the legal use of force and to use it as your only line of defence against anyone opposing it.

Your underlying expectation is that people will risk their very lives and the lives of others by blindly and unquestionably following your principles.........Why?

You are not qualified to "agree with Voices of Reason"

Paul

[triadic]

Having been in North America recently, I asked a few questions of people that have significant experience flying in that part of the world.

Seems that if there is E over B or D (zones) then the "culture" of the VFR pilot and the "way" he has been trained, is to keep away from flying anywhere near over the top of such locations. They laugh when it is suggested that because it is E they could just cruise across the top at a VFR level. (special VFR procedures like LAX excepted) Of course they "could" but they "don't" because they have been taught how to use their airways system in a manner that reduces the risks involved.

The very problem with NAS and the Education (or lack of) associated with this change is that nobody including the Smith's have, it seems, either recognised or bothered to address the CULTURE differences between North America and Australia.

Until the people driving this project come to terms with the FACT that Australia is not and never will be North America (culture wise) and address the culture differences and the training and education we will continue to have problems trying to process airspace reform.

Australia it seems is creating an airspace environment which actively discourages VFR operations from participating in the system. I believe this to be on the verge of criminal and certainly not in the interests of safety.

To address the issues of change and the introduction of a North American style system the culture differences must be addressed. The system and those that operate it and train people how to use it, must be on the basis that the door is always open and should the VFR want/wish to participate, he/she should be welcomed with open arms. He/she should also be trained in how to operate outside the system if that is their choice.

The training and education of both pilots and controllers must reflect this, otherwise we will just have more of the same and airspace change proposals (reform) will continue to stumble.

[NAMPS]

Hempy, I totally agree.

It seems to me that the proponents of both sides of the argument will never see eye-to-eye.

I admit that I am not a professional pilot (I hold a PPL/MECIR) and that my involvement in the industry is limited having handled a number of matters involving aviation law. My practise consists entirely of commercial litigation matters.

Disputes involving a conflict of legal rights, where the parties are unwilling to resolve their differences, are determined by the Courts.

Whilst the issues raised in this thread are not strictly 'legal' (although the ramifications of any incidents arising may raise legal issues), the method of analysis which is applied to legal problems can be adopted topics such as this to determine the preferred argument.

I have read the arguments put forward in this thread (and others). I have also read the arguments (both for and against) ventilated prior to the introduction of NAS on 27 Nov 03. I have also considered BASI's 1991 Report regarding the limitations of 'unalerted see and avoid' and the ATSB's findings regarding the incident at LT on 24 Dec 03.

The fundamental issues as I see them (there are other related issues) are 1) see and avoid and 2) communication.

BASI found that unalerted see and avoid "has a 'limited place as a last resort means of traffic separation at low closing speeds', and is 'completely unsuitable as a primary traffic separation method for scheduled services'".

Dick Smith disagreed with those findings stating the "recommendation could never be complied with, and never was. If you look at the incidents in MBZs in the last 2 years (I suggest you check my website www.dicksmithflyer.com.au) it will be noted that there are numerous occasions of unalerted see and avoid taking place. The BASI requirement simply could not be complied with unless every airport operated in a minimum of Class D airspace (even then this would probably not satisfy the requirement) and the cost would be horrendous." [refer http://www.dicksmithflyer.com.au/]

With respect, it appears to me that Dick Smith has missed the point. BASI's findings were made by comparing the merits of alerted see and avoid and unalerted see and avoid. Quite simply, it found that alerted see and avoid was safer than unalerted see and avoid. The fact that there are "numerous occasions of unalerted see and avoid taking place" is beside the point. The fundamental finding is that unalerted see and avoid is not as safe as alerted see and avoid.

Dick Smith's other argument is that it would cost too much to operate "every" airport in Class D airspace. There is no need to operate every airport as Class D. Whilst there are limitations so far as human factors go, the provision of 'mandatory broadcasts' (eg MBZs) assists the pilot in situational awareness. The fact that VFR pilots are encouraged to remain silent, even in E Class, flys in the face (no pun intended) of BASIs Report.

