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Flying Ted
16th Oct 2017, 09:38
Apologies if this has been posted before but has everyone read H29/17 AERONAUTICAL DATA ORIGINATOR RESPONSIBILITIES?

Airservices has lost the details of who is responsible for some 2000+ airfields currently listed in the ESRA and WAC. If the people reasonable for these airfields don't come forward Air Services will remove these details from the AIP.

You will be surprised at what airfields are on the cull list.

Has something gone wrong here? Are airfield operators boycotting Airservices?

https://aopa.com.au/wp-content/uploads/2017/10/a17-h29.pdf

compressor stall
16th Oct 2017, 09:52
It's quite extraordinary. There are half a dozen airports in there including a large one licensed all managed by the aviation manager of a government department. That's his title. Not too hard to find.

What is of greater concern is the background to this. Have a read of the form that you as farmer Joe, or publican Joe has to sign to be responsible by law for the veracity of all obstacles, notams etc. if I had a strip that I used and was happy for others to use, no way would sign that form unless I was a paid airfield manager.

So the airfields get deleted from th databases and situational awareness decreases when these no longer pop up on your track on your moving map....

Lead Balloon
16th Oct 2017, 09:56
Anything for which Airservices cannot charge a fee is being bureaucratised out of Airservices’ in tray. All of those pesky ALAs and NOTAMs about nobodies daring to fly little aircraft to far away places don’t make money for Airservices. The solution? Make it frustratingly time-consuming and difficult to deal with Airservices on these matters. Most give up. Job done so far as Airservices’ ‘brains trust’ is concerned.

Ixixly
16th Oct 2017, 09:57
Gosh, I don't know if they tried very hard, there's a few Hospitals on there and some in the Territory and such are well known. Surely contacting a Hospital or some of the Charter Companies in the areas concerned or looking up Regos that travel to them to ascertain who uses them wouldn't be terribly difficult?

Places like Apollo Bay, why not try Apollo Bay Aviation? Flinders Naval Depot..hmm, wonder who they could contact about that one?!

This is an absolute disgrace, who did they try and contact about these?!?!

Lead Balloon
16th Oct 2017, 10:02
There is nobody to “contact them”. That person has been sacked from Airservices. The ‘brains trust’ now has to go through a process to show that it’s everyone else’s problem.

outnabout
16th Oct 2017, 10:02
There are a number of these airfields that are privately owned, and which are currently listed as PPR.

In speaking with some of those airfield owners, they don’t want their details listed anywhere because they have had an increase in pilots landing without permission, because the pilot has always wanted to go there, but either doesn’t want to pay landing fees or can’t be arsed going through the rigmarole of ringing up or submitting the paperwork to get permission.

In one case that I know of, old mate pilot turned up to a privately owned airstrip without permission, rolled out his swag under the wing, then tried to help himself to avgas and oil from the scenic flight operator. Did I mention this was a Station that offered accommodation (from tent sites through to four star) for travellers, and that the airstrip was leased to a licensed air charter operator who had the avgas for their company’s use? Some clown coming through on the wrong frequency, flying backwards against circuit direction, and then trying to “borrow” avgas didn’t impress them much - all could have been solved with a quick phone Call to get permission, check the frequency and circuit direction.

Or the hero who turns up and lands, without permission, and admits he thought he was at an airstrip 20nm away. Both airstrips required permission to land, the one he was aiming for never gives out permission to land but he didn’t have permission from either. And admitted it was because he couldn’t be bothered. Bragged about how he was a check & training captain for (insert international airline here).

Lead Balloon
16th Oct 2017, 10:07
None of which is Airservices’ problem...

Ixixly
16th Oct 2017, 11:58
Then they should get their details removed from ERSA and AOPA Directory if that's the problem, but that's a totally seperate problem from what we're talking about here.

B772
16th Oct 2017, 12:05
Beggars belief.

LeadSled
16th Oct 2017, 13:39
Folks,
This would be funny if it wasn't so bleeding serious.

In the AIC it uses the words (AICH29/17, para. 2.2) "Airservices has now exhausted all reasonable avenues of enquiry in relation to the identification of the remaining ADOs".

2000+, 80 pages of them !!!

One is Flinders Naval Depot (aka HMAS Cerberus). I wonder did they think of giving the Navy a call? In terms of warm bodies, that is probably the biggest RAN base in Australia.

Far more importantly, the Emergency Services Helipads from a majority of NSW hospitals are on the list, the idea that they will all be expunged from ERSA, GNSS/FMCS, AvMap/OzRunways databases and paper maps, and eventually WACs etc. is just too ridiculous for words.

The other one that really gets me is the airfields with a full listing in ERSA, I wonder did it ever occur to anybody in Airservices to ring the contact number in their own publication. They couldn't find anybody to officially tell them (the duty of an ADO) where the Jindalee (JORN) aerial site strips are?? DST is in Canberra!!

All this is "so Australian bureaucracy", a mindlessly literal and narrow interpretation of a regulation, all in the name of "safety compliance", without regard to the real safety ramifications of the data no longer being available in a publicly available format from an approved source.

One of the missing is Royal Adelaide Hospital, given all the publicity it has had recently, shouldn't have been hard to find, my local hospital, the SAN is missing, most of the hospitals in Perth are missing.

This is the cancellation of many GPS approaches on steroids.

In my opinion, it would be quite reasonable to describe Airservices behavior in this matter as scandalous, given its obvious risk ( safety) ramifications, particularly EMS.

Tootle pip!!

Ixixly
16th Oct 2017, 14:03
Surely we could get some Journos in on this and a bit of publicity? This seems pretty clear cut that someone hasn't done much work at all and is going to cause endless troubles.

"Apologies Rescue 500, we no longer have that hospital in our Database, could you please take a few of your precious minutes and ours and tell us the Lat and Long for the 10th time this week? Cheers!"

outnabout
16th Oct 2017, 22:20
I did hear a rumour that the information has been sent to the last known operator / contact for the airfield, and they have chosen not to return it. For a variety of reasons.

