PDA

View Full Version : NAS - Common Risk Management Framework


V.O.R
15th Jun 2007, 05:09
It appears that the airspace reform debate in Australia is about to be re-opened by the previous protagonists, operating under a new legislative regime. We recently forwarded the commentary below to your Department of Transport and Regional Services. We will continue to provide comment.

We urge you to provide comments direct to the Department, both on this document, and the draft airspace policy. It is clear that the policy 'directs' certain outcomes, which will inevitably pre-dispose or pre-bias the proponent organisations, making it difficult for them to conduct the transparent and balanced risk assessments that are critical to aviation safety.


We have recently been made aware of a draft document entitled “Common Risk Management Framework for New and Changed Operational Requirements within Aviation – February 2007”, and we would like to offer these preliminary comments.

First, may we say that the goal of implementing a common protocol and understanding for managing change risk is to be commended, and is a significant step in the direction of increased safety in aviation. It is, of course, critical to change management that all of the parties affected by any particular change understand what part of their daily operation will be affected by that change, and what measures have been agreed to mitigate any risks associated with that change.

Too often in the past factors including denial of the significance of the change, misinformation about the change, wrongly targeted training, and so on, have conspired to increase the risk, rather than mitigate the risk – both through the implementation phase, and in the actual post-implementation daily operation. Whether or not the change is supported by all parties to the change, a common understanding – and a common risk mitigation focus – should, at the very least, serve to reduce the risks associated with implementing the change – and in the long run increase acceptance of the change, for a net safety benefit.

That said, we find a number of areas of concern within the document, and we offer some commentary that we trust you will take constructively.

One of the key tenets of a quality control system – which is essentially what we are talking about in aviation safety - and which underpins the ISO 9000 approach to quality management – is to “say what you do, do what you say, and be able to prove it”. It is clear that the Common Risk Management Framework document is aimed at the first part of the trilogy – saying what you intend to do. It is critical that the organisations that embrace the document must have in place structural mechanisms to be able to do what they say they will do – AND critically, to be able to prove it.

This requires that each organisation have in place a detailed and robust safety management system, and that that system complies not only with Australian and International standards and best practice – but that it is also completely transparent and auditable. Only then will the requisite levels of trust and common understanding be gained by affected parties.

The tendency in the past – not just in Australia, but globally – has been to cover or secrete those areas of risk or risk amelioration that may become contentious – no matter the fact that they have been subjected to a full and complete risk management process. As you have witnessed in past attempts to implement change, the process of change has become difficult, or impossible – not because the change was substantially significant – but because the processes around the change management were mismanaged. Much of that mismanagement came about as a result of attempts to hide information.

Sunlight is a great antiseptic, and conducting risk management processes in the open will yield far more satisfactory results that a subversive campaign.

On that issue, it is also essential that the risk management processes undertaken allow for a change to be accepted or rejected – WITHOUT fear or favour. It has been clear that there has been an agenda for change written into various government or organisational policies that REQUIRES a change to occur – rather than allowing a proposed change to be properly assessed and treated on merit. An organisational predisposition to effect a change does NOT allow a free and transparent risk management process to occur. Necessarily, the architects or implementers of change will bias the risk studies towards the change, rather than allowing the change to determine its own fate.

That does not mean that inertia should prevail in all instances – i.e., the process should allow for the fact that some affected parties will always resist change. The way to deal with that – and we find this missing in your document – is to conduct an assessment of the risks associated with the current operating system.

To our knowledge, no such complete study of ‘day-to-day’ safety and risk management in Australian airspace has been conducted – even though there is substantial evidence of systemic problems within the system. We have only superficial access to your incident data – but it is clear from what we see that there are issues relating to training, culture, maintenance, human factors, fatigue, and so on, across the gambit of actors within the system, that need to be quantified and qualified as part of a ‘whole of system’ safety audit.

Once that audit has been completed, you will be able to quantify the effect of a proposed change in absolute rather than relative terms. Seeing a net positive influence in absolute safety can have a tremendous effect on your ability to implement a proposed change that might otherwise have been resisted.

The document makes an oblique reference to the target levels of safety associated with the implementation of reduced vertical separation minima. In fact, prima facie, the implementation of RVSM apparently [and it seems from North Atlantic monitoring actually] increases collision risk. But taken in the context of overall aviation safety, the reduced height keeping tolerances, supported by better altimetry systems, and regimented monitoring and constant remediation of gross errors – plus the implementation of better traffic management systems and procedures in ATC units - actually improves overall system safety, whilst significantly enhancing capacity.

One of the points that needs to be resolved – and is addressed only tangentially in the document – is the idea of what constitutes an acceptable level of risk. ALARP in and of itself is a nebulous term, and can be used [or misused] as required, to win or defeat and argument. Unless it is supported by broadly acceptable numbers, it is an impotent goal. Some of the signatory organisations to the document have, as we understand it, already conducted a number of reviews of safety or risk targets – and most of those studies have been ‘buried’ within the organisations, because the results would not support the change agenda [refer to our previous comments]. It is critical that the signatory organisations agree to establish numerical targets for risk acceptance BEFORE setting out to justify a change agenda.

This actually works to the advantage of the organisations concerned, allowing a complete and transparent debate to take place – and allowing senior management and Boards to make solid and justifiable decisions – for OR against a particular change – in the interests of aviation safety.

There are many more specific comments that we would like to make – and we will be providing more detailed comment progressively through the coming weeks.

Thank you again for the opportunity to comment.

John Williamson
for and on behalf of
Voices of Reason

Dick Smith
18th Jun 2007, 02:02
VOR, your posting contains a lot of good logic and rational argument – similar to your excellent post in relation to Class E airspace here (http://www.dicksmithflyer.com.au/Is_Class_E_safe.php).

I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.

At one moment you are saying everything should be open and transparent, and at the next moment you are giving a message that in relation to Voices of Reason the name should be completely secret and hidden – this is inconsistent.

You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective.

I have a handsome reward to help the Royal Flying Doctor Service if you are prepared to “out” yourself so your organisation or group can be of real use to Australia – see here (http://www.pprune.org/forums/showthread.php?t=268065).

Come on Voices of Reason, stand up and be counted! It is obvious that you (whether an individual or a group) have some very important skills that are needed here in Australia. You make out that you are posting from overseas and that you do not have a good knowledge of statistics in Australia. This seems very strange.

It is completely beyond comprehension to me (and to any rational person reading your post) why you would put in so much work and then hide your name. Aviation safety is simply science. It is not directly involved with national security. As you have said in your own posting, everything should be completely open and above board.

I suggest you place your next posting with the name of your organisation so you can be of real use to Australia. Also it will allow me to send off a cheque to the Royal Flying Doctor Service.

Howard Hughes
18th Jun 2007, 02:49
So VOR, how about becoming up front and identifying yourself so you can be effective and see if you can get involved in the necessary reform.

John Williamson
OK jobs done! The RFDS could do with that $5000!:ok:

gaunty
18th Jun 2007, 03:15
HH:ok:

Mr Smith.

It is completely beyond comprehension to me (and to any rational person reading your post) why you simpy refuse or are just unable, to "get it" in relation to PPRuNe.

why you would put in so much work and then hide your name is exactly why PPRuNe works the way it does. You yourself say that;

your posting contains a lot of good logic and rational argument – similar to your excellent post in relation to Class E airspace here.

I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.

What possible difference is it going to make should it have a series of names attached. PPRuNers are mostly grown ups who know who and who does not offer horsefeathers or cannot sustain their position without resorting to personality assasination.

Experience of the past has shown that the identification of sources here can and often does have negative and inappropriate results and also gives a protagonist the opportunity, taken often, to negatively and unecessarily personalise the debate, notwithstanding the posters point being spot on. You have been guilty of this yourself.

On one hand you use PPRuNe as a source to enhance your "usefulness" to the Aviation Regulation Review Taskforce and seem to have absolutely no problem accepting the "usefulness" of anonymous suggestions there and on the other hand you assert that the VOR can not be of any use to Australia unless they out themselves.:{

It should be clear to you by now that had they wished to avail the RFDS of your qualified :rolleyes: largesse they would have done so by now.

It is a right of PPRuNe and attempts to out a PPRuNer used to lead to banning, but you seem to have corrupted that as a principle.

Just deal with it OK.

Dick Smith
18th Jun 2007, 03:28
Howard Hughes, unfortunately it is not as simple as that. I understand that John Williamson is a pseudonym, or maybe he has extra talents over being one of Australia’s top country music performers! PS: Are you really the Howard Hughes? I thought he passed away.

Howard Hughes
18th Jun 2007, 03:33
I am a simple man, with simple tastes, most unlike my alter ego, that is why the situation appears plain and simple to me...;)

Although I must declare my close association with the aforementioned organisation, in the interest of propriety!:ok:

Dick Smith
18th Jun 2007, 03:56
Gaunty, there is nothing inconsistent about my beliefs. I have always supported the usefulness of anonymity on PPRuNe. It is obvious that many things can be posted which otherwise would not be posted. This is healthy for debate and healthy for aviation safety.

In relation to VOR, I’m simply making the point that Australian aviation is desperate to have competent, qualified people to work on the airspace changes. I cannot find any person within the realm of airspace change who makes the rational and logical comments that VOR does. Are we forever to have an “invisible” person or group telling us the best way to go about the change, but actually not have a real person who can do this work?

As I’ve said before, it is all very mysterious to me. One day I’m sure the reason will all come out!

V.O.R
18th Jun 2007, 04:27
Thank you for your interest, Mr Smith. We were aware of your kind and magnanimous offer to provide a cheque for $5000 to the Royal Flying Doctor Service – however, it would take a little more than that to tempt us to remove our anonymity. As has been pointed out by other respondents on this and other threads, it is anonymity that gives PPruNe its power. Yes, sometimes there are frivolous, funny and even odd postings across the network, but at times much good is done by allowing free interchange and exchange of information that would otherwise be hidden. We think that is worth a lot more than the $5000 ‘reward’ you offered.

We would, however, encourage you, in the spirit of magnanimity, to make the donation anyway – as a sort of quid pro quo for the sometimes spirited and always entertaining interchanges between us!

Now to the more serious topic of airspace reform.

Our posting regarding the need for a free and open risk management framework contained some comments about pre-biased outcomes. In particular, the posting needs to be read in conjunction with the draft policy statement that contains specific direction about airspace changes, including continued roll-out of the National Airspace System.

We think we have been clear in the past that the changes proposed under NAS are not, in and off themselves, inherently ‘dangerous’ – what we have raised concerns about is the need to carefully manage the changeover from the current operational environment, to any new operational environment.

You often cite the ‘dirt road’ versus ‘super highway’ example. Simply putting a set of stop lights on a dirt road will have little effect – unless it is carefully educated – and the country drivers affected understand what to do when they come across that stop light (there was a tragic reminder of that, we believe, just recently in country Victoria).

But even before that, a fully deployed risk management system will allow you to determine if you even need that set of stop lights.

Simply saying that something is safe, does not make it so. Simply copying an established system, even the US system, and superimposing it on Australia does not necessarily make the Australian operating environment safer. You need to properly assess the risks associated with the whole system, including pilot and controller training and procedures, the institutional and regulatory framework (which we note that you are working on), the economic framework, and so on – and then determine which parts of the system truly need to be upgraded or changed.

We are concerned that the risk framework has been framed to facilitate the introduction of a predetermined outcome – not to truly test the risks associated with operating the current system, and to identify mitigations against those risks – which MAY include elements from your ‘proven US system’, but may, as well, include other more progressive solutions.

We are not opposed to the risk framework – we would simply like to see it cast in a more neutral posture, providing an environment within which changes can be made which will decrease risk and maximise consensus.

squawk6969
18th Jun 2007, 05:13
Observation from the peanut gallery.

It would be far more constructive if they would at least identify themselves and set up a decent dialogue directly with Mr Smith.

I see many benefits from their words of wisdom and his ability and position to gain attention and influence.

Surely that would help.

Cheers

David Brown........yes sounds like a tractor and its not fake

gaunty
18th Jun 2007, 05:13
Mr Smith

I'll leave the first paragraph alone for the moment.

Are you prepared to accept that the;
competent, qualified people to work on the airspace changes may actually be here in Australia under your very nose or are currently expatriate for very good reasons. ??

and;

I cannot find any person within the realm of airspace change who makes the rational and logical comments that VOR does. is not as mysterious as you imagine. I don't think do at all.
Are you prepared and I mean this sincerely, to accept that they may be those who are, or have been, but are no longer prepared to engage with you directly for fear of the consequences. Surely you must realise that you have, by your actions in the past, sincerely motivated or not, shut many more doors than you have opened.
Maybe and I'm not saying they are, but maybe, the VOR are one and the very same people.

For whatever you may think of it, them and the reasons they may feel they have to be anonymous, it is clear they have and their activities demonstrate it, the efficiency and safety of Australias airspace at the forefront. They have given credit where credit is due, they have demolished puffery and wishful thinking presented as fact where necessary.

Efficient and safe airspace is your goal too, why do you think they have not associated themselves with you.

That they felt it necessary to alert the International community about the hazards they perceived in the 2C implentation, (almost an exact replay of the events surrounding 2B) says clearly, to me anyway, that the lessons of the 2b implementation so carefully pointed out by them had been simply ignored, they were not being heard internally or they were being overridden in the places they should not have been.

Some person or persons have so effectively derailed and corrupted the process that would normally have these same people leading it rather than having to influence it, that they have to resort to a respected website, whose principle driver is anonymity, they know is read by those who matter.

You have the access, surely it should not be difficult for you to find out how, who and why and to demand that the train be put firmly back on the rails.

You would have ours and their eternal gratitude should you be able to accomplish this.

I suspect they know very well who that person or persons is/are.

I suspect they understand very clearly that the absolute integrity of their reasoning and advice would not be improved by accepting the gratuitous offer of a donation to a wonderful charity by revealing themselves. IMHO your offer does none of the parties justice.

I know beyond any doubt that the very anonymity of their advice is its fundamental strength. It stands completely on its own, unassailable from any agenda, personality or political attack other than careful discussion, clear logic and fact.

Clive
18th Jun 2007, 20:03
Allow me to apologize in advance for what will, no doubt, be a lengthy post. Reference to the number of posts I have made since my date of joining this forum should, however, be testament to the fact that my input to this place is normally minimal. This is an important topic, however. The primary reason for my low level of input is that so much of this forum seems primarily dedicated to name-calling and the hijacking of some very important issues.

It is for this reason that I cannot hold my tongue on this vital topic. I am saddened to see that the initial response to a valuable submission by VOR has degenerated into discussions of anonymity which I feel is somewhat unrelated to the core topic.

Before I continue, and in the interests of a declaration of any conflict of interest (rather than simple “big noting”), it is important that I disclose my credentials and interest in this topic. I have been involved in this dynamic industry for 30 years now and am currently an airspace user as a 747 commander for a south East Asian carrier. As an aside, I hold two aviation degrees (BAv, MSc.) which focused upon safety management, and I have been heavily involved in the LOSA program. Additionally, I am the lead Threat and Error Management instructor at my airline and I am a distance educator for RMIT in both Human Factors and Safety Management Systems. Most importantly to this topic, I retain a consultancy role as a Risk Advisor with one of Australia’s only dedicated Aviation Risk Management organizations with offices in Sydney, Asia and Washington DC.

I see two very important issues here which must remain in focus during the debate of this vital issue. They both relate to contemporary Risk Management practices. Particularly as they are applied to our industry.

Firstly, it is imperative that the definition of risk management be totally understood in any argument of this type. The Australia New Zealand Standard 4360-2004 defines risk management as “the culture, processes and structures that are directed towards the effective management of potential opportunities and adverse affects”.

The reason this definition is so important to the argument is because it highlights that the concept of risk implies both a positive and a negative paradigm, not just the negative - which is incorrectly assumed in contemporary Western society. So in defence of Mr. Dick Smith the risk of a change in the airspace arrangement in Australia brings with it the chance of great opportunity, which he has spent much time in this place attempting to explain. For this reason his views demand respect and should be encouraged to assure one half of the Risk Management process is adequately investigated.

However, before those in the “Smith camp” get too excited, the other end of the spectrum of risk defends the stance of VOR et al, who eloquently highlight the potential adverse effects of this change. This spectrum of Risk Management is of course most important to ensure the potential benefits are not the sole driver at the expense of the safety of users unaware of the potential adverse effects. This, incidentally, is the premise behind CASA’s Regulatory Policy – CEO PN001 2004 (http://www.casa.gov.au/corporat/policy/notices/CEO-PN001-2004.pdf).

