Voices of Reason and Class E

[Dick Smith]

I can’t believe we could have a Class E thread without bringing up the wonderful wisdom of Voices of Reason and Class E of over a decade ago. Here is what he said from his post.

By the way, many people say that Voices of Reason was the late Phil Faulkner, a knowledgeable air traffic expert from Airservices.

“Class E Airspace and United States Practice

We have watched with incredulity at the dangerously naive statements being made on threads in the Australian PPRuNe sites, concerning the operation of Class E airspace. Class E airspace is NOT an unsafe categorization of airspace, and is in fact used safely and effectively in substantial portions of the globe.

EACH AND EVERY transport and passenger carrying aircraft operating in the United States is required to operate for some portion of their flight in designated Class E airspace – effectively between 18,000 feet and the upper limit of Class B, C or D airspace – or the surface for non controlled aerodromes. This equates to over 10,000 passenger-carrying flights per day, every day of the year. The Class E airspace within which they operate is in the so-called most dangerous phase of flight – climb or descent. Your national carrier is no exception.

There are in excess of 150,000 general aviation aircraft operating in the United States, to either the visual or instrument flight rules – many many thousands per day.

There are CONSTANT interactions between IFR passenger carrying aircraft and VFR aircraft on a daily basis – with no hint that this practice is unsafe.

There are countless examples where aircraft provided with routine terminal area instructions whilst still in Class E airspace are routinely provided sequencing descending turn instructions by controllers in one breath, and VFR traffic information in the other.

We agree that Class E airspace is mostly within radar cover in the United States – probably the greater part of 95%. In that airspace, air traffic controllers positively separate IFR flights from other IFR flights – and where they can, provide traffic information on VFR flights.

Radar coverage is NOT a prerequisite for Class E airspace, and in fact in several cases the Class E airspace linking certain aerodromes to upper airspace is not covered by radar. In that airspace, air traffic controllers positively separate IFR flights from other IFR flights – and as they cannot observe VFR, do not pass traffic unless they know by some other means. That positive IFR-to-IFR separation may, in many cases, be applied on a “one in at a time” basis. The airlines accept that mode of operation.

NOT ONE SINGLE AIRLINE in the United States is lobbying for a higher level of service in current Class E areas.

Our observation in relation to the Australian experience has been one of giving proper effect not just to training and education, but also to the cultural change requirements. Pilots need to understand that operating in Class E airspace IS FUNDAMENTALLY DIFFERENT to the service that they have received in the past – but need to accept that this is a normal way of doing business.

Australian controllers need to STOP being negative, embrace the concept of Class E airspace and tobeblunt, get on with it. Controllers in the United States provide services in Class E, without questioning its “safety”, day in and day out, and have done so [either as Class E, or its predecessor], for over 50 years.

NOT ONE SINGLE CONTROLLER in the United States is lobbying for a higher level of service in current Class E areas.

We are concerned that this constant questioning and second-guessing by your pilot and controller fraternity will in fact generate a safety deficiency larger that the problem you are trying to solve. By our estimation, there is NO JUSTIFICATION for the large amount of Class C airspace presently designated in Australia, and subject to the appropriate change management processes we have previously described, you should introduce Class E airspace wherever possible.”

[Atlas Shrugged]

By the way, many people say that Voices of Reason was the late Phil Faulkner

Really..............??????

[Dick Smith]

Strange that such a rational and knowledgeable poster would remain anonymous.

[Traffic_Is_Er_Was]

Many people say the earth is flat.

[topdrop]

Phil was a very respected controller and Head of ATC. I knew him quite well and followed the Voices of Reason threads. While VOR could have been Phil, I doubt it from what VOR said in the thread and what I knew of Phil's personal feelings about NAS.
It is a great pity Phil died so early. RIP.

[alphacentauri]

I can’t believe we could have a Class E thread without bringing up the wonderful wisdom of Voices of Reason and Class E of over a decade ago. Here is what he said from his post.

I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.

[Lead Balloon]

Is ForG this century’s answer for this century’s problem? If not, what is?

(Not ‘having a go’, alphcentauri. It is clear you know of what you speak.)

[Plazbot]

"Class E is last century's answer for a modern problem.....and its obsolete."

Probably true and I don't disagree. Australia and the USA's geographic location/isolation allows for a bit of a home grown spin on ICAO airspace classification. When you take the concept to Asia, Europe and Africa, standardisation is essential and unfortunately has to cater to the lowest common denominator.

[alphacentauri]

Lead Balloon, I think its premature to determine an answer at this point. However, the path to a solution is not hard to follow.

1. We need an agreed upon risk framework so that risk can be determined for certain operations in to particular locations (note I have not used the term airspace). The risk model is to include, traffic mix, traffic density and CNS capability. (amongst other things).
2. We also need an agreed methodology to determine the problem we are attempting to solve.
3. We need a risk acceptance framework where by risk can be determined, assessed and accepted against the problem. Not all problems need solutions. Some risks may be acceptable provided all parties are informed.

Lets take Ballina. (None of what I am about to type is a proposal. I have used these examples to trigger a discussion. That is all)
What exactly is the problem we are trying to solve? OAR would have you believe that communications masking from Lismore and over transmission is the problem that lead to the A320/Jabiru incident. But it is known fact that the Jabiru made a transmission, and no one else transmitted at the time. The A320 was in line of sight so terrain shielding also was not at play. So what caused the incident? Is it traffic mix? Is it poor training from Jabiru or A320 crew....I genuinely don't know, but shouldn't we try to find out what the root cause was before we introduce another set of complexities and problems? Class E at Ballina, would not have prevented the incident, and neither would the broadcast zones that are being proposed. Here's the final question, do we absolutely want to prevent a Jabiru from taking out an A320? I would argue, most probably, yes. So the solution is going to have make that the priority outcome, and that may mean excluding some types of operations. So we don’t want any probability of that even happening. (stay with me, I'm going somewhere with this)

Now take Mangalore.
We really don't know yet what actually caused this accident? We may end up putting it down to bad luck? But, how do we know there is not a latent error in the airspace system that could have this happen anywhere else? (I’m sure I read a comment along that line by you somewhere, I agree by the way).
But what if this is the 1:10(-9) event. Is that ok? Should we invest time/money in trying to make a system more safe, when everybody seemed happy with the 1:10(-9) risk?
In this way we need to develop tools to determine if a) there is an latent error or, b) this is the 1:10(-9) event. If its b) we also then need the testicular fortitude to stand by the level of risk that we have accepted. I feel terrible for those 4 blokes, its sad and I hope it never happens to me. But flying has a risk, we all accept it. Its not zero. If we establish that the risk at Mangalore is as we thought it was...does it need a solution?

So take the 2 scenarios above. 2 totally different problems, with what I hope would be 2 different set of airspace performance requirements, which would lead to 2 different outcomes with 2 different associated levels of risk. How then can the same solution be applied to both locations, and the same outcome be expected? All you are doing is adding another variable to an existing set of variables that have not been assessed appropriately in the first place.....this makes the risk increase significantly.

The point being if we have a mutually agreed framework with which to assess and determine the risk of operations at a particular location, and then you have an agreed framework with which to mitigate that risk (or not) then the outcome should be valid.

We are not ready for solutions yet.

[Lead Balloon]

Thanks, alpha. We can but dream.

[PPRuNeUser0201]

Alpha, this is the most reasonable post on here, I have to say. the Airservices proposals are red herring as no one has defined the actual issue/s that need fixing. Your post also brings to the fore the age old question about what is acceptable in terms of risk. If 10 *-9 is what we are aiming for, it is very low but it means there is still a chance of the risk eventuating. But does it pass the pub test? My opinion is that yes it does, but when it comes to the public who are mostly informed through sensationalised media, they would say any accident is unacceptable - illogical when you compare the road toll. It’s for this reason that both CASA and Airservices are always going to be on hiding to nowhere because the public is who the politicians are answerable to, not aviators. So where to from here? In my view, and dare I say, industry, the regulator and ANSP need to come together to agree on a best achievable outcome when it comes to risk appetite and then try and convince the government AND opposition that this can be the only way forward. It’s only then will we be able to have acceptable regulation that doesn’t destroy the industry. For the nay sayers, I get this is idealistic and shock horror that someone would suggest such a thing, but I’m at a loss otherwise.

