RESPONSIBILITY and ACCOUNTABILITY - REDUX
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RESPONSIBILITY and ACCOUNTABILITY - REDUX
Accountability and Responsibility
On the 11th of August 2004, Mr Dick Smith publicly admitted liability for his actions in relation to the current airspace reform debate. This is the text posted on PPRuNe:
By the way, PPRuNe readers will be interested in the fact that I have informed the Deputy Prime Minister that I will cover my share of the costs of the NAS 2b wind back. I’ve also got John Forsyth to agree to cover his share. I’ve spoken to Angus Houston and I will be speaking to the other ARG members (Ken Matthews and Ted Anson) to make sure everyone contributes their share.
I’m sure everyone will agree that if people take public positions and are given responsibility by the Government to make important decisions, they must be accountable for their actions. This will probably be a first.
It is pleasing to note that despite his constant and consistent protestations to the contrary, Mr Smith has finally recognised that as a person appointed by government, and charged with a responsibility, he must accept accountability should those responsibilities be inappropriately discharged.
Now we trust that Mr Smith accepts the true import of his admission – that is, that had there been, or should there be, an accident directly or indirectly caused as a result of the misapplication of his responsibilities, some criminal liability may, and probably would, accrue.
It is also interesting to note that Mr Smith will pay for the cost of “rollback” of NAS 2B.
Will Mr Smith now offer to repay the $100 million + that has been expended on aborted aviation reform in Australia? We would suggest that a trust fund containing $100 million, aimed at providing flying scholarships for young people, would have a significant and substantial effect on aviation in Australia, and would substantially satisfy the Government’s stated will to foster aviation in Australia.
We estimate that it costs around $10-15,000 to train a pilot to unrestricted VFR status. A trust fund of $100M would fund around 2000 pilots a year for a very long time. If only 10% of those new pilots decided to continue flying on a regular basis, flying schools and training organisations would flourish and who knows, perhaps investors may buy new aircraft for the general aviation industry in Australia.
Mr Smith – we challenge you to establish a fund such as this, and truly encourage aviation in Australia.
We suspect that every one of your no-sayers would recant and laud your actions.
Can you imagine 2000 Dick Smith Aviation Scholarships each year, distributed across Australia, and Australian flying schools. It would be perhaps the most substantial aviation fostering activity ever undertaken in Australian history. Not one person could be critical of such an initiative, and if matched by the government with some tax incentives to scholarship supporting flying schools, particularly in the purchasing of new aircraft, it could only have a positive effect.
Take the challenge, Mr Smith. Do what you are so good at doing. Build a strong and vibrant aviation industry in Australia.
On the 11th of August 2004, Mr Dick Smith publicly admitted liability for his actions in relation to the current airspace reform debate. This is the text posted on PPRuNe:
By the way, PPRuNe readers will be interested in the fact that I have informed the Deputy Prime Minister that I will cover my share of the costs of the NAS 2b wind back. I’ve also got John Forsyth to agree to cover his share. I’ve spoken to Angus Houston and I will be speaking to the other ARG members (Ken Matthews and Ted Anson) to make sure everyone contributes their share.
I’m sure everyone will agree that if people take public positions and are given responsibility by the Government to make important decisions, they must be accountable for their actions. This will probably be a first.
It is pleasing to note that despite his constant and consistent protestations to the contrary, Mr Smith has finally recognised that as a person appointed by government, and charged with a responsibility, he must accept accountability should those responsibilities be inappropriately discharged.
Now we trust that Mr Smith accepts the true import of his admission – that is, that had there been, or should there be, an accident directly or indirectly caused as a result of the misapplication of his responsibilities, some criminal liability may, and probably would, accrue.
It is also interesting to note that Mr Smith will pay for the cost of “rollback” of NAS 2B.
Will Mr Smith now offer to repay the $100 million + that has been expended on aborted aviation reform in Australia? We would suggest that a trust fund containing $100 million, aimed at providing flying scholarships for young people, would have a significant and substantial effect on aviation in Australia, and would substantially satisfy the Government’s stated will to foster aviation in Australia.
We estimate that it costs around $10-15,000 to train a pilot to unrestricted VFR status. A trust fund of $100M would fund around 2000 pilots a year for a very long time. If only 10% of those new pilots decided to continue flying on a regular basis, flying schools and training organisations would flourish and who knows, perhaps investors may buy new aircraft for the general aviation industry in Australia.
