CASA experiments with lives at Avalon

[Dick Smith]

Just over two weeks ago a NOTAM was issued informing pilots that the Avalon terminal airspace is now a TRA – a Temporary Restricted Area. The main change is that in the Class G airspace at Avalon, a transponder is now required for all aircraft. This is similar to the CASA Office of Airspace Regulation decision in relation to Williamtown.

What a great way of experimenting with human lives.

The manager of the Office of Airspace Regulation hails from the British CAA. Nowhere in the UK, or anywhere else in the world that I know, has a mandatory transponder requirement been used to protect airline passengers in uncontrolled airspace in busy terminal areas.

Has a proper safety case ever been performed? How would anyone know if a transponder was actually working?

It is total hypocrisy. The same people who are now with the CASA Office of Airspace Regulation were previously working at Airservices Australia, where they made the decision that a transponder was not allowed to be used as a safety mitigator for Class E airspace. Now they have moved on to CASA and are kowtowing to the airlines in every way they can, suddenly a transponder becomes a great safety mitigator – so great that not even Class C airspace is required.

There has been no industry consultation in relation to this decision. Don’t believe for a second that proper Class D controlled airspace could not be provided there in the time. I have heard a rumour that there is asbestos in the tower – big deal! If Airservices can provide a portable tower in Birdsville for the races, or even a portable tower for the Grand Prix in Melbourne, they could clearly provide a portable tower at Avalon.

It is now obvious to everyone that the Office of Airspace Regulation – rather than being an independent unit without fear or favour – is now simply an extension of the profit making arms of the airlines and Airservices.

There will definitely be an accident soon. We must make sure that we hold these people responsible. They are operating under a cloud of secrecy and they try to not be accountable. They obviously have some support from above in CASA, but I would imagine that most of the decent CASA people are as horrified as I am.

[Kangaroo Court]

Dick,

They require transponder usage in the United States, even below 10,000, within thirty (30NM) miles of Class B terminal airports. Further restrictions include not allowing "Special" VFR or student pilots.

The Yanks now require transponder recertification every 24 months. They call it a "Static/transponder check".

Regards,

Kangaroo Court

[Dick Smith]

This is "as well as ATC", not "instead of ATC"!

ie, totally different.

[Capcom]

Dick,
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Whilst not disagreeing with the thrust of your argument re: AV, there are a couple of relevant points:-
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1. CASA (as I understand it) determined that a Class C tower service is required
2. AsA (apparently) could not come up with the service as determined in the time frame envisaged (how, why and for how long .. you would have to ask them ... I haven't a clue)
3. Mandatory TXPDR requirements as a supposed mitigator has been attempted, and used ... that being here in OZ and part of the now historical and nostalgic :E AusNAS i.e. Class E ... and before you say CTA E is not OCTA G ... IFR/VFR conflict pairs are for all intents and purposes uncontrolled and possibly/probably unaltered i.e. same as they would be in G …. If I may, in raising this, is to highlight that your other valid arguments are able to be diluted with inconsistencies that distract from the real issue/s
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Now, far be it for me to defend the OAR but ... if they say a C tower (as opposed to a C centre service) is the go (not that I personally support either of those classifications in this case), and the ANSP have not/cannot pony up ….. weeeeell ;)
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.... perhaps the OAR had no other option than to do the next best thing i.e. CA/GRS and TXPDR mandate (not that I personally support that classification in this case) whilst waiting for the ANSP? .... dunno?
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Like so many things in life, if proper consultation occurs, and the industry understand the why and wherefore’s, then perhaps these issues would not bob-up as they do :ok:
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So, where should the bone be pointed? ;)

[Freewheel]

I'm sure there was a thread on this at the time, perhaps I'm also using the wrong search terms.

[Dick Smith]

Here is a bit more information. At a recent meeting in relation to Avalon, where Graeme Rogers of the Office of Airspace Regulation was present, it was claimed by the people at Avalon Airport that the provision of a control tower would cost approximately $2 million per year. If this charge was added onto Jetstar they would stop using Avalon!

This to me seems a classic example of manipulating figures to keep the status quo.

