Full Industry Defies CASA CTAF Ruling

[Dick Smith]

Despite meetings with the various RAPACs and with AOPA, it appears that the CASA ”Iron Ring” is still maintaining that pilots operating at aerodromes not marked on maps must give calls – including taxiing calls – on the air traffic control area frequency which is also used to separate traffic.

Since CASA issued the NOTAM I have carefully monitored area frequencies when I fly and I have not heard one pilot comply with the CASA ruling. I have also checked with an air traffic controller who monitors over seven frequencies – he, once again, has not heard one pilot complying.

Notwithstanding this, it is clear that CASA will not change the ruling. It is obviously impossible for CASA to admit to making an error. I wonder how many other CASA regulations are simply ignored by the industry?

Can someone please post what the current position is in relation to negotiations on this issue between RAPAC, AOPA and CASA. Is there any light at the end of the tunnel?

[triadic]

It is understood that the subject it is still on the table at some of the RAPACs. The OAR, last year, rejected the subject for discussion at most RAPACs but seem to be relenting a bit of late. They say it is not a matter for the RAPACs ! Blimey, the RAPACs have always discussed Procedures which includes what you say on the R/T. I hear that recent letters from CASA have not engaged further and it seems have pulled the shutter down. Like you say Dick, it seems they cannot ever admit they are wrong. Someone in the Iron Ring maybe ?

Yes, it's a dumb decision and there seems to be very little compliance ?

Just have to wait for an incident where Comms between a high flyer and centre is jammed.

[Dick Smith]

I love it! Yes I heard that one . RAPACs were told that discussion of this issue was not permitted by CASA management.


The organisation is disfunctional. It will be fascinating to see how this ends up.

[Hempy]

Just don't get involved in an accident after your non-compliance. It wont sit well with the judge.

[David75]

CTAF radio procedures have always been a ugly compromise anyway - unless operating/monitoring with 2 radios - one on area and one on CTAF.


1 aircraft just inside CTAF on CTAF freq & 1 aircraft just outside CTAF on area can be broadcasting correctly just not talking to each other and heading straight for each other.


Jandakot- Rottnest is a classic. Luckily Perth Centre has radar to advise the area frequency aircraft of the other aircraft. And Rottnest is marked on maps...

[triadic]

Hempy: Just don't get involved in an accident after your non-compliance. It wont sit well with the judge.

You have it wrong... It will be your compliance that might contribute to an incident ( or worse..)

[FoolCorsePich]

The irony of this issue is the fact that the only way to get this rule repealed would be if everyone actually complied with it.

[Squawk7700]

1 aircraft just inside CTAF on CTAF freq & 1 aircraft just outside CTAF on area can be broadcasting correctly just not talking to each other and heading straight for each other.

That is simply called VFR in a CTAF. See and avoid, it's what your eyes and windscreen are for! No different to class D really unless your friendly controllers are bored and bother to give you updates for traffic outside the zone.


Dick - I've heard the occasional call on centre from a lowly non marked CTAF and I would assume on most occasions that centre can't hear the transmission at all due to the remoteness so I'd be surprised if any complaints would come from ATC. I have a 5 watt VHF with Comant 121 antenna and I struggle to get area freq on the ground even 30 miles from a station.

The guys over the top would be affected but they could literally talk over the top of the ground station and Centre would be none the wiser.

I would agree that compliance is low, but not non-existent.

[Hempy]

triadic, you are preaching to the converted with me, it's the CASA lawyers that you'll need to convince..

Stay safe out there.

[triadic]

Good on ya Hempy, yes and the legals certainly don't now much about the subject matter. Part of the iron ring no doubt...?

The irony of this issue is the fact that the only way to get this rule repealed would be if everyone actually complied with it.

Correct!!

S7700, yes, see and avoid is the prime method of collision avoidance at the lower levels, not putting your head down to change frequencies. There are often many a/c about that are not using radio, let alone the CTAF of MULTICOM.

[cogwheel]

A classic example of Iron Ring speak:

From the CASA minutes of the Regional Aviation Safety Forum (RASF) meeting held 7Oct2014. (from their web page)

7. Regional Airspace and Procedures Advisory Committee (RAPAC) – Radio Calls Issue
Mr Ward (CASA) facilitated a discussion on issues surrounding radio calls at non-controlled aerodromes not marked on charts. This had been raised at a recent RAPAC meeting in Victoria. Mr Ward (CASA) advised that the changes to the AIP were recently made to clarify and align procedures with the legislation. The issue of area frequency versus Multicom was discussed amongst members and no safety issues were raised. Mr Cromarty (CASA) advised members that this type of issue is not one for RAPAC as it is not an airspace issue but rather a pilot (frequency) issue. Mr Thorpe updated the members on the discussion that was held at the Victorian RAPAC meeting in relation to this issue. Ms Bailey (RA-Aus) advised she would take the opportunity to raise this matter with the RA-Aus CFI’s at their upcoming conference in November 2014 and relay any information back to CASA if required.

This shows that those in that level of management have very little idea of what goes on in the real world, and it seems they don't really care.

If this matter is not for the RAPACs then what world are these people on?

It seems also that the various divisions within are not talking to one another either, otherwise they might have put forward the change to the RAPACs for discussion. But from the above seems the OAR did not like or want that.

So what are they afraid of? True and open consultation maybe ????

[Dick Gower]

The irony of this issue is the fact that the only way to get this rule repealed would be if everyone actually complied with it. Could not agree more with that quote.