[alphacentauri]

Agreed Flying Higher,

If 10 *-9 is what we are aiming for
That's the problem, we actually don't know what we are aiming for. I would argue that we are not aiming for the same risk level in all airspace. This needs to be determined! Airservices/CASA proposed solutions assume that the risk is the same (this assumption is made because they role out the same solutions)....its not.

How can we have solutions, when we have not identified the problem, or its extent?

Cheers, α

[Dick Smith]

If class E is last centuries answer to airspace classification what is this centuries answer?

This is a serious question! Do you think Australia should lead the way with this new category?

[alphacentauri]

We haven't determined this centuries problem/s yet, nor have we determined what level of risk we are prepared to accept in a solution. All we are doing is proposing solutions that are looking for the problems and increasing the complexity of the airspace.

No reason why Australia can't lead the way, it needs to be a performance based airspace classification system. The problem is going be finding people who have an ability to free their minds of last centuries' thinking.

α

[Dick Smith]

We want the highest level of risk reduction we can afford. Pretty simple really.

[Geoff Fairless]

alphacentauri - your words, on the surface, seem very reasonable. They are however not soundly based and I will try to unpack all of that with my comments:
Post number 1

I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

The "reason" for airspace (I assume you mean airspace classes) has not, as you claim, changed over the last 20 or 50 years. Technology has moved on but in some ways that has increased, not decreased, the risk. There are now more aircraft, even GA has high-performance jets and navigation accuracy has eliminated what ATCs used to call "the big sky theory" (that is even if separation was non-existent, the aircraft would probably miss each other).

The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

Quite correct, that is why there are different classes of airspace. ICAO standards contain some requirements but most are imposed nationally in accordance with local needs.


Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.

This is incorrect, the US NAS has hardly changed in the 30+ years I have been watching. It is basically a large "bathtub" of Class E with higher standard classes embedded where they are needed.



I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

ICAO, not Dick, believes that the current airspace solution is fit for purpose, with the exception of unmanned aircraft, about which there is currently a lot of discussion.



The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

This is precisely the process used to derive the type of airspace, from the internationally agreed list, that is need for a given location. National authorities then impose aircraft equipment requirements on top of the basics based on "what do we need the airspace for?" Obviously, Sydney/Ballina/Pilbara are different, that is why we have different airspace classes.



Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.

I can assure you (past chair IFATCA standing committee 4) Class E is universally hated by the world's ATCs; this is mainly because the majority, outside of the USA, are used to hard lines of delineation between controlled and uncontrolled airspace. None operate anything other than a FIS in class G and I guarantee that most would be appalled by having mandatory traffic information to IFR in Class G. How can you do that, they would ask. I would ask, if you know where the IFR aircraft are why don't you separate them?



Post Number 2

1. We need an agreed upon risk framework so that risk can be determined for certain operations in to particular locations (note I have not used the term airspace). The risk model is to include, traffic mix, traffic density and CNS capability. (amongst other things).

See Australian State Safety Program 2021



2. We also need an agreed methodology to determine the problem we are attempting to solve.

See Australian State Safety Program 2021



3. We need a risk acceptance framework where by risk can be determined, assessed and accepted against the problem. Not all problems need solutions. Some risks may be acceptable provided all parties are informed.

CASA requires risk assessments for all changes, airspace or otherwise. The process is similar to AS ISO 3100:2018; risks are determined, assessed, categorised, mitigated, and should be accepted by an accountable person. As you say, some risks are classified as acceptable but should still be recorded and watched for change.



Lets take Ballina. (None of what I am about to type is a proposal. I have used these examples to trigger a discussion. That is all)

What exactly is the problem we are trying to solve? OAR would have you believe that communications masking from Lismore and over transmission is the problem that lead to the A320/Jabiru incident. But it is known fact that the Jabiru made a transmission, and no one else transmitted at the time. The A320 was in line of sight so terrain shielding also was not at play. So what caused the incident? Is it traffic mix? Is it poor training from Jabiru or A320 crew....I genuinely don't know, but shouldn't we try to find out what the root cause was before we introduce another set of complexities and problems? Class E at Ballina, would not have prevented the incident, and neither would the broadcast zones that are being proposed. Here's the final question, do we absolutely want to prevent a Jabiru from taking out an A320? I would argue, most probably, yes. So the solution is going to have make that the priority outcome, and that may mean excluding some types of operations. So we don’t want any probability of that even happening. (stay with me, I'm going somewhere with this)

I have first-hand experience and I believe that the root cause is trying to operate a multi-purpose airport in a moderately trafficked airspace without the supporting ATS infrastructure. I am on record with CASA and the ATSB as recommending a Class D airspace solution with a small ATC Tower. Class E instead of G should be the overlying airspace because ATC has (or should have) surveillance of all IFR aircraft.



Now take Mangalore.

We really don't know yet what actually caused this accident? We may end up putting it down to bad luck? But, how do we know there is not a latent error in the airspace system that could have this happen anywhere else? (I’m sure I read a comment along that line by you somewhere, I agree by the way).

But what if this is the 1:10(-9) event. Is that ok? Should we invest time/money in trying to make a system more safe, when everybody seemed happy with the 1:10(-9) risk?

In this way we need to develop tools to determine if a) there is an latent error or, b) this is the 1:10(-9) event. If its b) we also then need the testicular fortitude to stand by the level of risk that we have accepted. I feel terrible for those 4 blokes, its sad and I hope it never happens to me. But flying has a risk, we all accept it. Its not zero. If we establish that the risk at Mangalore is as we thought it was...does it need a solution?

I agree, however most authorities in the rest of the world try to protect IFR flights with controlled airspace. The deaths of these pilots may have been prevented if ATC was able to intervene, this is being proactive. A cost/benefit study 30 years ago may have determined that the cost of the ATC equipment was very high compared to the risk. Today however we know that ATC can actually see IFR aircraft on their surveillance displays and if not a few more ADS-B receivers are not expensive. So now the cost/benefit study would come to a different conclusion.



So take the 2 scenarios above. 2 totally different problems, with what I hope would be 2 different set of airspace performance requirements, which would lead to 2 different outcomes with 2 different associated levels of risk. How then can the same solution be applied to both locations, and the same outcome be expected? All you are doing is adding another variable to an existing set of variables that have not been assessed appropriately in the first place.....this makes the risk increase significantly. The point being if we have a mutually agreed framework with which to assess and determine the risk of operations at a particular location, and then you have an agreed framework with which to mitigate that risk (or not) then the outcome should be valid.

You mention again "airspace performance requirements", I am not sure what you mean by this. The variables you mention have been assessed many times all over the world, this is what led to the proliferation of different types of airspace, brought together by ICAO as the classes. Why do you think Australian problems are any different to anyone else's problems?



We are not ready for solutions yet.

I disagree, we do not need to re-invent the wheel, or worse, some Australian odd-ball solution like CA/GRS. Outback USA is very similar to outback Australia but with a hundred times more aircraft movements. Let's learn from others for once....

[alphacentauri]

Geoff, with respect, you just made most of my points for me.

No I did not mean airspace classes. If modern technology has increased the risk, why are we proposing an airspace solution that was developed decades ago in an environment where that technology did not exist? Airspace classes are not going to solve these problems. The only organizations left on the planet who don't understand this are ICAO and the regulators. The UTM framework that is under development start down the exact path I'm discussing.
ICAO classes of airspace do not set performance requirements. As in, how do we determine that a piece of airspace is meeting the demand being placed on it? We have no tools for this, its why the OAR cannot determine why the airspace at Melbourne is Class C, or whether it should be something else (like Class B). Its Class C because it always has been.
The US NAS has not changed, you are correct. But its use has and now the FAA are being presented with the same problems. US NAS is obsolete.
See Australian State Safety Program 2021, I had a quick read. There isn't anything in there that opens the door to the type of thinking required to solve these problems. The draft document exists for the sole purpose of protecting the minister, it offers nothing as a solution.

​​​​​I am on record with CASA and the ATSB as recommending a Class D airspace solution with a small ATC Tower. Class E instead of G should be the overlying airspace because ATC has (or should have) surveillance of all IFR aircraft.
Is the root cause analysis, risk assessment and mitigation for your determination of this also on record? Where is the supporting evidence? Why does it need to be Class D? What methodology did you use to determine this?