How could a Class D tower of the type Airservices operates at Lihue in Hawaii cost $2 million per annum? A more typical figure would be about $500,000 per annum – i.e. one quarter of their cost. $500,000 per annum would cost less than $1 per passenger, and I’m sure passengers would be happy to pay this to get acceptable safety levels.

It looks as if CASA is still misleading people by saying that the risk is not close to the aerodrome. In fact, I believe the risk at Avalon is in the circuit area and on the runway. That is why we have an aerodrome control service at airline airports.

I remember back in the old Two Years in the Aviation Hall of Doom days – over 20 years ago – the regulator was full of this type of dishonesty. It is so sad that it seems to have crept back in again.

[TrenShadow]

Depending on the hours of coverage, you'd need approx 5 ATCs.

Top pay scale is ~$130k x 5 = $650k per annum, add on super and you're up for $708k.

Then you have to pay for the communications setup. Radios, ground links to ML Center/APP, maintenance of same (salary for the maintenance techs).

$2m sounds much closer to the mark than $500k

[Dick Smith]

At those costs I can see why we have about 50% of the towers of the USA when you compare traffic levels.

Maybe we need a little competition.

AsA run Class D towers in the USA subsidised by our industry here.

We need US companies to run towers at a loss here subsidised by the US!

Even if the tower cost $1 million PA thats only a little over $1 per PAX.

How much does it cost to run Albury tower with about 250k pax and no jets?

[vee1-rotate]

not including the twice daily DJ Embraers, or...?

[Sunstar320]

Bit O/T, but is their a newly contructed Tower at Avalon?, or have they just painted it white for some odd reason??:confused:

[Dick Smith]

Vee1, thanks, I stand corrected.

[Plazbot]

Dick, I am an ATC and there is no doubt there should be at least a D Tower at Avalon. Same with Broome, Port Macquarie, Ballina and Kunnanurra.

I bagsed port Mac by the way.

[Dick Smith]

Plaz, Would you go for a D tower at Port with E replacing the existing G above or would you insist on Class C above the D and become a martyr as Scurvy would?

ie- nothing or everything as per the Aussie ATC tradition!

[Ex FSO GRIFFO]

Gee Dick,
RE;
"I remember back in the old Two Years in the Aviation Hall of Doom days – over 20 years ago – the regulator was full of this type of dishonesty. It is so sad that it seems to have crept back in again."

I can remember too....when the industry was told that that ole' F.S. thingy cost $80Million per year to operate - and 'we' had to get rid of it because it cost too much - 'Affordable.....What was that other word???'

Well NOBODY believed that figure either - so what has really changed??

AAh - HISTORY!! (seeing as you brought it up.):(

[Blockla]

How could a Class D tower of the type Airservices operates at Lihue in Hawaii cost $2 million per annum?What costs are included, tower maintenance, navaids on the aerodrome, contributory costs for radar feeds etc; electricity, cleaning, or just wages? Who says you could "more typically" do it for 1/4 of that, did you make it up?

As for Jetstar pulling out of Avalon if a control tower went in there, well let them pull out.

The safety case or stats that determine a service should not be undermined by commercial imperative, cognisant of it but not undermined. Where would Jetstar go if they pulled out of AV, ML? not likely a cost reduction; or simply close down all ops on 100 odd flights a week (maybe more), huh?

I'm based in Europe now, even Ryanair the low cost "leader" doesn't fly to places without ATC unless absolutely avoidable; in some locations new ATC services have opened after they have signalled their intention to use the aerodrome.

But what is the regulator to do if the company it regulates won't provide the services that regulator requires? "GROW SOME BALLS CASA"...

Competition is not the answer unless the agenda is to crush the ATC wages claim, I'm not sure that is what you are pushing for?

What we need is recognition that ASA is a shambles, that the chronic staffing shortages are real and then we could perhaps concentrate on how to 1)fix the current 'real' problem and 2) get back to making improvements not simply cost cutting.

Dick I admire your passion for this I truly do, but unfortunately the situation in Oz is so bad that you need to make baby step changes, again, as big steps will simply dig the hole deeper at this point in time.

Plazbot, need a hand in PMQ? I'm there in 6 or so... Should be perfect timing...

[The Euronator]

Plazbot,

I will take Ballina . 8 years in Europe , I'll come back for Ballina no problems. I might even be able to dust off the old Flight Service Licence :ok:

[Rudder]

:ugh: OK,

I'll step out of line.