There are three unintended consequences that CASA claim they are not concerned about (I have their letter stating this).

The most serious issue is unintentional jamming of ATS transmissions by aircraft in the weeds. This occurs because there is no area frequency coverage down to lower levels in vast areas of G airspace Australia wide. Consequently traffic in the weeds do not know when ATS is transmitting.

The lack of coverage is not an issue for the original use of the area VHF frequency but it is a serious issue for the May 2013 changes.

So we have now have a unique situation where an expert consultative group is worried about a safety issue but the regulator is not.

It will be an interesting time if there is a serious event because of this.

[Pinky the pilot]

I recently heard a highly experienced GA Instructor and former Charter/RPT pilot say that as far as he was concerned, the sole intention of CASA now appears to be to totally destroy General Aviation in Australia.

I now know that he is correct!:(

Can they be stopped from doing so, and if so, how?:confused:

[Ultralights]

from what i have seen over the last few decades working and living this industry, is that CASA is not out to intentionally ruin or destroy anything. you have to think of CASA as a bureaucracy in that every department is made up entirely of cats. (not fat cats, the 4 legged furry kind) as in, every single one has its own agenda, ideas, attitudes, refuses to talk to any other cats, or anyone for that matter, and goes off totally autonomously at its own leisure following its own rules, that only it made up and understands. put all this into one organisation, and you have a perfect model of CASA.

[poteroo]

Out in the real world, where pilots can recognise a stupid rule from a sensible one - there is absolutely bugga all compliance. Mark Skidmores' standing with industry is going to rise, or fall, with his response to his underlings' incompetence. Let's hope he has the bottle to 'retire' or 'retrain' a few of these fools. happy days,

[tipsy2]

So we have now have a unique situation where an expert consultative group is worried about a safety issue but the regulator is not.

Agree with what Dick says here. It reminds me similarly, CASA ignores/fails to implement findings and recommendations from Coroners Courts as well.

At least they are consistent!:ugh:

Tipsy:E

[Dick Gower]

Here is a response to a request to discuss the issue at the Sep. 2014 AACF. Note the name: Airspace and Aerodrome Consultative Forum.

19/August, 2014.
Good afternoon Mr Gower,

Thank you for your email. I am happy to confirm your attendance at the Airspace and Aerodrome Consultative Forum 13.

Unfortunately I have been advised that the AACF is not an appropriate forum to discuss your submission for an agenda item ‘Broadcast Requirements in G Airspace – Recent Changes’. This is an Operations/Standards issue and has been referred to these divisions of CASA for action.

Please let me know if I can provide any further information or clarification.

Kind regards,

Elle May Starbuck
Administration Officer
Airspace and Aerodrome Regulation Division
Civil Aviation Safety Authority
In other words, in spite of our name we are ducking the issue. I did eventually attend as an observer however. It was a CASA talking at the industry all day with no sign at all of any consultation. A total waste of time.

[The name is Porter]

I'd say pilots are ignoring the procedure because they don't know about it, not because of defiance.

[Hempy]

I'm pretty sure it's a cultural thing within CASA.

Every time a senior position opens up, people apply. When interviewed they are asked 'what can you bring to CASA? How can you make things better?'.

This encourages 'change'. The issue is that, in reality, there are only a handfull of possible solutions for any given scenario, therefore the wheel keeps being reinvented.

In one or two iterations of DAS at CASA, we'll be back to a great, wonderful new system of MBZ's...

[triadic]

The suggestion that presently unmarked airfield/s should be marked on charts is a dream that won't work. What charts? The lead time for most charts is a year or more and for the WACs it can be 4 or more years. Maybe this might change with EFBs, but don't hold your breath. Many such strips would disappear whilst waiting to be marked.

One might recall the NAS procedures introduced over a decade ago, the MULTICOM (126.7) was the catch all at airfields that did not have a designated CTAF frequency. Seems the regulator has forgotten that over the years.

Yet again, they are trying to fix something that was not broke, with no risk assessment/analysis or education to promote the change.

It is far safer to have a single frequency for use at low levels (below 3000ft AGL) than to have a choice of two or three. Besides see and avoid should be the prime collision avoidance procedure at low levels, not the radio. Most pilots, one would hope, would practice same.

[Dangly Bits]

Clinton has it spot on!

My mate's property could be an ALA, therefore I should be on 126.7.

Old mate tootling along at 1000 feet legally is now traffic to me on a different frequency!

DB

[Tankengine]

From what I have seen a lot are not saying anything at all unless going to a major airport. They then use somebody else's callsign to get around radio billed landing fees!:mad:

[Sunfish]

I've given up on trying to understand the rules. The only lot who will hear departure calls from my valley strip will be Qantas and Virgin high overhead.

[CaptainMidnight]

This old chestnut raised again?

Done to death over 15 months ago after 22 pages:

http://www.pprune.org/pacific-general-aviation-questions/533316-multicom-vs-area-frequency.html#post8299600

Move along now - nothing to see here.

CASA bashing is just clouding the matter.

[LeadSled]

Midnight,
Raised again, because CASA has got it wrong!! To the potential detriment of air safety outcomes.

The CASA attitude is that they are the only soldier in the battalion marching in step.

If we go back before all the recent sodding around with CAR 166, the policy intent (backed by an ICAO compliant safety case) was to keep low level local traffic off ATC (by whatever name) frequencies.