So this brings me to the second very important issue which must remain in focus during this debate. I will however rest here in the interests of not breaking the record for the longest post on this forum. Also I have just arrived in SFO and need some sleep. To be continued…

Dick Smith
19th Jun 2007, 00:01
Gaunty, you state:

Are you prepared and I mean this sincerely, to accept that there may be those who are, or have been, but are no longer prepared to engage with you directly for fear of the consequences. No, I’m certainly not prepared to accept such a claim because it is utter rubbish. No person has ever engaged me directly and then had to fear the consequences. It is quite the opposite. I like people who engage me directly and stand by their views. In my own business they are the people I have promoted and made the most money from. During my time at CAA and CASA, they were the people I encouraged and were the most successful.

You can go on bleating this constant claim, however you will not be able to provide any evidence because it is simply not true. You can believe as long as you want that I have some type of mysterious power to affect people’s livelihoods. I don’t.

You may remember that a person made claims on this website, including the claim that she thought that I was somehow responsible for the many people who lost their jobs during the recent reform process at CASA. She retracted this statement because it was simply untrue. I had no input or involvement in any of the job changes at CASA. They had not been discussed with me directly or indirectly. In fact, a number of my good friends lost their jobs in these reforms.

I do not believe the reason that VOR remains anonymous has anything to do with the perception that I could somehow affect VOR’s future or livelihood if their name was known.

If I ever suggested to anyone in CASA, Airservices, the ATSB or the Department that someone should be demoted, removed, or not promoted I would be ignored. In fact, the most likely thing would be that the reverse of what I suggested would happen. That is why I would make no such suggestion.

You can go on forever making out that I have some type of Rasputin-like power, however it is not true. If I actually knew who VOR was (especially in relation to the comments on Class E airspace) I would be doing everything I could to make this person or people succeed. I would probably have little effect on whether this happened or not, the political process and many other circumstances would affect the result.

You can believe a myth as long as you like – it may give my ego a boost – but you would be a lot better off if your beliefs were based on fact.

WELLCONCERNED
19th Jun 2007, 00:52
Dick,

I think I agree with VOR – but I’m no risk expert. I do think there’s a whole lot of safety areas out there that need to be looked at besides airspace. Didn’t the ATSB recently say that the average age of the GA fleet in Oz is about 25 or 30 years. If that’s an average, that means there probably some 40 or more year old GA aircraft carrying paying passengers out there – scary, no matter how good the maintenance.

Then you have this spate of accidents happening recently involving light aircraft – maybe I’m missing something – but does anyone see an increasing trend in accidents over the last year or so? It may not have anything to do with the age of the aircraft – but then again, if you look underneath it all, maybe the fact that our GA industry is in such decline, and as an industry we can’t afford to get newer aircraft, and the cost of hiring these older airplanes is so expensive, maybe we’re forcing people to fly in less regulated environments, like ultralights and so on.

And if you look at some of the recent threads, you have airlines screaming for pilots, and offering to take them on with a lot fewer hours that the old days. There’s got to be something worth looking into there.

Even Dick’s thread about changes to streamline the system is throwing up heaps of ideas, some good, some bad, that should be looked into, and which would deliver a whole lot of benefits at a lot less stress that the airspace change stuff we’ve been agonising over for nearly 20 years.

And of course my old hobby horse – who’s looking over the shoulder of the service providers. There’s heaps of safety incidents amongst controllers – and they keep saying on this forum that they’re overworked and stressed and that Airservices and Defence keep pushing for more.

Somehow I think we need to take a look at the whole picture, like VOR says. Work out where to spend the safety or productivity dollar best. After all, unlike the ‘States, we’re paying for most of the services we get – not the taxpayer.

illusion
19th Jun 2007, 02:24
Dick,
You said of VOR:

"You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective". (bolding added)

The contrary applies to you Dick- We know who you are and know your reputation and past conduct in this debate- Which makes you totally ineffective (or is that defective) as you have little support or respect for your views regarding airspace reform.:=

Atlas Shrugged
19th Jun 2007, 02:53
airspace reform

I seem to recall that was the topic of this thread, not whoever Voices of Reason or who John Williamson may or may not be.

Whilst I'm sure that this topic will always be an emotive issue for those who can't help themselves anyway, we would all benifit a good deal more if those who choose to reply to VOR would stick to the issue at hand an not play little games between the lines. It won't achieve anything other than aggravation.

I used to look forward to reading these discussions but I'll go away and not read this one for a few weeks, or months if need be, and when I do choose to, hopefully I will be able to get something out of it and not feel like I'm watching a Simpsons episode, one that no doubt I've seen countless times before.

Grow up kiddies and play nicely - it ain't all just about you!

:mad:

Clive
19th Jun 2007, 03:09
Here, Here Atlas Shrugged. I'm with you on that point! :D

I'm also not going to get anymore rest on this layover so I'll continue with my previous post.... which I hope brings us back to the core of the thread.

So, following on from my previous post…..

The second very important issue which must remain in focus during this debate relates to the timing of the Risk Management process. I believe this to be at the core of VOR’s post.. Let me explain.

Traditionally our industry has tackled safety through the valiant efforts of folk using safety systems which have been primarily built upon the premise of leaning from our mistakes. This has developed into what we know as Error Management. Admirable, but flawed. The weakness in this system is that we are dealing with the past. The error has already occurred and we rely on contingency planning to reduce the consequence of the error (if it is detected) and awareness, through human factors training, to reduce the likelihood of error – somewhat unsuccessfully.

The answer to a safer system, I believe (and it seems VOR and his colleagues believe), is the implementation and integration of Risk Management into the safety management system. In this way we can influence the future not just deal with the past. The result is that the “what ifs” are considered, investigated and treated rather than waiting to act upon the “what now”. To date the closest our industry is to this, in most cases, is through the use of Threat Management. An important move forward.

So what does this add to the debate on the topic in question?

Just as VOR et al insist, the only way a process of identifying, analysing, evaluating and treating the risk of airspace change in Australia is to apply this Risk Management process BEFORE the changes are enacted. This is the only way the efficacy of the process can stand up to scrutiny and the process itself becomes fit for purpose.

Additionally, and perhaps most importantly, 40% of the time spent within the Risk Management process should be dedicated to the initial step of “Setting the Context” for the analysis. This requires continual consultation and communication with the stakeholders involved. Without this the result can simply become a plethora of motherhood statements on only some of the risks with no effective mitigation strategies emerging.

As a consequence the same respect I suggested was due to Mr. Smith et al should be afforded to VOR, Gaunty and others who’s input, as airspace users and therefore stakeholders, is mandatory. I guess this place is not always the ideal forum for this given the hijacking that takes place from time to time. I'm sure Atlas Shrugged would agree with me here!

In conclusion, should the decision to affect change be enacted and the system itself changed prior to the use of a viable Risk Management framework, simply because there is a perceived requirement to change (as VOR has pointed out), then we are destined to continue down a path of being reactive rather than proactive in the vital process of keeping our industry, and its airspace, safe.

I vote for the former.

tail wheel
19th Jun 2007, 06:30
Thread drift! :mad:

Thread title: NAS - Common Risk Management Framework (http://www.pprune.org/forums/showthread.php?p=3357643#post3357643)

Play the ball - not the man - or a little "moderating" may be in order! :E

Tail Wheel

V.O.R
19th Jun 2007, 06:54
Clive,

To a large extent we agree with your synopsis, and focus on pre-emptive action in risk management. We have no doubt that we could engage here in a substantial and meaningful discussion on the whole issue of inculcated risk management cultures.

There are many examples of organisations and industries that have realised the benefit of moving to a lead safety model rather than relying on the traditional lag analysis.

As an example in our own industry, we understand that the international airline organisation IATA has pressed this whole issue through its IOSA program, spilling membership, and refusing to re-admit member airlines unless they not only subscribe to an integrated risk and safety management system [say what you do], but also demonstrate both a commitment to that program [do what you say] – and demonstrate results [prove it].

That is what we would have liked to see in the Common Risk Management Framework – not simply a manual on how to evaluate risk and treat it – but how to inculcate a complete risk and safety management culture – not just in the regulator, not just in the service provider, but across the whole spectrum of aviation.

Once that is truly embedded, debates about changes to airspace, changes to procedures, changes to practices, can be held [mostly] without the passionate polarisation that has taken place in the past.

Our other point is that the Framework document appears to be a ‘post hoc ergo proctor hoc’ – or ‘the end justifies the means’ – salve to a predetermined policy of change. That is, the change protagonists have decided to go ahead with an agenda – and to ‘prop it up’ with a means of justifying the changes. This is a ‘circular cause and consequence’ argument, as you know doubt would agree, Clive.

As we have said previously, simply ‘saying something is so does not make it so’.

We also agree with you, Clive, when you say that a risk management framework is not just about tracking the negatives. It is about finding opportunities for system improvement - not just in areas of safety, but across the spectrum.

But coming back to the point of this thread.

We were simply alerting the readers of PPRuNe to the apparently disguised fact that processes were in train that will inevitably lead to the same endless debates that were held last year, and the year before, and the year before…..and that providing detailed comments to draft documents now might circumvent those debates.

Our intention is not to shut down talk of airspace reform. We live in a constantly evolving world, and aviation has to evolve if it is to survive. But that evolutionary path would be a lot smoother if the foundations for decision making were actually built in ‘show me’ bedrock – not in ‘trust me’ shifting sands.

Two last points to Mr Smith.

Dick, you choose to selectively quote posts that we have made to this forum, without showing the entire context – in particular a reference to comments we made about Class E airspace. We would be happy to amplify any of those comments, but this is not the appropriate thread.

We also note, Dick, that you have chosen not to respond to our request earlier in this thread that you go ahead and make the payment to the RFDS – as we understand the Australian way, it would only be the fair thing to do.

SM4 Pirate
19th Jun 2007, 06:55
Very interesting thread; combine this document (see link) http://www.dotars.gov.au/aviation/airspace_reform/pdf/Common_Risk_Framework.pdf with the airspace policy document (mentioned elsewhere) in the same area of the information supa highway (Dotars) and you can draw most of the elements together.
NAS is fully back on the agenda and rightly or wrongly we are going to go through substantial change again.

The problem I see is that we are here and we are going there. But where are the people there going? Why charge full steam ahead to get where noone wants to be? The European model is to have two classes of airspace by 2015; isn't that where we just came from?

There would appear to be no way to model the current risk (due to lack of imperitiveness) and thus any assessment is against the change and the change alone at each increment; but who is assessing the whole?

Class E is safer than G, Class C is safer than E etc. Is it so black and white?

Consultation is the key; but who is 'invited' to the process; are they going to be individually based (secret squirrell style) or industry wide meetings (yeh ha!, and take forever)

Is the lack of progression anything to do with a class of airspace? Can anyone resonably argue lack of financial progression because of the classes of airspace restricting their business. Well perhaps we will see that with Class E at 1200AGL; all those IFRs getting a one in one out service.

Back on topic, the risk and the framework needs to be effectively managed. The proposal must not determine the outcome; but like all change processess will anyone ask the real questions before making the changes?

Let's see whether dates and agenda's are determined before risk analysis or consultation; if they (dates and characteristics) are determined before we begin then we are behind the eight ball again.

V.O.R
20th Jun 2007, 00:38
Hi SM4 Pirate,

You need to very careful about making statements about the relative safety of various airspace classes. On the whole, perceptions and realities regarding the safety [or otherwise] of a particular class of airspace come from there practical and actual application around the world – not their intended application.

ICAO developed the ‘alphabet airspace system’ to address safety issues relating to increasing levels of VFR traffic – particularly in busy terminal areas – operating amongst IFR aircraft.

The intent was to create a uniform risk environment for IFR flights – that is, to ensure, to the extent possible, that IFR flights would not be subject to significantly varying levels of risk across their gate to gate operation – whilst also allowing as much flexibility as possible to allow VFR operations to continue.

The intent was that an airspace authority would determine appropriate risk tolerance levels – then put in place various levels of service, or levels of restriction, to ensure that risk was reduced to as low as reasonably practicable, and spread uniformly across the system.

Rather than have a myriad of rules, service options, or restrictions, ICAO chose to develop a set of codified airspace classifications. We have given you a more detailed synopsis of the development process in past postings – but to summarise, ICAO took the best [or worst] from several Contracting States, and initially developed a 5 tiered system [Class A to Class E] – which was later redeveloped as a 7 tier system [Class A to Class G] of airspace classification.

Unfortunately, the panel of experts that was set up by ICAO to develop this framework was prorogued before it had time to develop the guidance material for application of the airspace classification system. Draft material was, however, developed, and though it is difficult to access, we have seen the material. You may access the material through Australia’s representatives to ICAO [the papers are not available on-line - ask them to search for hard copy working papers of the ICAO Visual Flight Operations Panel 1985-1990].

The panel envisaged operation of the system like this.

A State would determine an acceptable risk level for aviation operations within its airspace. This allowed a small level of flexibility for States to set different risk targets based on their current operation – and also to allow a transition to lower risk levels over a period of time.

Based on those acceptable risk levels, States would assess the levels of risk that IFR flights would be exposed to in various phases of flight, over various sectors, and in various operating environments.

Taking into account the existing or planned infrastructure available within any particular operating environment [communications capability, surveillance capability, navigation infrastructure, air traffic service infrastructure, etc] the State would find the ‘nearest fit’ airspace classification system elements that would satisfy the risk equations.

It was recognised that some options would fit better than others, and that some elements of one classification, mixed with some elements of another classification, would be a better option [e.g., some parts of Class D, and some parts of class C – for a Class C-lite] – but States were to be encouraged to adopt a ‘whole’ classification.

The next step was to rationalise the application, so that a State didn’t have hundreds or thousands of small blocks of airspace in close proximity with different classifications.

Inevitably, this rationalisation would partially defeat the ‘uniform risk’ expectation – but the end result would be a system with ‘smooth transitions’ between risk areas – not abrupt changes.

Bear in mind that the whole classification system was about uniform risk exposure for IFR flights [in relation to other IFR flights, or in relation to an IFR – VFR conflict]. At the time, ICAO was not particularly interested in risk to VFR operations.

It should also be noted that ICAO did not factor infrastructure in the classification system – for example it did not require radar for any particular class of airspace. The presence [or otherwise] of radar was a factor in the determination of risk exposure as a precursor to choosing an airspace classification.

So, arguments that say that Class C airspace MUST be serviced by radar, or that Class C towers MUST have radar, are, to be blunt, plain wrong.

So what has this to do with the current thread?

The point that we have been trying to make through this thread, and in the past, is that a Common Risk Management Framework must have as one of its objectives an agreed tolerable level of risk – and a means by which to measure and treat such risk.

Once that agreed risk level is established [and agreed by all stakeholders], a thorough risk analysis must be conducted to determine what levels of risk exist across the country. Only then can discussions be had on ameliorating that risk.

Risk amelioration strategies may include changes to procedures or practices [including changes to airspace classifications], or changes to infrastructure – including extension of surveillance capabilities, enhanced navigation infrastructure, and so on.

This is when airspace policy statements should be made – AFTER an open analysis of risk and risk objectives.

Because of the ad-hoc way in which the ICAO airspace classification system has been introduced in Australia, and around the world, you will inevitably have areas where the levels of risk are well below target levels – simply because a lot of infrastructure and rules effort has been focused. This should not mean that this becomes the de-facto risk target. Neither does it mean that service levels should be reduced to drop to a uniform risk level – unless the cost benefit is substantial.

This is a debate that will need to take place in a truly mature consultative environment.

One of the best foundation stones to that maturity is a robust and transparent risk management framework that allows ALL of the arguments to be put, and accepts that there may be a number of ways to achieve a strategic objective. Such a framework is a guiding tool for making choices, not a pacifier for decisions already made.

gaunty
20th Jun 2007, 02:00
Phew.:ok: Thank you for the clear light of reason.

Anybody who doesn't take that on board as ground zero, from which ALL else must follow, needs professional help.

I have been becoming increasingly disturbed at the "policy" = "political" statements coming from the Minister in regards to a determination (n) to implement the NAS. Which NAS is becoming increasingly clear, yup folks the same old and comprehensively discredited one sold to the Government 5 years ago.
Dejavu or is it Ground Hog Day now folks.
In tatters, threadbare and full of holes maybe, but the same one nonetheless based on the same quicksand foundation, which/who by the way is/are going through a process of complete and fundamental redesign, rethink and funding debate as we speak.

If Mr Smith truly and honestly believes that change is an opportunity to make things "better" he would welcome any and ALL input to the debate regardless of whether it contradicts his personal beliefs or not.