You mention again "airspace performance requirements", I am not sure what you mean by this. How do you determine if a particular piece of airspace is doing the job (meeting the performance) it has been designed for? You need a set of performance criteria to assess this against. Where are these documented? And no the ICAO airspace classification is not what I am referring to.

CASA requires risk assessments for all changes, airspace or otherwise. You and I both know they will not, and cannot adequately perform this risk analysis

Obviously, Sydney/Ballina/Pilbara are different, that is why we have different airspace classes.. I didn't mention Sydney. But the current airspace at Mangalore/Ballina/Pilbara are exactly the same, CLASS G. The solution being proposed (Class E) is also the same. How can this be if the problem at all three locations is completely different?

The variables you mention have been assessed many times all over the world, this is what led to the proliferation of different types of airspace, brought together by ICAO as the classes No they haven't. ICAO classes of airspace were first published in 1990. There has not been a significant change to them in 30 years. Technology and aircraft performance on the hand has developed 10 fold.

...we do not need to re-invent the wheel.... my point is, we don't even know if we need a wheel.

With respect to your knowledge and experience Geoff, and it is highly respected, it won't be the traditional solutions of the past that solve the modern technological problems of the future.

Cheers, α

[UnderneathTheRadar]

Alphacentauri - great posts - absolutely agree with discussion airspace systems rather than classes. A good case example is the work going into autonomous cars - there will be no 'airspace class' for them as the hive will be left to sort it out - an airspace system if you will. How long it takes to get there is another question but ultimately it will have to - society will demand it. TCAS is another great example - works irrespective of airspace class but is an airspace system.

The risk framework can ultimately be developed by looking at a simple financial equation - the cost of not mitigating a risk vs the cost of mitigation. The cost of mitigation can be determined easily enough (unless Airservices are managing the implementation....:oh:). The cost of not mitigating is what actuaries are paid to do and is no different to the process of determining your insurance policies. The key item is the cost of life. Various organisations attempt to quantify the cost of life including here in Oz where the government in 2014 valued 1 life at $4.2m. ("Best Practice Regulation Guidance Note: Value of statistical life" (https://www.dpmc.gov.au/sites/default/files/publications/Value_of_Statistical_Life_guidance_note.pdf)(PDF). Department of the Prime Minister and Cabinet. December 2014 - with thanks to Wikipedia for the link).

So using the two examples above.

Mangalore - allowing for inflation plus arguably some additional costs relating to ATSB investigations, emergency services responses, destroyed aircraft, and intangibles like reputational damage (yeah I know - could be used to manipulate any answer you want) - lets say 4 casualties + extras = $20m in todays money. Lets also say that Managalore was a 1 in 20 year event - or even 1 in 50. What solution exists that costs $1m or even $400k? per annum?). (I know - mandated, federally funded ADSB-IN transponders for all IFR aircraft? Enough overtime to staff a second set of eyes at ML CTR watching YMNG during training hours? Enough to establish a new control position including frequencies etc during YMNG training hours?)

Ballina - hasn't happened yet but lets assume that sometime in the next 90 years - call it a 1 in 100 year event given we've gotten through the last 10 unscathed. At a cost of, say, $5m * 120 people plus a new airbus plus etc gets you close to $700m. What could you do at Ballina for $7m per year? Quite a bit I imagine. Extend the model to all similar airports in Oz and say its a 1 in 50 year incident and you have $14m/pa to spend across all similar airports. Going to pay for several new ATC positions plus increased radar coverage where required?

So the ability to price risk around human lives exists - agree or disagree with it. But it's far from perfect as statistics and particularly risk assessments I often find are geared to generate the desired answer particularly by manipulating the likelihood of an event. The distribution & skew of the costs of not mitigating are also horrendously vague - but it shouldn't be beyond the wit of man (or Airservices or ORR) to develop the framework based on fairly common methodologies and good worldwide data on expected accident rates that have good data behind them due to the nature of aviation investigation and reporting.

UTR

[Lead Balloon]

It’s so (so) refreshing to read some expert and objective analyses and discussion.

So the ability to price risk around human lives exists - agree or disagree with it. But it's far from perfect as statistics and particularly risk assessments I often find are geared to generate the desired answer particularly by manipulating the likelihood of an event. The distribution & skew of the costs of not mitigating are also horrendously vague - but it shouldn't be beyond the wit of man (or Airservices or ORR) to develop the framework based on fairly common methodologies and good worldwide data on expected accident rates that have good data behind them due to the nature of aviation investigation and reporting.Hear bloody Hear!

[missy]

I would argue that we are not aiming for the same risk level in all airspace.
I think we are aiming for the same risk level in all airspace. What will vary is the surveillance, the communications, the procedures but surely the target level of safety should be the same. There may be some ATC equipment that is installed for efficiency, examples being PRM at Sydney, Ground Radar at Sydney (and Brisbane, Melbourne, Perth).

One of the major problems is determine the value of life. AsA tried to close Camden Tower but no-one could agree on the value of life. If its AUD $4.2m indexed for CPI (or any other figure) from 2014 then this should be agreed and then used in the calculations.

[alphacentauri]

I think we are aiming for the same risk level in all airspace.

Are we? We dont have it in our current airspace structure, even amongst locations that have same class of airspace.

[Dick Smith]

I believe you will find that the FAA has not completed a “ cost of life” study for the different categories of airspace.

The airspace has simply evolved over a hundred years of experience with a lot of aircraft, high mountains and extreme weather conditions.

Also a wealthy and quite litigious society where no one wants to die in an aircraft accident.

The end result in the view of many people is a very safe and affordable system that encourages high participation levels.

And the VOR post is clearly as valid today as it was when it was written.

[missy]

Are we? We dont have it in our current airspace structure, even amongst locations that have same class of airspace.
Shouldn't the target level of safety for a Dash 8 flying into Melbourne be the same as flying into Kingscote or Cairns or Dubbo? The ATS surveillance, communications and procedures might vary but if you are flying MEL-MQ-MEL, ADL-KGC-ADL, CNS-GOV-CNS or SYD-DBO-SYD, shouldn't these flight be equally safe, that is the same target level of safety?

[missy]

I believe you will find that the FAA has not completed a “cost of life” study for the different categories of airspace.
No, but from my research the US does have a "cost of life" value. I think this is an important consideration as it informs the cost/benefit analysis. And, we (Australia) should have their own "cost of life" figure and not simply import one from the US. Surely Governments have a figure when they are making objective decisions.If not then someone like Australian National Audit Office or Australian Competition and Consumer Commission or Australian Bureau of Statistics or Bureau of Infrastructure and Transport Research Economics should develop such a figure.

[UnderneathTheRadar]

I think we are aiming for the same risk level in all airspace. What will vary is the surveillance, the communications, the procedures but surely the target level of safety should be the same. There may be some ATC equipment that is installed for efficiency, examples being PRM at Sydney, Ground Radar at Sydney (and Brisbane, Melbourne, Perth).

Missy is almost correct - we should be targeting the same level of risk in all scenarios but that will provide different levels of safety in each class of airspace. The "cost of life" is the same irrespective of what airspace class you're in - what changes in the cost of providing enough safety such that enough lives will be saved to justify that cost.

A properly constituted risk framework would identify the hazards and their likelihoods & consequences (i.e. the risk) of each part of the country (and beyond) and apply the correct mitigations for each. The underlying risk level around YSSY is massively different to the underlying risk level at YSBK - mainly due to the number of people on each flight - despite the higher number of aircraft in closer proxmity at YSBK. Each control placed to mitigate the risk has a cost - and they can generally all be boiled down to a $$$ figure. That's why we don't have Class C (or B) at YSBK - the cost to industry would be huge - both in cost of additional controllers and costs to operators to operate and would achieve a reduction in risk to a level significantly less than existed at YSSY - which sounds wonderful but isn't warranted.

The objective is to consider the requirements to use airspace and all of the controls available - airspace type, procedures, technology (radar, ADSB receivers, ADSB-in, ADSB-out, TCAS, GPWS, EGPWS, CATI, CATIIIB) etc - and determine which combination provides 'about the same' residual risk as the next location. For practical reasons this is limited to a few different systems - generally we think of Oceanic, A, C, D, E & G in Oz but with special procedures in areas where an increase in procedure/cost to the next level up isn't justifiable but 'something' should be done - that's where an alternative airspace system may be used - CA/GRS or VFR LOEs.