Mr Smith – we challenge you to establish a fund such as this, and truly encourage aviation in Australia.
We suspect that every one of your no-sayers would recant and laud your actions.
Can you imagine 2000 Dick Smith Aviation Scholarships each year, distributed across Australia, and Australian flying schools. It would be perhaps the most substantial aviation fostering activity ever undertaken in Australian history. Not one person could be critical of such an initiative, and if matched by the government with some tax incentives to scholarship supporting flying schools, particularly in the purchasing of new aircraft, it could only have a positive effect.
Take the challenge, Mr Smith. Do what you are so good at doing. Build a strong and vibrant aviation industry in Australia.
Last edited by Voices of Reason; 11th Aug 2004 at 12:36.
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Imagine the good PR, not to mention what an injection of $100 million dollars would do for the flying training and GA in Oz if Dick were to set up a Flying Training scholarship such as suggested by VoR.
Dick, the challenge has been made. Start the Dick Smith flying scholarships for young pilots. Invigorate the GA industry of Australia, and truly help the aviation industry of Australia. We have the blue skies, the instructors, the airfields and airspace.
Make Australian flying school training the world's best practice for aircrew training.
Dick, the challenge has been made. Start the Dick Smith flying scholarships for young pilots. Invigorate the GA industry of Australia, and truly help the aviation industry of Australia. We have the blue skies, the instructors, the airfields and airspace.
Make Australian flying school training the world's best practice for aircrew training.
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Now this sounds like a great idea to me, albeit a bit of a pipe dream.
However, I actually dont think the money should be given to people as they start their training as some will not fulfill this obligation, due to lack of competency and/or application.
What if amounts were paid for completion of certain licences/ratings to scholarship hopefuls, resulting in a final sum of $15,000.
ie: GFPT $3000
PPL $5000
NVFR $2000
IFR $5000
I can think of many young people who would be interested in such a scheme.
This idea has a lot of merit.
Cheers, HH.
However, I actually dont think the money should be given to people as they start their training as some will not fulfill this obligation, due to lack of competency and/or application.
What if amounts were paid for completion of certain licences/ratings to scholarship hopefuls, resulting in a final sum of $15,000.
ie: GFPT $3000
PPL $5000
NVFR $2000
IFR $5000
I can think of many young people who would be interested in such a scheme.
This idea has a lot of merit.
Cheers, HH.
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What will happen is that they other ARG members will tell him to p!ss off as they dont have a spare $25million and he will use that as justification not to put in his 'share' (I doubt very much if he would even put in if they did). Even discussing the possibilities of his actually paying the money has has thrown away is rediculous.
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Voices of Reason
A capital idea indeed and I would certainly recant and laud his "altruistic"
actions but only were he to do so without "naming rights" and were it to be from a trust fund administered independently by a whole of Industry/Government appointed authority and which would specifically exclude his participation and declared a "limelight free zone".
Then I would be impressed, or will we see another "Australian Geographic".
It is the least he could do to "repair" the damage he has wrought by his regulatory adventures over the last 20 or so years.
I don't subscribe to the notion of being "rewarded" in any form for causing "loss", I do subscribe to the notion of restitution without it.
A capital idea indeed and I would certainly recant and laud his "altruistic"
actions but only were he to do so without "naming rights" and were it to be from a trust fund administered independently by a whole of Industry/Government appointed authority and which would specifically exclude his participation and declared a "limelight free zone". Then I would be impressed, or will we see another "Australian Geographic".
It is the least he could do to "repair" the damage he has wrought by his regulatory adventures over the last 20 or so years.
I don't subscribe to the notion of being "rewarded" in any form for causing "loss", I do subscribe to the notion of restitution without it.
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I am sure all the flying training schools would love to have lots and lots of new students under paid for scholarships. We already have a couple of thousand unemployed CPL holders vying for crap jobs around Australia most with little hope of success. We don't need any more sausage machine graduates.
Too many pilots- too few jobs and that situation has been like that for decades and it will never improve. If a benevolent chappie hands out scholarships then it should only for a set number of flying hours such as 22 which is the minimum for a GFPT. Forget PPL, CPL, Night VFR etc. If the lucky scholarship holder wants to add to his experience beyond 22 hours then that becomes his financial responsibility.
