Dicksmithflyer
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Dicksmithflyer
SAFETY CASE, ICAO COMPLIANCE, US PROCEDURES, CLASS D, Etc
We have been shown a number of recent entries on Mr Dick Smith’s web site.
Mr Smith’s assertions are somewhat exaggerated.
We have spent several hours reviewing all of the relevant ICAO documents, and have not been able to find any references to the United States procedures for CTAF. We have found provisions in Annex 2 to the Chicago Convention that allow States to determine additional procedures in an aerodrome traffic zone. Presumably this is what the United States – and other States – have used as justification for their various terminal area procedures at uncontrolled aerodromes.
This would appear to validate the use of your MBZ procedures.
It is therefore, in our opinion, incorrect to state that CTAF and MBZ procures are not ICAO compliant, as there are no ICAO provisions relating thereto, or excluding their use.
In relation to Class D airspace, both Annex 2, and Annex 11, refer to the need to obtain an air traffic control clearance prior to entering controlled airspace. Annex 2 reinforces the need for VFR flights to comply with this requirement in Classes B, C and D airspace.
In all countries operating Class D airspace - except the United States - VFR aircraft request a clearance prior to entry into Class D and unless they receive an positive and explicit clearance, they may NOT enter Class D airspace.
In the United States, the reverse procedure is applied – that is, unless the aircraft is specifically excluded – by either being told to remain clear, or by being effectively ignored (no acknowledgement of callsign) – it may enter the airspace.
We are not saying that this is necessarily a wrong thing – but it is NOT ICAO compliant.
In relation to Safety Case, perhaps Mr Dick Smith should read the changes that have been put into effect in ICAO documentation over the last four years, requiring that Safety Management Systems be adopted by all air traffic services provider organisations, and effectively requiring explicit safety processes to be applied whenever ANY change is effected to the air traffic system.
We have already de-bunked the argument about reference system that Mr Dick Smith has previously attempted to use, and on which your government made its incorrect judgements to proceed with the National Airspace System reform program.
One would have to question the integrity of a man who is unwilling to face the reality of modern safety management systems. As many large organisations have found to their loss, it is no longer satisfactory to use the phrase “but we’ve always done it that way”, or “trust me”. All of the major businesses in the United States, and other major developed countries, have adopted explicit safety and environment management practices. Aviation unequivocally needs to play in the same league.
We do not feel the need to respond to Mr Dick Smith’s rhetoric regarding Broome and Class D towers – that argument is effectively dealt with in the Broome Safety Study and related threads – but suffice it to say that the position taken by Mr Dick Smith in this instance would appear to be totally at odds with his previously stated and widely acknowledged views on the cost of safety versus the benefit.
Mr Dick Smith may also want to contact representatives from FAA senior management and the US Department of Transportation in relation to privatized ATC towers – notwithstanding the fact of those towers, it is unlikely that the process of privatization will continue.
Once again we re-iterate that the dollar cost ($75,000,000.00+ (refer previous thread on this issue)) to get to the position you find yourselves in is NOT justifiable, and in some States might be deemed criminally negligent. The cultural cost, through loss of trust and faith “in the system” is far more significant.
We have been shown a number of recent entries on Mr Dick Smith’s web site.
Mr Smith’s assertions are somewhat exaggerated.
We have spent several hours reviewing all of the relevant ICAO documents, and have not been able to find any references to the United States procedures for CTAF. We have found provisions in Annex 2 to the Chicago Convention that allow States to determine additional procedures in an aerodrome traffic zone. Presumably this is what the United States – and other States – have used as justification for their various terminal area procedures at uncontrolled aerodromes.
This would appear to validate the use of your MBZ procedures.
It is therefore, in our opinion, incorrect to state that CTAF and MBZ procures are not ICAO compliant, as there are no ICAO provisions relating thereto, or excluding their use.
In relation to Class D airspace, both Annex 2, and Annex 11, refer to the need to obtain an air traffic control clearance prior to entering controlled airspace. Annex 2 reinforces the need for VFR flights to comply with this requirement in Classes B, C and D airspace.
In all countries operating Class D airspace - except the United States - VFR aircraft request a clearance prior to entry into Class D and unless they receive an positive and explicit clearance, they may NOT enter Class D airspace.
In the United States, the reverse procedure is applied – that is, unless the aircraft is specifically excluded – by either being told to remain clear, or by being effectively ignored (no acknowledgement of callsign) – it may enter the airspace.
We are not saying that this is necessarily a wrong thing – but it is NOT ICAO compliant.
In relation to Safety Case, perhaps Mr Dick Smith should read the changes that have been put into effect in ICAO documentation over the last four years, requiring that Safety Management Systems be adopted by all air traffic services provider organisations, and effectively requiring explicit safety processes to be applied whenever ANY change is effected to the air traffic system.
