DRAFT NFRM 0814OS. Broadcasts by pilots at non controlled airports.

[Frank Arouet]

More CASA stupidity.

I have just read the DRAFT NFRM. (it's not yet on the CASA website). Note if published, annex B, B3 to B7.

Defines “in the vicinity of a non controlled aerodrome as 10nm from the aerodrome and at a height above the aerodrome that “could” result in conflict with operations at the aerodrome.

But this applies if you have one serviceable VHF radio, but goes on to state, if you have two VHF radio’s, that distance is 8 minutes flying time. (120KTS =16nm)?

Strict liability offences.

Imagine being fined for failing to give a radio call when “in the vicinity” of an “aerodrome or you “could” cause conflict, but the rules for doing so are different depending on how many radio’s you have.

If you have no serviceable radio I assume you don’t have to call at all.

I am told the FAA approximate equivalent to this unique piece of Australian lunacy is covered in 80 words and ours over 1,000 words.

[RadioSaigon]

If you have no serviceable radio I assume you don’t have to call at all...

That would strike me as a fairly safe assumption... :E

ROFPML :}

[The PM]

I may be dim (Healey, Joppich, Macca et al, shut up......) but what was so wrong with 15nm/5000ft or something similarly simple ?!?

[Jabawocky]

PM

Good point, I think it should be 10miles and 3500AGL..... that is a sensible dimension for the space around a CTAF aerodrome.

FRANK

Why not join the AOPA and give them your support at objecting.

With the general idea of it, I support it, some good CTAF practices, except the dumb ideas and strict liability big stick poinetd out by Frank. Well spotted mate! :ok:

If one of you has time on your hands and knows how to get at the respective Canberra folk, it would be good to see you "improve" this document.

J:)

[Frank Arouet]

I believe this was left as a legacy from the previous Director. It is up to the new holder of the poison chalice to see it as dumb and affirm his hold on the reigns by chucking it out. (with the Board's permission of course).

If you, jabawhosit, are a member of that once proud organisation, why don't you give them your support. I have more pressing things to do than ameliorate their "situations".

They, can of course support my efforts by objecting.

With the general idea of it, I support it,

Do you know what the definition of a non controlled aerodrome is?

[Capn Bloggs]

Do you know what the definition of a non controlled aerodrome is?
Pick me! Pick me!

How about, "one that is not being controlled by an ATC"?

[Frank Arouet]

Collins English Dictionary: aerodrome. "a landing area,esp. for private aircraft, that is usually smaller than an airport".

CASA could describe an ALA as an aerodrome. Or any place where an aeroplane can take off or land. Depends on how they feel on the day when determining if your particular flight "could" result in conflict with operations at that aerodrome.

[Sunfish]

The outcome of this is simple. The next survivor of a mid air collision within Ten miles (or Eight minutes flying time) of a non controlled airport will be prosecuted and no doubt convicted.

[Jabawocky]

Frank

At least pay me the coutresy to use my name correctly, its on the left side of every post I make.

You know full well I am not a member of the organisation and you know exactly why. No need to waste more time here.

I do believe that the general idea of better radio calls and distances etc needs fixing up. As said previously I do believe 100% the points you raise about being bad with respect to strict liability and so on.

This sums up the stupid parts.... copied from an email.
we pointed out that the VFR and IFR charts showed different CTAF so what to call enroute – their answer that IFR should check a WAC.

A WAC.....:ugh::ugh::ugh: Most aerodromes on a WAC do not exist, and all the bush strips that do are not printed. WAC's show roads hills and rivers and provide good sunshades for those who need them.

[Frank Arouet]

Lets not get too precious about identities.

The NFRM I read is in DRAFT form and needs to be attacked before it gets to be a FINAL. It's a pity that the "we" you refer to in your email snap don't push to get this DRAFT published for general comment, (you know consultation with industry), before they, as in "their" answer referred to, have it foisted upon us, strict liability and all. Has anybody asked CASA to publish it? I can't being a "leakee" and all that, but you could.

The bits about the WAC charts leave me confused to say the least. Highways are commonly used as "aerodromes" by rescue aircraft, how many calls do I need to give flying across the Nullabor.

[flying-spike]

What about keep the CTAFR and CTAF,5,000' x 15 nm or 10 minutes whichever is further

My two bob's worth for what it is.

[Jabawocky]

Has anybody asked CASA to publish it? I can't being a "leakee" and all that, but you could.