A related issue is that of the definition of 'appropriate frequency'. I will not entertain the argument that listening to the area frequency will lead me to be "complacent" or "stressed". This is an insult to my and other private pilots' intelligence.

I find it difficult to see as enhancing safety, the possibility that any number of pilots in close proximity could be on different frequencies based on their subjective definition of 'appropriate'.

The argument that NAS will help reduce incidents in CTAF/MBZs is illusory as the radio procedures prescribed under NAS are still subject to the same human factor limitations identified in the BASI report. The problems are exemplified by the active discouragement of the use of radios (see the ATSB report re: incident at LT).

The argument that NAS will help allocate resources to where they are most needed (ie terminal areas) where the risk of collision is greatest is not satisfactory in light of the ATSB report re: incident at LT. That incident occured just 14nm from the aerodrome.

Finally, I cannot get past the fact that those who are against NAS predicted the type of incident that actually occurred at LT even before this system got up and running! (this opens whole can of worms legally!)

One thing is for sure, I would rather argue the case against NAS than for it.



NAMPS B.A., LL.B. (Hons), LL.M. Barrister-at-Law

[themwasthe days]

Mr Smith,

look how terribly wrong it can go, when it does go wrong.
http://news.bbc.co.uk/2/hi/europe/3484878.stm

More than enough has been written and spoken on the Australian NAS debacle, and much can be learnt from our Swiss colleagues on their experiences, with the tragic results of failure demonstrated, and now this latest development just further adding to the anx of all involved.

Assuming you still have the ability to provide input to the decision makers, isn't it time to stop the postualtion, chest beating and general grand standing, and take the necessary actions to ensure such a scenario as witnessed in Switzerland does not occur on Australian shores?

"Affordable safety" was a catch cry once attributed to your reform processes. Such a price as experienced elswhere can never be measured.

Do something, and do it NOW.

[DownDraught]

NAMPS,

In regard to your last post, how does the fact those who introduced stage 2b new that by doing so would cause" Apparent more en-route risk and less terminal risk.", as stated in Hansard (Senates Estimates Comittee)?

[Annex 11]

Found this message floating around the other day. Apparently the words early in September of that frustrated Airservices employee to his GM:
"My whole week seems to have been taken up by NAS2b and the inconsistent behaviour of an organisation that on the one hand as an ATSP desires to introduce capabilities (ADS-B & TAREP) to increase safety and efficiency, that issues directives to staff because we need to ensure separation assurance, and on the other as an airspace authority is expected to rubber stamp an initiative that is not its own and that deliberately reduces the level of safety and through the random movement of unnotified VFR traffic will likely hamper the efficiency of operations."

[WALLEY2]

Well

I am of the opinion, as are others that this debate is between facts and analysis vs beliefs and is getting no where.

Re: See and Avoid. The CTAF USA where there is no feed back to advise a VFR pilot if they are on the wrong frequency as they choose to monitor rather than call vs a MBZ or Radio equipt a/c in CTAF(AUS) requiring a mandatory call with a AFRU beep back which the pilot only gets when on the right frequency is self evidently safer and beyond dispute.

At our busiest uncontroled airports, this is augmented by a CAGRS giving DTI of a/c relevant to the approach or departure path of a new comer is even more robust as all pilots expect a reply from "Broome Radio" and start checking frequency or switching radios to check for faulty equiptment.

Undoubtedly the statistics will be in our consultants study.

Why then am I informed, after my enquiry, by NASIG that they have asked CASA to delete the regs on CAGRS as they are "non compliant to NAS." As the provider of the service and owner of the airport why was I not advised? ICAO states I must be involved and advised and asked to comment.(ref VoR posts which you agree with!)

I also note USA has AAS at many uncontrolled airports providing the same services as our CAGRS, a logical cost effective step before the expense of a D class Tower.