The US NAS no longer serves its original design and purpose so they are fixing it, to base our safety metric on theirs is nothing short of hilarious. The AUSNAS needs an overhaul, no argument, but;

Because of the ad-hoc way in which the ICAO airspace classification system has been introduced in Australia, and around the world, you will inevitably have areas where the levels of risk are well below target levels – simply because a lot of infrastructure and rules effort has been focused. This should not mean that this becomes the de-facto risk target. Neither does it mean that service levels should be reduced to drop to a uniform risk level – unless the cost benefit is substantial.

This is a debate that will need to take place in a truly mature consultative environment.

One of the best foundation stones to that maturity is a robust and transparent risk management framework that allows ALL of the arguments to be put, and accepts that there may be a number of ways to achieve a strategic objective. Such a framework is a guiding tool for making choices, not a pacifier for decisions already made.

What can be simpler than that and what possible justification for resisting it could there be.

Dick Smith
20th Jun 2007, 05:07
VOR, perhaps you can explain how these safety studies can come up with meaningful results.

Let me give you an example. In the USA, VFR aircraft can overfly JFK airport in Class E airspace, whereas in Australia at a place like Sydney this is not generally allowed. This means that in the USA, VFR and IFR aircraft pass through the same levels when in Class E airspace. In the US system, safety is maintained by air traffic control giving the airline pilot traffic on the VFR aircraft, and where necessary giving the airline pilot a radar vector away from the VFR aircraft.

In Australia it is quite different. VFR aircraft cannot overfly a place like Sydney, but are directed to a location such as Hornsby – where they would normally be at 2,500 feet. IFR airline aircraft from the north operate over Hornsby at 3,000 feet. Air traffic control is not involved in any way in relation to separation. There is no transponder requirement for the VFR aircraft at Hornsby and air traffic control generally does not give traffic information to IFR airline aircraft on VFR aircraft which are in Class G airspace at that location. The controller presumes that the VFR aircraft is at the correct altitude.

Which system is safer? In the history of aviation there has not been a midair collision between airline and VFR aircraft at these locations – i.e. in the Class E airspace above the Class B at New York, or in the Class G airspace around Sydney – so we cannot use historic data.

How do you find which is safer, or whether they are as safe as each other? Do you have a group of pilots and air traffic controllers sitting around a table (as in the Class E over Class D study), being asked what the chance is of pilots making errors in each of the circumstances? Or do you use a mathematical model – or a combination of both?

I wonder if the reason that this form of modelling has not been widely used in the past is because it is not possible to get a meaningful result as the variables are so great and expert opinion is so subjective.

I will look forward to your advice.

V.O.R
20th Jun 2007, 05:57
Mr Smith,

We hadn’t intended in this thread to get into discussions and debates about the efficacy, or otherwise, of elements of NAS, or the risk analyses that were conducted in the past. However, we will respond on two issues.

First, we believe you have inadvertently recognised your own logical incongruence in the examples you quote about the United States. The procedures and practices you describe have been in operation in the United States for over 40 years. Class E airspace was not ‘invented’ by ICAO until 1991. It was adopted by the US shortly after, and the 7 elements codified by the ICAO Class E label were superimposed across existing practices without substantially altering those practices. There are many more elements to the US operations above major airports that the 7 basic codified elements [communications, speed, clearance from cloud, etc].

If you want to mimic the practices used by the United States, you need to adopt ALL of the elements – not just the 7 ICAO elements – AND you need to adopt ALL of the elements in the surrounding environments. This also includes inculcating a significant cultural shift, where pilots are taught the response and reaction cultures required to operate comfortably and safely in the terminal airspace. Ad yes, it is possible – you have seen our previous postings on this matter – but it requires substantially more effort than a simple stroke of the pen to redesignate airspace from C to E.

You ask about the efficacy of fault tree analysis, and the process of codifying error probabilities using pilots and controllers. In fact, the use of fault tree analysis is widespread through a range of industries, and is one of a number of methods of assessing risk, and identifying potential points of failure within a system. The ‘mathematical analysis’ that you refer to relates principally to the process of summing the error probabilities, and producing a numerical representation of risk.

The number is less important that the processes used to derive that number.

We agree that it is possible to ‘adjust’ the various parameter values in the fault tree to skew the final number one way or another – BUT what is key is the ability of the facilitator to draw out from the contributors as many of the potential failure points as can be determined – and then identify risk mitigators for those failure points.

If we were providing advice on the use of fault tree analysis of elements of NAS, we would recommend that any failure mode identification procedures – including the assignment of possible failure rates – is conducted not only in the target environment [i.e., not just with Australian controllers and pilots] but also in the environment that you are trying to replicate. So, if you interview 10 or 20 controllers and 10 or 20 pilots in Australia, you should also do a similar study, asking the same questions, to a similar group, in the United States, and in other areas where these practices and procedures are used.

This in fact what Europe has done in implementing certain procedures from the United States recently. They conducted what is known as a reference study, using a number of operating environments in the United States that as closely as possible match the target operating environments in the Europe.

This gives you a twofold benefit. First, it provides a reasonable benchmark – and gives a value to the potential benefit that may accrue from implementing the change. In other words, if a group of Australian respondents, who have not been exposed to the operations proposed, say the risk is “x”, and a group of US respondents, who have operated the system for 40 years say the risk is “½x”, then you have a quantification of possible benefit that could be introduced to a cost benefit analysis.

You can see that as long as the potentially [and demonstrably] achievable target number [“½x”] is under your Australian risk tolerability line, then you proceed on the basis of treating the identified failure points – not on the basis that the number “x” is too high. As we said, the number is less important that the processes used to derive that number, and the processes used top treat the risks that derived that number.

The second benefit – and this is important for you as a change proponent - is that it extricates you from the role of change proponent AND risk arbiter [a conflict of interest] – that is, the community has a risk reference group of peers rather than – and we say this with respect – a perceived ‘self appointed expert’.

If you do choose to use overseas reference groups, you MUST do it in an open and transparent way – and must not seek to influence the outcomes one way or the other. You must trust the fact that if the system operates as you say it does, then the people operating it will provide the evidence.

Chimbu chuckles
20th Jun 2007, 06:04
Ohh yeah!!!!!:D:D:ok:

That is a system I could get behind...except ask 2000 pilots from a broad spectrum of experience and regions.

putytat
20th Jun 2007, 12:31
VOR has mentioned the one thing that you have never acknowledged Dick:
CULTURE
You cannot change a culture in one year or one AIRAC cycle! 'Should" versus 'shall' is a great example. Another would be 'recommended'. These words have different meanings to different cultures.
'Recommended' in the US is interpreted as "do it unless there is a definite reason for not doing so". This was the explanation used by the NASIG when educating pilots on CTAF changes in 2005 during their forums. The NASIG staff quoted continually that this is the way it works in the states and reason for recommended practices for CTAFs. It was CASA who stepped in and mandated certain calls for CTAF procedures during the implementation phase. The NASIG wanted no mandated calls for CTAFs, and therefore in Australia, no enforcement.
In Australia, the term 'recommended' is interpreted as "good advice but NOT mandatory". Road signs recommending vehicle speeds are shown in yellow in most states in Australia are an excellent example of this. There is a maximum speed limit, and at times recommended speeds for certain areas. These recommended speeds are not enforceable.
Airspace reform must be beneficial to industry. The paying industry should benefit the most. Controlled airspace is in place for the control area protection of RPT operations and full separation of these aircraft is essential. These are the paying customers of aviation in Australia, not GA. You mentioned in a previous post that in E airspace that an IFR RPT was vectored away from VFR aircraft to ensure separation.
Why should a large airline business incur extra track miles, burn more fuel and increase emissions therefore effecting the environment to avoid a non-paying VFR aircraft? Where is the priority?
Whilst you play with insignificant things such as changing classifications of airspace and hindering the industry by constant change, others with limited resources are saving airlines fuel and track miles, and costs.
Consider the additional technology that could be engineered and implemented if the resources wasted on NAS reform were redirected to new technologies.

putytat
20th Jun 2007, 21:47
VOR,

Another issue to observe in Australian aviation in the near future will be attempts to have TCAS used as a risk mitigator for future NAS reforms.

In the past reform cycles, particularly with NAS some hazards identified could not be effectively mitigated. The only mitigators available were pilot and ATC training and education. This was especially relevant where the hazard may relate to violation of CTA or collision risks with changes to airspace classification in an enroute terminal environment.

With the attempts to implement the US style CTAFs in 2003 / 2004 / 2005, the large majority of industry would not accept these proposed changes. During 2003 / 04 attempts industry was able to identify hazards that were significant enough for the NASIG to change the model or delay the implementation. By 2005 the model had not changed significantly, but the hazards identified in 2003 / 04 had been negated by minor changes to the proposal. Industry were still against the proposed changes, but could not identify any significant show stopping risks.

The end result was another hybrid procedure that partially represents the US procedure, but does not fit with the rest of the Australian airspace model and the operating Culture.

This will occur again with low level E corridors and E base FL145. Low level E corridors will require increased numbers of controllers and training, and will restrict IFR ops in imc to one in, one out. As mentioned in a previous post, lowering the base of Class E to FL145 will hinder turboprop ops in non-radar airspace obtaining a clearance. Currently in these areas, if an IFR turbo cannot obtain a clearance at FL180 or above, then some economical cruise can be achieved at FL150 - FL170. Under the NAS proposal of FL145, this is more restrictive and less economical for turboprop ops.

These significant issues will be ignored by the committees that Mr Smith again sits on. The political agenda has been set; it usually is just before an election. Resistance will be rather futile.

V.O.R
20th Jun 2007, 23:50
Putytat,

It seems that we are being drawn into a discussion about elements of a system change that may or may not go ahead – and whilst we would be happy to discuss the pro’s and cons of specific elements such as Class E corridors and their application and use, we would rather focus this thread on the processes used to identify and manage risk – that is, the development and application of an integrated risk management framework.

If you have that in place BEFORE setting the change agenda, and if it is agreed by stakeholders as a reasonable tool for decision making, then you can circumvent many of the arguments that you have had in the past. The key, as we have said, is to use the risk management framework as a before the event tool – not a post the event justifier or pacifier.

You cite examples of unmitigatable risks being identified in certain elements of the previous airspace reforms, and we would offer the following advice.

Risk is nearly always about perception. If people have not experienced a particular circumstance, most will err of the side of caution, and overstate both the likelihood of an event, and the potential consequences of an event. That is to be expected, and there is nothing inherently wrong with the response. If, however, you question the same group about the same circumstance after having operated it for a number of years, it is likely that there ‘tolerance’ of the risk has increased, and they will most likely reduce the likelihood and consequence of an event. [Example: in the 1970’s, the international pilots association IFALPA vehemently opposed the installation of TCAS on commercial aircraft – now you couldn’t get it off a commercial aircraft if you tried].

It is unfair, however, to confront a risk assessment group with a scenario such as “well, we accept that you are being cautious, but over time you’ll see that it will get better!”. There is no better way to alienate your stakeholders.

If a proposed change element has never operated in Australia, and the proponent of change indicates that the changes proposed are operating ‘safely’ in other parts of the world, then it is reasonable to assume that the benefit of operational experience itself has mitigated the risk.

In this case, as we indicated in a previous response, it would be advantageous to run a number of control group sessions in those ‘other pasts of the world’, and ask them the exact same questions, and get them to rate the potential likelihoods and consequences – and even to identify any other risks that may have become apparent from their years of operational experience.

This is NOT a case of bringing so-called ‘experts’ across to Australia to tell you how backward you are, and how much better the system is ‘where I come from”. Again, no better way to alienate your stakeholders.

No – you must conduct those risk studies in the reference countries, independently, transparently, and with a sufficiently representative group that gives confidence that the results are legitimate.

An important point here is that the results from reference studies should NOT be used to try to ameliorate the identified risk levels. That is, you should not go back to the Australian risk groups and say “our reference groups said the risk is half what you said – we want you to reconsider”. Rather, you should present the results to your risk groups, and ask if they would be willing to accept the higher level of risk - mitigated or unmitigated – for a period of time, subject to reassessment post implementation, on the basis that operational experience in other countries has shown potentially better risk results.

We don’t want to understate the complexities here. This example should not be taken as ‘the only option’, or a ‘preferred solution’ – it is offered only as an example of actions that might be taken.

The key is to ensure that these options – and others – are built into your draft Common Risk Management Framework.

One last point on the issue of TCAS.

TCAS is a last line of defence, and is used as a collision preventing mechanism – not a risk ameliorating strategy – i.e., it is something that is factored AFTER collision risk modelling and system design, not as part of collision risk modelling and system design. Until such time as ICAO changes its policy on this issue, we will continue to oppose any attempts to factor the presence of TCAS in risk modelling.

apache
21st Jun 2007, 10:48
Wouldn't it be funny if V.O.R was actually John Andersen, Warren Truss, and Mark Vaile getting together over a cheap bottle of red, and just rustling feathers ?

very unlikely, but could you imagine it ? Balanced, reasoned arguments under the cloak of anonimity. Without fear of someone saying "I will stand for election in your seat if you block me on this..."

makes me laugh.


Apache

Perhaps if you consider the topic frivolous, you belong here (http://www.pprune.org/forums/forumdisplay.php?f=16)?

:ugh:

Tail Wheel

WELLCONCERNED
21st Jun 2007, 11:06
More like a good bottle of Barossa Valley Estate E & E Black Pepper Shiraz!!

putytat
21st Jun 2007, 11:11
VOR,

I agree with your statements. Time will tell if these processes are put in place prior to any change proposals.

The Australian airspace system is now a hybrid of designs and procedures mixed between the ICAO and US system. AIP is now filled with non-ICAO terminology since Nov05 with the CTAF changes. The future NAS characteristics of Special Use Airspace (SUA) does not align with ICAO, but with the US system; well at least partially anyway. The last time the NASIG visited the SUA concept they discovered that they would need to amend the characteristics to fit into the Australian airspace system. Another diversion from ICAO.

I agree with you comments on TCAS and ICAOs position on this. Let's just see what the hybrid Australian airspace and risk model is at the end of the next NAS phase. My guess will be a direction to use TCAS as a mitigator. The same players are in place as last time; moving to an open transparent risk analysis system brings discussion and delays to reform agendas. This will not be tolerated; dates have already been set for implementation.

Dick Smith
21st Jun 2007, 22:52
VOR, you state in relation to TCAS that ICAO will not allow it to be used for risk modelling:

Until such time as ICAO changes its policy on this issue, we will continue to oppose any attempts to factor the presence of TCAS in risk modelling. Can you advise when ICAO made the decision, who was on the panel (i.e. were they air traffic controllers, pilots, and what countries did they represent?) and also can you give me a reference to the actual decision? I’ve been searching for it for the last few days and haven’t been able to find it – even though I had read something in relation to TCAS and airspace categories.

I will look forward to the information. Thanks.

Dick Smith
21st Jun 2007, 23:47
I’ve just noticed this quote from the Professor Terry O’Neill report of his analysis of NAS 2b (which he conducted for CASA). As a footnote in relation to TCAS it states:

‘TCAS cannot be included in risk modelling when determining the need for air traffic services in an area.’, it …‘ought to be taken into account in any model which purports to predict absolute risk’. (Review of NAS Class E and Class C, May 2004, Risk Reliability and Associates Pty Ltd., primary recommendation b, page 6 and 7.)(My underlining)

By the look of it, ICAO was saying at the time that it shouldn’t be used for determining the need for air traffic services – I think it was 1993 when TCAS was very new and possibly even reliable resolution advisories didn’t exist. However ICAO doesn’t actually say that it shouldn’t be put in a model to predict risk. Why then would you “continue to oppose any attempts to factor the presence of TCAS in risk modelling” - especially when the reputable company Risk Reliability and Associates Pty Ltd recommends that it should be taken into account?

V.O.R
22nd Jun 2007, 00:59
In relation to your comments about TCAS, there are a number of references throughout ICAO documents – however, the following is probably the most germane:

ICAO Annex 11, 13th Edition, Page 20, Paragraph 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…”

Note that ACAS and TCAS are synonymous in this context.

The amendment to incorporate this paragraph became effective on the 11th November 1993. It was a result of work carried out by the Secondary Surveillance Radar Improvements and Collision Avoidance Systems Panel and finalised at their 4th Panel Meeting [SICASP/4] in 1989. The proposed amendment was adopted by the ICAO Air Navigation Commission on the 26th February 1993. It was circulated to States [including Australia] for comments, and was finally approved on the 26th July 1993.

It should be noted that SICASP continued to develop applications for ACAS, and several years ago, ICAO established a panel to look at ASAS applications that would leverage developments in SSR, TCAS and other airborne systems. This has resulted in some of the recently deployed, and soon to be deployed air to air separation and spacing applications, the use of ADS-B, the use of datalink, and so on.

Australia is heavily represented on the Panels developing these applications – and is served by a Council member based in Montreal. Australia also provides a ‘technical expert in his/her own right’ to serve on the Air Navigation Commission. We are sure you can access copies of papers, etc, from DoTARS, which oversights Australia’s participation at ICAO.

In relation to your comments about ‘ Professor O’Neill’s statement that: ‘[TCAS] ought to be taken into account in any model which purports to predict absolute risk’ we offer the following comments.

First, you need to distinguish between absolute and relative risk. What most safety cases will do is try to identify absolute risk, as far as it is practical to do so, and then determine by how much the risk will change as a result of changing elements of the system. In many cases, it is not possible to establish the absolute risk with certainty – but it is possible to more accurately quantify the relative change in risk.

IF, as Professor O’Neill suggests, you take TCAS into account at the output stage, then you MUST factor TCAS at the input stage – that is, you must factor the risk mitigation effect of TCAS in the current operating environment. You can’t simply say that you will factor it in the end-state – that will significantly skew the relative risk results.

This has been an ongoing debate in ICAO. For example, in the North Atlantic, the collision risk modelling was conducted excluding the use of TCAS as a mitigator – yet 95% or more of the near miss reports in the North Atlantic are generated as a result of TCAS reports. The Target Levels of Safety [TLS] for the North Atlantic are only just being met – however, if you exclude the TCAS near-miss reports, the TLS will be easily met.

That might prompt some to say that if you factored TCAS in the original calculations, you could easily meet the targets. Of course, those same proponents would seek an increase in traffic levels to the point where the TLS is again only barely being met – but now you have absolutely no defence against error.

It is a complex subject – and not one for this forum.

Suffice it to say that you should not take away the last line of defence against poor system design [whether it be the current system, or some future system] without serious consideration of the consequences.

Australia has significant representation at ICAO, at all levels of the hierarchy, and is well respected. We understand that DoTARS can direct Australian representatives to adopt Australian preferred positions. If you feel sufficiently strongly about this topic, we suggest you establish a process to have ICAO change its position.

Dick Smith
22nd Jun 2007, 02:10
VOR, I couldn’t agree more with your comment:
Suffice it to say that you should not take away the last line of defence against poor system design [whether it be the current system, or some future system] without serious consideration of the consequences. It seems to be quite a change from your original statement, which said:
… we will continue to oppose any attempts to factor the presence of TCAS in risk modelling. I also note that the ICAO paragraph does not say, "…shall not be a factor in determining the level of air traffic services in that area…” (My underlining).
It actually says:
“…shall not be a factor in determining the need for air traffic services in that area…”

V.O.R
22nd Jun 2007, 02:47
Mr Smith,

There is no conflict in our statements.

You asked for references. We provided them.

We stated that “you should not take away the last line of defence without considering the consequences”. We will continue to oppose any attempt to factor TCAS unless ICAO changes its stance. Note the emphasis.

Australia, as a sovereign State, can do as it wishes over its territory and within its territorial waters – so long as it notifies ICAO that it is doing that. So you can choose to factor TCAS. But then, you would not be able to claim that you are complying with international best practice.

On your second point – you are arguing semantics. The context is clear – we suggest you reference ICAO Annex 11, and look at the content and intended application, before trying to second guess the authors. ICAO is absolutely clear in its position. ACAS/TCAS may NOT be factored in airspace design. You may like to confirm that with Australia’s representatives to ICAO.

By the way - have you written the cheque to the Royal Flying Doctor Service? We understand you will qualify for a tax deduction if you donate it prior to June 30, 2007.

putytat
22nd Jun 2007, 04:10
Your Worship, I rest my case!

Dick Smith
22nd Jun 2007, 05:10
VOR, it is not semantics and you know it. It clearly says, “in determining the need for air traffic services in that area”. That is very different to determining the actual service level that is provided in that airspace, and I’m sure you know it.

Regarding the donation – no way! The offer was very clear. I am still totally mystified why someone who spends so much time on this issue, and appears to have such an in-depth knowledge, has to remain “secret”.

I know there are many others who are just as perplexed. Why you would not be completely open in making your statements is quite beyond me. No doubt the reason will come out one day.

V.O.R
22nd Jun 2007, 06:30
Mr Smith, we will just have to agree to disagree on this matter. We urge you to seek clarification through your own Australian resources - surely you have sufficient influence within DoTARS to request that the Australian representatives to ICAO provide you with the information you seem not to want to hear from us.

On the matter of RFDS - we're sorry that such a worthy organisation is not worth such a small donation from you. Clearly you need the money more than they do. On our calculation, and based on our standard consultancy fees, the advice we have provided you through this thread alone would be worth more than the $5,000 you offered. Never mind.

Mr Moderator,

We believe we have acheived what we set out to do with this thread - that is to alert your readers to the fact that your DoTARS has released documents for comment - and that they should provide that comment now, rather than wait until another round of airspace reform begins. Influencing the Risk Framework in the right direction now may save some angst and aggravation later.

We would be quite comfortable for you to release the 'sticky tag' at your convenience. We will not be contributing further on this thread.

Many thanks.

Voices of Reason

WELLCONCERNED
22nd Jun 2007, 09:59
Well, I for one am disgusted at Dick Smith's attitude.

I can't believe that he is so tight that he can't spare five grand for the flying doctors.

I just hope he doesn't find himself in the middle of Australia looking for medical help one day.

So much for the Aussie Icon.

P*ss poor, if you ask me.

tail wheel
22nd Jun 2007, 10:32
V.O.R

Thank you for your very professional contribution to this thread. And I also thank Dick Smith and the others who contributed to a very professional debate.

I will "unstick" this thread.

WELLCONCERNED

You are very wrong! We are well aware Dick Smith contributes very generously to many very worthy Australian causes. Whilst it does not earn him any PPRuNe "Brownie Points" or privileges, it does earn him the respect of most Australians.

I'm sure he will keep your comments in mind when he next experiences a philanthropic whim! :ok:

Tail Wheel
Dunnunda Moderator

Clive
23rd Jun 2007, 00:20
VOR

I too wish to thank you for your input to this debate.

In the 4 and a half years I have been frequenting this forum I have never come across a topic so professionally debated.

It gives me great pleasure to read your thoughts, beliefs, and well educated dissertation on risk and safety in our industry.

It warms my heart to find someone “on the same page” (as the Americans would say) as I, in relation to a shared concern for the maturing of the safety culture and processes within our industry.

I trust you are in a senior position in aviation safety management and hope your skills are being put to good use in our risk and threat rich environment.

Godspeed my friend.

Dick Smith
25th Jun 2007, 03:46
Wellconcerned, I’m very happy to donate to the Royal Flying Doctor Service separately to my offer in relation to VOR. You come up with an amount that you will put in, and I’ll put in the same.

Dick Smith
25th Jun 2007, 05:22
VOR on your post dated 20 June 2007, you made the following statement:

This in fact what Europe has done in implementing certain procedures from the United States recently. They conducted what is known as a reference study, using a number of operating environments in the United States that as closely as possible match the target operating environments in the Europe.

This gives you a twofold benefit. First, it provides a reasonable benchmark – and gives a value to the potential benefit that may accrue from implementing the change … The second benefit – and this is important for you as a change proponent - is that it extricates you from the role of change proponent AND risk arbiter [a conflict of interest]... My suggestion is you look at the NAS document. You will see under Safety Analysis Methodology 3.1, that it is quite clear that NAS follows the reference system methodology.

Yes, I was one of the change proponents, but I certainly was not the risk arbiter.

It is extraordinary that Airservices has gone down the path of creating a most complex fault tree analysis to support reversing the Class E over D when Europe has implemented procedures from the United States by following the reference system methodology that was proposed in the Australian NAS document as approved by Cabinet. Let’s hope that Adrian Dumsa can get Airservices to follow the reference system model in future.

By the way, what were the procedures that Europe has implemented which come from the United States?

SM4 Pirate
25th Jun 2007, 05:51
You will see under Safety Analysis Methodology 3.1, that it is quite clear that NAS follows the reference system methodology. What does that mean? Call it the USA model and therefore no safety assessment is required because they have enough safety? The question I then ask is it really the same system? Especially in transition?

Dick Smith
26th Jun 2007, 05:34
Can anyone advise on the TCAS in trial climb procedures used by airlines in the Oceanic airspace?

I understand this procedure relies on TCAS, outside of radar coverage and the TCAS is used as a risk mitagator in planning and managing this type of airspace.

Why is this trial accepted by the countries concerned? Does ICAO, have any objections?

V.O.R
26th Jun 2007, 06:32
Mr Smith,

We had intended to leave this thread - and will after this final post.

TCAS In-Trail [Climb] Procedures [ITP] were developed by the FAA in the mid 1990's for use in the transition airspace off the coasts of the United States - primarily the oceanic transition zones east of New York, and West of Oakland Centres.

ITP was meant to address problems where heavy long haul aircraft were climbing slowly, and could not reach a preferred level before leaving radar coverage [around 250Nm] - and so might be held down below another aircraft.

ITP was designed to allow two consenting aircraft to 'self separate' under quite strict conditions, allowing the following lower aircraft to climb through the level of the leading aircraft.

One of the requirements was that the following aircraft must positively identify the aircraft whose level it intended to climb through.

As you know, TCAS will show you level and position information on other aircraft in the vicinity - but not callsign - so procedures had to be developed whereby the following aircraft would ask the leading aircraft to turn its transponder off for a short period of time. If positive identification was made, and there was an appropriate distance between them [around 20NM] - AND if ATC agreed, the following aircraft could climd to a higher level.

We understand that only three US companies, including United Airlines, agreed to allow the procedure to be used in their company policies - only one airline [United] actually used the procedure more than a few times [we have not had time to check with colleagues here to confirm current application].

We understand that controllers in New York rejected the procedure as too labour intensive [and before you indict the controllers, you need to understand that the NY Oceanic Centre is one of the busiest en-route centres in the world, handling both North Atlantic entry/exit traffic - and the WATRS airspace]. Only Oakland contined to make the procedure available. We are not aware to TCAS ITP being applied anywhere else in the world.

TCAS ITP was not, and is not, intended to be used for regular separation functions, and as the recent NASA study [refer link below] shows, the minimum safe spacing between aircraft using the procedure is determined to be 15NM.

http://shemesh.larc.nasa.gov/people/vac/publications/safety_perf.pdf


Note that one of the hurdles you would need to overcome in using TCAS as a separation tool, rather than a conflict resolution tool, is the fact that TCAS is designed to give warnings, and resolution advisories, if the spacing between the aircraft comes below preset minima. So, trying to fly 100 feet from another aircraft would generate resolution advisories in both cockpits, leaving substantial room for misunderstanding [refer the report of the Uberlingen accident].

Of course, you could move from Resolution Advisory to Traffic Advisory mode - but we suspect you would find a lot of resistance from pilots [that is not to say it can't be done - we understand it is done at your Sydney airport in parallel runway operations, under quite controlled conditions].

FAA, and, we believe, Australia, are trialing ITP using ADS-B. This should provide better opportunities for self separation, given the positive identity that unique code ADS-B provides.

We commend to you [and other readers] the study referred to above. It is a fine example of a proper safety study.

As a point of interest, and not to put too much emphasis on it, we recommend you read the first paragraph under section 4.4 on page 23. We are sure this will generate some responses.

WELLCONCERNED
28th Jun 2007, 09:18
OK. If no-one else will bite, I will!

I read the section in the report.

How come the FAA mandates 'see and avoid', but our ATSB says its not effective and pilots shouldn't rely on it?

BTW - good response on TCAS!

putytat
28th Jun 2007, 09:44
It would appear that Mr Smith just cannot leave TCAS alone. An election looming, Govt struggling in the polls; Here comes TCAS as a risk mitigator!!

You Honor, I again rest my case.

Another first for Aus!! First is not always the winner though.

SEE and AVOID is flawed! Ask any pilot who has obscured vision from the cockpit, particularly in marginal VMC. ATSB is correct.

Chimbu chuckles
28th Jun 2007, 10:13
Wellconcerned I post it here for you to read again.

A crew operating an aircraft, regardless of whether an operation is conducted under instrument flight rules or visual flight rules, should perform the function of see and avoid to prevent a collision.

This requirement is mandated in the USA National Airspace System under Chapter 14 of the Code of Federal Regulations, Part 91.113. A flight crew of an aircraft which is in a collision trajectory can successfully implement the see and avoid functionality if it can visually acquire the traffic in sufficient time to perform an avoidance maneuver.

There are several factors that affect the probability of visually acquiring a traffic aircraft by the own ship (or the own ship being visually acquired by the traffic). The geometry of the encounter is one of such factors.
Figure 21 in Section 4.6 depict possible geometries for which visual acquisition is not possible.

A visual acquisition program, Visual 3D, was used to determine the probability that an aircraft, which is in a collision course with a traffic aircraft, will see the traffic in sufficient time to avoid a collision [8,9].
The time required to avoid a collision after visually acquiring a target has been estimated to be on the order of 12 seconds [10]. The visual acquisition program uses the following parameters to estimate the
probability of seeing the traffic:


'See and avoid' might be a perfectly reasonable procedure for aircraft in trail in VMC but 12 seconds is about 7 seconds to long when anywhere close to head on...that is why ATSB suggests most strongly that see and avoid is not the panacea DS likes to portray.

This procedure was suggested for aircraft operating in trail...that is following along a precisely defined FMC track in the same direction at very close to the same speed...a maximum typical speed delta of Mach .04.

TCAS gives an accurate distance to target but the bearing information is not near as accurate...but when it is near impossible for the following aircraft to actually catch the preceeding aircraft it's bearing becomes irrelevant...anyway you know the bearing because they are on the same airway as you.

WELLCONCERNED
28th Jun 2007, 10:50
Sorry CC.

I read it totally the wrong way. Now I get it.

See and avoid has a chance of working, but only IF YOU CAN SEE the object to be AVOIDED.

Thanks for the correction.