It was never the policy intent that traffic on uncharted strips should use the overlaying ATC frequency.

As to "charting" all the uncharted strips, this is a practical impossibility, even without consideration of map cycles etc.

Tootle pip!!

[CaptainMidnight]

As you well know, there are no such things as "ATC frequencies", but for the education of others:

There are frequencies used by Air Traffic Controllers to provide services, including Class G FIA (Flight Information Area) frequencies (otherwise known as "Area" frequencies). These are not "control" frequencies, where separation services are provided. It is entirely appropriate - and required in AIP - to use FIA frequencies for their intended purpose.

To not use or monitor FIA frequencies when appropriate and required could cause a nasty situation, given the wrong circumstances.

Whether an FIA frequency is retransmitted onto other frequencies by Airservices is irrelevant to pilots, and not a reason to not use it or ignore the rules.

AIP ENR 1.1 para 44.1:

Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own call-sign and, as appropriate, aircraft type, position, actual level and intentions.

The appropriate VHF frequency stated in para 44.1 is:

a. In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discrete CTAF shown (including Broadcast Area CTAF) or otherwise;

b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the Multicom 126.7; or

c. In all other cases, Area VHF.

These procedures have been in place for many (the last 10+?) years. For CASA to try and undo them now would in itself present a safety issue.

I'm not aware of any formal intention to publish all currently uncharted aerodromes on aviation charts, which would clearly be impractical.

If there are such aerodromes that have a significant level of traffic then they probably should be published on charts, in the interests of safety of both the users and itinerant traffic, who would be unaware of the aerodrome. In these cases, when published on aeronautical charts, Multicom 126.7 would apply.

It's not rocket science.

If the level of chatter from an unpublished aerodrome or group of aerodromes causes congestion on an Area frequency, then any one of a number of existing measures would be taken to address that (publish the aerodrome on charts, declare a Broadcast Area, etc.).

[Captain Nomad]

These are not "control" frequencies, where separation services are provided.

Say what???!! How often do you fly IFR? Been into Class E or A airspace recently? Tried changing levels up there without a clearance have you?

Separation services (at least for some aircraft) are most definitely provided on area frequencies!

[Horatio Leafblower]

It reminds me similarly, CASA ignores/fails to implement findings and recommendations from Coroners Courts as well.

....except for one recommendation - that Charter and RPT be treated the same by the regulator to minimise the exposeure to the general public.

As the changes slowly become effective and are implemented, it is aparrent that the only reason the general public will be "safer" is because there will be no GA sector left to expose them to :ugh:

[CaptainMidnight]

Separation services (at least for some aircraft) are most definitely provided on area frequencies! Take a look at a (say) VNC chart legend.

What we are talking about are the wide green lines, which are Class G FIA ("Area") frequency boundaries. Within those volumes from the surface up to the base of CTA a Flight Information Service is provided, not a separation service.

Wide dashed brown lines are Class E airspace boundaries, on which a separation service is provided to IFR aircraft.

In some instances the frequency used is the same, but the service in the volumes is in accordance with the airspace classification.

See AIP definitions for "Area VHF" and "FIA".

[Tankengine]

Thanks to Captain Midnight we have the answer!:p
You only need to "listen out" and only talk if you hear a "potential conflict":ok:

So : no calls required in or out of your small unmarked private strip!:ok::E

[Hempy]

Some of you guys really need to visit an ATC Centre and see how things operate tbh

[Creampuff]

Some of you guys really need to visit a brickworks and see how camels swim.

What's your point, Hempy?

[LeadSled]

except for one recommendation - that Charter and RPT be treated the same by the regulator to minimise the exposeure to the general public.Horatio,

That is NOT what the Seaview Royal Commission recommended, what you have quoted is a CASA perversion of the findings just for the purposes of imposing additional unjustified restrictions on "charter".

Specifically, he DID NOT recommend that Charter operate to the same standard as RPT.

As per usual, few in the industry ever bother to check the sources, but just accept the CASA spin. Find yourself a copy and see what Staunton actually said.

Tootle pip!!

PS: Midnight, I did say " ---- (by whatever name)" to avoid exactly the picking of nits that has happened. Perhaps I should have said: " inappropriate CNS/ATM frequencies" to be technically accurate.

[Hempy]

Creampuff, my point is in response to

There are frequencies used by Air Traffic Controllers to provide services, including Class G FIA (Flight Information Area) frequencies (otherwise known as "Area" frequencies). These are not "control" frequencies, where separation services are provided. It is entirely appropriate - and required in AIP - to use FIA frequencies for their intended purpose.

ATC sectors are generally split according to service provision. They are, however, generally combined so that an ATC controlling CTA (remember that one?) also has the Class G frequencies merged. In a headset, there is no differentiation. If you think your calls on the Class G area frequency don't potentially affect comms in CTA you are wrong.

[Creampuff]

Got it. I knew that.

Let me fix one of Captain Midnight's posts for him:If the level of chatter from an unpublished aerodrome or group of aerodromes causes congestion on an Area frequency [e.g. by disrupting control of aircraft where a controller has responsibility for an Area frequency combined with a frequency used for the control of aircraft] then any one of a number of existing measures would be taken to address that (publish the aerodrome on charts, declare a Broadcast Area, etc.).Name the places so that the problem can be addressed using any one of the existing measures designed to address the problem.