Too many pilots- too few jobs and that situation has been like that for decades and it will never improve. If a benevolent chappie hands out scholarships then it should only for a set number of flying hours such as 22 which is the minimum for a GFPT. Forget PPL, CPL, Night VFR etc. If the lucky scholarship holder wants to add to his experience beyond 22 hours then that becomes his financial responsibility.
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Our original post was, of course, a little tongue in cheek, and it is unlikely that anyone, let alone Mr Smith, would be willing to establish a $100M trust fund.
It is interesting to note that in the United States, there are several hundred thousand private pilots who do not strive to be commercial pilots – they simply want to fly recreationally. Hire costs for light aircraft are reasonable, ranging around US$80 and hour, insurance included, for a C172 or PA28, to US$100 for a C182 or Archer, and one hour’s light aircraft flying from just about anywhere in the United States can actually take you to some interesting destinations. We understand it is a little more expensive in Australia.
Again, our intent was only to recognise that Mr Smith has publicly admitted his error, and to say to Mr Smith that there are many, many, more ways within his power to stimulate general aviation in Australia other than running “bull at a gate” for abortive and unproductive airspace reform.
It is interesting to note that in the United States, there are several hundred thousand private pilots who do not strive to be commercial pilots – they simply want to fly recreationally. Hire costs for light aircraft are reasonable, ranging around US$80 and hour, insurance included, for a C172 or PA28, to US$100 for a C182 or Archer, and one hour’s light aircraft flying from just about anywhere in the United States can actually take you to some interesting destinations. We understand it is a little more expensive in Australia.
Again, our intent was only to recognise that Mr Smith has publicly admitted his error, and to say to Mr Smith that there are many, many, more ways within his power to stimulate general aviation in Australia other than running “bull at a gate” for abortive and unproductive airspace reform.
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It seems Mr Smith spoke too soon on PPRuNe, if the post that contains and extract from the Australian newspaper is to be believed.
As we have indicated in previous posts, the release of a safety case into the public domain is a mark of the maturity of the safety management practices that prevail in any given environment. Secrecy breeds distrust, and begs the question as to whether or not “true science” was applied, or whether expediency was applied to ensure the “correct” results were obtained. This is an observation that could as well be made in relation to processes Mr Smith used in forcing NAS as a “model of choice”.
What a public safety case also does is builds confidence amongst those likely to be affected by the changes detailed in that safety case – in this case pilots, and the traveling public.
To debate a safety case in the public domain, however, after it has been completed, and in the manner that is likely to be used here by Mr Smith, is likely to destroy any remaining confidence that the aviation community, and the traveling public, have for your service provider and regulator’s safety management system.
It is extremely likely that Mr Smith will find appropriate experts who will challenge the findings of the report and call into question the processes used, the calculations made, and the expertise of participants. Put to the task, we could most likely find significant faults in the safety case. But that is not the key issue.
The key fact here is that Airservices Australia actually conducted a safety case on the proposed changes, using processes published by Airservices, audited by your regulator, and totally consistent with world’s best practices, from what we have seen. If the safety case has been completed, as we suspect it has, in accordance with those published procedures, all participants will have been clearly identified, their qualifications noted, the safety arguments appropriately recorded, and the findings validated. It is extremely likely that the findings are conservative – most safety cases are.
The Board of Airservices Australia, rather than basing their decision making on guesswork and hearsay, is now able to make a decision based on expert judgment.
A safety case, in and of itself, does not tell you that you should, or should not, proceed with a particular change. It simply identifies the safety risks associated with a change, identifies potential mitigators, and makes judgments about the effects of a change. It argues the safety factors in a particular change. There are other considerations beside safety that a Board MUST take into account before making a decision, including the business case, governance issues, political considerations and so on. The safety case is one element – an important one – but just one input into consideration of a particular proposal.
It is the Board that will decide whether, on balance, if it is reasonable to accept the safety and business risks associated with a change.
Now to Mr Smith’s efforts. Those who understand the principles of risk management will understand how broad the various risk tolerability bands can be. They will also understand that many subtle changes in safety arguments can have order of magnitude affects on risk lines. So it is entirely reasonable that the finding of 5 fatalities every hundred years could actually be a range of 0.5 to 50 or more. It also needs to be understood that increases in traffic numbers do not have a simple linear impact of risk.
