NPRM. VOTE for Mandatory Radios and joining on base etc

[VH-XXX]

Civil Aviation Safety Authority - NPRM 0908OS - Carriage and use of Radio and Circuit Procedures at, or in the vicinity of, Non-Towered Aerodromes (http://casa.gov.au/scripts/nc.dll?WCMS:PWA::pc=PC_93417)

Competition closes Friday 23rd October so get your votes in.

Carriage and use of Radio and Circuit Procedures at, or in the vicinity of, Non-Towered Aerodromes

Key change proposals

The objective of this NPRM is to provide an opportunity for public and industry comment on changes being proposed by CASA to requirements relating to radio carriage and use by pilots operating at or in the vicinity of non-towered aerodromes, and to the current requirements for straight-in approaches and circuit procedures at non-towered aerodromes

General, performance based regulatory requirement for radio qualified pilots of radio equipped aircraft to make appropriate radio broadcasts at and in the vicinity of all non-towered aerodromes, with specific, recommended standardised calls published in educational and guidance material (CAAPs/AIP). PIC is to be responsible for broadcasting on the aerodrome frequency whenever it is reasonably necessary to do so to avoid a collision, or risk of a collision, between his/her aircraft and any other aircraft operating at, or in the vicinity of, the aerodrome.
Carriage of serviceable VHF radio, and being qualified to use it, to be mandated for aircraft operating at or in the vicinity of aerodromes that are certified or registered (as published in ERSA) and other aerodromes designated by CASA (and published in ERSA) on a case-by-case risk basis.
Introduce new provisions for the arrival and departure of aircraft with no radio, and for aircraft having unserviceable radio and for aircraft carrying serviceable radio which the pilot is not qualified to use.
Withdrawal of CAR 166 paragraph (2)(d) and subregulation (4) - base-leg circuit join no longer prohibited.
Amend CAR 166 paragraph (2)(f) to allow for non-into wind runway use when the AFM permits.
Withdrawal of CAR 166 paragraph (2)(g) - 500m minimum length of the final approach leg no longer mandated.
Withdrawal of CAR 166 paragraph (3)(a) – carriage of a serviceable VHF radio when conducting a straight-in approach no longer required (other than at certified, registered and other designated aerodromes).
Withdrawal of CAR 166 paragraph (3)(b) – specific mandated broadcast for straight-in approaches deleted (although still recommended in CAAPs/AIP).
Amendment of CAR 166 paragraph (3)(d) - reduction in the minimum distance from the threshold by which an aircraft making a straight-in approach must be aligned with the runway, from at least 5 miles to not less than 3 miles.

[Recflyingdotcomdotau]

Not on my watch!

[D-J]

1 vote for sensible radio use..... :ok:

for the most part I agree with what they've come up with & I don't think by any means is it a burden on RAAus members to fit & properly use a radio

[maverick22]

Recflying,

are you against the proposed changes in general or just the mandated use of radio in the vicinity of an aerodrome?

I think it makes total sense having to use a radio. In the interest of safety, the cost of installing and using a radio can't be such a ridiculous ask can it? Compared to the cost of owning and operating an aircraft, they are pretty cheap really...

[triton140]

As a recreational flyer, I reckon the radio proposals are sensible and pretty innocuous really since most of us carry and use radios anyway.

Overall, I'm happy with the other changes, although I did wonder a bit about the non-standard approaches (base joins, no mandatory broadcast for straight-ins and non-into wind) - my first thoughts were it just increased complexity in the circuit with the potential for confusion - at least in the standard circuit you have a pretty good idea where the traffic is coming from.

But on reflection, I thought why not - we need to actively look out for traffic and not just assume where it might be.

So seems OK ......

[AussieNick]

as far as i'm concerned, the safety/situational awareness provided by a VHF radio should mandate that all aircraft be equipped with one.

[AirBumps]

Agreed. If your going to fly into a field in use by others, people need to know what the hell your doing. The idea that RAAus aircraft don't need to be fitted with radios is crazy.

[D-J]

What does everyone thinl about the removing of the manditory straight in calls?

personally I think they should be kept manditory with intentions at inbound call & establised final at 3nm with calls at 3 & 1nm

[Frank Arouet]

This subject thread was posted on 29th September permalink #1, (about 3 pages ago), and VH-XXX posted permalink #3 in response;


Quote:
Withdrawal of CAR 166 paragraph (2)(d) and subregulation (4) - base-leg circuit join no longer prohibited.
Yay, thanks Dick!