How is it you are any different as a leakee to me....... I am not on the inside and I can assure you "they" would probably take you just as seriously as they would me. They at least know who you are! You read too much into some things and not enough into others.

As for attack the NFRM, I would suggest that you may have more time and resources at your disposal to attack this. This is right up your alley, and not mine. I would also support your efforts and ####'s effort's to turn what is another good opportunity to sort some BS out and not let it go nuts like it sounds.

As for the Nullabor........you may well be right! :ooh:

J:ok:

PS Lets not get too precious about identities. no not your real identity.......or mine....just some manners and do not try to talk down to me or others thanks. You will catch more flies with honey. Otherwise I will resort to not respecting my elders :=

[Frank Arouet]

http://www.casa.gov.au/rules/1998casr/139/139m01.pdf

Definition Meaning
Aerodrome A defined area on land or water (including any buildings,
installations, and equipment) intended to be used either wholly or
in part for the arrival, departure and surface movement of aircraft.

[Joker 10]

8 minutes at 180 knots = 24 miles somewhat over the top methinks and in some areas will cause all sorts of confusion as places 48 miles apart are not an oddity on the Eastern Coast so if you transit between 2 places 48 miles apart at better than 180 knots do you have to alert both ????

This is really silly stuff, what happened to common sense 10 miles inbound for low performance < 120 knots and 15 miles for high performance.

Seemed easy to me and has stood the test of time.

[peuce]

Definition Meaning
Aerodrome A defined area on land or water (including any buildings,
installations, and equipment) intended to be used either wholly or
in part for the arrival, departure and surface movement of aircraft.

My bolding and underlining.

[Frank Arouet]

CASA Please take note;

I "intend" to use my plot of land that is 8 nm from a regular RPT route, but more than 10nm of an RPT aerodrome, but in class G airspace, and I may "intend" to operate up to FL150 depending on whether I feel like it or not for aerial work or aerobatics. I own a Sopwith Zot aircraft that has a cruise speed of 90 Kts. I am thinking of buying a better wireless next year.

Please issue a NOTAM to this effect as soon as possible to prevent anybody who "could" be a conflict to my operations.

I am also installing floats to my aircraft and I may "intend" to operate anywhere up and down the East or west Coast of Australia.

What was that you say? It's up to the pilot who "could" be in conflict" to make him/ herself aware.

I see, common sense really.

[glekichi]

Where the radio calls are mandatory, then the boundaries of the CTAF should be clearly defined, and printed on the relevant maps also.
(3000', or 5000' if you must, and tailor shaped to suit the terrain, aerodrome, IFR approaches, etc.)

At the aerodromes where NORDO aircraft are allowed to operate, leave the calls to airmanship.

[mjbow2]

The adoption of this draconian and uniquely Australian requirement shows that we are no closer to a rationalized regulatory environment in aviation. In fact this is another indication that the ‘regulatory reform’ program is being manipulated in a way that we ‘reform’ the regulations right back to what we had prior to reform beginning. We all should be gravely concerned.

We will now have regulated back into existence the two tiered system of MBZ’s and CTAFs that we tried to do away with, albeit by using the seemingly innocuous name of CTAF and CTAFR’s. Now CASA has the power to prosecute pilots that have no possible way of complying with this unique requirement in certain circumstances.

Far more troubling to every pilot and industry professional is the way in which CASA has ignored the Aviation Policy Statement, CASA’s CEO Directives, the NAS (2c) Post Implementation Review and the Ambidji report findings.

Contrary to the Airspace Policy Statement mandated by the Airspace Act 2007 and contrary to the CEO of CASA’s directive dated 18th of June 2007 CASA has made a regulation that is simply not supported by its stated objectives in these documents

Aviation safety regulations must be shown to be necessary. They are to be developed on the basis of addressing known or likely safety risks that cannot be addressed adequately by non-regulatory means. Each proposed regulation must be assessed against the contribution it will make to aviation safety.

Where appropriate, the aviation safety regulations are to be aligned with the standards and practices of leading aviation countries, unless differences are required to address the Australian aviation environment and these differences can be justified on safety risk grounds. Where the standards and practices of the leading aviation countries vary, CASA will align its regulations with those that effectively address the safety risks in the most cost-effective manner.