We have already de-bunked the argument about reference system that Mr Dick Smith has previously attempted to use, and on which your government made its incorrect judgements to proceed with the National Airspace System reform program.
One would have to question the integrity of a man who is unwilling to face the reality of modern safety management systems. As many large organisations have found to their loss, it is no longer satisfactory to use the phrase “but we’ve always done it that way”, or “trust me”. All of the major businesses in the United States, and other major developed countries, have adopted explicit safety and environment management practices. Aviation unequivocally needs to play in the same league.
We do not feel the need to respond to Mr Dick Smith’s rhetoric regarding Broome and Class D towers – that argument is effectively dealt with in the Broome Safety Study and related threads – but suffice it to say that the position taken by Mr Dick Smith in this instance would appear to be totally at odds with his previously stated and widely acknowledged views on the cost of safety versus the benefit.
Mr Dick Smith may also want to contact representatives from FAA senior management and the US Department of Transportation in relation to privatized ATC towers – notwithstanding the fact of those towers, it is unlikely that the process of privatization will continue.
Once again we re-iterate that the dollar cost ($75,000,000.00+ (refer previous thread on this issue)) to get to the position you find yourselves in is NOT justifiable, and in some States might be deemed criminally negligent. The cultural cost, through loss of trust and faith “in the system” is far more significant.
Dick Smith said:-
Dick,
I take it then, that you classify Voices of Reason (as you seem to classify ANYONE who dissagrees with you) as either not an expert or not rational?
All of the evidence that has been given to me from rational experts shows that by making the NAS changes we will reduce the chance of accidents.
I take it then, that you classify Voices of Reason (as you seem to classify ANYONE who dissagrees with you) as either not an expert or not rational?
Vor,
An interesting post. Another aspect of our procedures which is neither ICAO nor US-compliant is the VFR Climb/Descent. As far as I know, these procedures are only permitted, according to ICAO, below 10,000ft. Dick obviously expects us to use them up the FL245 (the base of our non-radar E).
Also, the IFR Pickup procedure, while used in the USA, was, I'm sure, never intended to be used get get one up to FL245 outside radar coverage. In the US it is simply a tool to facilitate IFR departures until they can get on radar at much lower levels. But here, with no radar coverage, it is the only way of defeating the onerous non-radar separation standards applied by ATC in E. Hence our extensive use of Class F. We know the other aircraft is there, but we don't have to be subjected to overly conservative separation standards.
An interesting post. Another aspect of our procedures which is neither ICAO nor US-compliant is the VFR Climb/Descent. As far as I know, these procedures are only permitted, according to ICAO, below 10,000ft. Dick obviously expects us to use them up the FL245 (the base of our non-radar E).
Also, the IFR Pickup procedure, while used in the USA, was, I'm sure, never intended to be used get get one up to FL245 outside radar coverage. In the US it is simply a tool to facilitate IFR departures until they can get on radar at much lower levels. But here, with no radar coverage, it is the only way of defeating the onerous non-radar separation standards applied by ATC in E. Hence our extensive use of Class F. We know the other aircraft is there, but we don't have to be subjected to overly conservative separation standards.
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Capn Bloggs,
I understand where you're coming from but having had 25+ years in ATC and my fair share of IFR Commercial flying I hope you and other flyers understand the myriad of uncertainties taken into account when these "overly conservative" separation standards are devised.
Sure a lot of this stuff is a bit anal retentive but when somebody says they're at X DME on the Y radial then all sorts of errors from equipment to slant range error to atmospheric conditions are critical in determining the accuracy of the information.
When you as the pilot sit there in Class F and wonder "is 5 DME enough?", it all boils down to the level of risk you are happy with. Unfortunately 1 in a million is way too high for day to day ATC operations (try something with about 9 zeros).
Unfortunately this is the crux of the matter with NAS. Dick and his mates are happy with odds around the same as second prize in Powerball - mum and dad and the kids down the back of a 747 aren't.
But here, with no radar coverage, it is the only way of defeating the onerous non-radar separation standards applied by ATC in E. Hence our extensive use of Class F. We know the other aircraft is there, but we don't have to be subjected to overly conservative separation standards.
Sure a lot of this stuff is a bit anal retentive but when somebody says they're at X DME on the Y radial then all sorts of errors from equipment to slant range error to atmospheric conditions are critical in determining the accuracy of the information.
When you as the pilot sit there in Class F and wonder "is 5 DME enough?", it all boils down to the level of risk you are happy with. Unfortunately 1 in a million is way too high for day to day ATC operations (try something with about 9 zeros).
Unfortunately this is the crux of the matter with NAS. Dick and his mates are happy with odds around the same as second prize in Powerball - mum and dad and the kids down the back of a 747 aren't.