Quote:
Amend CAR 166 paragraph (2)(f) to allow for non-into wind runway use when the AFM permits.
Way cool. Finally I can do this without people having a whinge about it!

Quote:
Withdrawal of CAR 166 paragraph (2)(g) - 500m minimum length of the final approach leg no longer mandated.
Great! Better looking go-arounds (beat-ups).

Quote:
Withdrawal of CAR 166 paragraph (3)(a) – carriage of a serviceable VHF radio when conducting a straight-in approach no longer required (other than at certified, registered and other designated aerodromes).
Not good, but with the other NPRM out there for the mandatory carriage of VHF it's not going to matter soon probably.

Quote:
Amendment of CAR 166 paragraph (3)(d) - reduction in the minimum distance from the threshold by which an aircraft making a straight-in approach must be aligned with the runway, from at least 5 miles to not less than 3 miles.
Whilst I don't agree with this one 100%, it's more practical as it's what everyone does already. As long as 3 miles doesn't become 1 mile, but likely less of a problem with the ability to join on base.


:confused:So VH-XXX, why did you feel the need to start another thread when you could have simply got permalink #1 back on the front page and continued the discussion by simply adding one more reply? Things like this make for fractured and disjointed reading and doesn't encourage current participants to read what others have said before -and those that have contributed probably don't see the need to say everything again.:(

By not keeping the original topic on the front page, 7 days have probably been wasted in getting responses in to the NPRM.

EDIT TO ADD and to emphasise how disjointed the thread can get:

The D&G GA and Questions thread had 8 responses not including the posters and I posted the same subject the day before on Reporting Points 28 September with 14 responses.

[Capn Bloggs]

What does everyone thinl about the removing of the manditory straight in calls?
I don't have a problem. The problem with the "old" NAS 2C system was that aeroplanes would do their own thing announcing what they were doing and others would use that information to avoid them. All well and good in theory but not so much in practice as it clogged up the airwaves with unnecessary calls that were, in a lot of cases, unneeded, especially in a lighty-type visual circuit when unalerted see and avoid is a more practical option.

All that is required is that each aircraft announce it's presence and intentions so that others can, if necessary, arrange segregation or stay out of the way, combined with for example, a "call when you're on 3nm final".

Unfortunately, there is no ideal solution. At least the proposed rules allow more flexible radio use. Which, oddly enough, was just the way it was before Dick started mucking around with it! :=

Frank,
If the mods spent less time on keeping DEFCON4 under control and more on managing the board, we'd have a merged NPRM topic by now...:}

[goldypilot]

bring in the communitcation

[VH-XXX]

http://images.ibsrv.net/ibsrv/res/src:www.pprune.org/get/images/smilies/confused.gifSo VH-XXX, why did you feel the need to start another thread when you could have simply got permalink #1 back on the front page and continued the discussion by simply adding one more reply?

When you get an iPhone Mr. A you'll realise why.


New threads get the attention of readers and this one now has the words "NPRM vote for ...." in it, which will make people look. Had I added the link to the old thread many people would have probably missed it.

The old link said: CASA Proposed Rule Changes for Non-Tower Aerodromes (http://www.pprune.org/dg-p-general-aviation-questions/390513-casa-proposed-rule-changes-non-tower-aerodromes.html)

I would almost consider not opening that so that's why I posted with a catchy name, plus searching on the iPhone is a pain-in-the-butt.

7 days have probably been wasted in getting responses in to the NPRM.


There's still plenty of time left, even for those on dial-up or those that rely on the postal service!

[ZappBrannigan]

I have no problem with most of this. I particularly agree with manadatory VHF carriage and use - it's not as though a VHF radio is high-end, high-cost piece of equipment (in aviation terms), and basic reporting of position and intentions should be absolutely standard and required at the least at all licenced/registered aerodromes, as suggested. More than once I've been grounding 180+ kt with 10 POB inbound to a CTAF, popped out of cloud and had to take minor evasive action due to somebody randomly flying a shopping trolley with a prop in the vicinity of the A/D with no radio/radio calls of any kind.