[CaptainMidnight]

:ok:

And Hempy, I am very aware of how the system works :)

[anomaly]

I'd really like to see a CASA representative tag along on a C208 operating a 11+ sector mail-run, in and out of marked and unmarked strips operating under the IFR single pilot RPT. And how the new rules makes their workload easier and job safer. ;)

[triadic]

Name the places so that the problem can be addressed using any one of the existing measures designed to address the problem.

It is understood that the NQld RAPAC have a proposal in for a Broadcast Area, south of Cairns, however it seems the introduction is the best part of a year away, which is far from satisfactory for the current problem there.

A problem that the MULTICOM addressed successfully over the past decade or so. This did not become a problem until the recent change re uncharted airfields.

[Hempy]

You'd certainly think that blanket 126.7 (overlap aside) would be a better option.

[Captain Nomad]

Captain Midnight, if you do admit that:

In some instances the frequency used is the same

I think it was a bit disingenuous to say:

These are not "control" frequencies, where separation services are provided.

Especially given that in a lot of cases (and perhaps particularly in the more regional regions relevant to the discussion) the frequencies indeed ARE the same!

[triadic]

Capt Midnight said:


AIP ENR 1.1 para 44.1:

Quote:
Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own call-sign and, as appropriate, aircraft type, position, actual level and intentions.

The appropriate VHF frequency stated in para 44.1 is:

a. In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discrete CTAF shown (including Broadcast Area CTAF) or otherwise;

b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the Multicom 126.7; or

c. In all other cases, Area VHF.

These procedures have been in place for many (the last 10+?) years. For CASA to try and undo them now would in itself present a safety issue.

In fact that is an extract of the present AIP, but prior to the recent change re unmarked airfields, the AIP made no mention of marked or unmarked airfields which was in accordance with the NAS introduced over a decade ago, where the MULTICOM was introduced. Much of that, it seems, those in CASA have either forgotten or were unaware of (??).:ugh:

[CaptainMidnight]

but prior to the recent change The AIP amendment came in 2 years ago - mid 2013 - I don't call that recent - and at that time CASA said that change to make AIP clearer was consulted to the industry in 2009 -

The AIP is clear as to what frequency to use. As I've said - its not rocket science, and the pilots and instructors I associate with understand and comply with it.

Trying to impose a multicom across the whole country up to (say) 3500FT but of necessity needing it to be clear of CTR/CTA/CTAFs/Broadcast Areas/PRD would present its own safety issues and just complicate things further IMHO (and of course, would need a HAZID and safety case).

Captain Nomad: I concede the point you raise, however in those regional areas in most cases the common frequency is for Class G and Class E not the overlying Class A, where it is claimed light aircraft transmissions in Class G might jam a jet's call to ATC or vice versa and cause loss of life.

I don't believe the problem is as big as being made out to be, and as said, if the chatter proves to be a problem in an area or location then there are measures able to be taken.

[jas24zzk]

I don't believe the problem is as big as being made out to be, and as said, if the chatter proves to be a problem in an area or location then there are measures able to be taken.

Yes, the measure should have been to leave it as it was....it worked.

I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.

These 3 cannot recieve ATC on the ground.

Yep, I can see how well this is going to work with 100% compliance

The rule change fixed something that wasn't broken...yet again

[Creampuff]

Yes, the measure should have been to leave it as it was....it worked.Raising the questions: what was "the measure" and what did it do that "worked"?I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.What in heaven's name does "no overlying CTAF" mean?Yep, I can see how well this is going to work with 100% compliance

The rule change fixed something that wasn't broken...yet againI reckon the biggest problem is that most people don't have a clue what the current rules are or what they require and permit, or what was fixed that is now broken.

I'm beyond caring. :ugh::ugh:

[CaptainMidnight]

I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.

These 3 cannot recieve ATC on the ground.So it is unlikely ATC will hear them, and 135.7 is FIA SFC - base of CTA.

So what is the problem with those aircraft when taxying making a broadcast on 135.7 like:

"ALL STATIONS, ABC C172 TAXYING AT PRIVATE STRIP 10NM EAST OF WHITTLESEA; ON DEPARTURE TRACKING TO THE NORTH BELOW 5000 OCTA".


that's them using the most appropriate frequency per AIP;
other aircraft on 135.7 transiting the area will hear the broadcast, and will if necessary take avoiding action or make two-way contact and arrange same;
if the level of traffic and associated chatter at this or the other strips develops into a problem, one of the measures previously outlined will be taken.

[LeadSled]

kFolks,
Just as a reminder, EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166 --- and there is a very broad spectrum of representation at RAPACs ---- doesn't that tell you something.

As Triadic has stated so clearly, the intent of NAS over a decade ago was very clear, CAR 166 was amended for that purpose.

Again, I thing Triadic is on the money, those in CASA who are responsible for this either have forgotten the very good reason for the decisions of that time, or never knew.

One of the really great difficulties in dealing with CASA is the abysmal lack of corporate memory, hence the continual flow of answers to questions that were never asked, the continual flow of solutions to problems that do not exist.

Some of the "reinventing the wheel" that is going on in Certification is another example.

Tootle pip!!

[CaptainMidnight]

EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166Can you advise where that is documented i.e. when the matter was discussed by industry reps at their respective RAPACs?

I don't recall it being discussed, nor can I find any mention of CAR 166 discussions in ACT, NSW, SQLD or WA RAPAC minutes at all from the current minutes back to 2007, except when the NPRM was released for comment back in 2009.

CAR 166 discussions are only mentioned in the Victoria RAPAC minutes in July & October last year and March this year (apart from back in 2009 when the NPRM was released for comment).

