Voices of Reason
4th Jun 2004, 14:33
SAFETY CASE, ICAO COMPLIANCE, US PROCEDURES, CLASS D, Etc
We have been shown a number of recent entries on Mr Dick Smith’s web site.
Mr Smith’s assertions are somewhat exaggerated.
We have spent several hours reviewing all of the relevant ICAO documents, and have not been able to find any references to the United States procedures for CTAF. We have found provisions in Annex 2 to the Chicago Convention that allow States to determine additional procedures in an aerodrome traffic zone. Presumably this is what the United States – and other States – have used as justification for their various terminal area procedures at uncontrolled aerodromes.
This would appear to validate the use of your MBZ procedures.
It is therefore, in our opinion, incorrect to state that CTAF and MBZ procures are not ICAO compliant, as there are no ICAO provisions relating thereto, or excluding their use.
In relation to Class D airspace, both Annex 2, and Annex 11, refer to the need to obtain an air traffic control clearance prior to entering controlled airspace. Annex 2 reinforces the need for VFR flights to comply with this requirement in Classes B, C and D airspace.
In all countries operating Class D airspace - except the United States - VFR aircraft request a clearance prior to entry into Class D and unless they receive an positive and explicit clearance, they may NOT enter Class D airspace.
In the United States, the reverse procedure is applied – that is, unless the aircraft is specifically excluded – by either being told to remain clear, or by being effectively ignored (no acknowledgement of callsign) – it may enter the airspace.
We are not saying that this is necessarily a wrong thing – but it is NOT ICAO compliant.
In relation to Safety Case, perhaps Mr Dick Smith should read the changes that have been put into effect in ICAO documentation over the last four years, requiring that Safety Management Systems be adopted by all air traffic services provider organisations, and effectively requiring explicit safety processes to be applied whenever ANY change is effected to the air traffic system.
We have already de-bunked the argument about reference system that Mr Dick Smith has previously attempted to use, and on which your government made its incorrect judgements to proceed with the National Airspace System reform program.
One would have to question the integrity of a man who is unwilling to face the reality of modern safety management systems. As many large organisations have found to their loss, it is no longer satisfactory to use the phrase “but we’ve always done it that way”, or “trust me”. All of the major businesses in the United States, and other major developed countries, have adopted explicit safety and environment management practices. Aviation unequivocally needs to play in the same league.
We do not feel the need to respond to Mr Dick Smith’s rhetoric regarding Broome and Class D towers – that argument is effectively dealt with in the Broome Safety Study and related threads – but suffice it to say that the position taken by Mr Dick Smith in this instance would appear to be totally at odds with his previously stated and widely acknowledged views on the cost of safety versus the benefit.
Mr Dick Smith may also want to contact representatives from FAA senior management and the US Department of Transportation in relation to privatized ATC towers – notwithstanding the fact of those towers, it is unlikely that the process of privatization will continue.
Once again we re-iterate that the dollar cost ($75,000,000.00+ (refer previous thread on this issue)) to get to the position you find yourselves in is NOT justifiable, and in some States might be deemed criminally negligent. The cultural cost, through loss of trust and faith “in the system” is far more significant.
We have been shown a number of recent entries on Mr Dick Smith’s web site.
Mr Smith’s assertions are somewhat exaggerated.
We have spent several hours reviewing all of the relevant ICAO documents, and have not been able to find any references to the United States procedures for CTAF. We have found provisions in Annex 2 to the Chicago Convention that allow States to determine additional procedures in an aerodrome traffic zone. Presumably this is what the United States – and other States – have used as justification for their various terminal area procedures at uncontrolled aerodromes.
This would appear to validate the use of your MBZ procedures.
It is therefore, in our opinion, incorrect to state that CTAF and MBZ procures are not ICAO compliant, as there are no ICAO provisions relating thereto, or excluding their use.
In relation to Class D airspace, both Annex 2, and Annex 11, refer to the need to obtain an air traffic control clearance prior to entering controlled airspace. Annex 2 reinforces the need for VFR flights to comply with this requirement in Classes B, C and D airspace.
In all countries operating Class D airspace - except the United States - VFR aircraft request a clearance prior to entry into Class D and unless they receive an positive and explicit clearance, they may NOT enter Class D airspace.
In the United States, the reverse procedure is applied – that is, unless the aircraft is specifically excluded – by either being told to remain clear, or by being effectively ignored (no acknowledgement of callsign) – it may enter the airspace.
We are not saying that this is necessarily a wrong thing – but it is NOT ICAO compliant.
In relation to Safety Case, perhaps Mr Dick Smith should read the changes that have been put into effect in ICAO documentation over the last four years, requiring that Safety Management Systems be adopted by all air traffic services provider organisations, and effectively requiring explicit safety processes to be applied whenever ANY change is effected to the air traffic system.
We have already de-bunked the argument about reference system that Mr Dick Smith has previously attempted to use, and on which your government made its incorrect judgements to proceed with the National Airspace System reform program.
One would have to question the integrity of a man who is unwilling to face the reality of modern safety management systems. As many large organisations have found to their loss, it is no longer satisfactory to use the phrase “but we’ve always done it that way”, or “trust me”. All of the major businesses in the United States, and other major developed countries, have adopted explicit safety and environment management practices. Aviation unequivocally needs to play in the same league.
We do not feel the need to respond to Mr Dick Smith’s rhetoric regarding Broome and Class D towers – that argument is effectively dealt with in the Broome Safety Study and related threads – but suffice it to say that the position taken by Mr Dick Smith in this instance would appear to be totally at odds with his previously stated and widely acknowledged views on the cost of safety versus the benefit.
Mr Dick Smith may also want to contact representatives from FAA senior management and the US Department of Transportation in relation to privatized ATC towers – notwithstanding the fact of those towers, it is unlikely that the process of privatization will continue.
Once again we re-iterate that the dollar cost ($75,000,000.00+ (refer previous thread on this issue)) to get to the position you find yourselves in is NOT justifiable, and in some States might be deemed criminally negligent. The cultural cost, through loss of trust and faith “in the system” is far more significant.