Scurvy.D.Dog
28th Jun 2007, 15:21
Exactly
.
.. which begs the question/s … how the hell do RPT IFR get 100% alerted see and avoid in non-surveillance airspace …. only two ways:-
.
1. everyone is known via radio and receives DTI (directed traffic information); or
2. everyone is known via radio and receives an ‘Air Traffic Control Service’ (ICAO D or higher)
.
Because:-
.
- IFR RPT may not have mode S ‘in’ or TCAS to alert themselves,; and
- 100% of the threat traffic may not be transponding!
.
Until TXPDRS (Mode C/S) are mandated, and made active at all times (as Brazil has shown us) whilst the aircraft is moving, and RPT have 'in', a third party and radio is unavoidable!
.
.
.
Now don’t glaze over :E .. stay with me on this (one last time) …. IMHO, if one takes the process one step further:-
.
.
.
In determining the level of alert/ATS service appropriate for a given parcel of airspace:-
.
It should be as simple as determining CTA or OCTA
.
CTA should be:-
.
- ICAO D below FL150 where surveillance exists (as there is no discernable difference in the cost of providing D or E)
- ICAO C FL150 up to FL280 where surveillance exists (closing speeds during late climb/enroute cruise means ‘Alerted See and Avoid’ becomes impractical for IFR/VFR/VFR conflict pairs FL150 and above), ATC separation standards should be a must for IFR AND VFR at those speeds! VFR to operate at same altitudes as IFR i.e. FL160 rather than FL155 or FL165 .. as this provides no ‘500ft’ separation complications with larger aircraft .. ease of level assignment planning and wake turbulence considerations!
- ICAO A above FL280
.
To Pilots, the service level (D, C or A) becomes transparent!
.
OCTA should be:-
.
- ICAO F (flight service DTI)
- IFR participate
- IFR receive DTI on IFR
- VFR monitor and (on request) flight following (where surveillance exist)
.
where surveillance exists (say remote terminal areas and surrounds) give the picture to the FSO for the provision of DTI to IFR on IFR and ‘known’ VFR
.
Two classes of ‘serviced’ airspace only!
.
CTA where traffic volume and complexity warrants such as terminal areas (inverted wedding cake)
OCTA where ATS frequencies exists, and CTA is not established
DRA (designated remote area) where no ATS frequencies exist, ICAO G … nil services (pilot to pilot only) similar to TIBA
.
One aspect of determining CTA or OCTA
.
- Just one of the many factors considered will of course be frequency loading caused by DTI and pilot to pilot arranged ‘segregation’, weighed against the less saturated frequency of an ‘Air Traffic Control Service’ which unloads the frequency through ATS Separation Standards (no DTI babble)
.
.
Pilots should only need to know:-
.
CTA
.
IFR
- comply with the clearance
- Below FL150 listen for DTI on VFR, then look for the VFR (alerted see and avoid with ATS segregation)
.
VFR Operations FL145 and below
- Comply with issued clearances or proceed as notified once acknowledged by ATC
- Broadcast change of intentions, and receive an acknowledgement from ATC before executing the change in track or level
- Listen for DTI on IFR and VFR
- Look out for IFR and VFR
.
VFR Operations FL150 up to FL280
-Comply with issued clearances
-Operate at whole (IFR) levels
.
OCTA
.
IFR
- Listen out and look for alerted IFR and VFR (receive positional DTI in surveillance areas, workload permitting)
.
VFR
- Listen out for IFR and look for IFR and VFR (receive positional DTI in surveillance areas, workload permitting)
.
Workload permitting must be stated given ATS (flight service) cannot limit traffic or unload the frequency with 'separation' OCTA
.
ATS should only need to know:-
.
CTA
.
- IFR are ‘separated’ from IFR and SVFR
- IFR may be ‘separated’ from VFR (no traffic information required); or
- IFR may be ‘segregated’ from VFR (IFR receive DTI on the VFR in this case, and VFR receive Wake Turbulence cautions where required)
- VFR are ‘segregated’ from other VFR; or provided DTI on other VFR (workload permitting)
.
ATC’s retain the discretion to apply:-
.
- a ‘separation standard’; or
- issue DTI where ‘segregation’ can be reasonably assured
.
i.e. a separation standard does not exist however through surveillance it can be determined that the proximity of two or more aircraft is not unsafe (defined as a larger margin than that which constitutes an Airprox)
ATC’s can use bigger margins (due workload) such as ‘standards’ to mitigate frequency and work loadings or smaller ‘segregation DTI’ as desired or required at any given time … it is transparent to pilots!
.
Where a ‘separation standard’ does not exist, IFR pilots receive a Directed Traffic Information service for sighting purposes.
.
Where a ‘separation standard’ does not exist, VFR pilots may receive a Directed Traffic Information service (workload permitting)
.
As with the FAA reg’s, the ability or otherwise of an ATC to provide a service to VFR in respect of other VFR is not questionable after the fact (otherwise you will never have their agreement to provide services to VFR/VFR on a when able basis)
.
OCTA
.
ATS Flight Service
.
- IFR receive DTI on IFR and ‘known’ VFR (workload permitting)
- ‘Known’ VFR receive DTI on IFR and ‘known’ VFR (workload permitting)
.
General notes OCTA
.
’known’ VFR are those ‘seen’ in surveillance areas
.
VFR should only broadcast within 10minutes flight time of a CTAF (F)
.
CTAF (F) is serviced ICAO F and may include surveillance DTI
.
.
.
Add to the risk equation the simplicity in mapping and regulations (both ATS and Aircrew), it should create a risk reduction right there. Much of this would put a serious dent in some of the inherent risks of the current system, and when compared against ICAO E and G … well? :hmm:
.
How it would go against C or B below FL150 is the bit I would be most interested in learning about! (other ATC’s and metal drivers around the major capitals please comment)
.
Cost effective and safe with reasonable access is the name of the game is it not?
.
… FARKK I hear you all say :p ... it really is simple in practice when compared to multiple classes of CTA and OCTA (as we have now) and having to understand what you will/might get as far as anti-collision services!! .. that’s what is doin’ everyone’s head in!!
.
Why do I think the the above is simple (for you lot) and works safely and effectively (for us and you lot)? …. I use Surveillance D everyday, and (although not current) I am a bug smasher driver too! :}
.
It is about as close too US NAS practices, and a simple I can come up with that fits CTA/OCTA contemporary expectations of service safety and efficiency!
.
... as for where (geographically) CTA and OCTA should exist .... over to ewe's :E

WELLCONCERNED
29th Jun 2007, 09:13
Yes, Mr Dog, but...

...aren't you going in the same circles as everyone else when you suggest where the various airspace divisions should go? Dick says put Class X here and Class Y there. You say put Class X somewhere else and Class Y somewhere else, and add Class Z. Others suggest putting the boundaries in other places.

Wasn't VOR suggesting that before you even think about what airspace class to use, and where to put it, you should do a proper risk analysis? And wasn't that the point of this thread? To get us to agree to the risk management process before we start assigning labels and locations.

Seems like we're going in the same circles we've been round for the last 15-20 years.

Scurvy.D.Dog
29th Jun 2007, 12:13
... no ... quite the opposite!
.
... determine where CTA is required (as per VOR explained process)
.
... then apply a common set of CTA rules as above
.
... where CTA is not required .. OCTA as above
.
All I am suggesting is simplifing the variables in the application/s and recognising the safety/risk benefit to both CTA and OCTA of simple common rules!
.
.. in simple terms, ask yourselves:-
.
- do I really understand what I can expect in classes G, E, D, C, B and A airspaces?
- do I clearly know where those airspaces are and end or change?
- do I really understand what I can expect (and how do I know) within surveillance coverage in any given class of airspace?
- do I really know what to look for and when in any given class of airspace
- do I think frequency management at the moment give me the best chance of knowing where actual threat traffic might be?
.
.. now if you know and fully understand that maze of variables in familiar and not so familiar airspace areas, then I would suggest you are in the minority!
.
.. surely by comparison, pilots knowing only 2 sets of rules and expectations i.e. CTA and OCTA removes a deal of complexity (mapping and rules) and therefore reducing opportunities for confusion?!
.
The suggested simplification/s above (in a vertical sense SFC- FL150- FL280) are not to be confused with allocation geopraphically as determined by the common risk management processes :ok:
.
.. at some point, reducing complexity must be considered in the overall picture ..as I have tried to explain (perhaps not very well) :ooh::{

werbil
1st Jul 2007, 02:41
Scurvy.D.Dog - Your suggestions sound awfully like the procedures that were replaced back in the early 1990's - except for DRA's.:ugh:From a pilot's perspective I understand the difference between the different classes of alphabet airspace - if you don't understand them you shouldn't be flying in that class of airspace.:=

The CTAF(R) system works extremely well in the YBHM area (especially since the establishment of a discrete frequency last year) where there may be a couple of dozen fixed wing (including seaplanes) and helicopters flying around below 2000 AMSL (mostly VFR) to numerous landing areas. :ok: It is often easier to develop a complete situational awareness of other traffic when the airspace is "G" than when the tower is open and the airspace is class "D". Mind you we do reply when in conflict in "G" to facilitate separation.

I personally believe that "E" is a great airspace classification - I just think that it is poorly implemented in Australia. Before I get flamed - I believe it would work well on a two frequency system - a frequency for IFR to talk to ATC and a working frequency that all aircraft broadcast their intentions on, however this would require IFR aircraft to have two VHF comms. This "multicom frequency" for want of a better word would need to be separated in level bands so that the high density of low altitude VFR aircraft do not congest enroute aircraft flying at higher levels (say one frequency B050, another frequency A050-A100 and a third frequency above FL100). And before you say a pilot can't do it - way back in the 80's outside VHF FIS coverage IFR flights had to report and receive traffic information on HF and broadcast on VHF. OK the workload will be higher in VMC, but when you're in IMC you won't need to worry about listening for VFR aircraft as there shouldn't be any there anyway. And yes - this would need scientific analysis to determine if and where it is appropriate.

I have no argument with change - but as VOR suggests only implement change after a process to determine that the benefits outweigh the risks and negatives has been undertaken and not just to implement change for change's sake or that's because how some other country does it.

Most importantly ALL pilots MUST understand and follow the rules and procedures for whatever class of airspace they are in. BFR's are there to ensure a pilot is procifient, and as far as I am concerned proficiency includes radio and airspace procedures as well as the basic stick and rudder skills.

W.

BTW One thing that doesn't make sense to me - when the YBHM tower is closed I only have to fly clear of cloud. When YBHM tower is open I am required to be 1500m horizontally or 1000ft vertically clear of cloud unless I obtain a special VFR clearance when ATC has to close the zone to ALL other aircraft. :confused: Somebody please explain the logic in that (and yes high capacity RPT DOES operate when the tower is closed).

Scurvy.D.Dog
1st Jul 2007, 12:25
Werbil some interesting issues raised .. certainly worthy of a considered response.
I have used separate quotes to respond to. It is not intended to be rude, rather ensure the context of my reply is properly understood! - Your suggestions sound awfully like the procedures that were replaced back in the early 1990's - except for DRA's. .. don’t ya’ remember designated remote areas .. you mustn’t have been around that long .. yes it is similar OCTA, with the benefit of utilising today’s technology to enhance it. In any event, compare it to Aus G at the moment (if you can that is)!
.
.. the difference is reducing the number of frequencies for IFR and VFR giving them a better ability to receive the fullest traffic picture possible … no missing calls on the other frequency close into CTAF’s etc! … even if the OCTA stuff was identical to the F of the past (which it is not) … are you arguing that it is less effective than the current?From a pilot's perspective I understand the difference between the different classes of alphabet airspace … with respect, I think most folks understand the ‘differences’ in classes of airspace, that is not the point. The point is the practical application (what it does NOT deliver as far as SA to both ATS and Aircrew), complexity and therefore compliance (knowing the what to expect and being actively aware of what that means as far as their SA)!- if you don't understand them you shouldn't be flying in that class of airspace. … no argument there, again it is not the point. The point is the variable complexity provides additional opportunities for error or un-alerted Airprox!The CTAF(R) system works extremely well in the YBHM area (especially since the establishment of a discrete frequency last year) where there may be a couple of dozen fixed wing (including seaplanes) and helicopters flying around below 2000 AMSL (mostly VFR) to numerous landing areas. great to hear! … that area of local activity on a common CTAF freq is basically an AFIZ (for the dinosaurs) .. whilst you are belting around below 2000ft broadcasting when you feel it appropriate … how much of that traffic does the IFR RPT Jet/Turbo-prop slowing up from 250KTS on the drop really know? If the F (FSO) function was being provided on the same frequency, the IFR would not have to make separate broadcasts on a different freq, you and the VFR colleagues would hear those transmissions, and the IFR and FSO would hear yours …. ALL OF THEM! …. Granted, the geographical areas serviced by any one given OCTA frequency would have to be assessed carefully for loadings! …. BUT … it delivers the nearest you can get to 100% alerted traffic for IFR and VFR … and most particularly IFR RPT! .. that is what the discussion is about is it not?It is often easier to develop a complete situational awareness of other traffic when the airspace is "G" than when the tower is open and the airspace is class "D". … Well, isn’t that what CTA is for? a third party who is trained and rated to provide a standard of services that will only alert you when there is a reason to i.e. ‘relevant’ threat traffic when it is necessary .. as I said earlier, if a separation ‘standard’ exists between you and other IFR or VFR, ATC won’t load the frequency with traffic information on aircraft that are no threat to you.
.
OCTA (CTAF) means you MUST hear, and understand traffic calls and know how that flight will interact with yours ….. not to mention … how many you do not hear or do not transmit that may be lurking or closing fast … most of us have had that surprise at some point!
.
TWR D … OCTA CTAF (R) ….. ??? this is ‘part’ of the assessment process to determine if a parcel of airspace is utilised to a level that becomes unmanageable from a frequency use and loading point of view! In the context of CTA and OCTA the difference in this regard is clear:-
.
- CTA = third party traffic management
- OCTA = pilot arranged ‘segregation’ (with or without third party DTI)
.
.. how much is too much do ya’s reckon? … how much frequency activity before the average GA jockey, let alone RPT Jet/turbo jockeys are gunna absorb before SA is lost or impaired?? … mores the point, at what level of access is it reasonable to expect pilots of motorised hang-gliders, to Navajo’s to B737 or A320’s to rely on the others ability to be a competent self trained ‘self segregator’? Mind you we do reply when in conflict in "G" to facilitate separation. ..glad to hear that you speak-up!
.
.. on the subject … it might be semantics, but in the context of discussion of airspace, self arranged ‘anything’ is ‘segregation’ not ‘separation’!
.
‘Separation’ infers a separation standard as described by ICAO (parent docs such as 4444), the MoS (CASR Manual of Standards), and the MATS (Manual of Air Traffic Services), as applied by ATC (not FS or Aircrew). Apart from 1000ft Vertical (which is widely known), other self arranged lateral, longitudinal (distance or time based) segregations being referred to as ‘separation’ is potentially misleading. I only raise this as IMHO it is creating erroneous understanding of expectations OCTA.I personally believe that "E" is a great airspace classification .. do you operate VFR or IFR? .. do you have TCAS .. do you pay insurance and fly paying passengers? .. not being smart, but think of others operating in the airspace! - I just think that it is poorly implemented in Australia. … no argument there! Before I get flamed - I believe it would work well on a two frequency system - a frequency for IFR to talk to ATC and a working frequency that all aircraft broadcast their intentions on, however this would require IFR aircraft to have two VHF comms. … this is what you in effect have now … IFR cannot listen on two (concurrently) reasonably busy frequencies effectively when monitoring both means often the two frequencies tandem transmissions are over the top of each other in the headset! … again, I stand to be corrected on this, but one of the most labour intensive items on an IFR flight deck seems to be selecting and de-selecting frequencies and hanging off the volume control! … I cannot see how that is better from an SA point of view when compared to a single frequency in a given geographical area OCTA (that may include 2 or 3 aerodromes in a vicinity Flinders Island or YSDU/NRM examples I am familiar with). This "multicom frequency" for want of a better word would need to be separated in level bands so that the high density of low altitude VFR aircraft do not congest enroute aircraft flying at higher levels (say one frequency B050, another frequency A050-A100 and a third frequency above FL100). OK, so:-
.
- VFR operating wholly B050 will need to know and juggles between the CTAF freq’s appropriate for the flight, and the multicom B050
= 2 frequencies minimum (3 if they are interested in high speed IFR with ATS)
.
- IFR operating wholly B050 (unlikely in some areas given LSALT’s) will need to juggle ATS area, CTAF/s appropriate for the flight, and the multicom
= 3 frequencies minimum
.
- IFR operating SFC to B100
= 4 Frequencies minimum
.
- IFR (pressurised) operating to higher levels
= 5 Frequencies minimum (if the base of CTA is FL125 or higher)
.
I am sure the SAAB/DHC8/BRAS/Embraer/Boeing and Airbus drivers climbing and descending through that 5 or 6 times a day will be very happy with that, particularly if (as I assume) they are expected to broadcast on each frequency (some more than once i.e. ATS) from the SFC to base of CTA or CTA to SFC for arrivals …. Reasonable from as SA point of view? … are VFR expected to broadcast on these multicom frequencies??
And before you say a pilot can't do it - way back in the 80's outside VHF FIS coverage IFR flights had to report and receive traffic information on HF and broadcast on VHF. .. never said a pilot can’t do it! The example you cite is 2 frequencies, and only because of the absence of an ATS VHF in that area otherwise in the same example 1 frequency! OK the workload will be higher in VMC, but when you're in IMC you won't need to worry about listening for VFR aircraft as there shouldn't be any there anyway. … errm how is that different in the scenario I put?? And yes - this would need scientific analysis to determine if and where it is appropriate. AMENI have no argument with change - but as VOR suggests only implement change after a process to determine that the benefits outweigh the risks and negatives has been undertaken and not just to implement change for change's sake or that's because how some other country does it. again AMEN .. I am not suggesting anything other … there might be another contributor who sees it the way you describe it (based on past performances) … not this little black duck though .. scurrilous to suggest it really! Most importantly ALL pilots MUST understand and follow the rules and procedures for whatever class of airspace they are in. .. we are in lock step here fella BFR's are there to ensure a pilot is procifient, and as far as I am concerned proficiency includes radio and airspace procedures as well as the basic stick and rudder skills. … come and spend some time plugged in listening to the results of the last ten+ years of GA and in particular VFR disengagement with ATS … BFR’s and other standards and mechanisms for proficiency in radio telephony are not working terribly well, particularly where that pilot instruction is mostly outside ATS areas! BTW One thing that doesn't make sense to me - when the YBHM tower is closed I only have to fly clear of cloud. When YBHM tower is open I am required to be 1500m horizontally or 1000ft vertically clear of cloud .. because when you are receiving an ATS service, the rules supporting that are designed to give you, and other VFR and IFR a fighting chance of seing you, particularly in an IFR/VFR conflict situation, where ATC are contemplating relaxing vertical separation by assigning visual separation to a pilot! .. just to name one! unless I obtain a special VFR clearance when ATC has to close the zone to ALL other aircraft. ATC do not close the zone for SVFR ..sport!
.
.. SVFR can be due cloud OR visibility!
.
.. Due Cloud
… if you are operating VFR .. say …not above A025 and the cloud base is A035 on QNH (although we all know the cloud is referenced AGL …) there’s your 1000ft rule right there!
.. ATC can descend an IFR to 1000ft above you cleared altitude i.e. A035 (not below the steps etc) and have a fighting chance of:- 1. getting the IFR in sight and applying visual separation from the tower 2. getting the IFR into visual conditions for further descent 3. asking the VFR to sight and then maintain visual separation from the IFR 4. have the IFR sight and then maintain visual separation from the VFR
If you were permitted to operate closer than 1000ft vertically from cloud in CTA, …. who gets fecked over? … IFR, ATC and VFR (you) because you will not get a clearance that will leave an arriving IFR in cloud over the top … sorry n’ all!
.
Due visibility
.. if you are operating VFR ..say ..not above A010 and there is no discernable or uniform cloud base, the lowest an IFR can be cleared is A020 (not below the DME steps etc) .. why?
.. because 1. ATC may not/cannot see you (to apply visual separation) 2. the IFR may not be able to see you (from A020) and therefore cannot be assured of continuing to see you (visibility remember) on descent (pilot assigned visual separation) 3. If the IFR requires an instrument approach (due the visibility) then in the absence of visual separation, a procedural standard is required (remember neither you or the IFR can see each other) 4. once an IFR aircraft is cleared for an instrument approach (whether VOR, NDB, GNSS, ILS), the navigation tolerances are considered all the way to the threshold and the missed approach path . Unless you have visual reference to a geographical fix that is clear of the procedural tolerances of the IFR approach … you loose! …as quite frankly VFR in less than VMC are treated as IFR for that reason. Believe me, in SVFR (due visibility) conditions the average VFR pilot is often not sure of their actual position or misidentify where they are … TSAD has shown us that!
.
Now if you are SVFR and you lodge a plan that tells us you can use a VOR, or DME .. that’s a different story!Somebody please explain the logic in that .. hope that helped! (and yes high capacity RPT DOES operate when the tower is closed). .. with you lurkin around below the cloudbase or in marginal visibility ol’ cock … hope your TXPDR is on and accurate and the big guys are nice and slow early! ….IMHO, It should be the same (1000ft and 1.5klm) OCTA .. in fact it is more important for the reasons explained above .... perhaps another example of difference for no apparent reason .... :E
.
Nite all