[LeadSled]

Midnight,
Perhaps Triadic can help.

I certainly contributed to the N.Qld. discussions, and was made aware of other discussions that all came to the same conclusion, resulting, as I understand it, in a letter to CASA, but as far as I know, all the RAPACs were polled on the issue.

Nothing changes the fact that the long standing AND INTENDED interpretation has been upended by CASA, without any meaningful consultation, and apparently without any knowledge or understanding of the background to the long standing usage.

As Triadic say, more than a decade.

Nothing can justify what CASA has unilaterally done.

Tootle pip!!

[triadic]

As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.

When the matter was raised with the OAR for discussion at the RAPACs it was rejected as not being an airspace matter.

For about the last year, all of the Industry RAPAC Convenors have been canvassed and included in a string of emails on the matter. There have over this time been a number of attempts to table the MULTICOM for discussion, but the subject has been rejected by the OAR.

Discussions have been held out of session as the OAR has refused to include the subject at the RAPACs and therefore it is unlikely you will find mention in the minutes, even when it was discussed, even briefly. The management of the OAR have to take responsibility for this debacle. Even correspondence from CASA has not addressed the subject in any detail or the safety issues that have been raised. As if they just don’t want to know?

Things seem to be changing somewhat since the new DAS entered the building and the MULTICOM has been subject to some further discussion of late. One can only hope that those responsible for this change are directed to place the matter on the table for open discussion, especially with the RAPACs.

[jas24zzk]

Ok,

Yes, the measure should have been to leave it as it was....it worked.
Raising the questions: what was "the measure" and what did it do that "worked"?

Reword it to, The decision made. should have been...........


What in heaven's name does "no overlying CTAF" mean?

Out here in the Yarra Valley, we have several strips that are within the Lilydale/Coldstream (or Yarra Valley if you like) CTAF. They have an overlying CTAF...or if you wish to be pedantic, are inside the Yarra Valley CTAF, and therefore should operate on 119.1

By saying they have no 'overlying ctaf' I also mean other airspace classes, except G. In G under the current rule, they should be on the Area Freq...

Quoting Captain Midnight, and myself


I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.

These 3 cannot recieve ATC on the ground.
So it is unlikely ATC will hear them, and 135.7 is FIA SFC - base of CTA.

So what is the problem with those aircraft when taxying making a broadcast on 135.7 like:

You are correct, ATC won't hear them. The crux is that the lil guy on the ground cannot hear ATC as well. He would be clueless that he is Tx over the top of ATC..the jet over the top can certainly hear him! Its that info suppressed by a guy trying to comply with the rules that generates a problem.

His compliance with the rules, especially so close to a control zone, means that he is likely to transmit over important information intended for people that need it.

As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.

Says it all really

[Traffic_Is_Er_Was]

They are, however, generally combined so that an ATC controlling CTA (remember that one?) also has the Class G frequencies merged.

Which is the problem the present system has created by expecting one ATC to provide services to all classes of airspace. If the Area VHF was kept separate from the dedicated control frequencies, then there would be no over transmitting of the "control" comms by "uncontrolled" comms. It's probably just the push of a button to uncombine, but it makes more work to listen to it like that.
Putting my grandpa hat on, I remember many years ago having an ATC sit in on my FS console for a famil, and him being amazed at all the radio chatter on the Area Freq. "How do you put up with that for a whole shift?"

[Creampuff]

Just so I can understand what "full industry defiance of the CASA CTAF ruling" means, is it just that everyone is using 126.7 as the default frequency for strips that aren't marked on the charts?

If so, and that's the safer approach, why all the fuss? All this protest would seem to be so much sound and fury, signifying nothing, given that everyone is ignoring CASA and continuing to do the safer thing.

When something in aviation doesn't make sense to me, I immediately get a whiff of the stench of politics or industrial relations or some other nefarious explanation.

What is all this really about?

Don't tell me: "Safety".

[yr right]

Yeah Clinton you and safety in the same sentence dose not make any sense hey !!!!!!!!!!

[Trent 972]

I think it is more about the majority of the GA community exercising 'Common Sense' and doing the practical thing.
CASA will eventually wake-up.

[CaptainMidnight]

the jet over the top can certainly hear him!135.7 is FIA SFC - base of CTA. It used to be called "Melbourne RAS", and operated as a standalone position. When that was (and maybe still is, at times) you won't be transmitting over jets.

As I said earlier, how Airservices manages its frequencies and operating positions (i.e. resulting in retransmitting FIA onto frequencies used for CTA and vice versa) is not your problem. You need to comply with CAR 166 and AIP. If you don't, in the event of an incident, CASA may skin you -

I also make the point that the retransmission situation is not the fault of ATC. Its the result of their having to deal with staffing & workload constraints imposed on them by Airservices.

I think it is more about the majority of the GA community exercising 'Common Sense' and doing the practical thing.

Exactly.