LeadSled
16th Oct 2017, 22:43
Outnabout,
Interesting so called rumour, what could possibly be the reasons?

The navy deciding to keep HMAS Cerberus top secret?

Take the dozens of hospitals for example, could this be a collective decision by state health services to boycott helicopters EMS to reduce A&E waiting times??

Balgo Hill, perhaps to make it harder to fly in illicit grog?

Lizard Island, a plot to save the Barrier Reef from tourists?

A bunch of council owned airfields in NSW a cunning plot by property developers to hide them from aviation??

Or, just perhaps, Airservices not taking responsibility for publishing aeronautical data that they are obliged to publish under national legislation and international treaty, by claiming that establishing an "ADO" for every spot is the responsibility of somebody else -- hiding behind a suitably self-serving and Airservices budget friendly interpretation of a CASR Part 175 regulated requirement.

Tootle pip!!

mostlytossas
16th Oct 2017, 23:08
If all these ALA's are removed from the data base would this in any way affect your insurance cover should one have say a prop strike on landing or hit a roo etc. Would the insurance company treat your landing as an irresponsible landing in a paddock somewhere (even if the strip was well maintained)because it was no longer an authorised landing area?

jonkster
16th Oct 2017, 23:59
Interesting that the circular states: As part of this effort, assistance was provided by the RFDS and other organisations involved in servicing remote communities, with some success.

And yet Broken Hill is listed as one of the problem facilities. That the RFDS with a large base of operations there cannot provide details of the operator of the BHI aerodrome (or the operator refuses to provide details to AirServices) is interesting.

Makes me think in many cases operators are not responding to requests rather than not being able to be identified. Which is still very concerning.

Lead Balloon
17th Oct 2017, 01:15
Given that the original data made it to and remained in the AIP since Noah played fullback on the Ark, something has changed. Either Airservices has changed the way it does things or all of the operators of the aerodromes in question have changed the way they do things. Which do you reckon is more likely?

Lead Balloon
17th Oct 2017, 01:31
I’m guessing that what has really happened is that no one wants to expose themselves to all of the strict liability offences in Part 175. Have a look at Division 175.D.1, in particular, to see bureacracy and criminalisation gone mad.

Biggles_in_Oz
17th Oct 2017, 01:52
Golly., there are a lot of 'medical/hospital' entries in that AIH !

It seems to me that quite a few of those entries are actually VFR waypoints that (for reasons unclear) still have a 'Y' ICAO prefix,
eg. "Majura Training Area', 'Stag Tanker Mooring Platform', 'Walcott Inlet', 'Roper River Aqua Farm', 'Blenco Falls', 'Beaver Reef', 'North Solitary Island', ...

LeadSled
17th Oct 2017, 02:23
Folks,
For those of you who haven't, please have a look at what is actually included, it is NOT anything to do with conditions on the ground, liability for prop strikes, or anything else your fertile imagination can dream up, it is a list of geographical positions. And it is NOT just a few private ALAs.

These "official" positions are vital in compiling databases, whether for GPS/GNSS systems, FMCS systems, EFBs (Garmin/AvMap/OzRunways/Jeppesen) or, eventually, paper maps. Publishers are only permitted to publish data from "approved" sources, in Australia Airservices is the only source of such data.

In my opinion, Airservices has an obligation to obtain the information, including providing resources to obtain the information in an accurate and verifiable form, as many of the places listed will not have access to adequately reliable up to date data, nor the specialist expertise to obtain same.

Just imagine a letter turning up to:

The Approved Aeronautical Data Originator,
Upper Kikatinalong Shire Council,
PO Box 1,
GAFFA.

It would probably go straight into File 13 as junk mail

Tootle pip!!

PS: Two on the Victorian list are Tyabb, and Lilydale, not your average idea of an ALA

KRviator
17th Oct 2017, 03:00
I've just emailed the missus who is reasonably senior in NSWHealth to at least get their ones sorted out. Fcuk knows what ASA is playing at with some of those entries though, Westmead & Royal North Shore hospitals?? Sydney Children Hospital?

Hey, if Warnervale is delisted as an airport, does that mean the council will stop charging excessive landing fees as it isn't at an airport anymore?!?

alphacentauri
17th Oct 2017, 03:25
Leadsled,

Your comments on here only indicate that you don't know what you are talking about and don't understand the reg you are reading.

Responsibility to publish does not mean responsibility for accuracy or data custodianship...

You amongst others have been calling for privatisation of AsA on here for a while. Now you have the beginnings of it, and start crying about obligation. What a joke

Lead Balloon
17th Oct 2017, 03:37
Just imagine a letter turning up to:

The Approved Aeronautical Data Originator,
Upper Kikatinalong Shire Council,
PO Box 1,
GAFFA.It’s worse than that, LS. The letter probably says something like this:

Aeronautical Data Originator,
Upper Kikatinalong Shire Council,
PO Box 1,
GAFFA.

Airservices would like to continue to publish information about your aerodrome/HLS/ALA. Before you provide the information, and before Airservices publishes the information, please note the following:

You must appoint a single senior manager within your organisation as the AIP responsible person for your organisation. If you do not, you commit a criminal offence carrying a penalty of 50 penalty units.

If the person you appoint does not have knowledge and competence to carry out the responsibilities of an AIP responsible person, you commit a criminal offence carrying a penalty of 50 penalty units.

Equivalent requirements and offences apply to your NOTAM authorised person, if you have one.

You must provide Airservices with the name of the AIP responsible person (and your NOTAM authorised person, if you have one) and notify Airservices of any changes. If you do not do so, you commit a strict liability criminal offence carrying a penalty of 50 penalty units.

You commit a criminal offence carrying a penalty of 50 penalty units if you do not notify Airservices of the need to change aeronautical information, as soon as practicable after you become aware of the need.