Yet through our FOI process we are told there is no Design safety case been done on CAGRS,MBZ,CTAF(AUS) vs CTAF(USA)

Forget the waffle this is happening as we speak while 2b is being fine tuningly unwound, and you are arguing on this forum about safety. NASIG is surely being directed by ARG- Not overly happy Dick, a phone call would have been nice- Hardly inclusive consultation. When all parties know the one and only Aeronautical Design Study done on this characteristic is by our independent consultants and is due in 2 weeks.

But lets forget about safety, as it appears all agencies except ATSB have, and look at your major aim to get GA happening in Australia. An aim I share. This fiasco on 2b is scaring RPT pax (personal experience as I am getting asked. Is it safe to fly? - My answer is the same as Captain Chris Mannings : ) .

I'd be interested to know how it is effecting flight training numbers 2003 vs 2004. I'd be suprised that a continued all ahead full and forget about those como pilots and atc degenerates will allow us to portray a safe and easier to fly impression to the public and get them moving to the nearest training school

Has anyone got any data on this?

[NAMPS]

DD

I too read the Senate Estimates Committee hearing transcript. Unfortunately I didn't get a chance to read the documents to which they were referring.

My understanding is that they are comparing NAS 2b airspace with the airspace it is replacing.

The increased risk enroute is created by replacing C Class with E class airspace, thus allowing unannounced VFR traffic into airspace that would previously require a clearance to enter.

Another factor is the 're-allocation of resources to terminal areas'. This means taking away resources from enroute sectors.

These actions have the effect of increasing risk enroute.

[SM4 Pirate]

The increased risk enroute is created by replacing C Class with E class airspace, thus allowing unannounced VFR traffic into airspace that would previously require a clearance to enter. This is true, the likelyhood of a collision in class E is statistically very low, but LT and the earlier CANTY example were easily foreseeable events; the risk of collision is statistically lower in C; why have E when the cost of C is less?

Another factor is the 're-allocation of resources to terminal areas'. This means taking away resources from enroute sectors. Not to pick on you, but there are no resources taken away or moved elsewhere. Class C became class E, that's it; over towers Class C steps became Class E.

We have increased the risk in tower and enroute airspace; we have increased the 'staff' needed in enroute and not saved one body from any tower.

I think the concept is that because the tower controller is now only responsible for class E it is less work than class D; which could be true in some circumstances; but not in others. This means we can get rid of Tower controllers; or we certainly won't need anymore than we all ready have ever....

All, you can't claim to be increasing or re-allocating resources where the risk of collision is higher, without doing so, it's a bad joke and "Dick Smith" is the punch line.

[NAMPS]

SM, thanks for clarifying that.

I think it was Gemmell (?) that made the statement during the Estimates Committee Hearing that DownDraught referred to.

If what you say in respect of the allocation of resources is the case, then I don't understand how the assertion made during the Estimates Committee Hearing is correct (or at least accurate).

Anyway, NAS has fleas.

[themwasthe days]

Is this true?


Annex 11:
----------------------------------------------------------------------------------------------------------------------------------------------------
“….initiative that is not its own and that deliberately reduces the level of safety and through the random movement of unnotified VFR traffic will likely hamper the efficiency of operations”

----------------------------------------------------------------------------------------------------------------------------------------------------
The highest levels of the ANSP were advised by their HATC that this initiative, that was from another source, was a deliberate lowering of safety standards? How was this factored into the “safety assessment process” - assuming some credible one was undertaken?

And he was ‘rewarded’ with the sack!!!

[DownDraught]

My original question to namps was for a reason. If the ugly had happened, or indeed does happen now, where there is a collision en route, and the safety submission given to CASA pre implementation regarding nas2b implementation acknowledges that by implementing nas2b there will be "Apparent more en-route risk and less terminal risk.", then does not meet the classic case of negligence?

[Creampuff]

A very, very simple question, on a very specific matter of fact: Do Jumbo jets arriving or departing JFK get routed through or otherwise transit class E airspace as a matter of procedure or practice?