[DWB50]

I'm certain most aren't talking on Area Freq's at unmarked strips however they are certainly listening, myself included. I used to transmit rolling calls from mine when I first started flying & only ever got one reply from a Cathay Pacific at a FL overhead advising that I shouldn't be a problem for him. Over the years I simply dispensed with it & use my eyes (& still my ears) now.
Last weekend a group of 12 aircraft flew to a farm strip just outside of Tamworth & we all agreed before departing that we would communicate on MULTICOM. It worked well & Brisbane & everyone else (except for the other NW airfields using 126.70) weren't bothered by us. Just made sense to all involved & we did discuss the fact it was not what was required.
I am organising a fly in to a private unmarked on charts strip shortly & I have advised everyone to use 126.70. Why? Expecting maybe 40 or 50 AC to arrive during a 1 hour period. Imagine the congestion on Area Frequency during that period. Certainly no doubt 90% of them will have dual monitoring anyway & be listening still on area.
Just seems to be common sense to me but maybe I (& others) have it wrong

[CaptainMidnight]

Expecting maybe 40 or 50 AC to arrive during a 1 hour period.There are existing measures to deal with that sort of situation.

Contact your local CASA area office, advise them of the situation and ask for a discrete CTAF to be allocated. There are frequencies reserved for fly-ins, airshows etc. Given the discrete frequency and in particular the level of traffic, CASA would issue a NOTAM ("INCREASED TFC IN THE XXX AREA DUE FLY-IN etc.".).

It is - unwise - to decide to not comply with published rules and procedures. In the event of an incident .........

[DWB50]

Thanks for that advice Captain:ok:

[andrewr]

Contact your local CASA area office, advise them of the situation and ask for a discrete CTAF to be allocated. There are frequencies reserved for fly-ins, airshows etc. Given the discrete frequency and in particular the level of traffic, CASA would issue a NOTAM ("INCREASED TFC IN THE XXX AREA DUE FLY-IN etc.".).

Some people don't want to advertise the location of their private strip to the general public.

I know one person with an airstrip at his house where an ATO decided it was a good place to have students demonstrate precautionary searches - to his and his neighbor's displeasure.

Any significant danger of collision at an unmarked strip is with other traffic using the strip or others in the same area - not with traffic in cruise on the area frequency.

[LeadSled]

There are existing measures to deal with that sort of situation.

Midnight,
Which of the hourly rates do you think CASA would levy for such an application, the $130 p/h or does it need expert technical consideration, at $190 p/h, and for how many hours. As I assume you know, it is not just a matter of applying to Airservices.

Why don't you just accept the fact that CASA has got it wrong, as a Prince of Process yourself, you should understand that CASA did NOT undertake the process they should have, including a safety case for such a fundamental change in "interpretation" of CAR 166.

That OAR ( or whatever it is called now) have put so much effort into assuring the matter is not "officially" discussed should tell you something.

Tootle pip!!

[CaptainMidnight]

andrewr

The situation DWB50 cites is one where there is a significant increase in traffic in a particular area for an event, and awareness by non-participating aircraft is warranted. Happens all the time across the country with fly-ins, field days etc. and a NOTAM serves to provide that awareness and is entirely appropriate.

Such an event is not related to someone not wanting their private strip "advertised" to the general (flying) public, which I take to mean they don't want it published on charts.

LeadSled

I'm not aware that CASA charge for taking the above action with fly-ins or with glider or hang-gliding clubs to arrange one of those "intense GFY activity" type NOTAM. However no doubt DWB50 will find out when he enquires :)

As to CASA's actions - or lack of - re the CAR 166 & AIP text change, from all I've read, we're in agreement.

[Creampuff]

Just for my continuing education, what difference do the many and varied amateur interpretations of "CAR 166" have to do with the question as to what frequency must be used by VHF-equipped aircraft in the vicinity of aerodromes that are not marked on charts?

[Hempy]

135.7 is FIA SFC - base of CTA. It used to be called "Melbourne RAS", and operated as a standalone position.

Seen the staffing levels these days? No re-transmit does not equal no over-transmission...

[jas24zzk]

And further to Hempy's post,

Have you listened out on 135.7 in the last 10 years? it is a VERY busy Frequency, totally loaded with IFR guys

Its busy enough, that I doubt the controller on it is monitoring any extra frequencies....he/she would be glad the days of vfr's requesting QNH are pretty much gone.


If there is one area with what I have described, there are surely more...

[CaptainMidnight]

The fact that ML CEN 135.7 carries comms from ML APP 132.0 much of the time I agree is not conducive to aircraft in Class G FIA making calls & broadcasts.

Which is not the fault of ATC, as I said:

I also make the point that the retransmission situation is not the fault of ATC. Its the result of their having to deal with staffing & workload constraints imposed on them by Airservices.

[triadic]

Just for my continuing education, what difference do the many and varied amateur interpretations of "CAR 166" have to do with the question as to what frequency must be used by VHF-equipped aircraft in the vicinity of aerodromes that are not marked on charts?

From 166C:
...the pilot is responsible for making a broadcast on the VHF frequency in use....

Note 1: See the AIP for the recommended format for broadcasting the information mentioned in this regulation

Up until the recent change that was either the assigned CTAF or the MULTICOM. - Simple! Now not so simple and even dangerous!

But then there is always interpretations!:uhoh:

[LeadSled]

Just for my continuing education, what difference do the many and varied amateur interpretations of "CAR 166" have to do with the question as to what frequency must be used by VHF-equipped aircraft in the vicinity of aerodromes that are not marked on charts?

Creamie,
Only that the CASA co-chair of the SCC Operations Standards Sub-Committee, on this subject, has stated words to the meaning: "CAR 166 has not changed, the CASA interpretation (and hence the AIP) of frequency usage has changed" ----- as has been pointed out by Triadic.

The original "intent" of this part of CAR 166 is quite clear, and was established by an acceptable risk assessment process, including compliance with an ICAO acceptable reference system.