The data or information you provide must be in accordance with specifications Airservices gives you, or you commit a strict liability criminal offence carrying a penalty of 50 penalty units.

You must review, at least annually, the data and aeronautical information published in the AIP for which you are responsible, keep a record of that review and provide a copy of the review to CASA on request. If you do not do so, you commit a strict liability criminal offence carrying a penalty of 50 penalty units.

Yours in aviation safety and love and kisses

Airservices Australia

LeadSled
17th Oct 2017, 03:42
alphacentauri,
You must have me confused with somebody else, I have not recently or any other time, been calling for the privatization of Airservices.
Contestability for RFSS and small airport towers ( as per the contract towers Airservices operated in US) but not wholesale privatisation. Rejigging to something like the Canadian model would do very well - that is not privatisation.
As for chains of responsibility and legal liability, as seen by the courts, I understand that all too well.
Tootle pip!!

PS: Lead Balloon,
Too close to the truth for comfort.

compressor stall
17th Oct 2017, 04:17
This is the driving regulation.
175.140 AIS providers—aerodromes not covered by Part 139—removal of references in AIP
(1) This regulation applies if an AIS provider becomes aware of an aeronautical data originator:
(a) who is responsible for aeronautical data or aeronautical information about an aerodrome that is not:
(i) a certified aerodrome; or
(ii) a registered aerodrome; or
(iii) an aerodrome to which Subpart 139.D applies; and
(b) who has not complied with Subpart 175.D in relation to the aerodrome.
(2) The provider must remove any references to the aerodrome that the provider has published in the AIP from the AIP when the AIP is next amended.
Note: The aeronautical data or aeronautical information for which the aeronautical data originator is responsible must be specified in a data product specification: see paragraph 175.160(4)(a).

compressor stall
17th Oct 2017, 04:20
And yes, LB, spot on. 50 penalty unit fine for each airfield's contact (The Aeronautical Data Originator) for a whole raft of things.

175.455 Aeronautical data originators—requirement to provide updated aeronautical data or aeronautical information published other than in NOTAMS
(1) This regulation applies if an aeronautical data originator becomes aware of a change that is needed to aeronautical data or aeronautical information:
(a) for which the originator is responsible; and
(b) that has been published by an AIS provider:
(i) in the Integrated Aeronautical Information Package (other than in NOTAMS); or
(ii) on an aeronautical chart.
Note: The aeronautical data or aeronautical information for which the aeronautical data originator is responsible must be specified in a data product specification: see paragraph 175.160(4)(a).
(2) The originator commits an offence if the originator does not, as soon as practicable after becoming aware of the need for the change, provide the AIS provider with the following:
(a) updated aeronautical data or aeronautical information;
(b) the date the updated data or information becomes effective.
Penalty: 50 penalty units.

LeadSled
17th Oct 2017, 04:27
Folks,
Lead Balloon knows whereof he speaks ---- this would scare off most people.
Who from the local council or hospital or wherever would want to put their hand up for an ADO "job".
Australia's oh! so friendly and easy to use aviation regulation.
There has to be a better way.
For those of you who don't know, or have forgotten, 50 penalty point is near as makes no difference AUD $9000.
Tootle pip!!

Division 175.D.1—Aeronautical data originators—general
175.445 Aeronautical data originators—AIP responsible person and NOTAM authorised persons
AIP responsible persons
(1) An aeronautical data originator commits an offence if:
(a) the originator provides aeronautical data or aeronautical information to an AIS provider; and
(b) the originator has not appointed a single senior manager within the originator’s organisation as the AIP responsible person for the originator.
Penalty: 50 penalty units.
(2) An AIP responsible person is responsible for the provision of aeronautical data or aeronautical information, other than in NOTAMS, from the originator to an AIS provider.
(3) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as the AIP responsible person for the originator; and
(b) the person does not have the knowledge and competence to carry out the responsibilities of an AIP responsible person.
Penalty: 50 penalty units.
NOTAM authorised persons
(4) An aeronautical data originator commits an offence if:
(a) the originator asks an AIS provider to issue, review or cancel a NOTAM; and
(b) the originator has not appointed a person in the originator’s organisation as a NOTAM authorised person for the originator.
Penalty: 50 penalty units.
(5) A NOTAM authorised person is responsible for requesting the issue, review and cancellation of NOTAMS for the originator.
(6) An aeronautical data originator commits an offence if:
(a) the originator appoints a person as a NOTAM authorised person for the originator; and
(b) the person does not have the knowledge and competence to request the issue, review and cancellation of NOTAMS. Authorised Version F2017C00742 registered 15/09/2017
Aeronautical information management Part 175
Aeronautical information management—aeronautical data originators Subpart 175.D
Aeronautical data originators—general Division 175.D.1
Regulation 175.450
Civil Aviation Safety Regulations 1998 317
Compilation No. 77 Compilation date: 12/9/17 Registered: 15/9/17
Penalty: 50 penalty units.
175.450 Aeronautical data originators—telling AIS provider of AIP responsible person and NOTAM authorised persons
(1) An aeronautical data originator commits an offence if:
(a) the originator provides aeronautical data or aeronautical information to an AIS provider; and
(b) the originator has not told the AIS provider, in writing, of the following:
(i) the name of the AIP responsible person for the originator;
(ii) the names of the NOTAM authorised persons (if any) for the originator;
(iii) any changes (if any) to the persons who occupy the positions mentioned in subparagraphs (i) and (ii) since any previous provision of aeronautical data or aeronautical information to the AIS provider.
Penalty: 50 penalty units.
(2) An offence against this regulation is an offence of strict liability.
175.455 Aeronautical data originators—requirement to provide updated aeronautical data or aeronautical information published other than in NOTAMS
(1) This regulation applies if an aeronautical data originator becomes aware of a change that is needed to aeronautical data or aeronautical information:
(a) for which the originator is responsible; and
(b) that has been published by an AIS provider:
(i) in the Integrated Aeronautical Information Package (other than in NOTAMS); or
(ii) on an aeronautical chart.
Note: The aeronautical data or aeronautical information for which the aeronautical data originator is responsible must be specified in a data product specification: see paragraph 175.160(4)(a).
(2) The originator commits an offence if the originator does not, as soon as practicable after becoming aware of the need for the change, provide the AIS provider with the following:
(a) updated aeronautical data or aeronautical information;
(b) the date the updated data or information becomes effective.
Penalty: 50 penalty units. Authorised Version F2017C00742 registered 15/09/2017
Part 175 Aeronautical information management
Subpart 175.D Aeronautical information management—aeronautical data originators
Division 175.D.1 Aeronautical data originators—general