Given that there have been Jetstar operations into Avalon for some years, can somebody show the stats to support the alarmist position taken here. I've operated large jets in there on training for quite some time and never had a problem or what could be seen as a safety issue.

Just because it doesn't happen overseas is not a reason. From what I can see, what is there now and proposed works fine. There just isn't the traffic to justify a tower.

[Bula]

What Avalon needs are is a transit lane to the north and a transit lane to the south, keeping the lighties clear of the approaches and circuit area.

The most difficult thing about Avalon is not other practise IFR aircraft, but the fact that we have multiple bogies from multiple directions doing a vast array of different things but mostly transitting.

Make the airspace Glass C, the ground class G and provide lanes of entry. I view Avalon as workable, but inherently his risk, like Broome, but Broome just does not have the transitting aircraft.

[Rudder]

Bula,

Good suggestion.

I think there is one already to the north. Not sure where you would put one to the south except on the other side of the bay. You could of course put them straight over the top at 2000 which is not going to conflict with approaching, departing aircraft and circuit traffic.

[Capcom]

The lanes issue has some merit IMHO
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O/H might really screw up someones day if missed approaches and/or navaid training are in progress though :ooh: ;)

[Stationair8]

Been into Broome lately Dick?

Also Dick, what was the name of the bloke that was running CASA in the 90's was advocating closing the tower at Launceston, Albury, Port Headland, etc to save costs and make flying cheaper?

[sunnySA]

CASA experiments with lives at Avalon


Surely it is a case of Jetstar that is possibly putting lives at risk by operating into/out of Avalon and not CASA. Whilst I agree that the provision of an Aerodrome Control Service might be appropriate it is Jetstar that has chosen to operate into this aerodrome and would or should be fully aware of the risks involved. Obviously the advantages of tapping into the Geelong market and the quicker turnaround times outweigh any disadvantages.

[aulglarse]

Rudder, on some occasions an departing A320 will reach 2000' on upwind. An overfly requirement of 4000' will ensure traffic clearance for departing a/c up to the MSA.

[Rudder]

Aulglarse,

Absolutely

I fly them all the time and know how they perform. The fact is you can limit your downwind altitude until clear like any other aircraft. Or climb straight ahead and then back over the top at an altitude that will not conflict. These thing are done all the time to work out conflicts. Like I said, I conduct training down there in these aircraft all the time and have never seen or had a problem.

The reality is that the system works now and aircraft are seperating themselves safely and efficiently without any limits on corridors or altitides.

If corridors can be made work then I can see some sense in limiting the workload in restricting the "likely" known position of the aircraft.

This is just a beat up because it would seem Dick wasn't asked his opinion. While I think overall he is well meaning, sometimes I think the motivation for bringing forward issues needs reassessing. The changes at Avalon are minor and tinkering around the edges but Dick almost wants a Royal commission to justify them. This is all just emotion. The raisning of these nitpicking issues only has people saying hear we go again rather than Dick is saying something so it must be important.

This has nothing to do with CASA not doing thier job. They have no evidence to show that there needs to be a change to the status quo and that actually means they are doing their job.

[Capcom]

.... hmmmm :} ... what say you Richard? :E

[Capcom]

... but before you answer that .... answer this http://www.raaa.com.au/Issues/Articles/Regions/From%20the%20Regions%20Apr%2007.pdf

But amongst all of this recent activity, the February SCC Airspace Users Group meeting stands out as a source of hope for the future. In stark contrast to the unpleasantness which characterised the NAS process in the past, at this meeting the representatives of various industry organisations from both the commercial and recreational segments generally agreed on a way forward for the regulation of airspace once CASA takes responsibility.
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In general terms, the meeting agreed that CASA should embrace the regulatory processes developed post-NAS by Airservices’s AERU (Airspace and Environment Regulatory Unit). AERU, very much to its credit, recognised that decisions on airspace changes should only be made on the basis of fact, determined in a transparent process, instead of blind assertion as in the case of the NAS changes. Consequently it developed and implemented a risk-based process to identify and prioritise potential problem areas, and then by way of aeronautical studies conducted in accordance with ANZS 4360:2004, aimed to identify the most appropriate solutions to each particular problem. This process was developed to consider three main aspects: the safety and efficiency of the public transport system, the cost to the industry, and equity of access by all users.