It is all this that somebody in CASA has decided, without justification or genuine consultation, to upend the long standing usage, without a safety case or reasonable and supportable risk analysis, apparently in complete ignorance of why the long standing system was as it was.

Instead the: "Hey! Jack, wouldn't it be safer and a good idea if -----" system of in-depth analysis was undoubtedly the formal process for the change.

Tootle pip!!

[Creampuff]

The blind leading the blind, as usual.

Nobody's changed their interpretation of 166: everyone continues to agree that it obliges VHF-equipped aircraft in the vicinity of a non-controlled aerodrome to use the frequency "in use" at the aerodrome.

There are merely diametrically opposed views as to what the frequency "in use" at an unmarked aerodrome is. The answer to that question isn't found in 166.

But given that there is "full industry defiance of the CASA CTAF ruling", surely there's no safety problem?

[triadic]

Of course Creamy, you are correct, 166 has not changed, but the AIP has.

Say, as the PIC of your mates Cessna, going to a bbq at a popular unmarked strip, using your infinite wisdom and experience what would you do in practice in regard to selecting the frequency in use??

What about if the strip is near an Area Freq boundary?

What about if it is located outside the coverage of a VNC and you have to plot the boundary in flight from another chart or ERC?

What about if the strip is not on your WAC, but on your iPad?

What about if you can hear the high flyers, but not Centre?

[Creampuff]

I don’t need to carry and don’t carry VHF, so I don’t care. ;)

For people who do carry VHF: just make sh*t up. :ok:

[triadic]

Glad to know you understand.......:)

[CaptainMidnight]

what would you do in practice in regard to selecting the frequency in use??

What about if the strip is near an Area Freq boundary?

What about if it is located outside the coverage of a VNC and you have to plot the boundary in flight from another chart or ERC?

What about if the strip is not on your WAC, but on your iPad?

What about if you can hear the high flyers, but not Centre? What would you do in those situations, exercising common sense and IAW AIP?

[triadic]

Middy:

What would you do in those situations, exercising common sense and IAW AIP?


Certainly some common sense, but that seems to conflict with the AIP which does not cater for the unintended consequences (or the use of common sense) as those that pushed for this change did not/do not understand what was in place, nor conduct a safety case for the change.:mad:

As said previously, we had a simple system and now its not simple and certainly less safe.:ugh:

Common sense and good airmanship should cater for most issues.:ok:

But given that there is "full industry defiance of the CASA CTAF ruling", surely there's no safety problem? :D

Of course, that's not really the point is it??:=

[Tidbinbilla]

I have reopened this thread. Children, if you find it difficult to post without posting personal attacks, I suggest you don't post at all.

Lest thee face a blocking.

Have I made myself clear? :)

[Sunfish]

I have to deal regularly with a Yachting race director who has a number of what I will call "personal issues", sometimes also called "passive aggressive" behaviour ( and occasionally not so passive). These are a result of what I will call "health issues" earlier in his life.

This person delights in constructing racing instructions some, say, Twelve pages long that appear to be quite prescriptive and detailed….until you attempt to follow the course allegedly mapped out…and discover that half the fleet has gone one way and the other half another..all due to competing interpretations of the instructions.

What normally happens when the perplexed attempt to get a ruling is that the race director smirks and alerts them to the footnote on page Twelve that says the rules change on alternate Wednesdays and that therefore half the fleet sailed the wrong course because they expected the instructions to mean what they say,

Said Race Director gains huge pleasure out of all this by pointing out that the losers missed the footnote and therefore "hadn't read the instructions".

So when I try and read CASA regulations why do I get exactly the same feeling as reading those racing instructions? Because they are deliberately obtuse and self referential for exactly the same reason - to make CASA functionaries feel good.

The regulation should simply state that you will use the area frequency or other designated frequency (not the frequency "in use") period. The regulation may then state how the designated frequency may change and the single location where such a change can be found, leaving absolutely NO pilot in doubt as to what the correct frequency is.


Thus there is no room for interpretation, mind games, autistic pissing contests and other sports beloved of CASA.

Speaking as One who did get designated frequencies confused ( by a NOTAM about Maree in the tourist season) and potentially lined himself up for a midair as a result.

There should be no room for "interpretation" beyond strict common, published Weberian limits and all regulations should be self contained and internally consistent. Hell will freeze over before CASA agrees to this.

[triadic]

That didn’t strike me as surprising, because that’s my understanding of what the AIP says.

Yes, that is what is says now, but not what it has said for the past decade, pre the change.

What most of the participants in this discussion are concerned about is that there was a change, with no consultation, no safety case and no apparent consideration of the unintended consequences.

CASA's lack of understanding of the matter was displayed when they indicated that they only considered it a clarification (!!).

Most of us in the flying world out here believe that if the rules say one thing today and another tomorrow, that is a change. Seems some in CASA don't share that view! Seems also to show an ignorance of the established procedures that have been firmly in place for a decade.

At the recent evening at the local aero club there were three CASA safety folk there and this subject did not crack a mention.

I am not going to be dragged into any personal exchanges on this forum, I just want to see some constructive discussion on what is without doubt a safety issue that has not been managed well by the regulator.

[triadic]

Thanks - no offence taken by this duck! I admire your scriptures. I am sure the battle will continue and perhaps one of your suggestions might float. For the benefit of all including those without radio, we need to keep this discussion on the ball and ensure the likes of this exercise is not repeated.

Cheers

[triadic]

Well, here we are over half a year later and sadly nothing much has changed!

The subject has been rejected for discussion at some of the RAPACs last year and one CASA officer when asked for the Safety Case suggested that an application be made to FOI !! :mad:

Recently there has been much discussion over the procedure in both SA and Tas in relation to ops at strips not marked on charts.

It should also be noted that there would be little need for Broadcast Areas if the MULTICOM procedure was still in place.

Some CASA officers still don't seem to understand the issue.:ugh:

The matter would never have happened if there had been consultation and a safety case.

[Dick Gower]

Sad but true Triadic.
The three unresolved risks still remain unresolved and are causing problems.
There is wide spread confusion re frequency usage and at a recent fly-in event in Tasmania there was a serious congestion problem on the area VHF arising from the event.
I think that the increasing use of the area frequency will eventually get to the point where the problem can no longer be ignored and sanity will then prevail.

What a ridiculous way to manage airspace!

[Dick Smith]

Has anyone filed an incident or other type of report re the Tassie CTAF problems?

[Aussie Bob]

Check your PM's

[Ex FSO GRIFFO]

That is 'the way to go'....

Careful Dick....I'm agreeing wif ya....


Cheers

[CaptainMidnight]

One isolated occurrence in Tasmania does not mean an impending national disaster.

The problem in Tasmania would not have occurred had CASA done what they have always done everywhere else for fly-ins and airshows i.e. by NOTAM either declaring a temporary CTAF or specifying a frequency to be used in the vicinity of the ALA.

If what we read here is correct, CASA apparently refused to take such measures, despite having been warned of the possibility of congestion on the FIA, and due to their lack of action, the congestion did indeed occur.

And had the ALA been one published on the charts without a discrete CTAF, the same congestion problem would have occurred on 126.7 potentially causing disruption to other ALAs and users on that frequency.

[Aussie Bob]

Captain, unfortunately it is not just one incident. The real problem lies not in the granting of a temporary frequency, rather the absurdly long time it takes to get an airstrip marked on a map.

[CaptainMidnight]

It should take around 6 months (the time between an AIP MAP data cut-off date and the release's effective date). Example: the cut-off date for AIP MAP effective at the end of this year would be early June.

WACs aren't published as frequently though, but publication in AIP MAP is sufficient.

My last experience was it was simply a matter of providing details of the ALA (lat/long., owner & contact details, charts affected) to the Airservices Aeronautical Information Management people. They had a standard form to complete.

Who are you going through (don't say CASA....)?

See the links under "Changes to aeronautical charts and documents" here:

Contact us | Airservices (http://www.airservicesaustralia.com/contact-us/)

[Aussie Bob]

It should take around 6 monthsReally?

Who are you going through (don't say CASA....)?I am not the applicant. Thanks for the link but I am well aware of the correct process, as are the applicants (note plural). The application in Tasmania is not the only one I am aware of. There are several stretching across Australia. This is not an isolated case or a simple matter of filling out a form and getting instant results. There is a process that takes time and nothing is done in the interim to fix the problem which is not nearly as minor as you allude.

[CaptainMidnight]

Really?Yes, it's due to the lead times with printing, distribution etc.

The way it was explained once @ RAPAC was, working back from the maps effective date:


maps and documents are supposed to be received by pilots and other users at least 28 days in advance of their effective date, so for maps effective on 10 Nov. 2016 that would be receipt around mid October;
3 weeks is allowed for national postage and distribution to meet that receipt around mid October, so that process would start around late Sept.
two weeks is allowed for the mailing house to receive all the maps and documents, collate and send for distribution;
so the documents would be sent by the printers to the mailing house around mid September;
the printers have a week or so to do their bit, so that means they receive the data late August;
Airservices charting people have 4 weeks to process all the changes to the charts, produce drafts for checking then validate and finalse the electronic data for sending to the printers, so that process starts around the end of July;
mid June is the cut-off for author areas internal and external to Airservices to file changes with their AIS people, which allows for late filing, checking and validation of the data and creating the change documentation covering the whole AIP suite including maps.
Changes e.g. addition of a strip could be done by NOTAM if the level of traffic justifies it, but then the regulator gets involved to assess the safety implications of doing something by NOTAM (and the risk of some pilots not checking NOTAM) vs.. leaving the change till a map release.

[Aussie Bob]

Captain, the "really was in response to your rather optimistic 6 months. Realistically, from my experience, you are looking at 12 months minimum and probably 18 months to 2 years. Things progress at snails pace in the public service.

[CaptainMidnight]

For changes on WACs yes, because they are only printed every few years.

However I've never had a problem with having something published or corrected on the next AIP MAP release if the change RQ is filed with AIS by their cut-off date.

As I said, I don't know who the parties are talking to but if it is CASA instead of AIS Airservices (the aeronautical data managers and publishers), I can understand why a delay or no action.

Any questions an email to that docs_amend address and the ladies have been only too happy to assist.

[Radar Man]

Captain Midnight: it would be worth having a read of the new CASR Part 175 and updating yourself on what the requirements are now for Aeronautical Data Originators in Subpart 175.D. It's not like it used to be. The privacy of individual aerodrome owners, and their right to not be published (for any number of reasons), also needs to be respected.

For those interested in this thread's headline topic of CASA's constraint on the MULTICOM: there's more info now at RAPACs (http://www.rapac.org.au/projects/MULTICOM.htm) .