alphacentauri
17th Oct 2017, 05:15
Whats wrong with making a aerodrome licence certificate holder responsible for the provision and accuracy of the information pertaining to their aerodrome?
There are aerodromes who up until recently had threshold coordinates that were wrong by hundreds of meters with no response from the aerodrome for years.
If aerodrome licence certificate holders are not taking their responsibilities seriously then why should AsA? All this reg does is pressure aerodrome operators to take it seriously. And if they dont then damn straight they should be removed from the book as well as the approaches.
Its not Airservices responsibility to do it for them.
Yes the restructure forced the hand but the publication if CASR175 means it was coming eventually. I didn't hear anyone screaming when the NPRM was issued.

kaz3g
17th Oct 2017, 05:34
Be interesting to see reactions from RFDS and other providers of emergency response if half the regional aerodromes are wiped from databases.

Most of the GA stops across the southern continent are in the list as are large numbers from WA and NT. Most of the remote Aboriginal communities are listed and I guess the forms might be a tad hard to follow if English is your fourth or fifth language?

I can see one hell of a negligence suit down the way.

Kaz

Lead Balloon
17th Oct 2017, 05:41
Whats wrong with making a aerodrome licence certificate holder responsible for the provision and accuracy of the information pertaining to their aerodrome?
There are aerodromes who up until recently had threshold coordinates that were wrong by hundreds of meters with no response from the aerodrome for years.
If aerodrome licence certificate holders are not taking their responsibilities seriously then why should AsA? All this reg does is pressure aerodrome operators to take it seriously. And if they dont then damn straight they should be removed from the book as well as the approaches.
Its not Airservices responsibility to do it for them.
Yes the restructure forced the hand but the publication if CASR175 means it was coming eventually. I didn't hear anyone screaming when the NPRM was issued.Like motherhood and apple pie, complete and accurate aeronautical information is an objective good.

But whoever it was who decided that a substantial number of accidents and incidents have been caused by incomplete or inaccurate information published in relation to the thousands of aerodromes/HLSs/ALAs on the list has no grasp on reality. That disconnection from reality is confirmed by the fact that whoever it was also decided that the way to deal with the risk of incomplete or inaccurate information is to get people to nominate the ‘criminals’ responsible in advance.

What a surprise that the outcome is instead crickets chirping and unintended consequences including a reduction in safety.

Ixixly
17th Oct 2017, 07:07
alphacentauri, I'm pretty sure if there is an Approach then the information should be very accurate, I HIGHLY doubt the Aerodrome has moved much from year to year and doubt the information used for the approach is provided by an ADO and if it doesn't have an approach it shouldn't be an issue either then.

LeadSled
17th Oct 2017, 07:24
AlphaC,
Now who doesn't know/understand what they are talking about --- most of the places on the list are not certified (or even registered) airfields --- CASA regulatory requirements (CASR Part 139, complexity and cost) have meant that many local councils ( and others) have dropped out of that system, unless they have RPT of the size where they have to maintain same.

As has been made clear, a substantial proportion are EMS hospital helipads.

There has to be, there must be, a better (and affordable) way.

Tootle pip!!

alphacentauri
17th Oct 2017, 08:03
Ixixly, you'd be mistaken

Leadsled,
Let's just say that if I sat down with you over a beer I'm sure we'd both end up in fierce agreeance. I think your frustrations at Airservices are misguided. They have no obligations and are doing what they are allowed to do under the regs. It's the reg and CASA mindset that has to change first.

Do I like Airservices attitude toward the whole thing? No. Do I agree with reg as written? Not entirely. But there are still major airports that don't/can't/won't hand over important infrastructure information which can and does compromise safety. Should they be penalised for it? Not initially, but how long do you let it remain an issue and how else do you get them to hand it over? Some aerodrome operators in ERSA/DAP don't even know they have responsibility for an aerodrome.

Why I stated that I didn't think you knew what you were talking about was because if you understood the reg framework you wouldn't have come out all guns blazing at AsA. Part 175 requires them to do what they are doing.
Alpha

Ixixly
17th Oct 2017, 08:30
Alphacenaturi, care to explain further as to how I'm mistaken? I'm genuinely curious.

I was under the impression that an Instrument Approach design requires the area to be well surveyed for it and that any drift in the coordinates would be extremely minimal from year to year which is why they don't need a new survey conducted? And if the coordinates are off for a VFR flight by a couple of hundred metres then what's the major issue there?

Can anyone tell me if Part 175 is something new as well? Or has someone spied their eye over it and decided that even though nothing has changed and they could continue status quo that doing so would leave them open in legal sense and required this fairly drastic move?

I also think alpha that most us aren't necessarily against them trying to get the data current and checked, most of us are aghast at how so many that shouldn't be an issue suddenly are, I don't see how removing so many Hospitals Landing Sites for instance is of any use to anyone?

Sunfish
17th Oct 2017, 08:49
all this **** comes about because CASA is not required to have regard for the good of the industry.

Lead Balloon
17th Oct 2017, 09:05
Part 175 has been around for a while. Most have been ignoring it for the obvious reasons, and now bad things are going to happen as a consequence of it. If I were a betting person, I reckon the usual bandaid will be rolled out: exemptions.