The success of the AERU process is perhaps best illustrated by its effectiveness in resolving some recently expressed concerns about Avalon. There had been calls for a control tower to be established at Avalon to separate RPT aircraft from transiting VFR traffic. However, the AERU process determined that the actual problem occurred some 10 miles from the airport, and that creating a control zone, which would have cost industry dearly and could have impacted to some extent on GA’s access, would not have resolved the key problem. AERU’s aeronautical study based process determined that the issue would best be solved by some relatively minor changes including the provision of aVFR route past Avalon.

Thus through a proper review of the facts and the development and consideration of a range of options, the AERU process resulted in a solution which demonstrated the required enhancement of safety and efficiency, but (apart from the cost of the study itself) at no cost to the industry and with no restriction on access by GA.

In addition, AERU’s transparent and consultative approach meant that the decision was accepted as a matter of routine. It would be hard to find a better model for future airspace decisions. That the representatives of the various recreational and commercial groups at the meeting endorsed the adoption of this process by CASA, is cause for some optimism after the black days of the NAS debacle.

The continuation of NAS is still government policy, but no-one either in government or industry wants to see a repeat of the NAS2b or NAS2c fiascos. Those episodes were the result of trying to impose what we believe were safety reducing measures on an industry which philosophically is not prepared to accept reductions in safety. At the outset, the RAAA (along with other bodies) argued that the more contentious proposed NAS changes should be subjected to aeronautical studies, but the NAS Implementation Group refused to even countenance such an approach, to its cost and to the cost of the government, the industry and the travelling public.
One is entitled to ask the question “Why would a body charged with upgrading the national airspace system, supposedly in the national interest, refuse to conduct such a study or series of studies to prove the safety of the changes being proposed?”

There is a lesson here for all charged with safeguarding the travelling public. Today’s Australian aviation industry is maturing rapidly and is strongly focused on safety. Apart from a professional and ethical interest in safety, safe operations are increasingly critical to economic survival. The industry is now too sophisticated to allow safety to be trifled with as perhaps it once was in order to achieve political or ndustrial aims. It demands at least as professional an approach to matters of safety as it does to other
critical aspects of business. And it supports CASA’s move towards risk management.

AERU has demonstrated a professional method of dealing with airspace issues, based on transparent aeronautical studies conducted in accordance with that standard, and that method has been endorsed by both ‘sides’ of the airspace debate. If government can adopt an equally professional method of reviewing and implementing the rest of its proposed National Airspace System, (and all the signs, beginning with Warren Truss’s airspace discussion paper are good), then we can avoid a repetition of that unsavoury
series of events which we would all prefer to put behind us.

If that saga was the catalyst which brought us all to this point, then perhaps it may have been worth it. We look forward to the Minister’s Airspace Statement with guarded optimism.
… and your riding instructions as a board member of the CASA will be what Richard??? :E

[Spodman]

It is now obvious to everyone that the Office of Airspace Regulation – rather than being an independent unit without fear or favour – is now simply an extension of the profit making arms of the airlines and Airservices.A strange conclusion. ASA management are firmly and mistakenly convinced they are running a business. Expect them to do what the customers want, and to snow the shareholders about it.

Now the airspace is regulated by a crowd that just doesn't participate in things, having much more fun blagging people in the courts and fighting to keep the regs incomprehensible and complicated. How could you have expected a reasonable outcome by demanding that it be organised that way. Is anybody else surprised they have done nothing for a year or so? I'm not.

I agree the current TRA is complete bollocks and a bit like Mohamed Ali's left leg.*Plaz, Would you go for a D tower at Port with E replacing the existing G above or would you insist on Class C above the D and become a martyr as Scurvy would?

ie- nothing or everything as per the Aussie ATC tradition! Not interested in a tower job myself, but don't care about the airspace. Happy to work either. If the National Day of Inaction, where hordes of VFR pilots plotted to bring down the system with sheer traffic produced no noticable increase in workload anywhere I'm not frightened. Perfectly happy to work E airspace. There is an obvious increase in risk compared to C airspace, but it is still safe.

