Safety case for commercial ops outside CAS

[NorthSouth]

SRG has just issued a FODCOM which "recommends" that any commercial operator wanting to start regular pax services to an airport outside CAS "should" prepare a safety case and have it approved by SRG. It includes all kinds of stuff including routes, IAPs, availability of navaids including radar. Seems a bit late in the day given that there are lots of these operations going on already, and there seems to be no requirement in the FODCOM for established ops to airports outside CAS to prepare a safety case in order to continue their operations.

Implications of this for ATC would seem to be that they will have to provide all kinds of data to prospective airline operators before they get approval to start new services.

NS

[niknak]

Well someone is way behind operational practice, and as ever, it's the CAA, more importantly SRG..:ugh:

There are a miriad of airlines operating into airports outside CAS and although the CAA (SRG) are willing to give more and more airspace away to the military (the whole of the north sea north of Y70), airlines rely on operating oputwith CAS for commercial reality and ATC units to cope with the day to day realities of avoiding unknown traffic outside CAS.
Sadly, SRG is predominantly staffed by people who last did operational controlling a in the equivilant of the last century, have have absolutely no idea of what it is like to operate as an ATCO or a pilot outside CAS.

Thank god for the sterling service of London Mil' , the vast majority of whose ATCOs know what the real world is all about, without them, we would be well and truely screwed...

[2 sheds]

How about a potential commercial operator producing a safety case that demonstrates that CAA "should" provide appropriate CAS for their operation - into an aerodrome already licensed by them!

[NorthSouth]

niknak:
It may well be true that SRG are behind the game, but the reason I posted this was to see what people thought of their proposal. Seems to me SRG is faced with, on the one hand, a commercial aviation sector that operates increasingly in a safety case regime, and on the other, the day to day reality you describe of controllers using their skill and experience to separate traffic in a dynamic regime outside CAS. The problem is that controller skill and experience is not easy to codify into a safety case framework - it's all down to "feeling in the waters" and all those favourite phrases.

You say CAA staff haven't controlled for years, well maybe that's true too, but it seems to me it's the controllers whose only experience has been in the safety management mania of the last few years who would have most difficulty understanding what London Mil and their ilk do on a day to day basis, not controllers who were active in the 70s/80s.

On top of all that, while this proposal is for *airlines* to prepare a safety case, a lot of what will have to go into those safety cases is ATC material. Who will prepare it? And do airlines have the sort of people who will know what to look for and whether it's adequate?

NS

[whowhenwhy]

Nik Nak, many thanks for your compliment to the guys at London - as I'm sure that you're aware they often feel somewhat aggrieved at the situation with which they are faced going in/out of those airfields. Just one small point though - the North Sea changes were 4 years ago this March and were agreed on all sides. Since then there has been quite a lot of CAS created. West of Alphas, TC South West, planned TC North East.

On the original point, I wouldn't have thought that there was much scope for any new companies and if the proposal is not retrospective, what's the point other than to look like they're trying to do something. :rolleyes:

[danieloakworth]

edited edited

[chevvron]

Not only are many in SRG 'out of contact', they're also ex military with no prior experience of civil operations, whether ATC or airline.

[NorthSouth]

Not only are many in SRG 'out of contact', they're also ex military with no prior experience of civil operations, whether ATC or airline.But presumably only from the wrong bit of the military, not the London Mil controllers who everyone says are wonderful and who control civil traffic on a daily basis....
NS

[NorthSouth]

The guidance is not retrospective Interesting. So if an airline with existing services to an airport outside CAS wants to add more, and they follow the guidance and do a safety case, only to find it concludes that the risk is unacceptable, do they pull the plug on all their services?
NS

[danieloakworth]

Given that the SC will only relate to the issues concerning operating into and out of the airport I would only anticipate it coming into play were an airline starting routes from said airport for the very first time, i.e. it is emphasising new airport rather than new route.

[peatair]

:hmm:

1] There is the commercial reality that air operators will wish to offer services to airfields which lie outside CAS.

2] There is also the commercial reality that the same air operators do not really wish to pay air traffic service providers to provide air traffic services outside regulated airspace (ATSOCA) - hence, they rely on whatever services they can get - e.g. London Military etc.

3] There is little chance of the CAA (Airspace Policy) approving new controlled airspaces except perhaps in fairly rare cases where the movement rate is very high.

4] Those ATC Providers which do offer ATSOCA are likely to collect a quite high percentage of airprox reports as, I believe, was the case with Manchester ACC in the "Pennine Radar" days. Which ATC provider wishes to take on such risks and the associated liability insurance?

5] The "Injun Country" nature of Class G airspace is that there are numerous forms of aviation - (from high speed military to gliders etc) - operating. It is unregulated and a free for all.

Any "safety case" would have to recognise and explicitly state all of the above. However, it would be possible to produce a document which stated how the air operator "manages" his exposure to the above risks. It would have to cover a multitude of points - e.g. aircraft types, airfields involved, methods of navigating, details of any ATS providers with whom the air operator has entered into an agreement for ATSOCA, whether routes to/from the airfields vary dependent on known activity including danger areas and so on.

Even if one did all this, it would not be possible to claim any great level of actual safety was guaranteed since the operations remain subject to the unexpected happening.

If the CAA really wants to build greater safety for these operations then it should be working to build better services for the operators. Someone would have to pay however and, in this day and age, I am sure it will not be Gordon Brown!

[NorthSouth]

Given that the SC will only relate to the issues concerning operating into and out of the airport I would only anticipate it coming into play were an airline starting routes from said airport for the very first time, i.e. it is emphasising new airport rather than new routeIf that's the case then it really does look like an a**e-covering operation. Can anyone name a single airport in the UK which doesn't currently have commercial services but might in the future? They're all covered now. Only places I can think of are Cambridge, Carlisle and Swansea.
NS

[2 sheds]

"However, it would be possible to produce a document which stated how the air operator "manages" his exposure to the above risks."

Correct - an *rse-covering exercise conducted by the operator for the benefit of the CAA, merely words in a document on the shelf, none of which detracts from the fact that the operation is less safe than it would be in controlled airspace - in some areas of Class G, considerably less safe.

Note to the PC experts - how do you make quotes in pretty blue boxes nowadays?

[danieloakworth]

Can anyone name a single airport in the UK which doesn't currently have commercial services but might in the future?

As en example, if FlyBe wanted to start operating out of Coventry then it would be a new operation and they would be encouraged to write a SC. Alternatively they could get someone to do it for them, which is probably why I'm writing, (possibly the first?) one at this moment. And as has been mentioned, I'm seriously banging my head against the wall trying to turn aspiration to reality!

[VectorLine]

Not an arse covering exercsie but a pragmatic move as part of the ASI (if you don't know what that is then I suggest it might be you who is behind the times, not CAA) to help improve safety outside controlled airspace.
CAT, ATC and Airport operators all have to play their part in asessing and mitigating the risk of such operations.
Peatair you say;
If the CAA really wants to build greater safety for these operations then it should be working to build better services for the operators.
Surely that's what the current review of ATSOCAS is aiming to achieve? It will be interesting to see what the industry wide technical workshop on 8th May makes of the new draft procedures.
It's not all very ex ATCOS doing this work. There are a huge number of current operational staff involved in this work. I think the FODCOM is a good start, but I'm very much in favour of the CAA taking a stronger line if the operators don't come up to scratch. Regulatory initiatives and changes to the rules of the air are definite options.
Mind you, it looks like someone is taking it seriously with Daniel on the case!

[London Mil]

In our business we do a hazard analysis for any new or changed operating procedure. I don't see this as a*** covering, it is just a mechanism for objectively identifying and, where necessary, mitigating risks.

[Not Long Now]

Go on then, I'm behind The Times, having a snooze usually. What is 'the ASI'?

[ATCO Fred]

Absolitely agree! The whole essence of the application of a RAS is the formailisng of the VERBAL contract between the pilot and the controller. Cue
Cont " Clear of CAS what type of service do you require?"
AC " IFR Please":uhoh:
Cont " Do you require RAS, RIS is FIS"
AC " Which one is the best"
This actually happened to me, granted several years ago. So.....until such a time as the guys up front FULLY understand the conditions of the contract that apply to them, ATCO's are placing themselves at risk by applying a RAS to those who have little appreciation of the classification of the airspace in which they fly or the ATC services on offer. A safety case is deffinately the way ahead - how else are the drivers going to get the message!
Post caveated with the exception of certain operators who predominately operate in Class G whom are fully aware (so much so they fitted TCAS) - it's the summer holiday charters flown by Eurpoean crews etc...you know what I mean..

[NorthSouth]

it's the summer holiday charters flown by Eurpoean crews etcTo whom the new CAA policy doesn't apply :uhoh:
NS

[Il Duce]

".....doesn't apply." Unbelievable. Please tell me that isn't true.

[Mister Geezer]

The harsh but worrying truth is that the current arrangement of ATSOCA is very poorly understood by the foreign pilot population with the exception of those who operate on a regular basis outside CAS. To be honest... some UK crews have a ropey knowledge and when going into LF recently the ATCO asked what service we needed outside CAS and I replied with a RAS. My F/O openly admitted that he would not know what to ask for if he was put on the spot since he didn't know the difference between the different services! Part and parcel of routine ops inside CAS I am afraid!

It is SRG that should be doing a safety case in making an effort to make crews aware of what a FIS/RIS/RAS are all about. I laughed when I saw the ATSIN instructing ATCOS to insist on a read back on the service issued - It is the crews who do not respond who clearly have no idea of what service they are under and a read back is not going to help the situation either!

And I have heard of exchanges just like ATCO Fred’s on London Mil and it is cringe worthy yet worrying to listen to! One foreign crewmember replied with 'We need the full service please!’ On one occasion the pilot who was being asked what service he wanted was so confused the controller had to tell him what service he was getting. I guess the most dangerous situation is when an aircraft is under a RIS who has no idea that he will not receive any avoiding action who then ploughs through to have an airprox or even worse!

Rant directed at SRG and not controllers at the front line!

[London Mil]

MG, the one saving grace is that mil controllers tend to give a RAS when it is obvious a pilot doesn't know what he wants.

[Red Four]

London Mil
Except if the pilot is VFR shurely?

[London Mil]

Red Four, find me a bucket & spade airline that operates VFR (Ryanair excepted) :p

[aluminium persuader]

I have a nasty feeling that the CAA have issued this FODCOM as preparation for unilaterally imposing Controlled Airspace over the entire UK. I think they'll take all the problems thrown up by all the safety-cases and use them as a lever to push the CAS.

It could be a huge problem fo the GA community and aviation in the UK as a whole.

Call me a cynic, but....:mad:

[Mister Geezer]

Would not surprise me since the CAA are doing a sterling job in squeezing G/A out of this country! :ugh:

[Single Spey]

Not CAS, but Mode S. If enough airlines state that they have TCAS but the risk is increased because of non-Mode S equipped GA aircraft, then the CAA have the statistics (ie the safety cases) to prove and qualitatively assess that from the operators point of view, mandated Mode S equippage for GA would improve safety. This was the one area of their Mode S RIA that was not substantiated.

[NorthSouth]

ap:the CAA have issued this FODCOM as preparation for unilaterally imposing Controlled Airspace over the entire UKNow how exactly would they do that? DAP considering an application from, errrrmmm, DAP to put CAS round an airport that hasn't asked for it? We seem to have established that pretty much all the UK airlines that want to start services from a new airport have already done it and they won't be asked to do a retrospective SC. In any case, where is there an airport with commercial services and no CAS that isn't already in the process of applying for it?
NS

[NorthSouth]

Single Spey:they have TCAS but the risk is increased because of non-Mode S equipped GA aircraftThat's not an argument for Mode S, it's an argument for Mode C (and/or Mode S). As regards the current non-transponders, if airlines think that it's risky to make approaches which require them to fly close to gliding sites which were there long before the airline was (and I can think of at least two UK airports where this is the case) then they really should think about what measures they can take to reduce the risk. I don't see Mode S being the solution to that particular problem.
NS

[Not Long Now]

"I have a nasty feeling that the CAA have issued this FODCOM as preparation for unilaterally imposing Controlled Airspace over the entire UK. I think they'll take all the problems thrown up by all the safety-cases and use them as a lever to push the CAS"

Hmmm, given that there aren't enough controllers to manage the present airspace, and that there would be no revenue gain from it, I think that's probably a bit of a non starter.

[London Mil]

Ahem, its not just NATS who have the privelege of controlling within CAS. There was a few hours of today when I felt like send a bill for my services direct to Eastflight, Thomspon and KLM. Certainly no military customers. I'm pretty sure there is an untapped customer base out there.

[danieloakworth]

As mentioned before, having spoken to the bloke who drafted the 'regulation' this is, in the first instance, about ensuring that airlines are fully aware of the issues involved in operating out of such airports. ThomsonFly did a risk assessment before they started out of RHADS and have told CAA that they found it invaluable in identifying potential problems. CAA have grasped the idea and decided to align it better with CAP 760. It's good for a conspiracy theory but can't see a credible one tbh.

[NorthSouth]

ThomsonFly did a risk assessment before they started out of RHADSI wonder if it included a risk assessment of having wet-lease crews operate your flights out of RHADS and completely ignoring or failing to understand the NPRs
NS