No problems here either with base joins - the key as always is communication and traffic management, a base join is the same as a straight-in or any other join. Don't have a problem with the straight-in calls being recommended instead of mandatory - again, common sense applies. I'll admit, when conducting a straight-in with no other aircraft nearby, I sometimes forget the 1nm call. In line with what Capt Bloggs said, I sometimes think that I'm clogging up a CTAF freq with unecessary calls (especially up north where you might have 6+ aerodromes in the one area on the one freq in radio earshot of each other) when I make an inbound/intentions/established call, followed by a 3nm call, followed by a 1nm call, when there's no other aircraft in the immediate vicinity of that A/D.

[Frank Arouet]

VH-XXX;

I have reported the post to the mods asking that they merge them all.

If you believe it will get better attention with your "catchy" title, click the icon in the bottom and report the post to the mods with a request they merge it under your thread. It doesn't worry me as long as it gets the attention it deserves.

While you are at it start another thread pushing for mandatory iPhone's Mr X.

[aileron_69]

About time they dumped the no base joins rule. Almost looks as though CASA might be trying to let people use common sense instead of regulating the living hell out of every single little aspect of life in and around the sky.:E

[Capn Bloggs]

Aileron, I look at it as a natural progression. Now that everybody will be on the radio, pilots will know where to look and so a base join becomes feasible.

In the old days, when no-radio was the norm, it was fair enough to limit how pilots entered the circuit so that others only had to look in certain areas for other aircraft. It would have been impossible to look everywhere and maintain an acceptable safety level.

[aileron_69]

You make a very valid point my learned friend. Now if only we could get them to turn their radios on and listen to them, then couple this with a good lookout....:E

[cficare]

If the price of having the proposed changes is the installation of a VHF radio then I reckon the CEO of CASA just conned heaps of aviators into more expense, less safe procedures and (in the future) another opportunity to further restrict flying activities (due to an increase in incidents/accidents).
By the way. the NPRMis not a vote, It's an opportunity to put a position forward.

[Frank Arouet]

The NPRM is an invitation for industry input.

There are key words that should be noted in VH-XXX' first post on this thread among other things the requirement that pilots using a serviceable VHF radio should be "qualified".

This point should sort the wheat from the chaff if recreational pilots are as qualified, if not as proficient, as professional pilots by way of correct training.

The word mandate is only used in relation to the "vicinity" of licenced aerodromes or those published in ERSA "on a case by case basis" (which would lead me to suspect a modified name for an MBZ will be used), and it makes provision for non radio equipped aircraft, non qualified pilots and radio failure. It would seem the majority of aerodromes and airstrips where recreational aircraft operate are exempt from any great changes.

The majority of the NPRM deals with procedural changes.

As an ardent supporter of "alerted see and avoid" I personally don't see anything wrong with the major radio changes and support any provision that would allow non radio aircraft access, that in this case, would be the exception rather than the norm. I can get used to the procedural changes.

Whatever your leanings, people should submit their ideas to the NPRM, even if it is only to agree with the proposed changes, because in CASA's case, the lack of paperwork indicates to them the usual Australian apathy and they may use this to claim a mandate to do whatever they want. Usually at a cost to the participants.

[Frank Arouet]

The NFRM for CAR 166 & 166A should be out about now?

Non flying friend did a TIF at a small country aerodrome on the weekend and was advised of the following radio requirements;

Preceeded with "all stations xxx" callsign and at the end of each transmission "xxx"

1) Taxi with intentions.
2) Enter movement area.
3) backtracking.
4) Rolling.
5) Departure with details if leaving the circuit.
6) Inbound 10 miles.
7) Inbound 5 miles.
8) Crosswind.
9) Join circuit.
10) Downwind.
11) Base.
12) Final with intentions.
13) Clearing runway.

It will be interesting to see what, if any attempt has been made to streamline this amount of confusing chatter on the same 126.7 frequency as being used in neighbouring aerodromes.

Other than the stated base call and the straight in calls what else will we see changed?

[b_sta]

You would hope that common sense would precede making every single one of those bloody calls. With some shorter strips, no sooner would you have finished a leg turn call than you'd be starting the next one :ugh:

[Unhinged]

was advised of the following radio requirements

Even though the current recommended/required calls are stupid, that list far exceeds the recommended calls, and "all stations" was superceded years ago. Like far too many instructors in our game, whoever was in the other seat had simply made up their own rules and put them up as gospel. Just the kind of person to give flight instructors a bad name.

We do need to sort out the radio requirements, but we also need to sort out "pilots" like this who make it harder for all of us.