Don't you believe any buggar that tries to tell you it would be safer though.What Avalon needs are is a transit lane to the north and a transit lane to the south, keeping the lighties clear of the approaches and circuit area.Bollocks. Over the top is fine. Have heard 2 jets in the AV area, saw them about 3 miles away. If it was dangerous they would put a Tower in.





*It's not fair, and it's not right...

[Capcom]

... Spod ... you wanta check out a class D/C tower some time? :E

[Spodman]

... Spod ... you wanta check out a class D/C tower some time?Have done. Haven't worked one though. Your point?

[BeGoneTFN]

Av is a shambles ASA has never taken the operation seriously.

An accident is inevitabtle.

[Dick Smith]

Capcom, that crawling, cowtowing article by now departed RAAA CEO Terry Wesley- Smith was clearly written with one aim in mind - and it worked.

That is keep the Bureaucrats on side so that the multimillion subsidy for en -route charges remained and so that they would also not bring in the world accepted requirement for 10 - 30 pax RAAA Airline aircraft to be fitted with TCAS . That also worked.

Also it was clear that Wesley-Smith's mind was set in concrete- as many ex-military minds are.

I spoke to Wesley- Smith a number of times. It was clear that he was totally ignorant as to how Airspace in other leading aviation countries worked. In fact it was clear he had no interest in this.

He was fundamentalist when it came to Airspace reform. He is sure to be one of the posters on this thread desperately attempting to stop any change.

The AERU which he heaps so much praise on did no airspace reform at all- and that's why he thought it was so fantastic!

Spodman, I wiil repeat for possibly the tenth time, Class C is only "safer" if it properly staffed and proper equipment is provided.

In the AsA case an existing Class D controller, mostly one person who could already be overloaded with aerodrome traffic is also given the responsibilty for vast amounts of en-route C Airspace to 8500'.

This clearly must reduce the overall safety of the combined Airspace.

It appears to be only a very small number of really dumb controllers who keep insisting to AsA management that Dick Smith is wrong and that here in Australia one Class D controller can also handle vast amounts of Class C.

Just why these Controllers do this is beyond comprehension when you consider that in no other country are non radar tower controllers given such workload and responsibility.

Also as stated before it makes it clear to AsA management that some controllers are not very bright and can be exploited.

Fortunately there are new controllers coming along with lateral thinking ability and comonsense.

[Stationair8]

Why is Avalon any different to Broome or Yulara? What about some of the regional airports that have no tower or radar, or the tower is closed due to staffing?

[Dick Smith]

Stationair, Avalon and the other airports you mention should be subject to the proven FAA Class D establishment and dis-establishment formula. This takes into account traffic, pax and other issues to come up with an objective, scientific result.

CASA no longer uses this formula as it can't easily be manipulated to appease stakeholders.

Their Avalon study utilises subjective "guesses" to come up with the result they want- ie one that doesn't offend the powerful.

[WALLEY2]

Dick,
you do not help your reputation or argument by insulting Terry Wesley-Smith or his approach to airspace reform. Certainly I found him to be a genleman and willing to spend time examining an issue and seeking advise from his members and experts.

The RAAA is now one of the influential voices with regards air space reform and this was achieved by Terry. At meetings trying to get some studied approach to the NAS and NASIG, I have seen him stand up to Ministers and CASA. He is no crawler nor does he Kow-tow to Senior Execs or Ministers.

Dick, you raise a number of legitimate concerns that need to be answered.

What was the industy consultancy?

Has TCAS become a safety mitigator?

Where is the DAS for Avalon?

Is the DAS too subjective?

ATC COSTS. Allowing for support staff to cover leave etc, plus the inevitable taxes and charges, accomodation subsidies,including amortisation of capital investment. The cost to supply a 10 hour 7 days per week CAGRS service is around $750,000 pa. Therefore I would expect a D class tower to be less than 1 million.

For one I would like to see these questions answered by a post that directs us to the information raised by these questions.

Dick, for once we are not in direct conflict and I hope this post finds you and yours well. (that is not crawling and no one should believe I would Kow-tow to you!):rolleyes:

Cheers Mike

[Dick Smith]

Mike, In that case it would be less than $1 dollar per pax to provide class D at Avalon- ie easily affordable and well worth the cost I would reckon.