It's all an exercise in managing risk - there should be a targeted level of acceptable risk (from collision into aircraft or terra-firma) for anyone/anywhere in the air in Australian airspace - and Airservices and the regulators should be using the tools at their disposal to level it out. In theory the level of residual risk at YSBK and YSSY should be about the same - and one might say that the occasional fatality at YSBK might take '00s of years to add up to the same number of facilities that would occur if 2 x 737s collided at YSSY - its just that we don't want that to ever happen but are conditioned (value of lives vs value of life) to accept that the occasional mid-air collision is ok. Given there is a non-zero chance of the 2 737's hitting I would argue that to a member of the general public, flying into YSBK is less risky than flying into YSSY.

Ol'mate in his 152 flying into eastern bumblef*ck should be exposed to the same level of risk as a passenger on a 787 arriving into Sydney. Until there is a risk framework that spells out what an acceptable level of risk is then we'll keep getting knee-jerk reactions like E to 1000' AGL or continue to 'accept' that unalerted see-and-avoid for VFR is a genuine control as opposed to a residual risk level.

And we can then do all of this without resorting to arguments around SFARP......:E

UTR

[Vag277]

The FAA have this: Establishment and Discontinuance Criteria For Airport Traffic Control Towers https://www.faa.gov/about/office_org/headquarters_offices/ato/service_units/mission_support/faa_contract_tower_program/media/Establishment_Discontinuance_Criteria_for_Airport_Traffic_Co ntrol_Towers_APO-90-7.pdf

[alphacentauri]

Missy, you make a fair point. Perhaps that is what we dont currently have? When I wrote the post I had Class G airspace at Ballina, Dubbo, West Archerfield and Wellcamp in mind. All the same classes of airspace, all have different levels of, accepted, associated risk. (They are accepted because they are published. Someone must have accepted that risk, right?)

I think your point is they should all have the same target risk level. We need to establish what that is, and provide the enabling technologies to achieve it.

[Bosi72]

No ATC can look after myself better than I can.
I hope the outcome of this (and similar) researches will result in manufacturing a portable primary radar for GA.

https://journals.plos.org/plosone/article?id=10.1371/journal.pone.0239892

[Chronic Snoozer]

No ATC can look after myself better than I can.

Very good CRM. Here’s hoping you are joking.

[Dick Smith]

Vagg. When I was the chairman of CAA we introduced that FAA formula.

It resulted in towers at places like Wagga and Mt Isa being closed. Tens of millions has been saved by the industry since then.

Of course the airspace was to be changed to class E and run from the centre. That never happened!

[alphacentauri]

That never happened!

And thats a good thing that it didnt, because a few things would have happened by now;

Airservices still would not have provided the CNS infrastructure to go with it and operate it like 'the US does'
Which means we would have had procedural 'E'

and 2 things would have resulted.
a) an extremely inefficient lower airspace system that would have prevented Mangalore, but would be a nightmare to use for eveybody else, (thus creating its own residual risks that would need to be resolved) and;
b) Ballina still would have happened and would still be a risk we would need to mitigate.

Leading to the result, we would still be looking for a new airspace system, as I described, for efficiency and access as well as increased safety. Guaranteed we would still be here arguing for a better system.

And just for the record, the FAA have admited that NAS is in its twilight years, and is not suitable for their future concept of operations. They are preparing for another system 'NextGEN'. Might want to have a read of where they going.....because it isn't Class E and NAS.

And the VOR post is clearly as valid today as it was when it was written.

So no, it is not.

α

[Traffic_Is_Er_Was]

Ballina - hasn't happened yet but lets assume that sometime in the next 90 years - call it a 1 in 100 year event given we've gotten through the last 10 unscathed. At a cost of, say, $5m * 120 people plus a new airbus plus etc gets you close to $700m. What could you do at Ballina for $7m per year? Quite a bit I imagine. Extend the model to all similar airports in Oz and say its a 1 in 50 year incident and you have $14m/pa to spend across all similar airports. Going to pay for several new ATC positions plus increased radar coverage where required?Unless Airservices are found to be liable, it won't be them paying out the $700m for a loss. Someone will pay - the insurers, and they will go after someone else to recoup their money. Ultimately, if AsA can deflect the blame, they won't pay. So they don't have and won't have $7m or $14m to throw around per annum. I would imagine that in the case of Airservices, unless they pay their own insurance premiums and are "privately" insured, the taxpayer is assuming the risk, (and saving the $7-14m per airport per year). The government will take that deal any day of the week.

[Dick Smith]

Alpha. I can see why you post anonymously.

That old furphy about radar coverage has been used now for over 20 years to stop us from moving to the safer NAS system.

Our radar coverage in the J curve is similar to the US coverage across most of their country.

So why not bring the E down in the J curve?

I know- resist copying the best from around the world. I am sure you would support a Nomad over a 747 any day.

Resist change in every way you can.

And never have the self confidence to post openly under your own name!

And by the way. I heard that claim about the FAA moving to a new system over 20 years ago!

[alphacentauri]

VOR posted anonymously too. Why do you not question their credibility? By the way, where in any of my posts have I given the impression that I am resisting change? Im just resisting your change.

I heard that claim about the FAA moving to a new system over 20 years ago!

I heard the claim about Australia transitioning to NAS about the same time ago......and thats when we needed to do it. But now, we need to skip NAS and go to the next thing. Can you see that we are actually in fierce agreeance about the need to change? I just think we should be looking forward for solutions, not backward.

I think we can be better than US NAS.

α

[Traffic_Is_Er_Was]

NextGen is ALL about the NAS, however NAS as a term is a bit misleading. Whatever airspace system the US has will be the NAS, whether it is the current or future. There isn't a lot in the NextGen docs about fundamental changes to airspace classification per se, more about a lot of technology enhancements to better manage what they have. Apparently they are halfway there.

[Car RAMROD]

VOR posted anonymously too. Why do you not question their credibility?

α


Common theme.

agree anonymously, no problem.
disagree anonymously and all of a sudden it’s an issue.

it’s worn thin across most here it seems.

[Dick Smith]

Let’s see

The US NAS allocates airspace from - G all uncontrolled to A - everything fully controlled.

How can this be improved upon?

Are you suggesting that the FAA are planning to add to these ICAO categories?

[jmmoric]

As a controller working class E CTA, and class D TMA/CTR (radar and procedural), it works really well in less densely populated airspaces. So outdated? No. Unsafer than class B and A, sure..... Still usable, definately.

Oh, and some of the new separation rules for procedural control are actually pretty "efficient".

Did aircraft change much over the past 30 years? Performance-wise..... no, not really.... Equipment-wise, definately. So with an increase in onboard "surveillance" and other safety systems, I don't see why E should be worse now than it used to be.

You could argue some IFR pilots may rely too much on their precious TCAS and forget they have to look out..... but that's another story.

[Bosi72]

Very good CRM. Here’s hoping you are joking.

Please show me where in AIP ENR 1.4-8 and 1.4-9 says ATC will provide separation between "VFR and VFR" traffic in any airspace?
Who should you trust then?

[Dick Smith]

Because in Australia it is mandatory ($5000 fine) for VFR to monitor the ATC area frequency as marked on our charts.

This gives ATC a responsibility to warn a VFR pilot if he or she gets close to another aircraft.

[jmmoric]

This gives ATC a responsibility to warn a VFR pilot if he or she gets close to another aircraft.

You cannot deduce that ATC gets any responsibility just because pilots have to monitor a frequency. You'll have to find the rule stating so before claiming it.....

[Dick Smith]

I suggest you look up the judgment from the Navair Bankstown mid air.

The ATCs where given 30% of the blame because the judge said ATC could see the two aircraft and therefore had a duty of care.

For a decade after, ATC separated VFR from VFR to IFR standards in Sydney.

I would have to orbit at Hornsby for ten minutes while they separated my helicopter from the channel ten chopper with IFR standards!

[neville_nobody]

I suggest you look up the judgment from the Navair Bankstown mid air.

The ATCs where given 30% of the blame because the judge said ATC could see the two aircraft and therefore had a duty of care.

For a decade after, ATC separated VFR from VFR to IFR standards in Sydney.

I would have to orbit at Hornsby for ten minutes while they separated my helicopter from the channel ten chopper with IFR standards!

Well it certainly doesn't work like that anymore!! IFR are given traffic on known VFR, same as VFR to VFR. It's up to the PIC to ensure their own separation, which is then the Achilles heal of Class E airspace. In reality Class E is Controlled Class G. Ultimately the PIC is still responsible for VFR separation. Too bad for you if you are in the outback and wipe out someone on descent who is not "known".

It only takes one instance of avoidance action by a IFR aircraft to totally unravel Class E. They have to avoid a VFR aircraft, this means taking action, yet they need a clearance to take action so then a 4+ way radio conference has to take place, between the VFR traffic, other VFR traffic, the IFR traffic and ATC.

In reality Class G is safer and easier to operate in as everyone knows where they stand. Class E only really works if everyone is identified and ATC can actually give avoidance guidance. The current arrangement where jets are cleared through overlying Class E and have to self separate from VFR traffic is a nonsense at the speeds they operate at with no radar coverage.

[missy]

...industry said if they got FAA E access rules they would be on board.

An edited quote from another website.

Be careful what you wish for. Surely technology has advanced such over the past decades to make improvements on Alphabet Airspace. Just consider car technologies: cars currently on the market vs the first car you drove vs the first car you rode in as a passenger (probably on the drive home from the hospital where you were born). Surely we can do better.

[10JQKA]

For those who feel having small sections of Class C around regional TWRs creates roadblock airspace for VFRs, imagine the roadblocks for IFRs that will be created in the event of low level Class E. And this will be over the whole J-curve, thousands of sq miles as opposed to tiny bits around large country towns which only affects the odd VFR flight.

[jmmoric]

Well it certainly doesn't work like that anymore!! IFR are given traffic on known VFR, same as VFR to VFR. It's up to the PIC to ensure their own separation, which is then the Achilles heal of Class E airspace. In reality Class E is Controlled Class G. Ultimately the PIC is still responsible for VFR separation. Too bad for you if you are in the outback and wipe out someone on descent who is not "known".

It only takes one instance of avoidance action by a IFR aircraft to totally unravel Class E. They have to avoid a VFR aircraft, this means taking action, yet they need a clearance to take action so then a 4+ way radio conference has to take place, between the VFR traffic, other VFR traffic, the IFR traffic and ATC.

In reality Class G is safer and easier to operate in as everyone knows where they stand. Class E only really works if everyone is identified and ATC can actually give avoidance guidance. The current arrangement where jets are cleared through overlying Class E and have to self separate from VFR traffic is a nonsense at the speeds they operate at with no radar coverage.

A few noteworthy mentions here.

You do NOT need a clearance to avoid another aircraft....

Speed in class E is restricted below 10,000 feet to a maximum 250 knots, and the reason is traffic avoidance. I do agree that a few VFR flights venture higher than that, but most stay below.

Flying IFR in class G you'll meet IFR flights when IMC and both IFR and VFR flights while VMC, whereas you'll only meet VFR flights while VMC in class E. So no, in reality class E is the safer airspace....

Class E works fine when pilots are aware of the airspace classification, and the amount of VFR traffic is relatively low.

[Dick Smith]

Yep. And when the traffic gets too much a higher class of airspace is allocated!

Really simple.

[jmmoric]

I suggest you look up the judgment from the Navair Bankstown mid air.

The ATCs where given 30% of the blame because the judge said ATC could see the two aircraft and therefore had a duty of care.

For a decade after, ATC separated VFR from VFR to IFR standards in Sydney.

I would have to orbit at Hornsby for ten minutes while they separated my helicopter from the channel ten chopper with IFR standards!

Are you asking me to look at a report from 1974? 2 years before I was born?

"The cause of the accident was that, whilst operating in an environment where the maintenance of separation between aircraft was a pilot responsibility, neither the pilot-in-command of the Twin Comanche nor the pilot-in-command of the Dove ensured that a watch for other aircraft, adequate for the avoidance of collision, was maintained."

Nonetheless, if a judge then comes to another conclusion, why wouldn't controllers start separating aircraft according to IFR rules?

[Dick Smith]

Yes. And that’s why our unique system of forcing by the rule of law that VFR aircraft en route must monitor and announce on the ATC sector frequency gives the ATC a special responsibility.

[missy]

The objective is to consider the requirements to use airspace and all of the controls available - airspace type, procedures, technology (radar, ADSB receivers, ADSB-in, ADSB-out, TCAS, GPWS, EGPWS, CATI, CATIIIB) etc - and determine which combination provides 'about the same' residual risk as the next location. For practical reasons this is limited to a few different systems - generally we think of Oceanic, A, C, D, E & G in Oz but with special procedures in areas where an increase in procedure/cost to the next level up isn't justifiable but 'something' should be done - that's where an alternative airspace system may be used - CA/GRS or VFR LOEs.

UTR, some of these are safety nets - GPWS, EGPWS, TCAS and shouldn't be used to determine available controls.

In the case of TCAS - "TCAS does not substitute for air traffic control, but acts as a defence against a breakdown of the air traffic control system". "Australian aircraft that is a turbine-powered commercial aeroplane must not, except in certain limited circumstances, begin a flight unless it is fitted with an approved TCAS II that is serviceable".

The ATS Flight Notification doesn't have any reference to TCAS, there is no abbreviation for TCAS, there is no reference on an ATC display to indicate that an aircraft has or doesn't have TCAS, there is no reference on an ATC paper flight progress strip (most Towers) that the aircraft has or doesn't have TCAS, there are no procedures in MATS to indicate what an ATC should do if a pilot advises that TCAS is inoperable. TCAS is a pilot safety net and as indicated above, acts as a defence against a breakdown of the air traffic control system.

Same for GPWS, EGPWS etc.

Same for MSAW (Minimum Safe Altitude Warning), an ATC Safety Net for defined portions of airspace for defined flight procedures (IFR).

Same for CLAM (Cleared Level Adherence Monitoring), an ATC Safety Net based on defined parameters.

Same for STCA (Short Term Conflict Alert), an ATC Safety Net based on defined parameters. The fact that there are numerous (100's daily) false alerts has meant that "true alerts are not responded to and all alerts are delayed in their response."
False alerts (https://journals.sagepub.com/doi/10.1177/0018720809344720)

Technology is important however Safety Nets have been developed for when the human has failed.

[missy]

Yes. And that’s why our unique system of forcing by the rule of law that VFR aircraft en route must monitor and announce on the ATC sector frequency gives the ATC a special responsibility.
Did that work at Ballina?

[jmmoric]

Because in Australia it is mandatory ($5000 fine) for VFR to monitor the ATC area frequency as marked on our charts.

This gives ATC a responsibility to warn a VFR pilot if he or she gets close to another aircraft.

Yes. And that’s why our unique system of forcing by the rule of law that VFR aircraft en route must monitor and announce on the ATC sector frequency gives the ATC a special responsibility.

You bastard, you changed the reasons that was the foundation of my first answer :mad:

Ofcourse, once ATC knows you're there, we'll have to provide traffic information as far as is practical ;)

[sunnySA]

Yep. And when the traffic gets too much a higher class of airspace is allocated!
Really simple.
I'm not aware of any data that could be used to make an objective decision to upgrade airspace either at an aerodrome or en-route.

[missy]

You bastard, you changed the reasons that was the foundation of my first answer :mad:

Ofcourse, once ATC knows you're there, we'll have to provide traffic information as far as is practical ;)

Did that work at Ballina? And what do you mean by "as far as is practical" with such an EMOJI ;) ? Sounds like passing traffic is optional.

[Traffic_Is_Er_Was]

For a decade after, ATC separated VFR from VFR to IFR standards in Sydney.

I would have to orbit at Hornsby for ten minutes while they separated my helicopter from the channel ten chopper with IFR standards!
That accident happened in a Control Zone, ie in controlled airspace. It was just that it was under the then Secondary Control Zone procedures where VFR to VFR provided their own separation in the circuit. Outside that zone, in other controlled airspace, ATC would normally have provided separation between VFRs . Sure, maybe they got a little zealous (or more careful) but that was their job. Outside controlled airspace, you were on your own, as you well know. I bet ATC never separated you from anyone to any standards when you were OCTA.

[jmmoric]

Did that work at Ballina? And what do you mean by "as far as is practical" with such an EMOJI ;) ? Sounds like passing traffic is optional.

The emoji was supposed to soften up the previous emoji.

You know as well as I do, that it says as far as is practical, not optional. Which is practice would mean that if you know they are there, you'll give it.... whereas, if you have no clue they are there, you cannot give it.

What Ballina?

Okay, think I found the Ballina.

It was in G airspace, one aircraft forgot to turn on "ALT" on the transponder, the airspace was "broadcast" airspace.... so I'm a little confused why ATC is dragged into it?

Though you normally don't broadcast on ATC frequencies, they are a worktool for the controllers and they'll be pissed. You communicate with ATC on that frequency.

[Traffic_Is_Er_Was]

VFR aircraft en route must monitor and announce on the ATC sector frequency
You mean listen out and broadcast on the area frequency? Because if it was a requirement under rule of law for ATC to be able to hear all your announcements, there would be VHF to the ground everywhere, or you would have to announce on HF, but then that would be full reporting, and someone got rid of that.

[Traffic_Is_Er_Was]

Did that work at Ballina?
The two aircraft were on CTAF and didn't hear each other. In the real world, if two aircraft broadcasting on the same frequency don't hear each other, what makes you think an ATC might hear it. People miss transmissions directed at them, let alone broadcasts.

[missy]

The emoji was supposed to soften up the previous emoji.

You know as well as I do, that it says as far as is practical, not optional. Which is practice would mean that if you know they are there, you'll give it.... whereas, if you have no clue they are there, you cannot give it.

What Ballina?

Okay, think I found the Ballina.

It was in G airspace, one aircraft forgot to turn on "ALT" on the transponder, the airspace was "broadcast" airspace.... so I'm a little confused why ATC is dragged into it?

Though you normally don't broadcast on ATC frequencies, they are a worktool for the controllers and they'll be pissed. You communicate with ATC on that frequency.
I understand that the IFR was not passed traffic on the VFR...

[missy]

The two aircraft were on CTAF and didn't hear each other. In the real world, if two aircraft broadcasting on the same frequency don't hear each other, what makes you think an ATC might hear it. People miss transmissions directed at them, let alone broadcasts.
See previous post regarding traffic.

[neville_nobody]

A few noteworthy mentions here.

You do NOT need a clearance to avoid another aircraft....

Speed in class E is restricted below 10,000 feet to a maximum 250 knots, and the reason is traffic avoidance. I do agree that a few VFR flights venture higher than that, but most stay below.

Flying IFR in class G you'll meet IFR flights when IMC and both IFR and VFR flights while VMC, whereas you'll only meet VFR flights while VMC in class E. So no, in reality class E is the safer airspace....


Yes as evasive action you do whatever it takes, but the idea is you sort it out before it gets to that point. That will require a clearance and a radio conference.


Class E works fine when pilots are aware of the airspace classification, and the amount of VFR traffic is relatively low.


And there's radar coverage.

[Dick Smith]

Neville. Are you claiming that E does not work without radar coverage but G does?

This fiction has prevented us moving forward with E at low levels for over 20 years.

The USA has dozens of airports with IFR approach’s but no radar coverage at the IAF.

Using their enlightened procedural standards the delays are minimal.

[Awol57]

I've asked you this before, but what exactly are their "enlightened procedural standards" you speak of.

[neville_nobody]

You have two problems without radar:
One being unknown unknowns.
The other being what is Class E Airspace? As I said before it is neither controlled nor is it uncontrolled.
At least with Radar you eliminate the unknowns and some direction can be given to IFR aircraft on the best course of action.

I would suggest that in the US the vast majority of Class E is under radar coverage and whilst the parts without it would be pretty quiet.

I am personally not so bothered by having non Radar Class E at higher levels but to have Class E to low level without some sort of radar coverage is downright dangerous.

[missy]

The USA has dozens of airports with IFR approach’s but no radar coverage at the IAF.

Using their enlightened procedural standards the delays are minimal.

Non-radar E can work, radar E would work "better", primary radar would work better than SSR (only).

What exactly are these "enlightened procedural standards"? Please explain.

[Checkboard]

That will require a clearance and a radio conference.

I don’t see why. In cruise you are separated from VFR levels, so no conflict. That means you are only going to conflict with VFR in climb or descent, so you just stop/slow climb or descent until you are visually clear. That wouldn’t conflict with your clearance, so no talking to Air Traffic required.

[alphacentauri]

"enlightened procedural standards" - the IFR service one gets when ATC realise that you dont know how the airspace system works.

Its the same as the level of service you get when you announce you are 'unfamiliar' at a metro Class D aerodrome.

[neville_nobody]

I don’t see why. In cruise you are separated from VFR levels, so no conflict. That means you are only going to conflict with VFR in climb or descent, so you just stop/slow climb or descent until you are visually clear. That wouldn’t conflict with your clearance, so no talking to Air Traffic required.

If you want to stop your climb or descent you will need a clearance and you need to sort it out with the VFR traffic.

[triadic]

If you want to stop your climb or descent you will need a clearance and you need to sort it out with the VFR traffic.Not really... the rate of climb or descent is at the pilots discretion unless otherwise stated in a clearance - if that means slowing down for a bit, I don't see the need or requirement to seek ATC approval. Some just talk too much it seems!
As I recall, in the US there is no 'chat' between aircraft in Class E and it is not encouraged by ATC.
If Oz is to have a US style class E, then the mandatory transponder requirement needs to be revoked.
You need to remember that descending in G there is no assurance that any VFR traffic that might be of interest is even on the area frequency, so what is the difference in descending in E other than being provided with separation with other IFR traffic?

[Chronic Snoozer]

Not really... the rate of climb or descent is at the pilots discretion unless otherwise stated in a clearance - if that means slowing down for a bit, I don't see the need or requirement to seek ATC approval. Some just talk too much it seems!
As I recall, in the US there is no 'chat' between aircraft in Class E and it is not encouraged by ATC.
If Oz is to have a US style class E, then the mandatory transponder requirement needs to be revoked.
You need to remember that descending in G there is no assurance that any VFR traffic that might be of interest is even on the area frequency, so what is the difference in descending in E other than being provided with separation with other IFR traffic?

You'll get a TCAS RA?

[Traffic_Is_Er_Was]

I understand that the IFR was not passed traffic on the VFR...
Who was supposed to pass traffic to the IFR?

[Gentle_flyer]

Who was supposed to pass traffic to the IFR?

TIEW,

If I may be so bold I think Missy is asking if:

A/ Were both aircraft on SSR radar prior to the intersection of tracks,

B/ If so for how long?

C/.Did the ENR Sector controller issue traffic to the A320?

D/. If not, why not?

E/. Did the ground based system safety net (STCA) activate for the two aircraft?

F/. Was it displayed at the relevant controllers position?

All seemingly logical questions to ask....I’ll go back and check again ?but nothing was mentioned in the prelim investigation..

[Geoff Fairless]

GF - I do not have any inside information but as I recall there is no SSR coverage at low level in the Ballina area, only ADS-B. Hence:
A/ No only the A 320
B/ Not applicable
C/ I would think no
D/ The ENR controller would not have detected the Jab
E/ No because the system did not know about the Jab
F/ See E

More importantly, from the ATSB website, the Jab reported 4NM east of Lismore, which would make it 11NM west of Ballina, arguably not in the broadcast area of 10NM. (CASA - Now expanded to 15NM, always mopping up the last debacle; never looking for the next)
That should however have alerted the CA/GRO that the Jab was crossing the track of the A320, both on descent. In my view, that should have warranted a traffic alert to both aircraft.
But therein lies the rub, the A320 had already detected the Jab on TCAS, albeit without ALT information. (Jab ALT not selected), so detection was made, the A320 crew looked for but did not sight the Jab, so any involvement by the CA/GRO, at this stage, was superfluous

This Australia, is what CASA OAR thinks about paragraph 34 of the Airspace Policy Statement 2018 (AAPS) "34. The Government considers the safety of passenger transport services as the first priority in airspace administration and CASA should respond quickly to emerging changes in risk levels for passenger transport operations. ....." This is the airspace configuration chosen by CASA to operate Jetstar, Virgin and now Qantas jet operations into a rapidly expanding airport. Clearly there have been many "leading" safety indicators of separation issues at Ballina. (By leading, in this context, I mean when incidents occur that do not kill anybody, a lagging safety indicator is, therefore, one where deaths do occur.) How Jetstar's safety management system (SMS) does not classify operations at Ballina as an extreme risk, I cannot imagine. I know CASA does not have a functioning SMS so their inactivity does not surprise me. Perhaps Virgin and Qantas could apply their SMS and start kicking down doors at CASA.

Who else is there; Airservices and the ATSB? Airservices seems to have woken up to a deteriorating problem in the lower altitudes, they must be amazed that CASA OAR has done nothing. Class E to 1500 AGL, as proposed, would help but surveillance is required where needed and the US Class E rules are the only workable ones.

ATSB? Yes, I wrote to them a few months ago about the nonsensical arrangement at Sunshine Coast airport. There CASA requires a control tower because the airport falls within the Ministerial guidelines for Class D airspace (AAPS Table 1). CASA then allows Jetstar to operate outside of the Tower hours, presumably to save a few dollars of ATC costs. An Aero Commander (Incident AO-2019-62) took off at 6am using the into wind runway direction, only to find a Jetstar A320 turning on to final for a downwind landing; they just missed! ATSB claimed in the report that it was a simple matter of the pilots not communicating efficiently on the CTAF. In their response to me they said that if they saw any latent safety issues they would certainly act upon them. Well if an airline electing not to have the Tower on duty, no Class E airspace and not even a UNICOM operating constitutes no latent safety issues, then I came from another planet!

[Lead Balloon]

Ballina has an RFFS, Geoff. Just hose down all the charred bodies with PFAS substitute. Job done!

[Lookleft]

How Jetstar's safety management system (SMS) does not classify operations at Ballina as an extreme risk, I cannot imagine.

Under the previous COO Ballina would keep him awake at night. His solution? Get a job with Telstra! Jetstar has all sorts of policies and procedures to mitigate the risk but its a bit like the sexual harassment policies in Parliament House. It looks good in a CASA approved manual but in reality the whole situation is flawed.

Ballina has an RFFS, Geoff

I think the fire truck names are Irony and Bewilderment.

[jmmoric]

Well if an airline electing not to have the Tower on duty, no Class E airspace and not even a UNICOM operating constitutes no latent safety issues, then I came from another planet!

It's a question of regulation.

If the CAA deems it safe.... then the airline is fine with it. Though there are a few airlines around the world that require ATC to operate.

[Lead Balloon]

If the CAA deems it safe...That would be with some kinda magic wand, I’m guessing.

Do you know what ‘deems’ means in legal parlance? Making true in law that which is untrue in fact.

What’s true in fact determines whether an accident happens or not.

[jmmoric]

That would be with some kinda magic wand, I’m guessing.

Do you know what ‘deems’ means in legal parlance? Making true in law that which is untrue in fact.

What’s true in fact determines whether an accident happens or not.

I've done a lot of safety assessments over the years, and yes, noone just "deem" anything safe enough.

Safety management is about eliminating risks, or mitigating them to an acceptable level. the last means that we know there is a risk, but the cost of removing it is way beyond the actual gain from doing so, or it may not even be possible. We come up with the best assessments, which still contains the risks. That assessment is then forwarded to the management, they'll approve it... and the risk with it.

So yes, we all know that accidents may happen, though the risk is so low it is deemed almost non-existent, but since it's still there, noone on the ground level in the company can ever be the ones signing off the papers.

And on top of this comes the question of the users.... changing airspace structure and classification will always have pilots complain (VFR pilots feeling their "rights" to the airspace is taken away, or IFR pilots feeling their "rigth to decide themselves are taken away).

[Lead Balloon]

Noone is going to pick any holes in that, jmmoric. I hope you are enjoying, or are aspiring to, a career in OAR.

[jmmoric]

Noone is going to pick any holes in that, jmmoric. I hope you are enjoying, or are aspiring to, a career in OAR.

No, I hate paperwork :(

I try to stay operational as much as possible.

[Traffic_Is_Er_Was]

According to the Prelim, the Jab pilot broadcast to Lismore traffic he was 4 east of Lismore, 5300ft and descending. The Jet didn't hear it and there is no evidence the CA/GRO did either. In any case, the CA/GRO is employed to provide traffic at BNA, so traffic broadcasting to Lismore, which he probably hears all day, is irrelevant, especially if it sounds like he's inbound to Lismore.

As an aside, in the old quadrantal days, those two aircraft on those tracks (in cruise) would have crossed with a minimum of 500' separation and no one would have batted an eye.

[Geoff Fairless]

TIEW - I too am waiting to find out if the CA/GRO heard the transmission from the Jab, however, I do not agree with your conclusion.
1. If the CA/GRO knows the tracks of both aircraft then he/she knows they will intersect, regardless of the directed broadcast from the Jab, so they are mutual traffic. That is why the aerodromes share a CTAF.
2. 500 feet vertical in cruise is a far different risk to 600 feet with both aircraft on descent. The second is pure chance.
The incident has also proven that for Australia to rely on TCAS to avoid providing ATC is going to end in tears.....

[Gentle_flyer]

Geoff,

Chance ? I agree, I used the word Providence in a post on the incident several weeks ago.

Are you sure the relevant aircraft were not on radar?

I seem to remember a post of yours in regard to Ballina re the non display of SSR tracks due track duplication with ADSB tracks on the CAGRO’s “air situation display”.

Perhaps I misunderstood. If I did I was not the only PPRUNE reader who took it that way? If I misunderstood what were you referring to?

AsA’s published radar coverage dictates I at least ask the question...The facts should have been in the ATSB report.

Given your accusation that AsA is using a airborne based safety net in lieu of ATC based procedures (surveillance or procedural methods), ( an accusation I have sympathy for by the way and not just in G airspace) could you simply explain to me (and other readers)in a sequential list of processes how E airspace NAS version would have prevented this incident from occurring.

I think it would be very educational.

Don’t worry I wont ask you to do the same for MNG but others might...

Thanks in advance!

Gentle_flyer

[Ex FSO GRIFFO]

To 'rely' on T C A S = T E A R S .........

Stated over 20 years ago.....So....What's changed..??

NO CHEERS HERE....NOPE...NONE AT ALL...!!!

[Geoff Fairless]

GF - Thanks for the question, the short answer is that Class E would not have prevented or even mitigated the incident at Ballina. I will try and keep the longer answer as short as possible.

Class E exists because the FAA believes that IFR flights should always be in controlled airspace. This is linked to an ICAO requirement for instrument approaches to be contained in controlled airspace. For instance, take the UK, until RNAV came along an aerodrome with an instrument approach had to also have a control tower. (Admit to being out of touch now that RNAV available), The US solves that problem with Class E airspace because they have many aerodromes that do not warrant a control tower, just like Australia....

That is why I maintain that Class D airspace and a control tower is required at Ballina. The Tower would be the equivalent of an FAA VFR Tower because the Class E airspace surrounding it would require Brisbane Centre to control IFR approaches and separate IFR aircraft. When the Centre has solved whatever IFR separation problems exist then the inbound aircraft is transferred to the Tower which is responsible for separating the VFR aircraft from the IFR. Hamilton Island manages to do this with one controller while separating IFR and VFR aircraft, hence costs are kept as low as possible.

If there is no Tower then the IFR pilot needs to listen on the CTAF and self separate with VFR traffic. If maneuvering is required by the IFR aircraft then it should be able to be accommodated by the Centre controller, however, if the clearance is via an instrument approach that may require a go-around. IFR aircraft can also make visual approaches if they have the aerodrome in sight. In fact, I believe that if an IFR aircraft reports the aerodrome in sight, in the US that automatically generates clearance for a visual approach. If IFR aircraft are consistently having separation problems with VFR traffic then very likely a Tower is required.