I wonder whether the people who came up with the masterpiece considered that maybe the person who has the knowledge and competence to carry out the responsibilities of an AIP responsible person for e.g. YBHI is not and never will be a “senior manager” within the Broken Hill Council, and therefore it’s impossible to comply?

Or whether they considered the possibility that when all information about and chart markings of places like YBHI disappear completely from the AIP, people will still operate in and out of those places, simply using whatever old and ‘bootleg’ information they can get a hold of. What a terrific outcome for safety.

If I were to dedicate time to responding to and explaining the disconnection from reality, the overkill, the unintended consequences and the impenetrable complexity of proposed civil aviation regulations, I would do nothing else until I went mad. Alas, I have a day job and would prefer to stay sane.

no_one
17th Oct 2017, 09:09
I have put all of the coordinates into google maps so that people can see which points are in their local area, from the names it is hard to work out sometimes.

https://www.google.com/maps/d/viewer?mid=12ZCqIxMnOn662_ZnzMRVD8lpR90&usp=sharing

A lot of them are Helicopter sites and a few are seaplane sites but there are also some site that I would have thought there was enough activity to warrant remaining listed eg Broken Hiil and "The Oaks"

Ixixly
17th Oct 2017, 09:28
Consider when I'm around there I hear "The Oaks" at least twice a day, I concur no_one, there's a lot of places up in the NT that are frequented as well in Arnhem land.

Lead Balloon, sanity is overrated, let's face it, if we were all truly sane we probably wouldn't have gotten into Aviation, let alone stuck around! :D

Lead Balloon
17th Oct 2017, 09:41
Lead Balloon, sanity is overrated, let's face it, if we were all truly sane we probably wouldn't have gotten into Aviation, let alone stuck around.Touché, Ix.

andmiz
17th Oct 2017, 09:58
There's also a few listed serviced by RPT flights, with IAP's designed and published by Airservices. Can only hope the AIP is trying to sling some responsibility back to CASA after a industry backlash.

alphacentauri
17th Oct 2017, 17:35
Ixixly,
Understood, aeronautical data in Oz suffers from inaccuracies over time mainly due to the different datums they have been surveyed in.
Eg. Many airfields were originally surveyed in AGD66 and the conversion to WGS84 is epoch based. Some agd66 positions have been published as wg84 and can be up 200m in error. We are still recieving data from Perth in Perth Coastal Datum and Adelaide in SA local.
175 has been created to try to solve some of these problems, but there is a long way to go.
Eg try telling the aboriginal elder at Kalkgurung that his data is incorrect.....they just dont understand

Lead Balloon
17th Oct 2017, 20:28
Any data as to the number of actual accidents and incidents actually caused by incomplete or inaccurate data published in AIP about these places? Any “evidence” and “risk analysis” to justify the statutorily-mandated bureacratic structure and criminalisation of human error?

Astonishing that Australia managed for decades without the equivalent of Part 175 bureacracy and offences but now it’s going to rain aluminium if all those criminals who haven’t been providing or updating complete and accurate aerodrome information continue to get away with it.

underfire
17th Oct 2017, 20:53
CAAP 89O-1(2) - Published aerodrome information and reporting changes

Unlicensed aerodromes. Unlicensed aerodromes are not required, under the regulations, to provide aerodrome information to AIS or CASA and to have their aerodromes included in ERSA.
However, on request of the aerodrome operator, an unlicensed aerodrome used by aircraft with 10 or more passenger seats and engaged in regular public transport operations will be accepted in ERSA with full aerodrome information similar to that of a licensed aerodrome.

FAA: Now, from I remember, the airport surveys are good for 10 years. You are supposed to update or verify the survey at least every 10 years, or if there are any changes. This is up to the owner of the airport.
Every 10 years is a minimum, or if there have been any changes. 10 years looks at the vegetation and obstructions, and of course, the magvar.
Waypoints are reviewed on the AIRAC cycle, every 56 days, any changes are noted, but if there are no changes, waypoints can stay forever.

EDIT: update...

The Civil Aviation Safety Authority (CASA) Manual of Standards (MOS Part 139 Sect 7.2) and Sydney Airport’s Airport Operations Manual requires an annual instrument survey of approach, take off and transitional surfaces of all of our runways.

Jetjr
17th Oct 2017, 23:00
Any reason they cant be left on maps marked as "unverified" with last known data and date.
Not only talking 10 pax RPT need this info
Small singles in trouble might be very happy to know an old runway exists somewhere under them.

mikewil
17th Oct 2017, 23:44
Small singles in trouble might be very happy to know an old runway exists somewhere under them.
Agreed, if I had to do a precautionary search and landing, I'd much rather attempt to do it on something that was once a landing strip than a dodgy paddock with sprinkler systems, undulating furrows and god knows what else that I wouldn't see until already bouncing along the ground.

Old Akro
17th Oct 2017, 23:57
In my pinion, the malaise that infects most government departments now is that they are Canberra based and staffed with career public servants who change between departments or disciplines regularly rather than industry specialists.

I suspect that this move is really driven by laziness from bureaucrats wanting to make their life easier without having any understanding of the impact of their decision.

Putting the regulations aside, AsA's raison d'etre is to provide infrastructure to facilitate aviation safety. Or in their own words:

Our purpose is to provide safe,
secure, efficient and environmentally
responsible air navigation and
aviation rescue fire fighting
services that are valued by the
aviation industry.

Safety is our number one priority. We
are proud that global benchmarking
consistently places Airservices as
one of the top air navigation service
providers for safety in the world.

It would seem to me that this move is an abrogation of this responsibility.

Or put bluntly, they are trying to short change us by not delivering a core safety service in the interests of cost cutting

Ixixly
18th Oct 2017, 00:47
Alphacentauri, I actually work in Survey so understand a little about this. My main point is that if an approach was now off by 200m then surely the approach is now no longer valid and would be pulled and to put it back in would need to be re-surveyed, thusly even knowing the details and calling an ADO wouldn't assist in this matter?

Plus, once again, what does 200m matter to a VFR Pilot?

Sunfish
18th Oct 2017, 01:22
I can't see any council finding a designated senior manager for this role given that a stuff up will result in them receiving a criminal conviction.

triadic
18th Oct 2017, 02:40
Instrument approaches to non certified/registered aerodromes was removed some years back due to the fact that the details of obstacles etc was not reviewed often enough, much to the frustration of some airfield operators.:{

I understand there is a push now to revisit the approval of an approach to such airfields, perhaps to a higher (circling) min.:D

It seems that this aerodrome data collection process has been handled badly by Airservices, however the real blame must rest with CASA and those that were responsible for the drafting of 175 (and other regs as well!) in that very little if any consideration is given to GA or operations below 5700kg and the unintended consequences of the poor drafting. One would think that the 'experts' in CASA might consider this in their reviews, but as said above they have no responsibility to foster or encourage aviation:ugh:!

Lead Balloon
18th Oct 2017, 03:10
Mostly CASA, but no prizes for guessing which ANSP would have been pressing for the regime that’s been implemented.

Ixixly
18th Oct 2017, 04:20
Or worse yet Triadic, they did consider the ramifications to GA and as usual, just don't give a damn!

weloveseaplanes
18th Oct 2017, 07:50
Am saddened to read what is happening to aviation in the Lucky Land :(

De_flieger
18th Oct 2017, 12:37
There's a few ports served by RPT flights in there too, I'd imagine those companies and operators won't be thrilled if their airports and instrument approaches disappear from the databases! What a mess.

triadic
18th Oct 2017, 13:01
Advice to hand is that some of the RAPAC convenors have been advised that the AIC is to be withdrawn. It will be redrafted to address industry concerns.

LeadSled
18th Oct 2017, 13:37
Why I stated that I didn't think you knew what you were talking about was because if you understood the reg framework you wouldn't have come out all guns blazing at AsA. Part 175 requires them to do what they are doing.Alpha,
I understand the regulatory framework all too well.

I also understand that the AIP is the responsibility of Airservices, an international treaty obligation of Australia as a member of ICAO, not CASA.

For Airservices to unilaterally decide that the answer to updating some 2000 or so spot positions (not aerodrome data packages), including a large number of hospital EMS helipads vital to public health, is wiping them from the database ---- to ensure CASA compliance.

It is simply not good enough that these positions will no longer be available for GNSS/FMCS/EFB updates, and later disappear from paper maps.

There has to be a better way than creating "inadvertent criminals", or losing the data altogether ---- an obvious way is for Airservices to contract suitable surveyors who do have the expertise to "get it right" ---- versus such as hospital administrations, local shire councils and the like who do not have the knowledge and expertise to even digest CASA's terrible regulations. How much has Airservices paid in dividends to the treasury in recent years??

Tootle pip!!

PS: I had a quick look for the "standards" for a survey of a position/airport reference point, to meet Part 139 requirement, can anybody give me a reference.

This is not a trivial question, given the recent "move" of Sydney's Centerpoint Tower, after all these years, necessitating adjustment to a number of procedures for YSSY 16L/34R.

I would think, but don't know, that a surveyors differential GPS would be satisfactory, but the differential corrections are not available in many remote areas, as I recall, unless you have OmniSat gear??

Lead Balloon
18th Oct 2017, 20:40
Here is a ‘good’ example of what is so wrong with the thinking of the aviation ‘safety’ rule makers:175.465 Aeronautical data originators—annual review of aeronautical data and aeronautical information

(1) An aeronautical data originator commits an offence if the originator contravenes subregulation (2).

Penalty: 50 penalty units.

(2) For subregulation (1), the originator must:

(a) review, at least annually, the aeronautical data and aeronautical information in the Integrated Aeronautical Information Package (other than in NOTAMS), and on aeronautical charts, for which the originator is responsible; and

(b) keep a record of a review mentioned in paragraph (a) for at least 3 years; and

(c) if CASA requests a copy of a record mentioned in paragraph (b)—comply with the request.

Note: The aeronautical data or aeronautical information for which the aeronautical data originator is responsible must be specified in a data product specification: see paragraph 175.160(4)(a).

(3) An offence against this regulation is an offence of strict liability.I note that there is no element of the offence requiring that the data or information is actually inaccurate. Nor is there an element of the offence requiring that any actual inaccuracies have any substantial effect on safety. (The structure of the regulation is also ridiculous.)

This regulation is not about safety.

It’s about bureaucracy.

The data originator is a criminal simply for failing to be a good bureaucrat. Whether that failure has any substantial impact on safety is completely irrelevant.

Sunfish
18th Oct 2017, 21:51
"It's about bureaucracy"? No it isn't, it's about Government and their minions not accepting any shred of liability for safety outcomes.

"Bureaucracy" as a system of administration saves us from corruption by and large.

What CASA, Airservices, the ATSB and Department of Infrastructure have done is attempted to build a firewall between the Government and the Governed by passing draconian regulations that purport to produce a safe system for the general public.

"I don't know what more we can do" the Government can piously say after the next aircrash. "We have the strictest safety standards in the world backed up with severe criminal penalties for anyone who breaks the rules" they will say.

It will take at least three large smoking holes, followed by a Royal Commission to give the lie to this.

Meanwhile actual safety performance will continue to degrade.

This latest safety bungle will reduce the number of aerodrome options available to a pilot in need of somewhere to land as well as limit the amount of information available on the remaining aerodromes.

To put that another way; you can't be held responsible for something you don't have to provide. I've noticed this with weather information, no forecaster will give you their opinion of weather at say, Kilmore Gap. Similarly Airservices response to this problem will be to minimise the amount of information presented, less some of it be innaccurate from a legal point of view.

To put that yet another way; Who is going to take responsibility for Marree considering the amount of tourist traffic it gets in a flood year?

Ixixly
18th Oct 2017, 23:35
It's all about the CARE Factor Sunfish, CARE being Cover Arse Retain Employment. Anytime someone from CASA, ASA or the Government tells you that they CARE, they're being honest, just not the way you think!

outnabout
18th Oct 2017, 23:43
Ixixly - such cynicism!

I am shocked and dismayed...........that you may - in fact - be bang on the money.

Lead Balloon
19th Oct 2017, 00:55
Here’s where these rule making processes go wrong, and why.

We start with an accurate statement about a risk: If information or data published about an aerodrome is incomplete or inaccurate, the incompleteness or inaccuracy could cause an aviation disaster.

That statement is correct, in the abstract.

But the next step is where it goes wrong: Given the potentially disastrous consequences, any regulation that mitigates the risk of incomplete or inaccurate information or data in AIP is justified.

Although that second statement may make perfect sense to some - usually the people on a mission to make the world risk-free by regulation - it is fundamentally flawed logic that produces regulatory over-kill and unintended consequences as a matter of practicality.

First, the statement fails to take account of the fact that the incompleteness or inaccuracy of some aerodrome information may have no or negligible consequences. Certainly the safety of the operations with which alpha centauri is concerned do depend on complete and accurate information. But many other operations don’t. Further, not all incompleteness or inaccuracies necessarily result in increased risks to safety.

Secondly, and probably more importantly in this case, the logic makes assumptions about human behaviour, which assumptions are disconnected from reality.

We know how to get the data and information complete and accurate: Make the people who provide it criminals if they don’t provide data and information that is complete and accurate. Brilliant! And it’s even worse in this case: Make them criminals even if the incompleteness or inaccuracy had no actual impact on safety. Extra brilliant!

The response of potential information providers in the real world? You can stick this up your ar*e.

no_one
19th Oct 2017, 01:42
So if all these airstrips disappear from the maps will we have to call on the Area frequency and not 126.7 when operating there? The cynical might suggest that the two issues are somehow interlinked....

Lead Balloon
19th Oct 2017, 02:18
They are linked, but I doubt causally.

The more obvious explanation is the usual one: People disconnected from reality have blown a risk out of all proportion and attempted to mitigate it in an impractical way.

thorn bird
19th Oct 2017, 02:40
Noble Cause Corruption?
or another reason to take the letter S from CAsA's handle?

no_one
19th Oct 2017, 02:54
The way CASA seem to go about implementing rules is:


Publish an incomprehensible NPRM buried in amongst so many rule changes so that the people affected by the change don't know that it is coming.
Ignore any comments received or worse integrate them poorly into the original proposal so that outcome is more onerous than it would have originally been.
Implement proposed instruments and amendments.
Sit back and wait. If done well someone else (in this case airservices) does the dirty work and cops the flack when the rules are followed through.
CASA saves the day by issuing an exemption to the new rule.


We are just waiting on 5 to happen here.

I suspect that we are at step 1 with NPRM 1426AS, "Post-implementation review of the legislative framework for Part 139 - Aerodromes".
https://consultation.casa.gov.au/regulatory-program/nprm1426as/consult_view/

It sounds OK but what is the devil in the detail??? Will this result in further airport costs of compliance and therefore closures...

Lead Balloon
19th Oct 2017, 03:01
Sunfish said: Who is going to take responsibility for Marree considering the amount of tourist traffic it gets in a flood year?You can comfortably assume that the volume of tourist traffic will remain the same, whether or not details of Marree are published in AIP.

You may be labouring under a misconception. Who do you think “takes responsibility” now? Marree’s already uncertified and doesn’t have a NOTAM service, so it’s effectively been ‘use at own risk’ and check suitability in advance, for a long time.

Marree’s one of many good examples of why Part 175 is an over-kill. I guarantee that Marree’s actual location and actual elevation won’t change much, whether or not those details appear in AIP. If some ‘criminal’ told Airservices that the elevation of Marree is 1,164’ rather than the currently-published 164’, and the erroneous 1,164’ were published in AIP, do you reckon it would rain aluminium? Would you keep trying to land on a non-existent runway at 1,164’ that you can see 1,000’ below you until you ran out of fuel, or would you land on the runway?

I’d probably land on the runway...

Sunfish
19th Oct 2017, 03:08
I suspect CASA will fight like hell to keep the penalties in place because to remove them would set a precedent for removing volumes more.

Lead Balloon
19th Oct 2017, 03:16
The penalities aren’t there because CASA wants them there. They’re there because another part of the bureacracy takes the view that a regulation is not a regulation unless there is a penalty for non-compliance.

The mistake is using a regulation to deal with a problem to which a regulation is not the solution in the real world.

Musician
19th Oct 2017, 07:20
Marree’s one of many good examples of why Part 175 is an over-kill. I guarantee that Marree’s actual location and actual elevation won’t change much, whether or not those details appear in AIP. If some ‘criminal’ told Airservices that the elevation of Marree is 1,164’ rather than the currently-published 164’, and the erroneous 1,164’ were published in AIP, do you reckon it would rain aluminium? Would you keep trying to land on a non-existent runway at 1,164’ that you can see 1,000’ below you until you ran out of fuel, or would you land on the runway?

I’d probably land on the runway...
What would an autonomous drone do? Computers are typically fairly bad at situational awareness, and they're going to need reliable ground and obstacle data. Who is going to pay for providing that? The answer might determine whether autonomous flying drone service is ever going to be a profitable commercial concern. (note also that once you have liable data providers in place, the next step can be extending he amount of data that needs to provided)

Some people have wondered why the regulation does not mention if the information is correct at all. If you can be held criminally liable, you're open to a civil lawsuit recovering damages if something actually happens. That's probably why the person responsible must be a senior manager: otherwise the organisation might escape liability.