And if a CAGRS costs $750 k I would prefer to have proper class D with currently rated ATC's.

And don't hold your breath waiting for an answer from CASA- they have gone down a path of dishonest un- accountability of late.

[undervaluedATC]

Mike, In that case it would be less than $1 dollar per pax to provide class D at Avalon- ie easily affordable and well worth the cost I would reckon.

And apparently it would cost less than $1 per ticket per passenger per year to give ATCs everything they asked for in the Vision document. But AsA hide behind the excuse that the ACCC would not let them pass that cost on. Which brings up the point of just how useless our negotiations are when AsA sets the revenue charge 5 years in advance after consulting with industry but not their employees.

[Tiberius]

Dick, you state:

Fortunately there are new controllers coming along

Really??

I seem to recall another thread somewhere on these boards where ATC are suggesting quite the opposite.

Oh well, I must be mistaken. Obviously the vast majority of Australian ATC's are change resistant neandertals who dont have the slightest idea of the real issues.

[dodgybrothers]

In the case of CAGRO, as there are at Broome and Avalon, who employs them (ie airport owners and or operators) and are the employers absorbing the cost or are the costs passed on to the consumer plus a tidy profit margin? Because if that is the case then there must be a conflict of interest there at Avalon because the airport have stated that they do not want ATC?

I'm not saying that this is the case but maybe somebody, ie Dick, may have knowledge of how the CAGRO system works. To me it looks like private ATC but without the benefits of controlled airspace.

[Dick Smith]

Tib, no not the vast majority- just some who in the past have run a campaign to stop or reverse change.

[Capcom]

Well not really ;)
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..... the ATC profession in OZ (Civilair postion on AusNAS 2b), AsA, CASA, ATSB, RAAA, RAA, ... anyone I missed in that group of 'just some'!
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... all discharging their professional responsibilites against a backdrop of poorly implimented 'less safe' change for changes sake! :ok:

[peuce]

Dick Smith you said:

" Spodman, I wiil repeat for possibly the tenth time, Class C is only "safer" if it properly staffed and proper equipment is provided."

It could also be said .... " Dick, I wiil repeat for possibly the fiftieth time, Class E is only "safer" than Class G if it is properly staffed and proper equipment is provided."

Take heed of your own advice ...

[WALLEY2]

Doddgy Brothers,

CAGRS costs are paid by the airport owner. The CAGROs are audited by CASA and reviewed by AsA. The CAGROs must have ATC or Flight Service experience.

At BME we levy a PAX charge to supply this service. We do not make a profit on this service and have invited airlines to examine our revenue and expenditure accounting reports direct from our computerised accounting package.

Prior to AsA taking over the RFFS we costed this item in a similar manner.

With regards ATC at BME this is now reviewed on an annual basis, we can and have provided AsA with traffic logs direct from the CAGRS computerised traffic comms recorder.

When it is determined that ATC is required, it shall be handed over to AsA, the only stipulation from us is the CAGROs must be offered training (if required) and given the first option of employment for this service. Alternatively they will be employed in other jobs at BME.

This was the procedure we used with RFFS, AsA willingly complied with this request and infact they employed most of our previous RFFS employees some though preferred to stay with us doing other roles.

It should be noted BME is different to nearly all other Australian airports as our terminals and aprons are joint user and all CI,Ramp,concession staff,security,ground staff,refuelers and administration are our employees so redeployment of RFFS and CAGRO to other activities is much easier than at a regional airport that has only ground staff and a small admin function answerable to a shire.

AsA have modelled the BME terminal airspace based on the traffic records data. We have found them very professional and studied in their work and are pleased with the way they have kept us informed with regards their analysis and conclusions on airspace requirements at BME.

We also have regular consultation with aviation users including airline captains to determine if they feel the CAGRS procedures are coping with the traffic and not overloading the pilots. AsA has also had direct comunications with users when they were assessing the terminal airspace requirements for BME.

The conclusion is the CAGRS terminal service at BME is the most appropiate system at this time.

Cheers Mike

[Spodman]

Spodman, I wiil repeat for possibly the tenth time, Class C is only "safer" if it properly staffed and proper equipment is provided.
I haven't been counting, but I'll repeat: You are wrong.

[Capcom]

:D
.
.
:ok: