Safety case for commercial ops outside CAS
 

SRG has just issued a FODCOM which "recommends" that any commercial operator wanting to start regular pax services to an airport outside CAS "should" prepare a safety case and have it approved by SRG. It includes all kinds of stuff including routes, IAPs, availability of navaids including radar. Seems a bit late in the day given that there are lots of these operations going on already, and there seems to be no requirement in the FODCOM for established ops to airports outside CAS to prepare a safety case in order to continue their operations.

Implications of this for ATC would seem to be that they will have to provide all kinds of data to prospective airline operators before they get approval to start new services.

NS

Well someone is way behind operational practice, and as ever, it's the CAA, more importantly SRG..:ugh:

There are a miriad of airlines operating into airports outside CAS and although the CAA (SRG) are willing to give more and more airspace away to the military (the whole of the north sea north of Y70), airlines rely on operating oputwith CAS for commercial reality and ATC units to cope with the day to day realities of avoiding unknown traffic outside CAS.
Sadly, SRG is predominantly staffed by people who last did operational controlling a in the equivilant of the last century, have have absolutely no idea of what it is like to operate as an ATCO or a pilot outside CAS.

Thank god for the sterling service of London Mil' , the vast majority of whose ATCOs know what the real world is all about, without them, we would be well and truely screwed...

How about a potential commercial operator producing a safety case that demonstrates that CAA "should" provide appropriate CAS for their operation - into an aerodrome already licensed by them!

niknak:
It may well be true that SRG are behind the game, but the reason I posted this was to see what people thought of their proposal. Seems to me SRG is faced with, on the one hand, a commercial aviation sector that operates increasingly in a safety case regime, and on the other, the day to day reality you describe of controllers using their skill and experience to separate traffic in a dynamic regime outside CAS. The problem is that controller skill and experience is not easy to codify into a safety case framework - it's all down to "feeling in the waters" and all those favourite phrases.

You say CAA staff haven't controlled for years, well maybe that's true too, but it seems to me it's the controllers whose only experience has been in the safety management mania of the last few years who would have most difficulty understanding what London Mil and their ilk do on a day to day basis, not controllers who were active in the 70s/80s.

On top of all that, while this proposal is for *airlines* to prepare a safety case, a lot of what will have to go into those safety cases is ATC material. Who will prepare it? And do airlines have the sort of people who will know what to look for and whether it's adequate?

NS

Nik Nak, many thanks for your compliment to the guys at London - as I'm sure that you're aware they often feel somewhat aggrieved at the situation with which they are faced going in/out of those airfields. Just one small point though - the North Sea changes were 4 years ago this March and were agreed on all sides. Since then there has been quite a lot of CAS created. West of Alphas, TC South West, planned TC North East.

On the original point, I wouldn't have thought that there was much scope for any new companies and if the proposal is not retrospective, what's the point other than to look like they're trying to do something. :rolleyes:

edited edited

Not only are many in SRG 'out of contact', they're also ex military with no prior experience of civil operations, whether ATC or airline.

But presumably only from the wrong bit of the military, not the London Mil controllers who everyone says are wonderful and who control civil traffic on a daily basis....
NS

Interesting. So if an airline with existing services to an airport outside CAS wants to add more, and they follow the guidance and do a safety case, only to find it concludes that the risk is unacceptable, do they pull the plug on all their services?
NS

Given that the SC will only relate to the issues concerning operating into and out of the airport I would only anticipate it coming into play were an airline starting routes from said airport for the very first time, i.e. it is emphasising new airport rather than new route.

Safety cases for airline ops outside CAS
 

:hmm:

1] There is the commercial reality that air operators will wish to offer services to airfields which lie outside CAS.

2] There is also the commercial reality that the same air operators do not really wish to pay air traffic service providers to provide air traffic services outside regulated airspace (ATSOCA) - hence, they rely on whatever services they can get - e.g. London Military etc.

3] There is little chance of the CAA (Airspace Policy) approving new controlled airspaces except perhaps in fairly rare cases where the movement rate is very high.

4] Those ATC Providers which do offer ATSOCA are likely to collect a quite high percentage of airprox reports as, I believe, was the case with Manchester ACC in the "Pennine Radar" days. Which ATC provider wishes to take on such risks and the associated liability insurance?

5] The "Injun Country" nature of Class G airspace is that there are numerous forms of aviation - (from high speed military to gliders etc) - operating. It is unregulated and a free for all.

Any "safety case" would have to recognise and explicitly state all of the above. However, it would be possible to produce a document which stated how the air operator "manages" his exposure to the above risks. It would have to cover a multitude of points - e.g. aircraft types, airfields involved, methods of navigating, details of any ATS providers with whom the air operator has entered into an agreement for ATSOCA, whether routes to/from the airfields vary dependent on known activity including danger areas and so on.

Even if one did all this, it would not be possible to claim any great level of actual safety was guaranteed since the operations remain subject to the unexpected happening.

If the CAA really wants to build greater safety for these operations then it should be working to build better services for the operators. Someone would have to pay however and, in this day and age, I am sure it will not be Gordon Brown!

If that's the case then it really does look like an a**e-covering operation. Can anyone name a single airport in the UK which doesn't currently have commercial services but might in the future? They're all covered now. Only places I can think of are Cambridge, Carlisle and Swansea.
NS

"However, it would be possible to produce a document which stated how the air operator "manages" his exposure to the above risks."

Correct - an *rse-covering exercise conducted by the operator for the benefit of the CAA, merely words in a document on the shelf, none of which detracts from the fact that the operation is less safe than it would be in controlled airspace - in some areas of Class G, considerably less safe.

Note to the PC experts - how do you make quotes in pretty blue boxes nowadays?

As en example, if FlyBe wanted to start operating out of Coventry then it would be a new operation and they would be encouraged to write a SC. Alternatively they could get someone to do it for them, which is probably why I'm writing, (possibly the first?) one at this moment. And as has been mentioned, I'm seriously banging my head against the wall trying to turn aspiration to reality!

Not an arse covering exercsie but a pragmatic move as part of the ASI (if you don't know what that is then I suggest it might be you who is behind the times, not CAA) to help improve safety outside controlled airspace.
CAT, ATC and Airport operators all have to play their part in asessing and mitigating the risk of such operations.
Peatair you say;
Surely that's what the current review of ATSOCAS is aiming to achieve? It will be interesting to see what the industry wide technical workshop on 8th May makes of the new draft procedures.
It's not all very ex ATCOS doing this work. There are a huge number of current operational staff involved in this work. I think the FODCOM is a good start, but I'm very much in favour of the CAA taking a stronger line if the operators don't come up to scratch. Regulatory initiatives and changes to the rules of the air are definite options.
Mind you, it looks like someone is taking it seriously with Daniel on the case!

In our business we do a hazard analysis for any new or changed operating procedure. I don't see this as a*** covering, it is just a mechanism for objectively identifying and, where necessary, mitigating risks.

Go on then, I'm behind The Times, having a snooze usually. What is 'the ASI'?

Absolitely agree! The whole essence of the application of a RAS is the formailisng of the VERBAL contract between the pilot and the controller. Cue
Cont " Clear of CAS what type of service do you require?"
AC " IFR Please":uhoh:
Cont " Do you require RAS, RIS is FIS"
AC " Which one is the best"
This actually happened to me, granted several years ago. So.....until such a time as the guys up front FULLY understand the conditions of the contract that apply to them, ATCO's are placing themselves at risk by applying a RAS to those who have little appreciation of the classification of the airspace in which they fly or the ATC services on offer. A safety case is deffinately the way ahead - how else are the drivers going to get the message!
Post caveated with the exception of certain operators who predominately operate in Class G whom are fully aware (so much so they fitted TCAS) - it's the summer holiday charters flown by Eurpoean crews etc...you know what I mean..

To whom the new CAA policy doesn't apply :uhoh:
NS

".....doesn't apply." Unbelievable. Please tell me that isn't true.