I hope this is useful

[extralite]

Bit off topic but dropped into Ballina again yesterday and there seem to be more RPT then before Covid. Pelican down to Newcastle. Jetstar and Virgin duplicating flights to Melb/Syd. Rex too now. Not many people in the terminal so can guess load factor is low. Radio congested mainly because the poor GRO was being particularly pedantic about passing on every bit of traffic to everyone in turn, so was hard to actually get a call in. (Not blaming the GRO, i am sure they have been put under a lot of pressure and that is his job and they do a bloody goon one in my opinion, just too much RPT.)

I really think Ballina is way over serviced with RPT now. It's a town little more than half the size of Dubbo but every low cost airline is there all the time. Sure Byron is down the road...but so is the Gold Coast and it has a lot more capacity then Ballina.The airline industry is being subsidized by the Govt at the moment, so there is oversupply. A friend said they flew down to Newcastle for $49. No wonder there is congestion if you can fly somewhere for less than a third of the cost of fuel to drive there. Yet the airlines are agitating to lock up the airspace to recreational users so they can fly people down to Newcastle/Sydney for less than a carton of Corona. It's not an essential service, we don't need more instagramers here. Its just a distorted market.

The simple solution would be to stop subsidizing these flights, let the market do its thing. There is a big International airport just an hour drive away. Lismore 30 mins away. It won't happen of course, but that is the best solution.

[jmmoric]

....

Good explanation.

There's only one hick-up... IFR and VFR is not separated in class D airspace. The separation the tower controller is responsible for is the "runway separation", which means he shall make sure there's only one aircraft on or over the runway at any time (which is not entirely correct, but can do as a rule of thumb). VFR and IFR will be provided traffic information about each other.

At the moment you establish a control tower, you can have one controller working at very low density airports. But still consider that the person would need breaks etc. Furthermore, the staffing need to be higher, since that one person would still need days off, vacation etc. So you'd need maybe 3 controllers to staff a unit.... On top of that you'd need an approach setup at the centre, which technically can be done by the sector covering the area, but still it's a task someone has to do etc. etc.

Setting all this up is not just one controller cheap and easy.

[Geoff Fairless]

Jmmoric - I understand exactly what you mean, there is a cost but the question is cost versus benefit. There comes a stage when the benefit outweighs the cost, and if a mathematical calculation does not do it for you go with your gut. I am not promoting jobs for air traffic controllers, I am responding to a perceived risk of collision at Ballina aerodrome. This is clearly recognised outside of PPrune because CASA OAR has reacted to airline concerns, as has Airservices who no doubt has had airlines ask just when they might put in a Tower.

On your other point, my explanation to pilot colleagues of Class D operations is that the Tower sequences aircraft for the available runways; this with sight and follows, creates separation in the circuit area and on the runway. It also contributes to worldwide comments about controllers "over-controlling" Class D or providing a Class C service. This is inevitable when the whole point of air traffic control is the prevention of collisions between aircraft, (See ICAO Annex 11 Para 2.2 (a)) not strict adherence to ICAO or national airspace definitions. It must, in visual conditions, sometimes be easier and safer to de-conflict two aircraft instead of just giving traffic and then having to react to unexpected pilot actions.

[Lead Balloon]

It’s not a “perceived risk”. There is a risk.

The only questions (in a coherent regulatory system) are: What are the probabilities of a collision between a HCRPT aircraft and another aircraft, what would the cost be of that collision and what would be the cost of reducing that risk to (e.g.) once in a thousand years collision versus e.g. once in ten years collision, if the latter is ‘unacceptable’ and the former is ‘acceptable’. As alphacentauri has pointed out elsewhere, everyone would like zero risk, but it ain’t achievable in the real world. In the real world, the question is how many millions are you prepared to spend per percentage point reduction in risk.

[Geoff Fairless]

Lead - While I agree with alphacentauri's argument, I worry about "paralysis by analysis". If figures such as he/she wants do exist then let us apply them to Ballina and make a decision.

In the 2017 CASA OAR supplementary study of Ballina, Paragraph 6.6 is entitled Safety Assessment. This contains two highly scientific statements:
6.6.1 Analysis of aerodrome activity at BBGA determined that the risk to airspace users in the BBGA area was highest between 0800 and1800 hrs which primarily covers daylight hours.
6.6.2 The likelihood of a safety incident between two aircraft after 1800 hrs was assessed as extremely low because all passenger transport movements are separated by time in their flight schedules and there are very few airspace users around BBGA after 1800 hrs.

In 6.6.1 CASA uses the words "determined" and "was highest" and in 6.6.2 "likelihood" and "assessed as extremely low". There is no evidence attached as to how OAR reached these conclusions, normally I would expect a hazard analysis and scoring based on a qualitative assessment matrix ranging from extreme to acceptable. If this is the standard that is acceptable to CASA when making decisions about the operating hours of a facility they believe will improve air safety then alphacentauri's suggestions are impossible in Australia. CASA further states that the airspace is "fit for purpose" (by the way CA/GRS is not airspace) so clearly they do not believe Class D airspace would be cost-effective. They are willing to wait for something - but what that something is we do not know.

My guess is that they are waiting for Airservices to say they are willing to open a Tower, and then CASA will write a report saying they should. In my view, as currently managed and operated, OAR is a waste of space.

[Lead Balloon]

To what probability/ies does ‘extremely low’ correspond? It’s a typical term that can be interpreted in different ways by different people.

But it ain’t zero (of course).

And what is the descriptor for the level at which OAR would ‘upgrade’ the airspace?

[alphacentauri]

Geoff, interesting you say that (paralysis by analysis). Id argue that is exactly what we have now. OAR are paralysed because they don’t actually have the skills or knowledge to make a determination of the best way forward. It’s not entirely their fault, because their management structure also won’t back them if they make a controversial decision.

So we end up with solutions looking for problems in the hope that the airspace it is applied to remains "fit for purpose" , then they can report that they have "done something"

Take the latest solution iteration for Ballina....the broadcast zone is to be 15nm. It makes the situation worse!! How long do we sit back and let the OAR wave the magic wand? Do we need to wait for them to kill someone? Or is that going to be ok because the latest airspace arse pluck (err I mean "risk assessment") declared it to be "fit for purpose"

Why dont we develop the tools to help the OAR do their job? Or get rid of the OAR......

Alpha

Oh and plus everything Lead Balloon posted

[Lead Balloon]

Where’s Vag277 when we need him/her?

Calling Vag277.

[sunnySA]

My guess is that they are waiting for Airservices to say they are willing to open a Tower, and then CASA will write a report saying they should. In my view, as currently managed and operated, OAR is a waste of space.

Agreed. The problem is that Airservices Australia have stated that they will not be building physical Towers. You have previously stated that bandwidth is a major limiting factor.

Invest in a portable Tower and operate a Class D. For Ballina to safely cope with additional traffic then extra infrastructure is required - additional taxiways for starters.

[Traffic_Is_Er_Was]

1. If the CA/GRO knows the tracks of both aircraft then he/she knows they will intersect, regardless of the directed broadcast from the Jab, so they are mutual traffic. That is why the aerodromes share a CTAF.
IF he knows the tracks. The aerodromes might share a CTAF, but they don't share the CA/GRS.

[Geoff Fairless]

Alphacentauri - a nice point and you are quite correct, although I might say that IMO the OAR has paralysis and a lack of analysis! The last review I could find was the 2017 supplementary I referred to above, yet the Minister states that they will respond quickly to any new issues that arise! I think we are in wild agreement, although I believe the evidence is in, we do not need any more analysis.

TIEW - I fail to follow your logic in terms of sharing a CA/GRS.
Sure Ballina Shire Council "volunteered" to install the CA/GRS but it operates on the common CTAF so it cannot ignore any communications on that frequency. I could understand the CA/GRO not getting involved with traffic advertising it is in or near LIS because he/she does not have the full picture. (For instance he/she cannot hear aircraft taxiing at LIS) There is still however a duty of care, If the CA/GRO thinks he/she has information that the pilot(s) should know he/she cannot withhold it due to a perception that it is not their business.
In this case though, one of the aircraft was heading for BNA on a track known to the CA/GRO and one was east of LIS heading for EVD. A simple chinagraph line on a map will indicate that the tracks will cross. The idea that traffic is not passed because one aircraft was broadcasting to LIS traffic instead of BNA traffic, has me foxed, I do not follow your logic.