Philthy
27th Feb 2004, 06:01
Here, for what it's worth, is my response to NPRM 0401AS (NAS 2c):
The changes proposed in NPRM 0401AS (NAS 2c) are not acceptable in any form.
For most of the time since the end of the Great War, Australia has been among the leading aviating nations. Our current rules and procedures for circuit operations have developed incrementally over the last 80+ years to suit our particular operational needs and environment. Given what it is that they are trying to achieve and the constraints under which they are required to function, by and large they work pretty well. Furthermore, the whole industry is thoroughly trained and familiar with both the legal requirements (e.g. CAR 166, MBZ) and the associated operational practises and norms (‘culture’ - e.g. dead side descent to circuit height).
The NAS 2c changes propose to overturn current procedures with the wholesale importation of a set of foreign practises. However, the NPRM fails completely to identify the risks and costs associated with doing so. On this basis alone the proposal should be abandoned. Furthermore, the NPRM entirely fails to establish a compelling case on any grounds for the change and on this basis too it should be abandoned.
The supposed ‘Cost Benefit Analysis’ in the NPRM is a disgrace. The sole identified benefit is a small benefit to certain operators by flying abbreviated circuits, notwithstanding the fact that it elsewhere recommends against doing so! On the other hand, the ‘analysis’ fails completely to weigh the cost of the envisaged extensive training and education processes against this benefit, not to mention the costs arising from arguably reduced levels of safety. Aside from the enormous cost of re-training every pilot in the country, there are also huge flow-on costs which are not even considered. For example, every basic flying training text-book would become obsolete overnight (for about the third time in the last decade). The cost of developing and purchasing replacements would not be trivial, nor would be the cost to every flying training organisation of having to develop and produce new instructional materials, revise syllabi and so on.
In safety terms, the NPRM relies on nothing more than unsupported assertions to support a claim that the proposed changes will improve safety, or at least not decrease it. On the other hand, no analysis is made of potential and probably significant risk increases such as permitting non-radio aircraft to perform straight in approaches, or removing mandatory radio requirements at busier aerodromes or those serviced by RPT aircraft. The inevitable increase in risk during any transition period is simply not considered at all.
Aside from a few substantial, though important, changes (e.g. to CAR 166) much of the proposed change relates to operational practise and culture, and much of that already exists or is, at least, permitted within the current arrangements. Some of it is just plain common sense (e.g. "A pilot may vary the size of the circuit depending on the aircraft’s performance"). You don’t need to be a rocket scientist to figure that one out. Some of it is inconsequential (e.g. current rules already permit a 45 degree mid-downwind circuit join). One could also, I suppose, currently even do a midfield reverse downwind join, if it wasn’t a such stupid thing to do. But why would you? And some of the proposal is just downright trivial (e.g. changing "uncontrolled" into "non-towered").
Some of the proposed changes are even contradictory. For example, one of the stated aims is to reduce reliance on radio, yet the proposal recommends the introduction of additional circuit broadcasts!
At the end of the day this proposal would deliver little of lasting economic benefit, result in an enormous cost to the industry in required training and education, and clearly result in decreased levels of safety in some areas. There is an absence of any compelling economic or safety case to support the imposition of a set of foreign procedures and practises on an industry already thoroughly familiar with our own perfectly satisfactory procedures. Pursuing it is simply a waste of the industry’s scarce time and resources. If there are specific problems with the current arrangements that need to be fixed, then CASA should address these specifically through a properly argued safety and economic case: if not, CASA should focus it’s attention on more important matters.
The fact that these proposed changes made it into an NPRM at all is a travesty and illustrates what a weak-kneed, nodding-dog Regulator CASA has become. Clearly nothing has been learned from the NAS 2b fiasco. Once upon a time much of the World looked to Australia as an authority on aircraft operation: Now we are looked upon as a joke.
The changes proposed in NPRM 0401AS (NAS 2c) are not acceptable in any form.
For most of the time since the end of the Great War, Australia has been among the leading aviating nations. Our current rules and procedures for circuit operations have developed incrementally over the last 80+ years to suit our particular operational needs and environment. Given what it is that they are trying to achieve and the constraints under which they are required to function, by and large they work pretty well. Furthermore, the whole industry is thoroughly trained and familiar with both the legal requirements (e.g. CAR 166, MBZ) and the associated operational practises and norms (‘culture’ - e.g. dead side descent to circuit height).
The NAS 2c changes propose to overturn current procedures with the wholesale importation of a set of foreign practises. However, the NPRM fails completely to identify the risks and costs associated with doing so. On this basis alone the proposal should be abandoned. Furthermore, the NPRM entirely fails to establish a compelling case on any grounds for the change and on this basis too it should be abandoned.
The supposed ‘Cost Benefit Analysis’ in the NPRM is a disgrace. The sole identified benefit is a small benefit to certain operators by flying abbreviated circuits, notwithstanding the fact that it elsewhere recommends against doing so! On the other hand, the ‘analysis’ fails completely to weigh the cost of the envisaged extensive training and education processes against this benefit, not to mention the costs arising from arguably reduced levels of safety. Aside from the enormous cost of re-training every pilot in the country, there are also huge flow-on costs which are not even considered. For example, every basic flying training text-book would become obsolete overnight (for about the third time in the last decade). The cost of developing and purchasing replacements would not be trivial, nor would be the cost to every flying training organisation of having to develop and produce new instructional materials, revise syllabi and so on.
In safety terms, the NPRM relies on nothing more than unsupported assertions to support a claim that the proposed changes will improve safety, or at least not decrease it. On the other hand, no analysis is made of potential and probably significant risk increases such as permitting non-radio aircraft to perform straight in approaches, or removing mandatory radio requirements at busier aerodromes or those serviced by RPT aircraft. The inevitable increase in risk during any transition period is simply not considered at all.
Aside from a few substantial, though important, changes (e.g. to CAR 166) much of the proposed change relates to operational practise and culture, and much of that already exists or is, at least, permitted within the current arrangements. Some of it is just plain common sense (e.g. "A pilot may vary the size of the circuit depending on the aircraft’s performance"). You don’t need to be a rocket scientist to figure that one out. Some of it is inconsequential (e.g. current rules already permit a 45 degree mid-downwind circuit join). One could also, I suppose, currently even do a midfield reverse downwind join, if it wasn’t a such stupid thing to do. But why would you? And some of the proposal is just downright trivial (e.g. changing "uncontrolled" into "non-towered").
Some of the proposed changes are even contradictory. For example, one of the stated aims is to reduce reliance on radio, yet the proposal recommends the introduction of additional circuit broadcasts!
At the end of the day this proposal would deliver little of lasting economic benefit, result in an enormous cost to the industry in required training and education, and clearly result in decreased levels of safety in some areas. There is an absence of any compelling economic or safety case to support the imposition of a set of foreign procedures and practises on an industry already thoroughly familiar with our own perfectly satisfactory procedures. Pursuing it is simply a waste of the industry’s scarce time and resources. If there are specific problems with the current arrangements that need to be fixed, then CASA should address these specifically through a properly argued safety and economic case: if not, CASA should focus it’s attention on more important matters.
The fact that these proposed changes made it into an NPRM at all is a travesty and illustrates what a weak-kneed, nodding-dog Regulator CASA has become. Clearly nothing has been learned from the NAS 2b fiasco. Once upon a time much of the World looked to Australia as an authority on aircraft operation: Now we are looked upon as a joke.