Chris Higgins – is Dick right or wrong when he implies that they do? If he’s right, please acknowledge that he is. If he’s wrong, please explain why.

If we can’t work out what classes of airspace are around JFK as a matter of simple fact, and work out what aircraft fly through it as a matter of simple fact, then it’s no wonder these discussions go in circles.

[Gunner B12]

Creampuff

With all due respects Who gives a flying f*&#k how Jumbos get into JFK, the question still is is it safer than what we had before? The answer is still obvious from the statistics and that is a resouding "no". I asked earlier and probably in another thread "who decides just what constitutes worlds best practice? but have yet to see any reply. America has had MACs involving RPT aircraft whereas OZ has not. The question is which is worlds best practice? It all comes down to point of view, doesn't it.

I think I would prefer worlds best safety practice, wouldn't you?

Dick

I'm glad I didn't hold my breath waiting for your reply!

I am glad i am not one of the Ozzie companies who have gambled their future on your support, as with your continued reluctance to accept the error of this debacle you do damage to those you claim to support. Please do not claim that as people turn on your image it only damages innocent ozzie producers as it comes down to the fact that it only damages them if they continue to remain associated with your public image.

With due respect your image is becoming tarnished (in my humble opinion) and it is time to accept that you were wrong. I don't care how you eat humble pie, but it is a meal long overdue, Please don't hold onto your beliefs to the expense of Australian Aviation.

Enough is enough call a halt now! Whilst you can still hold some credibility.

[OverRun]

I was very disturbed when I read what Walley2 said above

Why then am I informed, after my enquiry, by NASIG that they have asked CASA to delete the regs on CAGRS as they are "non compliant to NAS."

I surely can't believe this. CA/GRS?

Does this mean that NASIG are arbitrarily taking away the certified air ground radio operator service at Broome and Ayres Rock?

Without consultation?

Without enquiry?

Without analysis?

Without a review of all the airspace and risk modelling work that was done before their establishment?

Without a safety case?


Is this the final step on the path from good intentions, through blindly charging ahead, through ineptness, and now finally down to derangement?

Or is derangement the fact that NASIG are now pressing ahead with implementation of NAS 2c
we intend to conduct safety workshops in the near future to cover the changes that are planned for implementation in November 2004 as Stage 2c of the NAS

http://www.pprune.org/forums/showthread.php?s=&threadid=120419

[Voices of Reason]

We note in the last posting reference to NAS 2C, that one of the proposed changes in the next airspace change tranche is to amend Class D procedures. Our understanding from examining the NAS documentation is that this will involve a change in VFR entry procedures, so that simple acknowledgement of a call by VFR aircraft at the boundary may be taken as a clearance (implicit rather than explicit) to enter Class D airspace (on-line at the NAS website via Airservices Australia’s web-site) .

We have reviewed your AIP (on-line at Airservices Australia) and note that the current procedures require VFR flights to obtain a positive clearance to enter Class D airspace.

We note that the NAS 2C changes will not amend airspace boundaries for Class D – i.e., VFR flights may enter Class D airspace at a boundary distance of more than 20 nautical miles. At that distance it would be impossible for air traffic control to positively sight and identify the aircraft concerned, and provide a meaningful service between IFR and VFR flights.

We have examined the United States procedures (AIM and ATC Documents (7110.65)) and note that Class D airspace in the United Stated most often extends to a maximum of 7 miles (typically 5 miles) and upper limits in the range of 2000 feet at each of the several hundred Class D towers (refer also FAA web-site at www.faa.gov). As is the case with aircraft entering your GAAP airspace (ref Australian AIP) it would definitely be possible for a controller to sight, identify, and provide services in respect of that aircraft, even with an implicit clearance.

This begs the question of the potential changes in risk that would be associated not only with the implementation (as has been claimed in respect of other changes) but also with the actual design itself.

We referred again to ICAO DOCUMENT 9689 - MANUAL ON AIRSPACE PLANNING METHODOLOGY FOR THE DETERMINATION OF SEPARATION MINIMA. That document contains an appendix submitted by Australia which outlines an airspace risk model for small terminal areas – CTAF and MBZ.