And from the Airspace Policy Statement mandated by that Act.

the simplification wherever possible of airspace architecture and procedures. Airspace and procedures design must be simple and logical and supported by comprehensive training and education programmes;

Australian airspace management would be modeled on the US National Airspace System (NAS). This was to align our airspace classification system with the ICAO system and also to model our system on the proven US system. The National Airspace System changes have brought benefits to aviation in Australia, and the Government remains committed to its reform objectives, particularly greater flexibility and the allocation of air traffic management services on the basis of risk.

Here are some remarks made by PCR Australia in its Post Implementation Review of NAS 2c.

[the training] package did not constitute the effective training tool required to educate Australian pilots

It is obvious that, based on the accident and incident data supplied by the Bureau [ATSB], there has been no measurable change in the level of safety of operations as a result of the introduction of NAS 2C.

To summarise, the safety record of the NAS 2c changes has to date been a good one.

It is appreciated that in many cases a reduction in safety is perceived, but this perception may not be supported by reported incident data.


The NPRM is not supported by a measurable drop in safety. This NPRM is not supported by any identified safety need.

Yet it is required to be assessed "against the contribution it will make to aviation safety". Clearly this was not done or at best ignored.


The Ambidji Group CTAF v CTAF-R final report finds that the FAA uncontrolled airport CTAF procedures while only recommended and not mandatory experienced an extremely high level of compliance and safety that is supported by “a plethora of education and guidance material”.

PIR findings indicated that training and education was significantly inadequate and rated mention 6-1 compared to regulations in the document. Nearly every submission made by stakeholders pointed to inadequate training. The review strongly advised of the need to seek expert guidance on completely new training material.

Not once did the PIR make reference to the lack of regulated mandatory radio calls being responsible for failures of safety at CTAF airports. It is clear from the Ambidji report that CTAF radio procedure coupled with traffic pattern compliance was key to keeping separation incidences low both in Australia and world wide.

Why did they subject the industry to a regulation that by their own studies have shown will yield no safety benefit. Is it because this is ‘the Australian way’?

Are we so predisposed to overly prescriptive measures that CASA rushes to regulate that which would be more effectively served by better education and training? I think so.

The concern I have is that even though the Green Paper has stated that CASA should get through the regulatory reform process in the next 2 years, we are going to take the old ways, run them through the ‘reform’ process and come out the other end with a rehash of what we tried to move away from.

Have we really moved on from the two tiered system of MBZ and CTAF or have we merely done away with the MBZ name and mandated it right back into existence through 'reform’?

[GaryGnu]

mjbow2,

Your second quote from the AAPS merely referenced the decision taken by the Government in 2002. The efficacy of that decison has been debated here and in other places ad nauseaum. To use that as objective support for your argument against the changes in the Draft NFRM is a little disingenuous.

However, you quite rightly point out that this goes someway to returning to the two level MBZ/CTAF system. I haven't had time to refer to the PCR report again but I recall at the time of reading that there was a significant theme in the report of industry questioning the need for the NAS 2c changes in the first place. Perhaps those same industry types have convinced CAS/OAR of the need to revert part of the way back to what we had. What was so wrong with them in the first place that they needed changing? It certainly would have avoided most of the debate we have had since.

To those who have read the draft NFRM. Has it been decreed by CASA that aircraft carrying a radio in a CTAF not designated under CAR 166A (i.e not a CTAF [R]) must make the appropriate broadcasts and is that decree contained in any changes to the regulations and/or legislative instrument(s)?

[Spanked]

Oh no, lord help us. Australians and non controlled airspace. Let the pedantic wailing and nit picking begin. Get over it guys, the rest of the world has.

[LeadSled]

mjbow2,

You've just about covered all the bases on this one.

Far more troubling to every pilot and industry professional is the way in which CASA has ignored the Aviation Policy Statement, CASA’s CEO Directives, the NAS (2c) Post Implementation Review and the Ambidji report findings.
And I could add a few other studies, Government policies, OBPR etc., that all support the above, but since when (sadly) was evidence based, risk management justified rule making ever acceptable to a particular (not all pilot unions) pilot union, or several middle management identities in Regionals, and their sundry fellow travelers, to whom such evidence based rule making is anathema ---- particularly if the US is mentioned.

Who have demonstrated, over many years, that they are totally unmoved by anything that is contrary to their long standing beliefs that, unless the magic incantation "mandatory" was included, bodies would rain from the sky. Further, only "prescriptive" rules "work", under no circumstances are pilots to be allowed judgment calls, when it comes to "radio procedures".

In fact it has been clearly stated by this group, and past CASA legal counsel, that this group does not consider Australian pilots sufficiently mature to handle "outcome based rules" ( as do their peers elsewhere) , but must be bound by rigid criminal law based prescriptive and strict liability regulation ---- thereby making safe conviction so much easier to achieve ---- and if anybody wants to argue the toss about the existence of this view on the "maturity" issue, it's all in CASA records.

The last CASA CEO put in place a number of good programs, but in this area, unfortunately, it seem he always caved into to this small group.

Indeed, for those who have been actively involved in (long term) research into "what works" to reduce risk, ie make it safer, all research results illustrate that prescriptive rules are the wrong way to go. This not only aviation, but across the industrial safety spectrum.

Safety management in Australian (and elsewhere) has largely long since abandoned the legalistic prescriptive approach, for far more effective risk minimization strategies ---- and the results show ----- but not in Australian aviation, as is so clearly demonstrated in the whole CTAF saga.

Interestingly enough, this whole CTAF running sore is so clearly contrary to much other work that CASA, itself, is doing in promoting safety management systems, to name one program, amongst some very commendable current safety promotion programs.

There is a Senior Counsel's opinion re. the draft NFRM floating around, this really legally picks apart the draft CAR 166, and that is how you will be picked apart in court, by what the words legally say, not what bush lawyers think they say. The SC puts together a startling and frightening detailed picture, if you are the poor sodding PIC trying to "stay legal", where the "the letter of the law" makes it impossible to "comply".

Tootle pip!!

[LeadSled]

Folks,
SCOOP SCOOP SCOOP

In hearings in the Senate RRA&T, this afternoon, John McCormick, the new CASA CEO, announce that this NFRM is now on hold, and other comments sound like it is almost "back to the drawing board".

McCormick also made a number of very sensible comments about the evidence (or lack thereof) for the CTAF/CTAF(R) division, and detailed the research evidence that shows very high compliance rates with radio calls by all pilots, regardless of whether various radio calls were "mandated".

In short, he said that there is no evidence that "mandating" improves compliance to any significant degree. Whilst reading Hansard will not be as entertaining as actually seeing this afternoon's proceedings, the transcript will be well worth a read.

What a refreshing approach to an old chestnut.

Tootle pip!!

[Frank Arouet]

The power of Pprune.

Assisted of course by some interested bystanders in maintaing some sanity over the excesses of The Office of Legal counsel and their "compliant" baggage posing as representatives of the masses.

[LeadSled]

A PS to my last post:

Senator Bill Heffernan, from NSW, was very direct in asking CASA OAR just what present airspace policy was in place.

By my count, Heffernan asked three times, to make certain he understood the answer.

I am certain that it came as a surprise to many in this afternoon's Senate RRA&T hearings, to listen to Peter Cromarty, Head of the CASA Office of Airspace Regulation, come out so firmly in support of the current Government airspace policy, as contained in the Airspace Act and Regulations, in particular the current Airspace Policy Statement.

As some of you will know, the Airspace Policy Statement is under review, and believe me, the current draft needs serious work.

Bill Heffernan even asked him if ,"as a pom", words to the effect how he really supported a US based system for the Australian NAS, and not a "pommie" system.

In answer to (at least) the three questions on the subject, Cromarty came down very firmly on the side of the present policy,adopted years ago, which is, in reality, an ICAO compliant NAS very closely patterned on the US NAS ----- and we all know what the trogs think of that!!

It was good to hear that he is such a firm supporter of risk management based and cost benefit justified allocation of airspace management resources (which will never be unlimited ,you should have heard AA explain the controller shortages a little before CASA "took the stand") to produce optimum air safety outcomes **, ------ and very clearly not keen on some "do it yourself policy" that is just a bunch of motherhood statements, with no serious policy content or performance requirements.

Any suggestion that the current ICAO airspace classification, A to G, was going to change any time before 2025 plus, here or in the US, ( or anywhere, really) was also very thoroughly scotched. This will come as a disappointment to those who think alphabet soup airspace is headed for the scrapheap, in favor of some "controlled/uncontrolled" brave new world of ATC "knowing all traffic" ---- despite some suggestions, a few years ago, from a low level ICAO CNS/ATM "Wet Dream Team".

I guess this will all be available, in print in Hansard, it takes about a week to come out.

Tootle pip!!

** One thing we could copy from Eurocontrol is the publication of target standards of CNS/ATM risk levels, and actual achieved risk levels.