werbil
5th Jul 2007, 18:36
Scurvy.D.Dog,

Some very interesting responses, and definitely worthy of a reply to explain further to allow you to understand the why of my suggestions. Fundamentally, I am sure we are going to agree to disagree on a number of issues - I am assuming we operate in two very different sectors of aviation. I fly float planes (including turboprops) in single pilot VFR SE charter (yes I carry pax, transponder and carry carriers liability insurance). :ok: I am assuming that you fly either RPT or corporate pure jet because of your responses (or possibly ATC - but if so you should have advised this in your response).

When full reporting for VFR ceased in the early 90's it was a culture change - we had to learn to listen for calls from other aircraft. And then when NAS was introduced VFR aircraft were expected to remain silent on center frequencies in "E" & "G" unless in conflict with an IFR aircraft. :eek: The fundamental problem I have with this system (in both "E" & "G") is that it requires the VFR pilot (who is probably less experienced) to not only have the correct frequency selected, but also have the volume set appropriately and have enough SA to understand if the aircraft is in conflict. If this fails, with a 250 knot closing speed (theoretically could be 500 knots B100) and 5000m clearance from cloud both aircraft could be "sharing" the same airspace in under 12 seconds from the first possible opportunity for visual acquisition. :eek: And remember transponders are only required to be fitted in "A" and "C" airspace, above 10000ft (except gliders) and in "E" airspace if the aircraft has an engine driven electrical system, and radios are not required in G B050 (except CTAF R's) or for gliders. No radio, no transponder at 1000' - seriously is this a problem over a station strip in the middle of the outback - no, would this be a problem over YBBN - :mad: oath it would be.

Yes a third party directed traffic service does remove some of the risks, but it still requires accurate position information from ALL pilots to work. :ugh: I don't believe that anyone involved in aviation would for a second seriously suggest that all of Australia should be covered by radar "B" or "C" airspace - this would be simple for pilots - one procedure, and give the lowest risk for breakdown in separation - but imagine the cost.

My recollection is that alphabet airspace was introduced to harmonize Australian procedures with other countries (make it simpler for overseas pilots). Alphabet airspaces does not include a system the matched the old OCTA system -(directed traffic to and about all aircraft including VFR).

OK, so now I am getting to the crunch. Traffic, and location being equal, the earlier the letter the lower the risk of collision in the airspace should be. I think that the old OCTA system is closest to either "D" airspace (except IFR receives traffic information rather than a separation service) or "F" airspace (except all aircraft receive a traffic information service). So the risk of collision between a VFR and any other aircraft is now probably greater in both "E" and "G" airspace, the risk of collision between two IFR aircraft is now probably higher in "G" airspace and lower in "E" airspace. Two IFR aircraft means that both aircraft could be in cloud removing any possibility of a collision being avoided by "see and avoid". In other words I am NOT convinced that the old OCTA system was safer than class E airspace for IFR aircraft.

Secondly, flexibility in airspace procedures is essential because the usage of airspace is different. Where there is a large number of RPT, airspace procedures should be optimized for IFR - "C" or "B" are logical and obvious. Where there is no reasonable possibility of IFR (ie no approach procedures) airspace procedures should be optimized for VFR. The difficult ones are places which has only a few jet or IFR movements a day (like YBPN which has little other traffic or YBHM which has a large amount of VFR traffic).

The reason I suggested a multicom system is to allow VFR aircraft to broadcast their position and intention to other aircraft on a routine basis. Actually I would prefer the old system where VFR aircraft were encouraged to routinely broadcast on the center frequency, but now days this is very much discouraged (according to the AIP) except when responding to a conflicting IFR aircraft. Yes level banding has its limitations, but it will reduce the radio clutter from distant, high altitude traffic, and every aircraft has an altimeter that tells the pilot when to change frequencies. The intention of my suggestion is that CTAF calls would be made on the B050 multicom frequency (except where a discrete CTAF frequency is established) to reduce the number of frequencies that have to be handled. Remember the days of frequency after frequency being retransmitted by ATC - if you weren't getting directed traffic the bloke at the other end of the state could be loader and clearer than the other guy only 20nm away.

As for the RPT drivers - establish class C or D wherever you like - just don't ask me (or my pax) to pay for it in areas where it cannot be justified. I will use it if it is there to access the airspace, but I am happy in G. I would be much happier when in either E or G to be able make regular broadcasts that all other pilots can hear when en route though.


don’t ya’ remember designated remote areas .. you mustn’t have been around that long .. yes it is similar OCTA, with the benefit of utilizing today’s technology to enhance it. In any event, compare it to Aus G at the moment (if you can that is)!


DRA's are still in CAO 20.11 - they're just less relevant as all aircraft have to carry an ELT now days anyway. I don't remember the radio procedures being any different - my hazy memory is that you had to broadcast on the area VHF frequency and if operating full reporting report on HF when outside VHF range or lodge a SARTIME and carry an ELT if you didn't have HF - does this sound right?


that area of local activity on a common CTAF freq is basically an AFIZ (for the dinosaurs) .. whilst you are belting around below 2000ft broadcasting when you feel it appropriate … how much of that traffic does the IFR RPT Jet/Turbo-prop slowing up from 250KTS on the drop really know? If the F (FSO) function was being provided on the same frequency, the IFR would not have to make separate broadcasts on a different freq, you and the VFR colleagues would hear those transmissions, and the IFR and FSO would hear yours …. ALL OF THEM! …. Granted, the geographical areas serviced by any one given OCTA frequency would have to be assessed carefully for loadings! …. BUT … it delivers the nearest you can get to 100% alerted traffic for IFR and VFR … and most particularly IFR RPT! .. that is what the discussion is about is it not?

… Well, isn’t that what CTA is for? a third party who is trained and rated to provide a standard of services that will only alert you when there is a reason to i.e. ‘relevant’ threat traffic when it is necessary .. as I said earlier, if a separation ‘standard’ exists between you and other IFR or VFR, ATC won’t load the frequency with traffic information on aircraft that are no threat to you.


It would require at least one FSO to handle the traffic in the Whitsunday CTAF(R) alone - with the amount of traffic at Shute Harbour, Whitehaven, the Molle Group / Long Island Sound and Hardy Reef the discrete frequency would be jammed at times, especially when the FSO is trying to pass the traffic to five or so aircraft that happen to be at just one of these locations. Does the IFR RPT need to know about any of this traffic - absolutely not unless the pilot is making up his own approach or departure procedures. If they're in the murk in these areas they've either flown through or just missed cumuli granatis to get from the approach to these locations.

Just last week, the tower did not pass traffic to me that was on a converging course at the same altitude to a common location just outside CTA and a similar estimate. Was it a problem - no - I heard his call to ATC and the other pilot heard mine. ATC did pass a following aircraft on a diverging course to me though.

So being able to hear and understand traffic calls and how they relate to you (SA) is an essential skill, especially in areas where there is a high density of VFR traffic. In VMC the mark one eyeball is supposed to be the primary piece of collision avoidance equipment - I prefer not to rely on it as the only method.


come and spend some time plugged in listening to the results of the last ten+ years of GA and in particular VFR disengagement with ATS … BFR’s and other standards and mechanisms for proficiency in radio telephony are not working terribly well, particularly where that pilot instruction is mostly outside ATS areas!


VFR pilots are being told to shut up and look by the current documentation, unless hearing conflict from IFR or participating in a RIS. Every change to VFR procedures seems to reduce interaction with ATS in E & G. Is it any wonder pilots are becoming more reluctant to talk on the radio? Is it good? - definitely not. Is it understandable? - yes.

ATC do not close the zone for SVFR ..sport!


At YBHM you will not get a special VFR clearance if there is any other IFR or SVFR aircraft in the zone full stop. It's as certain as death or taxes.

If you were permitted to operate closer than 1000ft vertically from cloud in CTA, …. who gets fecked over? … IFR, ATC and VFR (you) because you will not get a clearance that will leave an arriving IFR in cloud over the top … sorry n’ all!


If I can't operate closer than 1000ft vertically from cloud in CTA I get :mad: over anyway because I need a 1600' cloud base to operate. I have no problems with being procedurally separated and having to wait (even outside the zone) - fifteen minutes holding doesn't cost as much as not being able to work. :ugh:


Now if you are SVFR and you lodge a plan that tells us you can use a VOR, or DME .. that’s a different story!

Firstly, VFR aircraft can ONLY navigate by visual reference to ground or water when below 2'000AGL (refer AIP ENR 1.1 19.2). :ugh:Secondly, the islands block the NAVAID signals through most of YBHM zone even at 1,000AGL.:ugh:


.. with you lurkin around below the cloudbase or in marginal visibility ol’ cock … hope your TXPDR is on and accurate and the big guys are nice and slow early!


Radio is required to be used when operating at a reduced distance from cloud in G even without CTAF(R) procedures (The only time fixed wing VFR flight is permitted in less than 5000m visibility is in controlled airspace with a special VFR clearance). You can be damn sure I will be communicating anywhere when I'm anywhere near the instrument approach paths and associated areas if I am close to cloud in "G". If an IFR is shooting an approach I will keep out of their way - the last thing I want is to be hit by another aircraft (even though CAR 162 (5) requires the higher aircraft to give way to the lower aircraft).

ACAS as far as I am concerned is a measure of last resort - if an aircraft has to respond to a RA to avoid a collision - there has been a major failure in the system. Interestingly transponders are not required to be fitted in either G or D (in the aircraft I fly they are fitted, calibrated as required by AD/RAD whatever and are switched on in any wx).

OK, lets just get scientific and objective about airspace and keep the emotion out of it. CASA (as the regulator) should be required to do proper scientifically based risk assessments before allowing changes to be made to airspace. It's a looong post I know, but its been a good exercise to flick through the docs to verify the rules.

W

BTW I believe one piece of technology that has increased the risk of collision between VFR aircraft is the humble GPS. With the accurate tracking provided, VFR aircraft are concentrated closer to the direct track than they used to be in the days when DR was king.

werbil
7th Jul 2007, 11:00
Scurvy.D.Dog

I just checked your profile and see you are ATC. Which is fine, but the way you replied I assumed that you had personal experience flying in "G". :confused: Are you or have you been a pilot as well? If not, I hope your comments about what you think pilots can manage in "G" are based on something substantial. :suspect:

Given the classes you control I have to assume you work where the airspace is generally quite busy with IFR traffic. It just isn't like that all over Australia. If you are up this way PM me and I may be able to give you a ride and a headset so you can hear what actually happens. :ok:

FYI sometimes seaplane pilots can manage five frequencies on a five minute sector - marina (clearance to water taxi through), CTAF, Tower, Marine (coordinating approach to boat) and company (SAR's, operational changes). And remember this is single pilot with four different traffic situations to assess ("D", CTAF(R), departure water and arrival water) - and water wakes can be just as dangerous as wing tip votices. Two pilots should be able to manage the same number of frequencies even in IFR.

And a final pilots 'understanding the airspace classes' comment - maybe pilots are confused between D & C because in some "D" airspaces the usual practice is for ATC to separate (or segregate) VFR from IFR as is required in "C". At YBHM I have only heard pilots made responsible for ensuring "segregation" between VFR & IFR aircraft after both aircraft have sighted each other - yet VFR to VFR is just given traffic. Have a look at ATSB comments in Jan/Feb Flight Safety Australia page 58 and May/June Flight Safety Australia page 59 - ATC contributed as well as the pilots. :uhoh:

W

Scurvy.D.Dog
8th Jul 2007, 12:30
Werbil I have again used individual quotes, this time mainly to be as patronising as you in returnFundamentally, I am sure we are going to agree to disagree on a number of issues - I am assuming we operate in two very different sectors of aviation. I fly float planes (including turboprops) in single pilot VFR SE charter (yes I carry pax, transponder and carry carriers liability insurance). I am assuming that you fly either RPT or corporate pure jet because of your responses … agree or disagree is irrelevant .the efficacy of the argument is the important bit. The fact that you assumed I was RPT or Corp is telling … I guess you perceive/assert that I ‘only’ see the issues from fast RPT IFR perspective? … not even close .. more on that later! (or possibly ATC - but if so you should have advised this in your response). .. it is in my profile, not to mention it being common knowledge in this place for a number of years … but then, again it is irrelevant …. as irrelevant as where and what you fly .. although now you mention it, your responses point to that in any case!
.
… content not motherhood statements eh?! .. on that note:-When full reporting for VFR ceased in the early 90's it was a culture change - we had to learn to listen for calls from other aircraft. …. Yep, no mean feat given half the traffic went silent en-route OCTA … less positional SA on VFR’s, IFR’s OCTA mixed up (freq wise) with ATC services being provided to aircraft in CTA above/adjacent .. yep a real boon for pilot SA OCTA AND in CTA (frequency loading) ..not withstanding … big sky theory (un-alerted see-and-avoid) was deemed appropriate for IFR/VFR/VFR OCTA in sparsely traffic’d areas … ships in the night on a big ocean! And then when NAS was introduced VFR aircraft were expected to remain silent on center frequencies in "E" & "G" unless in conflict with an IFR aircraft. .. daft idea ya think then? The fundamental problem I have with this system (in both "E" & "G") is that it requires the VFR pilot (who is probably less experienced) to not only have the correct frequency selected, but also have the volume set appropriately and have enough SA to understand if the aircraft is in conflict.… what percentage of VFR know the IFR stuff (including radials, holding patterns, sector entries, and approaches) in any given location? .. ppppplease :rolleyes:…VFR remaining clear of IFR routes when transiting over/around/across terminal and enroute surrounds is a practical impossibility! :ugh: Add to that … VFR being blind to ATC and IFR in E … OK … so run by me again why I personally believe that "E" is a great airspace classification - I just think that it is poorly implemented in Australia. …. WTF?? :suspect: … you also said If this fails, with a 250 knot closing speed (theoretically could be 500 knots B100) and 5000m clearance from cloud both aircraft could be "sharing" the same airspace in under 12 seconds from the first possible opportunity for visual acquisition. … errm what does class E deliver you then?? …. Mate pick a position and stick with it … a bob each way don’t cut it! .. never seen anyone try to argue both sides of a debate at once …… errrmmm then again … maybe one other! And remember transponders are only required to be fitted in "A" and "C" airspace, above 10000ft (except gliders) and in "E" airspace if the aircraft has an engine driven electrical system, and radios are not required in G B050 (except CTAF R's) or for gliders. No radio, no transponder at 1000' - seriously is this a problem over a station strip in the middle of the outback - no, would this be a problem over YBBN - oath it would be. .. lotsa words stating the bleeding obvious, I don’t think any of us need a lecture on basics …..citing two irrelevant extremes (which are outside the current discussion) is a waste of bandwidth and a tad insulting to the many here who already know shit from clay!! .. lets focus on the areas of relevant discussion shall we? i.e.
.
- Class D (no TXPDRS required BTW) … you seem to know .. you tell me why!
- Outback station strips ….. not what the discussion is about is it! .. it is about CTA rules and OCTA rules particularly where RPT operate i.e. CTAF(R) and low level regional CTA
.
Back to the issues Yes a third party directed traffic service does remove some of the risks, but it still requires accurate position information from ALL pilots to work. .. errrm how is that achieved in E?
… smarter minds that you and I will determine the answer/s based on factual data and then consider the cost and safety benefit compared to the status quo! …. The options and outcomes from the variables is what we are musing is it not? I don't believe that anyone involved in aviation would for a second seriously suggest that all of Australia should be covered by radar "B" or "C" airspace .. again, making a statement against an absurd suggestion such as blanket radar “B” and “C” (that no one else has suggested should occur) … does not point to a comprehension of the specifics …. Or, might be seen as an attempt to misrepresent points of argument … either way, that sort of ‘mudding’ will not slip through to the keeper in this place! … for the record though:-
.
… I have never, nor would I ever suggest that radar B and C airspace should be installed all over Australia. If you had bothered to read the many pages of debates in this place on these issues, you would know (perhaps you do) that I argue that where enroute SSR radar can be replaced with WAMLat/ADS-B it should! Why?
.
..it is solid state, cheap as chips (comparatively), with little ongoing maintenance … AND … (subject to an identified need - in CTA or OCTA), could be funded by the savings made from not having to service/replace existing or future radar heads.
.
Just so we are clear ..Only installed to replace existing radar and where future surveillance (at WAMLat prices) is desired/required, rolled out to improve CTA and OCTA services!- this would be simple for pilots - one procedure, and give the lowest risk for breakdown in separation - but imagine the cost. yes imagine the cost …. good thing no one is suggesting it!My recollection is that alphabet airspace was introduced to harmonize Australian procedures with other countries (make it simpler for overseas pilots). Alphabet airspaces does not include a system the matched the old OCTA system -(directed traffic to and about all aircraft including VFR). .. nor is there an alphabet ICAO G classification that includes IFR DTI .. so what! .. member states to the Chicago convention may operate their systems (lodge differences) as they see fit! .. in any event, how ridiculous (in hindsight) to have attempted harmonisation (which it never was, as has been demonstrated over and over) when ‘those (other) countries’ such as Europe are likely to harmonise on a system similar to the one we use to have i.e. CTA and OCTA ….. how much money, pilot confusion and consumer confidence has ABC airspace cost us???? ….. just so OS pilots could use it? …… bollocks … few OS pilots fly in this country outside the primary capitals … and, for the handful of tourist pilots … the old system was completely compatible …. No .. it was changed for other reasons … harmonisation was just the excuse!OK, so now I am getting to the crunch. Traffic, and location being equal, the earlier the letter the lower the risk of collision in the airspace should be. I think that the old OCTA system is closest to either "D" airspace (except IFR receives traffic information rather than a separation service) or "F" airspace (except all aircraft receive a traffic information service). nup OCTA F was nothing like D CTA as both VFR and IFR are known in CTA D, IFR/IFR are ‘separated’, and receive as a minimum IFR/VFR/VFR DTI (alerted see-and-avoid) … not in F (IFR/IFR DTI only) … the old OCTA system of VFR and IFR DTI does not conform to any ICAO alphabet classification … does it mean that alerted VFR was not a good idea NO … over the top … maybe …. onerous (radio) … maybe …. ADS-B will do the same once fleetwide is achieved … don’t get me started on that .. It’s already been done here … do us all a favour and look it up So the risk of collision between a VFR and any other aircraft is now probably greater in both "E" and "G" airspace .. how silly would that be to ‘refine’ a system and make it potentially less safe? …. by Jove …. as far as AUS E and G go, IMHO you might just be on to something!
If your assumption is correct ... how were the changes (AMATS, Airspace 2000 and all iterations since) justified against risk management criteria if risk may have increased ... one assumes an offset cost benefit? …. I would love to see a fair dinkum comparison of the number of operator positions back then (CTA ATC and OCTA FS) compared to today (after compensating for CTA traffic growth over that time against the ‘comparative’ cost/purchasing power)!
How can it be eh? .. hmmm … I can think of a common denominator … can you? the risk of collision between two IFR aircraft is now probably higher in "G" airspace and lower in "E" airspace. …. that assumes there is/was a data set that supported the notion that DTI to IFR (and self arranged segregation) in OCTA F produced airprox/collision incidents sufficient to trigger a change in classification that involves ATC intervention (CTA E)?! … if you can find and provide that data .. we would be much enlightened! .. I bet you can’t!
Not withstanding … even if IFR pilots OCTA had experienced ‘un-alerted’ or even ‘alerted’ airprox’s in OCTA F sufficient to warrant a change in service level, areas that were made G would/should have been made E, D, or higher .. i.e. an increase in service level not a reduction to G!
…. No the reason was to remove the supposed cost of Flight Service Officers (DTI OCTA) … Dick Smith (the then Chairman of the CAA) is most proud of that change …. A change that meant ATC’s took on the FS function OCTA on top of the CTA ATC function … peachy
… what do you reckon that has produced for IFR and VFR OCTA?, not to mention RPT in the higher levels that cannot get a word in edgeways (often) due the OCTA FS/IFR DTI function below! …. and the poor bloody ATC line controllers … ever since, re-sectorised, restructured, expected to do more and more with less and less ….. don’t get me started on that issue! Two IFR aircraft means that both aircraft could be in cloud removing any possibility of a collision being avoided by "see and avoid". In other words I am NOT convinced that the old OCTA system was safer than class E airspace for IFR aircraft. …crap …. 2 IFR pilots in conflict routinely segregated using levels and distances … 100% perfect … no …. Better than E … I reckon … particularly when you add in delay costs of procedural separation in E at low level and not knowing about VFR!
.. as for the reasons ATC E (outside surveillance areas down to MSA/LSALT’s) delays IFR .. it has been explained here so many times …. do some reading!
Secondly, flexibility in airspace procedures is essential because the usage of airspace is different. Where there is a large number of RPT, airspace procedures should be optimized for IFR - "C" or "B" are logical and obvious. Where there is no reasonable possibility of IFR (ie no approach procedures) airspace procedures should be optimized for VFR. The difficult ones are places which has only a few jet or IFR movements a day (like YBPN which has little other traffic or YBHM which has a large amount of VFR traffic). …. Round we go again ….. it is not difficult, read the suggested remedies!The reason I suggested a multicom system is to allow VFR aircraft to broadcast their position and intention to other aircraft on a routine basis. Actually I would prefer the old system where VFR aircraft were encouraged to routinely broadcast on the center frequency, but now days this is very much discouraged (according to the AIP) except when responding to a conflicting IFR aircraft. … again why do suppose that is …. Frequency loading … why is frequency loading an issue …. Join the dots dude! Yes level banding has its limitations, but it will reduce the radio clutter from distant, high altitude traffic, and every aircraft has an altimeter that tells the pilot when to change frequencies. … bollocks … lets poll the IFR drivers on here (that descend into and climb out of CTAF in to and out of CTA each day) shall we? ….. in fact it is not necessary … the multicom idea nearly killed people a number of times during the G airspace trial (suspended for same by CASA at ATSB/BASI recommendation) The intention of my suggestion is that CTAF calls would be made on the B050 multicom frequency (except where a discrete CTAF frequency is established) so there is two frequencies below A050, 3 if you are IFR talking to ATS for IFR DTI to reduce the number of frequencies that have to be handled. .. how is it less frequencies than to day or the proposal I have put! … just answer that without the waffle! Remember the days of frequency after frequency being retransmitted by ATC - if you weren't getting directed traffic the bloke at the other end of the state could be loader and clearer than the other guy only 20nm away. … remember the days …. Fark me … have you listened to the ATS frequencies of late? …. ‘the days’ are now .. not the past!As for the RPT drivers - establish class C or D wherever you like - just don't ask me (or my pax) to pay for it in areas where it cannot be justified. … typical rhetoric of the old guard …. No one is saying C or D where it is not justified … and as it is FREE for VFR in CTA (unless it is associated with an aerodrome for which the TWR is associated, and even then it is a piddle compared to most of your costs) … whining about getting a safety service for free …. Bout says it all … suppose it is too much to consider the IFR’s you pontificate about above … or is all that just hot air! I will use it if it is there to access the airspace, but I am happy in G. I would be much happier when in either E or G to be able make regular broadcasts that all other pilots can hear when en route though. …. Make up yer mind cobba!DRA's are still in CAO 20.11 - they're just less relevant as all aircraft have to carry an ELT now days anyway. I don't remember the radio procedures being any different - my hazy memory is that you had to broadcast on the area VHF frequency and if operating full reporting report on HF when outside VHF range or lodge a SARTIME and carry an ELT if you didn't have HF - does this sound right? DRA’s are (or should be) for all intents and purposes ‘proper’ ICAO G i.e. … IFR and VFR get nothing!It would require at least one FSO to handle the traffic in the Whitsunday CTAF(R) alone - with the amount of traffic at Shute Harbour, Whitehaven, the Molle Group / Long Island Sound and Hardy Reef the discrete frequency would be jammed at times, especially when the FSO is trying to pass the traffic to five or so aircraft that happen to be at just one of these locations. …. FSO is not gunna pass traffic to 5 or so VFR otherwsie it would be D. They will however pass IFR traffic to other IFR. That’s why a visual scan is still required (see-and avoid) for VFR and IFR pilots OCTA …. BUT … If you were paying attention, I have suggested the OCTA DTI service provider (where it is available)

Scurvy.D.Dog
8th Jul 2007, 12:32
would have access to surveillance data for the provision of DTI (only that which is relevant) … less frequency loading and only relevant traffic … Does the IFR RPT need to know about any of this traffic - absolutely not unless the pilot is making up his own approach or departure procedures. landing yer duck next to islands is one thing .. again not really relevant other than VFR/VFR! What is relevant is the aerodromes where IFR and VFR operate in the immediate area and can come into conflict … if there is a group or aerodromes in a vicinity, one of which services IFR RPT i.e. CTAF (R), put them and the surrounds on the OCTA FS freq and the others on separate CTAF freq if necessary … IFR RPT protection is the name of the game! …. In any event our ‘opinions’ on frequency loading and appropriateness in any given area is irrelevant .. it needs careful assessment ‘independent’ assessment! If they're in the murk in these areas they've either flown through or just missed cumuli granatis to get from the approach to these locations. … not if you are using the same airport .. come on mate, lets get real about this!Just last week, the tower did not pass traffic to me that was on a converging course at the same altitude to a common location just outside CTA and a similar estimate. .. not the towers job description Was it a problem - no - I heard his call to ATC and the other pilot heard mine. ATC did pass a following aircraft on a diverging course to me though. .. is the towers job description … if in or leaving CTA … this is becoming tiresome!So being able to hear and understand traffic calls and how they relate to you (SA) is an essential skill, especially in areas where there is a high density of VFR traffic. In VMC the mark one eyeball is supposed to be the primary piece of collision avoidance equipment - I prefer not to rely on it as the only method. …. Have you caught-up with your tail yetVFR pilots are being told to shut up and look by the current documentation, unless hearing conflict from IFR or participating in a RIS. Every change to VFR procedures seems to reduce interaction with ATS in E & G. Is it any wonder pilots are becoming more reluctant to talk on the radio? Is it good? - definitely not. Is it understandable? - yes. .. and who’s fault is that?At YBHM you will not get a special VFR clearance if there is any other IFR or SVFR aircraft in the zone full stop. It's as certain as death or taxes. … depends on your track and geographical features on which ATC can base separation …. Have you considered the amount of ‘blue’ topography around the YBHM zone … how often to you track via points that assist ATC in this regard … hmmm?If I can't operate closer than 1000ft vertically from cloud in CTA I get f#@ked over anyway because I need a 1600' cloud base to operate. ..not what you said before … or are you saying that if the base is 1600 AGL you can operate at A015 except in CTA?? ..careful with the answerI have no problems with being procedurally separated and having to wait (even outside the zone) - fifteen minutes holding doesn't cost as much as not being able to work. 15 minutes eh … how many time are you NOT delayed each year V’s delays? … selective negatives stick out like pooch jubes!Firstly, VFR aircraft can ONLY navigate by visual reference to ground or water when below 2'000AGL (refer AIP ENR 1.1 19.2). Secondly, the islands block the NAVAID signals through most of YBHM zone even at 1,000AGL. … who said anything about being VFR below A020? … or is that your normal operating altitude?Radio is required to be used when operating at a reduced distance from cloud in G even without CTAF(R) procedures .. yeh sure they use the radio (The only time fixed wing VFR flight is permitted in less than 5000m visibility is in controlled airspace with a special VFR clearance). … you’ve worked that out then … want to revisit your original question? You can be damn sure I will be communicating anywhere when I'm anywhere near the instrument approach paths and associated areas if I am close to cloud in "G". … carry IFR charts whilst VFR do ya?If an IFR is shooting an approach I will keep out of their way - the last thing I want is to be hit by another aircraft (even though CAR 162 (5) requires the higher aircraft to give way to the lower aircraft). … farken ellACAS as far as I am concerned is a measure of last resort - if an aircraft has to respond to a RA to avoid a collision - there has been a major failure in the system. … no shit Sherlock …. Aus NAS 2b Class E Launy Christmas Eve 2003 … pax down one side of the B737 saw the face of the pilot of the TOBA as he passed under the wing … had the TXPDR of the TOBA been off or out by 300ft or the jet crew not respond to the RA .. there likely would be a memorial each year on Christmas eve in Launy ….. FOR WHAT POSSIBLE REASON would you change C to E in this case?Interestingly transponders are not required to be fitted in either G or D (in the aircraft I fly they are fitted, calibrated as required by AD/RAD whatever and are switched on in any wx). …. Good for you, so do most others … why is it you religiously do so? … hoping to avoid a surprise?? .. of course it is!
… and for the last feckin time D do NOT require TXPDRS below A045 as the Tower Controller can apply Procedural standards most often Visual Separation …. It gives safe access to D aerodromes for non-transponder equipped aircraft!. I thought that was obvious to all!OK, lets just get scientific and objective about airspace and keep the emotion out of it. .. are you being patronising? … if so that is rich and hypocritical given the inconsistent clap trap I am sitting here responding to … which I might add, I am doing for others benefit! CASA (as the regulator) should be required to do proper scientifically based risk assessments before allowing changes to be made to airspace. .. no one is saying anything different …. Is that clear enough yet? It's a looong post I know, but its been a good exercise to flick through the docs to verify the rules. … yes, I just love quoting reams of rules and procedures over and over again when the water has turned to swamp from shit!BTW I believe one piece of technology that has increased the risk of collision between VFR aircraft is the humble GPS. With the accurate tracking provided, VFR aircraft are concentrated closer to the direct track than they used to be in the days when DR was king. …. Oh come now, if un-alerted see-and-avoid works A OK, why would GPS be a problem …. Or is it that see-and-avoid does not often work, rather the big sky theory does …. OH bugga eh!I just checked your profile and see you are ATC. Which is fine, but the way you replied I assumed that you had personal experience flying in "G". I do, and the old OCTA F as well Are you or have you been a pilot as well? yup (as many who contribute here know) If not, I hope your comments about what you think pilots can manage in "G" are based on something substantial. …. Not that it matters but 22 years and 17 ATS Given the classes you control I have to assume you work where the airspace is generally quite busy with IFR traffic. It just isn't like that all over Australia. … yet again, don’t put words in my keyboard fella .. it shits me more than listening to Howard If you are up this way PM me and I may be able to give you a ride and a headset so you can hear what actually happens. .. operated up and down the QLD coast some years ago, know the architecture of most D/C TWR’s (as the SATC’s are ‘like type’ colleagues) I am in touch with regularly. I am Check and Standards for D/C TWR/APP, as well as an ATS Investigator. I have been fortunate to have made many famil rides in most things from C404’s, through B767’s .. and have spend many a day providing CA/GRS and Unicom services at many airshows (6.5 years at YSBK came in handy for the airshow stuff) … I think (at a guess) I am full bottle on frequency management … thanks all the same though!FYI sometimes seaplane pilots can manage five frequencies on a five minute sector - marina (clearance to water taxi through), CTAF, Tower, Marine (coordinating approach to boat) and company (SAR's, operational changes). And remember this is single pilot with four different traffic situations to assess ("D", CTAF(R), departure water and arrival water) - and water wakes can be just as dangerous as wing tip votices. … good for you, so you should when that is primarily the same areas you always operate inTwo pilots should be able to manage the same number of frequencies even in IFR. … yeh right, specially when an IFR crew are likely to be outa towners …. Think man!And a final pilots 'understanding the airspace classes' comment - maybe pilots are confused between D & C because in some "D" airspaces the usual practice is for ATC to separate (or segregate) VFR from IFR as is required in "C". …. If you are gunna make statements in the ‘absolute’ check yer facts first:-
- In C IFR AND VFR are Separated
- In D IFR and VFR need not be ‘separated’, ATC will separate where able and segregate with traffic info if a critical collision risk does not exists!
note …. ATC in this country have been made very aware that ‘traffic information’ in CTA D (whether it is IFR/VFR or VFR/VFR) may not be enough if two subsequently go together …. The problem for us is spending years in all sorts of enquiries justifying why we did not ‘prevent the collision’ as part of the definition of an ‘Air Traffic Control Service’ (ICAO, CASR, MATS and AIP)
… look it up!
…. Unless we are to busy to separate or segregate (and can justify that decision after the event) WE WILL MAKE YOU MISS EACH OTHER ….. is that clear enough? At YBHM I have only heard pilots made responsible for ensuring "segregation" between VFR & IFR aircraft after both aircraft have sighted each other - yet VFR to VFR is just given traffic. .. ah dear
.. the first example is pilot assigned ‘visual separation’ .. this is a ‘separation standard’ in the books
.. the second fall into the category explained above Have a look at ATSB comments in Jan/Feb Flight Safety Australia page 58 and May/June Flight Safety Australia page 59 - ATC contributed as well as the pilots. … there is more than one line I could use here, but at the risk of offending many … I shall refrain!!
.
… lets end the pissing contest shall we …. I'm bored :suspect: ..... and I am dam’d sure everyone else has fallen asleep or committed hairycary!
.
Nite to those still breathing! :ugh: :ugh: :{ :mad:

werbil
13th Jul 2007, 10:13
Scurvy.D.Dog,

Some last comments.

IF YOUR GOING TO QUOTE ME, QUOTE ME IN CONTEXT - DON'T SELECTIVELY QUOTE PARTS FOR YOUR OWN PURPOSES.

If you read my arguments CAREFULLY, you will see that there are numerous points that we agree on. It was your argument that there should only be two classes of airspace (plus DRA's). My arguments are WHY I believe it wouldn't work and my reasons, and some comments about the way airspace is implemented. I was replying to the thread - other people may be following it.

I have not seen ONE positive comment by you about the competence of a VFR pilot in this thread. A person's background and experience does influence the way I evaluate their arguements, which considering the points you were making makes your background relevant.

D airspace is the currently the first airspace which has any VFR involvement with a third party for traffic purposes (except CA/GRS or UNICOM). Old OCTA had VFR involvement with FS - that is THE similarity I was referring to.

Re YBHM (1) - a VFR aircraft at A010 cannot physically be traffic for an IFR aircraft outside 6 nm YBHM very conservatively between the 000 and 090 radials (no circling to NE of AD and you don't have to be a rocket scientist to work out why). Yet in the area around 7nm to the NE (Whitehaven) there can be numerous VFR aircraft that are significant traffic to each other. This area is covered by a discrete CTAF(R) that also includes Hardy Reef, YSHR, Long Island Sound and Hayman Island underneath the CTA which has high densities of VFR traffic. When the tower closes for lunch and at night the reclassified airspace becomes part of the discrete CTAF(R) - there may be an arguement that it should be left as a CTAF(R) using the tower frequency.

Re YBHM (2) - converging heading was to the same waypoint approx 1nm outside the zone and we both arrived there within about a minute. Traffic whilst still in CTA ? - :mad: oath it was. Requirement to pass as traffic - I think so.

Re YBHM (3) - locations - Very few of the locally used waypoints are included on the VTC. ATC know where they are - they use them as clearance limits on a regular basis. Over a beer one evening one of the local controllers told me there is a chart in the tower that depicts them - and he named a few I that I didn't know where they were.

Re 1500' AMSL CLEAR of cloud in G - perfectly legal providing pilot uses radio as required.

Re E - If it's so dangerous / impractical it wouldn't work anywhere else in the world. Quoting myself (with emphasis):

I personally believe that "E" is a great airspace classification - I just think that it is poorly implemented in Australia.

And your argument is?

And a final comment - the local controllers are approachable and I can have a healthy discussion with them about airspace without it denigrating into a :mad: fight. Professionalism maybe?

W

Scurvy.D.Dog
14th Jul 2007, 08:53
IF YOUR GOING TO QUOTE ME, QUOTE ME IN CONTEXT - DON'T SELECTIVELY QUOTE PARTS FOR YOUR OWN PURPOSES. … perhaps you might point out said quotes?! :hmm:If you read my arguments CAREFULLY, you will see that there are numerous points that we agree on. … I did read your posts carefully (right up until the motherhood statements and irrelevant personal tangents that arrived in the latter posts), and responded to those points where the mechanics (of airspace operations) of airspace services were at odds. Your initial post raised issues worthy of ‘considered’ discussion. What followed read as defensive and patronising. It was your argument that there should only be two classes of airspace (plus DRA's). … in part yes, I have explained the reasons for that view. I still have not seen anything as far as tech detail that would suggest those views are not reasonable or supportable when ’compared’ to the status quo or ‘multicom’ and class E as you suggested. .. if my views are wrong explain why!My arguments are WHY I believe it wouldn't work and my reasons, and some comments about the way airspace is implemented. .. I still have not seen any argument or reason/s why it wouldn’t work (more effectively) I was replying to the thread … funny I got the feeling you were addressing me as each post starts with Scurvy.D.Dog .. not Pork Chop or Madam Lash or other :rolleyes:- other people may be following it. … I sincerely hope so :)I have not seen ONE positive comment by you about the competence of a VFR pilot in this thread. … that’s because you are being unreasonably defensive …. Re read my comments .. I have much respect for VFR pilots … I have merely highlighted the ‘unreasonable’ knowledge expectations placed on them from both an IFR flight trajectory and segregation assessment points of view … The fact remains many VFR pilots (no slight on their flying abilities) haven’t a schmick about these IFR airspace issues or, in the main, regular CTA participation and therefore competence.A person's background and experience does influence the way I evaluate their arguements, which considering the points you were making makes your background relevant. … errrrm OK :8D airspace is the currently the first airspace which has any VFR involvement with a third party for traffic purposes (except CA/GRS or UNICOM). … Unicom is not a function that is involved in ‘third party traffic services’ .. except for 'basic information on traffic' (whatever that means) AIP GEN 3.4 3 3.3.3 h - 7th June 07' ammendment other than that, absolutely correctOld OCTA had VFR involvement with FS - that is THE similarity I was referring to. … yes and the point I have made repeatedly is that the only similarity is VFR use’ish the radio … the services provided in those two examples (CTA D and OCTA F) are light years apart … you inferred other! :=Re YBHM (1) - a VFR aircraft at A010 cannot physically be traffic for an IFR aircraft outside 6 nm YBHM very conservatively between the 000 and 090 radials (no circling to NE of AD and you don't have to be a rocket scientist to work out why). … really Werner Von Braun :E … OK lets do it then shall we:-
.
1. Dig out DAP East (if you have it) … look at the inbound tracks for the NDB, 14 and 32 VOR App’s .. and the associated missed approach tracks … note the position of the VOR with respect to the ‘No circling’ area … then note the MDA’s ….. then note that the Approach clearances from ATC are from the IAF (initial approach fix) all the way to the threshold (including circling area and nav tolerances) …. So I say again, traffic must be clear of the Approach track, turn tolerances, circling area and the missed approach path Before the IFR reaches the IAF … which returns me to my original statement that unless there is a geographical fix that is surveyed (the little map you referred to in the tower :rolleyes:) outside 1nm (+ tolerances) from the areas listed (above) that ATC must consider … what do you reckon might happen to you at A010 if the above cannot be met?????
.
2. The ‘circling’ restrictions refer to IFR at night and in less than VMC … they do not mean an IFR could not be in VMC and manoeuvring below MSA to the North and/or East …. The Fact that ERSA stipulates ‘Right hand circuits RWY 14’ does not restrict ATC from using the airspace to the North and East .. IFR circling at night and/or in less than VMC are inexorably a different set of circumstances to IFR operations in VMC by day! …. Do you understand the difference? :ugh: Yet in the area around 7nm to the NE (Whitehaven) there can be numerous VFR aircraft that are significant traffic to each other. This area is covered by a discrete CTAF(R) that also includes Hardy Reef, YSHR, Long Island Sound and Hayman Island underneath the CTA which has high densities of VFR traffic. When the tower closes for lunch and at night the reclassified airspace becomes part of the discrete CTAF(R) - there may be an arguement that it should be left as a CTAF(R) using the tower frequency. .. possibly? .. have you floated the idea with RAPAC?Re YBHM (2) - converging heading was to the same waypoint approx 1nm outside the zone and we both arrived there within about a minute. Traffic whilst still in CTA ? - ######oath it was. Requirement to pass as traffic - I think so. … well now that depends on all of those issues I have gone to great length to explain earlier … without knowing the specifics, including what else was going on in CTA or in the tower (as there is a multitude of coordination and other items that are being worked that does not involve using the frequency i.e. you won’t hear anything) …. I don’t know, you sure as hell don’t know either .. what we do know is that you have said you both (VFR) heard each other, which no doubt the tower knew AND … that is why in D VFR/VFR are required to maintain comms and primarily see-and-avoid …. Go back and read the rules that underpin that in AIP and in this thread …. Chucking stones at ATC (mid hissi fit) with scant detail speaks volumes :=Re YBHM (3) - locations - Very few of the locally used waypoints are included on the VTC. ATC know where they are - they use them as clearance limits on a regular basis. Over a beer one evening one of the local controllers told me there is a chart in the tower that depicts them - and he named a few I that I didn't know where they were. …. I rest my case :zzz:Re 1500' AMSL CLEAR of cloud in G - perfectly legal providing pilot uses radio as required. .. ‘as required’ …. Yeeeeeeeees … I see … that works for the IFR on the drop outa IMC …. cuckoo cuckoo :ugh:Re E - If it's so dangerous / impractical it wouldn't work anywhere else in the world. Quoting myself (with emphasis):I personally believe that "E" is a great airspace classification - I just think that it is poorly implemented in Australia.
And your argument is? …. Do a search of the NTSB (US) database and others in Europe (its all been done to death in this place in the last few years) for Airprox and Mid-air collisions ….. and then come back and tell us E is just peachy … particularly in geographical areas where D or C can be provided for the same cost … do not gloss over the info on the other thread about the way E is REALLY run O/S V’s ICAO … unless of course you have Ostrich tendencies … in which case .. feel free to stick your head in the sand! ;)And a final comment - the local controllers are approachable and I can have a healthy discussion with them about airspace without it denigrating into a ####fight. Professionalism maybe? …. Had that hissi-fit inference come from someone who argued the tech issues rather than (when the going gets tough) the man …. I might have been offended …. Alas … neh, :} in fact, I nearly wet myself laughing at your last post! :D
.
… you see, in this place, you get back what you put in … i.e. reasoned, polite and erudite discussion .. or … reciprocated rubbish … I am most happy to play either game! And a final comment – …..
Saucer of milk to the Whitsunday’s :p
.
Nitey nite

Freedom7
14th Jul 2007, 20:51
I guess the famil flight is off????:E

peuce
15th Jul 2007, 05:56
Although we've drifted off topic a bit, the thrust and parry is still quiet entertaining.

One thing Mr WERBIL said was interesting ... and was, in fact, connected with the original topic ...

"If you read my arguments CAREFULLY, you will see that there are numerous points that we agree on. It was your argument that there should only be two classes of airspace (plus DRA's). My arguments are WHY I believe it wouldn't work and my reasons"

Fact is ... that system DID work ... up until it was dicked in the early 90's. That's 17 years now we have been fighting over airspace. Why do you think that is? Perhaps because there was never any really substantiated reason for changing. Was there any objective RISK ASSESSMENT made of the, then current, system ... before charging headlong into fantasyland?

As Scurvy implied ... the real driving factor was the "need" to get rid of Flight Service.

Do you think we would still be arguing the toss now if a risk assessment of the 1990 system had been done, shortcomings identified and appropriate corrective actions/changes initiated. Unlikely.

I've said it before, and I'll say it again ... where the end game is decided before the analysis takes place ... failure is certain. The last 17 years prooves that.

Scurvy.D.Dog
15th Jul 2007, 08:21
Addendum
.
Just goes to show, these discussions (no matter the tenor) are useful for everyone’s level of awareness.
.
werbil
.
Yesterday evening whilst working on some paperwork for an upcoming airshow, I had a flick though GEN (having reflected on our exchange ) and noticed a small but apparently very important change made to AIP in the June 7 amendment.
.
It is in the context of Unicom services, and changes the intent of Unicom. It is therefore appropriate to revisit the statement made by me to you i.e.D airspace is the currently the first airspace which has any VFR involvement with a third party for traffic purposes (except CA/GRS or UNICOM).
… Unicom is not a function that is involved in ‘third party traffic services’ .. other than that, absolutely correct …. AIP GEN 3.4 3 3.3.3 (h) has been added which now saysh. basic information on trafficThe wording seems to have been carefully chosen i.e. not ‘Traffic Information’ as defined in AIP ‘Flight Information Service’ GEN 3.3 2 2.15 (specifically 2.15.9)
.
…. I wonder what the intended difference is? ... if there is any?? …. Hmmm … :suspect: ... in any event, I have noted the correction in red in the above post :ok:
.
Interestingly, given the CA/GRS is a ‘certified’ role, and Unicom is not (the difference was always based on training and knowledge required to manage ‘interference’ on the G/CTAF frequency), this change would seem an excursion into the unknown. .. why I hear you ask :E
.
The little ‘gotcha’ ( 3.3.3 (h) above) is relevant when tagged to the other bits in AIP UNICOM i.e.
.
- GEN 3.4 3 3.33.3.1 Unicom (Universal Communications) is a non-ATS communications service provided to enhance the value of information normally available about a non-towered aerodrome.
.
3.3.2 The primary function of the frequency used for UNICOM services where the Unicom is the CTAF is to provide pilots with the means to make standard positional broadcasts when operating in the vicinity of an aerodrome. Participation in Unicom services must not inhibit the transmission of standard positional broadcasts.my bolding
.
Now, tie that in with:-3.3.6 The Unicom operator is solely responsible for the accuracy of any information passed to aircraft, while the use of the information obtained from a Unicom is at the discretion of the pilot in command.my bolding
.
Subtle to read, but as a whole, adding ‘basic information on traffic’ changes dramatically the role picture/expectation for those participating in or providing Unicom services.
.
Folks would be well advised to give very careful consideration to their liability coverage, and; for pilots, the same consideration if they choose to rely on the Unicom info or loose SA due Unicom frequency interference.
.
The glaring difference between CA/GRS and Unicom is the services provided and the fact that a CA/GRS is trained and ‘certified’ to do so, not so for a Unicom operator thus the ‘solely responsible’ caveat. ….. hmmm
.
I do not know (as yet) how this jem slipped in … would anyone in the know (CASA) care to comment.
.
At first glance, it may also raise ‘serious liability issues’ for those of us (ATC’s) that volunteer at CTAF airshows and fly-ins!
.
On a different note.
.
Having re-read the latest exchange/s, it was perhaps (on reflection) unfair of me to have assumed you (Mr/Mrs werbil) were deliberately throwing in curve balls to distract/detract from the discussion. If you are genuine in your beliefs, and not being obtuse, then I apologise for the tone of my responses.
.
Raising awareness of tech issues without the ‘carrier waves’ is a long and frustrating process. Genuine discussion and explanation (where sort) is what many of us are trying to achieve. No one 'expects' consensus, but in its absence, calm reasoning and explaination of the contrary view ... perceptions of motherhood statements are like Avgas near a naked flame in this place.
.
Unfortunately, there have been a number of those ‘deliberate misinformer’ types over the last number of years, which probably works to amplify the reactions (of some of us) when people appear to be attempting same.
.
Again, if that was not your intent, I apologise :ok:
.
Scurv