We understand that in 1996, attempts were made to change the Class C airspace associated with 12 regional non-radar towers to Class D airspace. We have been provided information that indicates that there e was significant community opposition, and significant debate, which forced a review of that decision. A particularly detailed risk study was conducted, a 1997 copy of which was provided to one of our members.

The report of that study indicated that the change from Class C to Class D would increase risk in the order of ten-fold. In some cases, this brought the risk close to (but not above) the limits of tolerability – however Airservices Australia was able to implement the change to Class D in 1997.

The study built on the airspace risk model that had been presented to, and accepted by, ICAO. It is therefore reasonable to say that the modeling carried out on Class C and Class D airspace would fall within a statement that “it was based on ICAO guidance material”.

We have examined the model and find that it contains a number of fault tree decision points, the likelihoods of which were determined from industry panel inputs.

It would therefore be relatively easy to re-assess the likelihood of certain events occurring if VFR aircraft were NOT subject to positive clearance – i.e., were potentially likely to enter controlled airspace by accident. A change in likelihood in just a few decision points can have dramatic effect on risk – to the point where the risk at a small number of the Class D towers would EXCEED the tolerable risk limits.

It should not require a great deal of effort on the part of Airservices Australia to re-model the proposed changes and provide a public risk statement.

We are not in a position to directly intervene here, but we believe that you should challenge your service provider both to re-release the risk analysis already done on Class D airspace – AND to carry out the re-analysis based on the changed procedure.

Summarizing, it is our considered judgment that without a commensurate change in the size of the Class D airspace to replicate the United States situation, the levels of risk to both IFR and VFR flights in Class D airspace would elevate significantly and may exceed already established risk tolerability limits.

Our apologies.

We omitted to add in our previous post that should the Class D airspace limits be amended to those applicable in the United States, a commensurate increase or lowering of Class E airspace would be required (as applies in the United States). This would result in the potential for unannounced VFR flights to transit above Class D towers at 2500 feet.

In short, not only will the risk in residual Class D be raised, but the risk in the volume previously categorised as Class D - i.e,. that airspace that becomes Class E - would increase even further than had it remained Class D with new procedures. The risk in Class E airspace between 2500 feet and 4500 feet can easily and validly be modelled within the model agreed by ICAO and referred to in the previous post (the Class D risk analysis conducted by Airservices Australia).

We re-iterate that it is our considered judgment that the levels of risk at certain Class D locations may rise above previously agreed risk thresholds, and in the risk workshops being conducted by your NAS teams, you must challenge them both to release that study, and commit to a re-calculation of design (and not implementation) risk.

[CaptainMidnight]

WALLEY2
Re the deletion of CA/GRS - to blow that proposal out of the water, if you haven't already I suggest a fax to Mr. Anderson and Bruce Byron CASA CEO pronto.

[Voices of Reason]

For those wishing to contact us direct, please use the following e-mail address:



[email protected]



We may be in a position to provide more explicit information via direct contact, or to validate information we have received from other sources and post that information for general viewing.

[Chris Higgins]

In the fourteen years since I have left Australia, I never thought I would read a post where Dick Smith said he has "worried" about me. Don't worry Mr Smith, I have not endangered anybody with my ignorance.

Yes, technically you're correct. From the base of the Positive Control Area (Class A) to the top of Class B ( the old terminal area), there is in fact a vertical transition through Class E. But the arrival overlays from Class A to Class B, there is no, "no man's land" in between. This observation is not based upon ignorance.

Yes, you're correct about my flying in Class E airspace, in fact I did it today enroute from Los Angeles, and let's talk about that too.

The departure today was one of many variations of "The Loop" which callled on this occasion for a transition over Thermal, near Palm Springs. The SID allows you to climb in Class B over the initial departure with a turn out over the ocean before returning over the Los Angeles Airport and transitioning via an unrestricted climb into the Positive Control Area.