Lead Balloon
19th Oct 2017, 09:15
What would a wedge-tailed eagle do? I’ve had far more near-misses with wedge-tailed eagles and other birds than drones. I’m assuming birds aren’t relying on the AIP to work out where not to fly.

You’re open to civil liability “if something actually happens”, whether or not you’re criminally liable. Vicarious liability of an organisation for the negligence of staff at any level is a settled principle. Your last paragraph therefore does not make sense to me.

Musician
19th Oct 2017, 12:04
TK726 had a runway excursion in Kathmandu in 2015 because of an error in the database. Now imagine small airplanes with autoland in the future. The problem is that the very same database is even today being used by machines and humans alike, and thus needs to conform to the higher standards of accuracy. Thus is the bane of automation.

Oh, and drones have worse situational awareness than birds, but there are less of them, and legal rules, so they're not around planes as often (and havent been around as long as birds, either).

LeadSled
19th Oct 2017, 13:39
Folks,
Allow me to repeat, for about the fourth time --- THIS IS NOT ABOUT AERODROME DATA PACKAGES, or arrival and departure procedures, or all that sort of stuff.

It is a list of latitudes and longitudes, each for a single position, it might be for an airfield reference point, or a number of other aeronautical positions of significance, or helipads.

To my mind, the most important of all these (and I think they all should stay because there is no good reason to remove ANY of the 2000+) are the EMERGENCY MEDICAL SERVICES hospital helipads ---- ANYTHING that makes it harder to get patients to Accident and Emergency at the nearest hospital ASAP is an unnecessary threat to human life and limb.

What part of this does Airservices NOT GET!!!!

Remember, knocking all these positions out means they get knocked out of GNSS/FMCS/AvMap/OzRunways/Jeppesen and all Airservices own publications. None of the just mentioned can turn to AOPA etc type airfield directories ---- ONLY Airservices published data.

Ixixly, you mentioned you work in survey --- what do you know about getting a lat and long to centimeter accuracy, to the standards of Geoscience Australia --- which I presume (perhaps a little optimistically) would meet any Airservices/ICAO standard.

I know multiple ways of doing it, from doing a rough check via Google Earth, right through the iterations up to what I would do in verifying the position of land on a title document ---- but what does CASA/Airservices require. Any help with references, please.

Tootle pip!!

Awol57
19th Oct 2017, 14:41
Whilst I tend to agree about losing the data, I am a bit perplexed as to how the emergency services helicopters suddenly won't be able to find a hospital.

Let's take an example of YXPD. I know there is a helipad there, a VFR helicopter flies in there fairly regularly. I have driven to the helipad. It is not marked on any charts that I can see, nor can I find any lat/longs to it anywhere.

I will concede I have only looked in ERSA. The only place I can find any reference to it at all is in the Encode/Decode area.

I only looked at that one hospital as it is a local one to me, but I can't recall any of the Perth ones being on the Perth VTC (happy to be corrected on that). May be different over east?

Either way I don't think the data should just be "dumped" but I am not sure it is all about the Emergency services suddenly being unable to find a hospital.

Sunfish
19th Oct 2017, 20:55
Awol57: Whilst I tend to agree about losing the data, I am a bit perplexed as to how the emergency services helicopters suddenly won't be able to find a hospital.


The locations ust be erased from the databases that are loaded into the GPS or FMC if they are not "approved" data. "Approved" data we are told must meet certain standards under threat of new criminal penalties for the originator.

That means that the locations will probably have to be manually loaded as user waypoints, probably by the pilot, using data out of an old paper copy of ERSA. How safe is that?

Sunfish
19th Oct 2017, 21:02
A further complication of this stupidity by CASA/Airservices is that even my Dynon system will "push" airport frequencies to my radios as I fly however it can't do this if the airport data isn't there in the pocket FMS database.

Which begs the question; if airports disappear from ERSA, doesn't that mean that the associated CTAF also ceases to exist? What about the myriad of airports with special procedures? Does all that vanish too? How would a pilot know? Isn't ERSA the primary reference for everything?

KRviator
19th Oct 2017, 21:16
And it is not "just" the individual HLS's going. It will be their associated instrument approaches as well. Westmead has 3, 2 GNSS 1 NDB. Merriwa has a GNSS, it's on the list, so is Mossman Hospital and Tully Hospital.

Sure you might be able to find an accident scene and get down in bad weather, but if the hospital approach no longer exists, how do you find the HLS to offload your patient?

outnabout
2nd Nov 2017, 00:16
From AOPA's newsletter published on Tuesday, 31 October:

The industry scored a big win this past week, with Airservices Australia announcing the withdrawal of AIC H29/17, giving a reprieve to 2,000+ airports that were facing removal from the AIP/WAC. Through the determined work of the RAPAC and AOPA Australia representatives, Airservices have agreed to re-draft the AIC so be more consistent with the intent and requirement of the CASR Part 175. More on this as it develops.

Ben Morgan
Executive Director of AOPA.

Lead Balloon
2nd Nov 2017, 00:46
.... Airservices have agreed to re-draft the AIC so be more consistent with the intent and requirement of the CASR Part 175....The requirements and effects of Part 175 seem to me to be quite clear. For example:

An ADO provides information and the information is published in the AIP. 367 days later the ADO has yet to do a review of that information. The ADO is a criminal, even if the published information remains complete and accurate in fact.

An ADO provides information and the information is published in the AIP. During the following year the ADO does a review of that information, but does not record the fact that the review happened, or its results. The ADO is a criminal, even if the published information remains complete and accurate in fact.

An ADO provides information and the information is published in the AIP. During the following year the ADO does a review of that information, and makes and keeps a record of the fact that the review happened and its results. During the second year the ADO does a second review and makes and keeps a record of the fact that the second review happened and its results, but throws the record of the first review in the bin. The ADO is a criminal, even if the published information remains complete and accurate in fact.

What’s not clear to me is how criminalising the ADO in these cases improves ‘safety’.