[Sunfish]

What concerns me is that the entire system seems to be designed to generate the maximum possible amount of work for lawyers.

I have been privileged to be at the centre of quite a few research commercialisation deals that always involve quite complex legal agreements. Working with really good lawyers taught me is that the highest form of their art is about finding solutions to problems.

When I went to the big law firms and spoke to their partners, with the exception of the blessed David Wells at Mallesons, all I ever got was a recital about the complexity of my problem and the many issues that it contained, and how these would all require extensive, and of course expensive, study by the firm. I never got a simple answer, except from Wellsy, God rest his soul.

When I look at the way the regulations are written, I don't see the essential clarity that should always be at the heart of good law and regulation. Instead all I see is a mish mash starting with a blanket "Thou shalt not", followed by various clauses providing exceptions to the blanket prohibition. This seems to me to be a stupid way to write regulations, since it implies that the behaviour concerned is regarded as unsafe except for the three or four behaviours specified in the exception clauses.

It seems to me that it would be far better to reverse this technique and put the onus of proof on anyone contravening the rules to demonstrate that the breach did not make anything less safe...but that wouldn't make much work for lawyers would it?

[Jabawocky]

Frank, I can only assume the power of pprune allowed a few interested folk become alerted to this issue, I do hope you do not sincerely believe it was this that was the major force in change of mind at CASA.

McCormick also made a number of very sensible comments about the evidence (or lack thereof) for the CTAF/CTAF(R) division, and detailed the research evidence that shows very high compliance rates with radio calls by all pilots, regardless of whether various radio calls were "mandated".

Having had some close range exposure to the study phase.......I would say this is very much the case.

A job well done by individuals and groups involved.

Now all they need to do is sort out the BS about the mandatory calls and some other rules for CTAF R and it may actually be "Worlds Best Practice" downunder. Won't hold my breath. :suspect:

J

[mjbow2]

GaryGnu

you say
To use that as objective support for your argument against the changes in the Draft NFRM is a little disingenuous.

NAS is still government policy!

It is hardly disingenuous at all. The changes to CAR 166 defy government policy and worst of all, is not supported by any safety case.

[Capn Bloggs]

The first time a 717/737/F100/146/A320 clocks a no-radio bugsmasher in a CTAF, you fanatical non-mandatory types will run for cover and radio use at jet CTAFs will be mandated. Too bad about the 100 lives it cost. :ugh:

The only reason you don't want mandatory radio is because you want to operate no-radio. Why on earth are you so opposed to it otherwise?

NAS is still government policy!
Rubbish. It's Dick Smith's policy which was swallowed by his pollie mates.

[megle2]

My information was that the 8 minutes related to what the regional Dash 8 drivers thought they could work with!

[Capn Bloggs]

This timing business has always been a furphy. The idea is to announce to RPT when you are in or going to be in "their" airspace. A fixed distance, eg 15nm/5000ft is much simpler and less confusing.

As for all those NAS calls, if the other aeroplane is on the CTAF, most calls are not necessary as you can talk if required. Turning base/5nm final is all that is needed. If they are not on the CTAF (heaven forbid), the number of calls you make are irrelevant.

[LeadSled]

Bloggs,

Why don't you go and read the (just for starters) Airservices Airspace 2000 research reports into what actually happened at CTAF/MBZ, ditto Rob Lee's PCH report, ditto the most recent, the Ambidji report, for the facts on what pilots actually do around airfields in Glass G airspace.

Then read what CASA's McCormick actually said, in the Senate hearings, about compliance rates for calls in CTAF/CTAF(R) ----- his whole point is that the magic word --- "mandate" ------ makes no difference to compliance rates.

If your belief systems tell you otherwise, that's fine, freedom of religion is enshrined in our Constitution, but to produce the best possible safety outcomes, I prefer informed fact based rulemaking.

As to Government airspace policy, is how it got into legislation the point? The facts is that the Airspace Act and Regulations package is in place, it incorporates (as part of the legislation --- enforceable) the Airspace Policy Statement.

As I recall, that legislation was supported by Labor, when in Opposition.

Tootle pip!!

PS: I do most sincerely recommend you read the proposed radio requirements in CARs 166 NFRM.

[Capn Bloggs]

So, Leadsled, what then is to stop the Gen Y/AOPA activist/red-neck/non-conformist buying a small bugsmasher and setting up, without a radio, at any of the CTAF Rs? He doesn't need a radio, much less a transponder, so why should he get one? Or the cheapskate who's radio goes U/S. Why does he need to get it fixed? Commonsense, as exhibited by your attitude ("the studies don't support it so we shouldn't do it") has disappeared from aviation, so don't pull the "oh he'd get it fixed because he knows his life depends on him knowing what is out there" claptrap.

Compliance rate studies up until now are in the main irrelevant, because up until NAS 2c, if you've had a radio, then you have had to use it in CTAFs (and obviously in MBZs). I have not seen any studies of how many aircraft operate into CTAFs without radios.

As to Government airspace policy, is how it got into legislation the point? The facts is that the Airspace Act and Regulations package is in place, it incorporates (as part of the legislation --- enforceable) the Airspace Policy Statement.

As I recall, that legislation was supported by Labor, when in Opposition.

No, that's not the point. Just because it is in legislation doesn't make it good policy. Do you seriously believe that 95% of pollies know anything about the subject? Policy has everything to do with the perpetrators/lobbyists, not necessarily commonsense.

I will say again, the first time a jet has a major scare with some twit without a radio (or one who chooses not to use it), you jokers will be running scared. I just hope it isn't me, and I survive. And yes, I have had my share of close calls.

Ambidji:
Non-radio aircraft able to access the airspace:
Very high standard of scanning required; The worst case scenario of high speed, head on closing gives very little time for avoiding action when the traffic is unknown; Recommendation from the then Bureau of Air Safety Investigation (BASI) that “un-alerted see-and-avoid is never the sole means of separation for aircraft providing scheduled services” (Note: the word “never” in this context has since been overtaken by the Australian Risk Management Standard)

I ask again:
The only reason you don't want mandatory radio is because you want to operate no-radio. Why on earth are you so opposed to it otherwise?

Why isn't anybody prepared to answer?

[Jabawocky]

Bloggs

What do you think of this idea. CTAF R with mandatory radio and Mode C minimum. CTAF R boundary based on say 10,000' and at 2000fpm/200kts average is 16.66 nautical miles.......:ooh: Starts to sound familiar! CTAF R = 15 miles/10,000 feet

CTAF's do not really need any strict boundary, just a 10 mile 3500AGL as a guide, but the CTAF R all of a sudden sounds like an old MBZ:E.

J:ok:

[positivegee]

Has a B747 ever operated into a CTAF-R in Australia?


Yes, a 200 series into Longreach a few years ago. Part of the QANTAS Museum, never to fly again! :ok:

+G

[LeadSled]

Bloggsie,
You have the answer, but can't see it.

Quite simply, there are not legions of pilots out there who want to fly around "no radio", this is all a myth, and all the research shows it is a myth. Likewise pilots operating in "stealth mode", to avoid charges, largely a myth.

Most of the identified cases (with one exception) of "non-compliance" have turned out to be finger trouble, the biggest "offenders" are those most likely to be "there" ---- professional pilot, like the SAAB crew recently in northern NSW, all the calls were probably wonderful, pity all they did was turn the lights on. Nothing intentional, just what most of us have probably done from time to time. Center just loves passenger PA's on frequency, particularly when the hapless sod announces his/her name to the several (in US-- several hundred) others on the same frequency. Welcome Captain Speaking, the world's best known Captain, anybody remember the "Captain Speaking" trophy over the old Bushie's Bar?

The "exception", ag. pilots at several centers (CTAF(R))---- not the dreaded "blundering bugsmasher" ,"Weekend Warriors" etc. By and large, this is one area where all pilots, regardless of license (or certificate) type, have been consistently shown to exhibit a very good level compliance and, in my experience, CBS.

But you will have to look at the records of the last Safeskies to learn about CBS.

As McCormick correctly stated, there is a demonstrated 96-98% compliance with radio calls at all CTAF/CTAF(R) for all aircraft, not just with those with a radio.

Three studies, all conducted at considerable expense, over about a 10 year period, all coming up with essentially the same findings ---- but some will never accept such challenges to their belief system, that's their right, your right, but no basis for rational regulation making.

McCormick is on the right track. Evidence/fact based rulemaking, not anecdotal war stories.

Tootle pip!!

[Capn Bloggs]

Leadsled,

there are not legions of pilots out there who want to fly around "no radio", this is all a myth, and all the research shows it is a myth.