Why? Partly so we don't run into the Sierra Nevadas, also to allow airspace for descending arrivals from the East and also to allow us to make a transition through E airspace from underlying Class B to minimize risk and facilitate a rapid transition to Class A.

The differences Mr Smith are that you are proposing what was once called cynically, "NO SAR/ No brains" as the normal part of a vast majority of your Australian airspace and expecting thousands of passengers hurtling through the sky at well over 250 knots above 10,000 feet to be protected by little more than the Mark I eyeball.

Are you expecting us to believe that people in their gliders and Cessnas are flying over LAX, JFK and San Francisco, without talking to anybody before they get there, because they remain solely in Class E? And are you suggesting that they do it without transponder?

Well to answer my own...

First of all. You can't operate anywhere within 30 miles of Class B in the United States without an operable Mode C. Yes Dick, I know it's possible on occasion to get a waiver, but they're rare now.

Denying us the obvious implications of September 11, 2001, (where anyone showing up over downtown Manhattan without contact would be escorted by fighters), it would be extremely unusual for a pilot who pays taxes to fly an aeroplane, to take off from a towered airport, get a transition through Class C airspace then continue to climb into Class E airspace without a discreet code and a courtesy hand-off for further flight following.

YOU might do it Dick, but none of us would!

No I won't correct my post. I'm too busy, I've got to get back to the West Coast to the Academy Awards.

[Chris Higgins]

We are going to be out of duty time...so I'm here for the night.

I just got a call in to Australia. It seems to me that it's a lot worse over there than I feared.

Just to reiterate:

Boston, Chicago, JFK, La Guardia, Pittsburgh, Philadelphia and Washington, Baltimore, Cleveland, Denver, Dallas, Memphis etc...etc are all Class B airspace which now I understand Australia hasn't even graduated to yet!!

The deal here is that NO aircraft can be admitted without a clearance and ALL movements are controlled at ALL times.

NO aircraft in America is permitted above 10,000 feet MSL without an altitude reporting transponder. In addition NO aircraft is allowed to operate at ANY airport within 30 nautical miles of a Class B airport at ANY ALTITUDE unless they they have a Mode C transponder.

The very thought of descending through Class E airspace with the knowledge that a high proportion are not communicating and might not have confirmed with center/approach of the servicability of their transponders is simply not acceptable.

As a Certified Flight (Flying) Instructor, I always taught students to establish contact with Center as soon as possible after departure from my non-controlled airport and achieve flight following with a discreet code and continuous communication. We never had any problems.

Dick, this is nothing like you have in Australia. From my conversations tonight, it sounds like you are discouraging VFR traffic from talking to already concerned and overworked controllers, and hoping for the best.

Your Class E analogies, using American examples, have absolutely no relationship to your arguments!

[NAMPS]

As a Certified Flight (Flying) Instructor, I always taught students to establish contact with Center as soon as possible after departure from my non-controlled airport and achieve flight following with a discreet code and continuous communication. We never had any problems.

Ahhhh... flight following.

I seem to recall the last Flight Service unit in Australia was 'decommissioned' about 10 years ago.

[Creampuff]

Chris Higgins –your short point appears to be that although heavy metal transits class E, VFR aircraft are never there unannounced or unverified.

A supplementary question if I may: is the process through which the VFRs make themselves known and get their transponders verified, a legal requirement or just a matter of general practice?

justapplhere –your short point is, as usual, pointless. But please post whatever makes the voices in your head happy.

[ftrplt]

if the VFR's dont go there then whats the point of the E airspace then?

[Chris Higgins]

I was there just the other night in Salt Lake City at Millionaire. A really nice spot. Perhaps on my next overnight we should talk about this some more.

With respect to the arrivals into any major US airport, they really share one thing in common that really alarms me about the NAS in Australia. We make these arrivals Stateside into Class B airspace. The ramifications of this are very real. Real control of real, and not assumed traffic, operating on identifiable transponder codes and in continuous two-way communication with a controlling authority.

Class C airspace dictates the need for communication and transponder usage, but no real control over VFR behaviours (behaviors).

Transiting the Australian interpretation of Class E airspace requires no transponder and no communication with a traffic advisory service. Dick Smith will point out to me that in the Midwest of the USA, this is not unusual...but he's wrong.

Nobody that spends a minimum of $180,000 on a Cessna 172 is only going to want to fly it 60 days a year. In addition, that same person pays a lot in taxes and will make full use of an instrument rating and the free services of radar following.

In 1998, a Mesa Airlines crew, was charged with "reckless endagerement" by the FAA, for flying VFR in the Northeast corridor. This was in a Beech 1900 that only carries 19 people and doesn't indicate over 250 knots in airspeed.

What Dick Smith is saying is that it's alright for a Virgin Blue crew to mix it up with non-reporting VFR Cessnas and do this with over 140 people on board and indicating over 310 knots in airspeed. My response, "Like Hell"!

To give Mr. Smith some credit, he was correct in asserting that the arrivals in New York do, in fact, transit Class E airspace. He is also correct in saying that for my three and a half years flying the turbo-props (Jetstream 41, ATR 42/72), I flew through E airspace everyday. He is completely missing the point about one thing though. Australians and Americans may both call it Class E, but, the similarity ends there!

To Ftrplt:

Class E inhabitants do in fact fly very happily in Class E and even Class B airspace. They tend to tell people where they're going though, it's the way they have developed the system here.

[Lead Balloon]

Chris Higgins posts seem to be lucid. I am following them with great interest as I'm moving to Phoenix in July I'll be hoping that my training in Australia doesn't confuse the heck out of me when I finalise it in the USA - I'll probably end up running that 172 into that rouge Mesa Air flight above Chandler, if I take class E from here to mean the same thing there. This is scary! May require a brain reset.

[Tail_Wheel]

It appears the ARG is now impotent and marginalised. NASIG are seen as an incompetent creature and the instigators have been defrocked for their amateur dabbling.

It is now understood at all levels, including the Minister’s office, that they were sold a pup. Airservices are going their own way as the professional Service Provider.

Only a handful of people in Australia ever believe NAS as proposed was a "good thing". Those who dabbled have had their day. Everyone is tired of amateur enthusiasts running the Australian aviation industry.

From another post: "My source says it is an injunction to prevent the distribution of documents (charts) with frequency and boundary info thereon." That legal action will be the death throes of both.

[NAMPS]

"My source says it is an injunction to prevent the distribution of documents (charts) with frequency and boundary info thereon."

I would be interested to know what legal principles are involved here. Sounds like some wishful thinking...

[Voices of Reason]

Extract from reports on the website of the Australian Transportation Safety Board:


……. to the outstanding recommendations contained in the 1991 BASI research report on the limitations of see and avoid. As you would be aware, most of the recommendations - including those concerning TCAS and the education initiatives - have been implemented and continue to provide positive safety outcomes for Australian aviation.

In respect of the remaining recommendations, CASA provides the following response.

"The CAA should take into account the limitations of see-and avoid when planning and managing airspace...."

CASA agrees that the limitations of see-and-avoid should be taken into account when planning and managing airspace. Where traffic densities are such that see-and-avoid does not provide the required level of safety, CASA will require Class D or a higher level of airspace.

....and should ensure that unalerted see-an-avoid is never the sole means of separation for aircraft providing scheduled services."

CASA understands the intent of this recommendation but does not agree with its absolute form. The wording of the recommendation reflected its time and was prior to the 1995 Standards Australia AS/NZS4360 Risk Management Standard. CASA also understands that the use of the absolute "never" is not consistent with current ATSB practice.

To accept the absolute form of the recommendation would require the allocation of Class D or higher airspace wherever scheduled services operate. This would result in an allocation of resources that is not commensurate with risk.

ICAO Class E and G airspace specifically has no radio requirement for VFR aircraft. ICAO has introduced both of these classifications with the full knowledge of the limitations of see-and-avoid. ICAO makes no recommendation in relation to scheduled services not operating in these airspace classifications.

Overly discounting the effectiveness of see-and-avoid and devising unique procedures has itself led to unintended consequences that are unresolved. Pilots may scan significantly less and become over reliant on radio alerting through a concept known as diffusion of responsibility. The BASI report RP/93/01 (December 1993) and the continuing incident reports that are being filed listing near misses in mandatory radio Class E and G airspace may support this concern. CASA believes that radio alerting is only effective when the alerting area is small with readily identifiable reporting points so that the alert is specific.


Extracts from United States Research:
(www.aviation.uiuc.edu/UnitsHFD/conference/Dayton03/talwic.pdf)


With regard to the major issue addressed in this study, scanning strategies, the current data appears to be the first to document the effectiveness of certain scanning strategies, as measured through eye-movements, and their effectiveness measured through traffic detection performance. In this regard, it is important to note that the FAA-recommended sector scan comes up as a clear winner over all others, including slightly better performance than the recommended sweep strategy, availing increased Outside World (OW) scanning, and less disruption with flight control. The sector scan also appeared to be encouraged by the auditory condition and this auditory condition was itself associated with somewhat better traffic detection. Furthermore, this strategy is coupled with more total OW scan time (although this proportion still did not approach the FAA recommended values).

It appears that whatever strategy is generally adopted, the appearance of a cue, whether visual (CDTI) or auditory, often served to preempt that strategy, to bring scanning into the region where the traffic is expected to be seen. This qualitatively different .find cued traffic. scan pattern seems to be fairly uniform across all pilots, but may leave them vulnerable for detecting a second, unexpected traffic aircraft that might appear after the cue is presented, an observation described by Harris (1979) in traffic detection, and observed as a statistically robust consequence of cueing in both freeflight scanning (Wickens, Helleberg, & Xu, 2002), and in other target detection domains (Yeh, Wickens, & Seagull, 1999; Yeh & Wickens, 2001).

THE RESULTS HAVE ALSO SHOWN THAT CUEING OR ATTENTION GUIDANCE, PROVIDED IN EITHER MODALITY, APPEARS TO MAINTAIN DETECTION PERFORMANCE AT A LEVEL OF AROUND 90%, CLEARLY BETTER THAN THE UN-CUED RATE OF AROUND 60% REVEALED IN OTHER STUDIES, AS PREVIOUSLY MENTIONED, IN BOTH SIMULATED (WICKENS, HELLEBERG, & XU, 2002) AND REAL FLIGHT (MARSHALL & FISHER, 1959) ENVIRONMENTS. NEVERTHELESS, IT IS IMPORTANT TO NOTE THAT THIS DETECTION LEVEL STILL REMAINS FAR FROM PERFECT, AND APPEARS TO BRING WITH IT A COST OF SOME ATTENTIONAL TUNNELING.

Finally, we note that the overall ratio of OW to inside scanning (slightly less than 1:2), as observed in prior research (Harris, 1979; Wickens et al., 2002), is one that departs from FAA guidelines to favor the OW. Even though all three modality conditions in this study had other sources of traffic cueing information (ATC, CDTI, or both), parallel studies where these resources were not available (Wickens, Helleberg & Xu, 2002), have shown that the optimal ratio was still not found.



The second last paragraph indicates that unalerted see and avoid may be as much as 50% less effective than alerted see and avoid.

[NOtimTAMs]

Umm, VoR, you might want to edit your mathematical calculations to preserve credibility.

Shouldn't that be "The second last paragraph indicates that unalerted see and avoid may be as much as 33% less effective than alerted see and avoid" ?

Not quibbling with the reported research, just the sums....

Fly safely

[Voices of Reason]

NOtim TAMS,

Our apologies.

You are correct.

We actually meant to state that the information provided would seem to indicate that alerted see and avoid may be 50% more effective than unalerted see and avoid.