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Captain Bloggs
Sir, in the United States, we don't have any VFR above FL180. This is the base of the Positive Control Area and all flights above Flight Level 180 are conducted in IFR without exception.
You can climb to any level VFR below this level...but again the culture lends itself to full radar participation by VFR pilots flying anywhere of distance or above 10,000 feet anyway.
Everytime I go out to teach aerobatics, I get flight following for traffic advisories, just in the training area.
You can climb to any level VFR below this level...but again the culture lends itself to full radar participation by VFR pilots flying anywhere of distance or above 10,000 feet anyway.
Everytime I go out to teach aerobatics, I get flight following for traffic advisories, just in the training area.
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Chris
I think you missed blogg's point. VFR climb/descent is a procedure just like a 20 DME standard or a 10 minute standard. Not a VFR climbing in airspace. The Aircraft remains IFR throughout the procudure but assumes sep responsibility of all advised traffic. Same with VFR on top. Not 1000 feet OTT but VFR on top @ VFR levels only.
I also agree with you on flight following. BUT!!!!! We had it years ago. Called Flight Service. Remember that? Your buddy Dick saw the end of it. We do not have the movement base that the yanks have therefore not the cash to provide such a thing without the massive subsidies that the yanks have. Beat that drum all you want Chris but without an increase in staff a full VFR flight following WILL NOT HAPPEN in this country. That means more cost and noone will cop that.
Our reform needs to be looked at with Australia in mind not some twerp's ego. LLAMP was on that path but a few threats about political interference in another theatre put a real quick stop to it. Confused? Let Richardo explain.
I think you missed blogg's point. VFR climb/descent is a procedure just like a 20 DME standard or a 10 minute standard. Not a VFR climbing in airspace. The Aircraft remains IFR throughout the procudure but assumes sep responsibility of all advised traffic. Same with VFR on top. Not 1000 feet OTT but VFR on top @ VFR levels only.
I also agree with you on flight following. BUT!!!!! We had it years ago. Called Flight Service. Remember that? Your buddy Dick saw the end of it. We do not have the movement base that the yanks have therefore not the cash to provide such a thing without the massive subsidies that the yanks have. Beat that drum all you want Chris but without an increase in staff a full VFR flight following WILL NOT HAPPEN in this country. That means more cost and noone will cop that.
Our reform needs to be looked at with Australia in mind not some twerp's ego. LLAMP was on that path but a few threats about political interference in another theatre put a real quick stop to it. Confused? Let Richardo explain.
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Confused
No, I don't think I'm confused at all. I still do non-radar time interval seperation in the Islands and in most of South America. I'm familiar with a VFR climb, although we're not allowed to do them by company policy, we have to take the seperation delay.
Flight Service offered FULLSAR/FULLDETAILS, but so there's no confusion to people who weren't around back then, you agree, this was only a radio interval reporting advisory, there was never radar involved.
Todzalp, I don't think you have the gravity of the workload, nor the density of airports in the USA. We have over 5,000 airports serving 225,000 aircraft. In Australia, we only have just under 10,000 planes.
You're going to come back at me and present the need for more radar and complain about the cost. Yep, infrastructure is expensive, but so are crashes. Each passenger seat these days is worth about $30 million dollars in potential liability.
You say that we don't have the money. I say we can't afford a crash.
You say that we can't have Class E Airspace in non-radar with non-reporting VFR. I agree whole heartedly!
All the best!
Chris
Flight Service offered FULLSAR/FULLDETAILS, but so there's no confusion to people who weren't around back then, you agree, this was only a radio interval reporting advisory, there was never radar involved.
Todzalp, I don't think you have the gravity of the workload, nor the density of airports in the USA. We have over 5,000 airports serving 225,000 aircraft. In Australia, we only have just under 10,000 planes.
You're going to come back at me and present the need for more radar and complain about the cost. Yep, infrastructure is expensive, but so are crashes. Each passenger seat these days is worth about $30 million dollars in potential liability.
You say that we don't have the money. I say we can't afford a crash.
You say that we can't have Class E Airspace in non-radar with non-reporting VFR. I agree whole heartedly!
All the best!
Chris
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Chris,
it would seem you are in touch with the details of the sour deal that is dished up to us.
Indeed, we cannot afford a crash!
Let us all hope that sanity prevails and that the No-Airspace-System dogma that our favourite cookie-crumbler proposes is stopped in its tracks (or at least radically changed).
Dick's deal is just no deal at all.
regards,
TJ
it would seem you are in touch with the details of the sour deal that is dished up to us.
Indeed, we cannot afford a crash!
Let us all hope that sanity prevails and that the No-Airspace-System dogma that our favourite cookie-crumbler proposes is stopped in its tracks (or at least radically changed).
Dick's deal is just no deal at all.
regards,
TJ