I've done a search of the Ambidji report for NORDO. From that, it appears they didn't make any attempt to find out if there were any NORDO aircraft in their survey. Aircraft that didn't participate on the airwaves, yes, but NORDO?

there is a demonstrated 96-98% compliance with radio calls at all CTAF/CTAF(R) for all aircraft, not just with those with a radio.
"Not just those with a radio"?. I didn't realise that NORDO aircraft could make radio calls.

So, from the numbers, the Ambidji report emphatically indicates that CTAF (R)s improved compliance rates by 2%. 2%!! And you are willing to ignore that? 96% may be near enough for you, but the 100+ punters down the back would probably be a little more concerned with the odds, considering most of the design safety standards for the rest of "the system" require failure chances in the order of 0.001% or less, I believe. If mandating radio carriage and use made only another one % difference, that would be worthwhile.

Which brings me back to my question; No, you haven't answered (no . What is the big issue with mandating radio? It can only be because you want to operate no-radio! Yes or No?

Tootle pip!

I do most sincerely recommend you read the proposed radio requirements in CARs 166 NFRM.
Been looking for it all day. Can't find it. Got a link?

[LeadSled]

What is the big issue with mandating radio? It can only be because you want to operate no-radio! Yes or No?

Bloggsie,

NO, spelt with a big N and a big O.

If you had half a clue about modern approaches to safety management (ie anything in about the last 20 years) or perhaps, read and understood any of the works of Hudson, Kern,Reason, Lees, Hall and so on, or any of the masses of data, research, field studies, and years of statistics, QAR analysis, operational (IOSA) audits etc., on what works and what doesn't, you might come to understand why "mandating" and prescriptive rules do not produce a "better" result, let alone the best result. Or put another way, the value of performance (outcome) based rules, instead of prescriptive rules with criminal penalties.

We know aviation is lagging much of Australian industry by many years in the field of safety management, but try and make some attempt to catch up with the knowledge of what works best, so far (and it ain't prescriptive regulation) in a field like flight operations.

We do want the best results, don't we ---- in this case minimizing the risk of a collision. I certainly do, I might be one of the passengers.

If you had some current background, you might begin to understand that "mandating" produces no detectable "better" results, and a range of negatives. One of which is complacency that "all you can hear is all that's there", not much use when all you have done is turn the lights on. Or you'r still on center, but out of range of the selected frequency, because you missed the change of center frequency you read back, as well as never broadcasting on the CTAF for your destination.

Don't read too much into 96-98%, apart from observational error, the AA figures showed the opposite, greater compliance in a CTAF than an MBZ, but a very high level of compliance in both cases. This goes double (not precisely double, just an expression) in an environment where "rules" cannot be enforced, anyway.

As you don't seem to be able to comprehend, the cases of non-compliance (with the mentioned exception) were mostly finger trouble, nothing to do with intentional non-compliance.

Wouldn't be a wonderful world if all we had to do achieve a perfect airsafety record was to "mandate" that pilots never make an inadvertent mistake, and where there are survivors from such a mistake, prosecute them as a criminal.

Just to reinforce the "value" of such a rule, perhaps we could make it absolute liability, not just a strict liability criminal offense, to reinforce in the mind of the flying potential criminal the draconian penalties for selecting the wrong mike switch, or selecting the wrong frequency, or any other of the variety of inadvertent non-compliances that come under the generic term:"finger trouble".

By the way, has it occurred to you that field survey teams might devise cunning ways to detect "non radio" traffic, perhaps those amazing observational devices called eyes, artificially aided by extraordinary devices called binoculars. And a little ripper called a digital camera with a thingie called a telephoto lens for easy identification of aircraft.

Amazing, some of the gadgets "they" have these days.They even have this beaut little voice recorder, so they don't even have to worry about a writing stick. Will modern miracles never cease.

Tootle pip!!

[Sunfish]

I thought the question being discussed was the proposed requirement that radio calls be made "in the vicinity of" every airfield even when in transit. I have no qualms about mandatory calls if I am going to that airport. But in transit? And on what frequency?

As it is, going to YMIA from YMMB via Kerang, my calls include: advising on area frequency when entering corridor to Kilmore, then calls overflying Mangalore, past the DZ at Nagambie, YKER and YSWH. You want me to make a call when I'm abeam Echuca and overflying Robinvale as well? On Unicom, CTAF or area frequency?

[peuce]

I remember when a very cluey ATC Manager type once said that the Manual of Air Traffic Services should be re-written in one page.

And on that page should be the words ... "Don't let the bastards hit !