What is more pertinent is the change in risk, versus the benefit achieved by accepting that change in risk.
We suspect that the risk of Class E over non-radar towers, when compared with that of Class C over non-radar towers increased by a factor of at least 10. That is to say, if the predicted statistical fatality rate was 10 with Class E, it may have been 1 with Class C. If the cost of this statistical fatality is around $2M in Australia, then the cost of the change would have been a notional $18M over 100 years, or $180,000 per year. The benefit would need to (substantially) exceed $180,000 per year to make the change cost beneficial. Based on statistical evidence we have seen, this would be hard to achieve.
If Mr Smith’s experts do review and challenge the safety case, they will need to do it in a manner that replicates the safety argument process, AND provide a method by which the change in risk can be quantified. We have seen several such processes – our instinct on this is that no matter what absolute value of risk they determine, the relative change in risk will be the same – about one order of magnitude higher between Class E and Class C.
As we have indicated in previous posts, the release of a safety case into the public domain is a mark of the maturity of the safety management practices that prevail in any given environment. Secrecy breeds distrust, and begs the question as to whether or not “true science” was applied, or whether expediency was applied to ensure the “correct” results were obtained. This is an observation that could as well be made in relation to processes Mr Smith used in forcing NAS as a “model of choice”.
What a public safety case also does is builds confidence amongst those likely to be affected by the changes detailed in that safety case – in this case pilots, and the traveling public.
To debate a safety case in the public domain, however, after it has been completed, and in the manner that is likely to be used here by Mr Smith, is likely to destroy any remaining confidence that the aviation community, and the traveling public, have for your service provider and regulator’s safety management system.
It is extremely likely that Mr Smith will find appropriate experts who will challenge the findings of the report and call into question the processes used, the calculations made, and the expertise of participants. Put to the task, we could most likely find significant faults in the safety case. But that is not the key issue.
The key fact here is that Airservices Australia actually conducted a safety case on the proposed changes, using processes published by Airservices, audited by your regulator, and totally consistent with world’s best practices, from what we have seen. If the safety case has been completed, as we suspect it has, in accordance with those published procedures, all participants will have been clearly identified, their qualifications noted, the safety arguments appropriately recorded, and the findings validated. It is extremely likely that the findings are conservative – most safety cases are.
The Board of Airservices Australia, rather than basing their decision making on guesswork and hearsay, is now able to make a decision based on expert judgment.
A safety case, in and of itself, does not tell you that you should, or should not, proceed with a particular change. It simply identifies the safety risks associated with a change, identifies potential mitigators, and makes judgments about the effects of a change. It argues the safety factors in a particular change. There are other considerations beside safety that a Board MUST take into account before making a decision, including the business case, governance issues, political considerations and so on. The safety case is one element – an important one – but just one input into consideration of a particular proposal.
It is the Board that will decide whether, on balance, if it is reasonable to accept the safety and business risks associated with a change.
Now to Mr Smith’s efforts. Those who understand the principles of risk management will understand how broad the various risk tolerability bands can be. They will also understand that many subtle changes in safety arguments can have order of magnitude affects on risk lines. So it is entirely reasonable that the finding of 5 fatalities every hundred years could actually be a range of 0.5 to 50 or more. It also needs to be understood that increases in traffic numbers do not have a simple linear impact of risk.
What is more pertinent is the change in risk, versus the benefit achieved by accepting that change in risk.
We suspect that the risk of Class E over non-radar towers, when compared with that of Class C over non-radar towers increased by a factor of at least 10. That is to say, if the predicted statistical fatality rate was 10 with Class E, it may have been 1 with Class C. If the cost of this statistical fatality is around $2M in Australia, then the cost of the change would have been a notional $18M over 100 years, or $180,000 per year. The benefit would need to (substantially) exceed $180,000 per year to make the change cost beneficial. Based on statistical evidence we have seen, this would be hard to achieve.
If Mr Smith’s experts do review and challenge the safety case, they will need to do it in a manner that replicates the safety argument process, AND provide a method by which the change in risk can be quantified. We have seen several such processes – our instinct on this is that no matter what absolute value of risk they determine, the relative change in risk will be the same – about one order of magnitude higher between Class E and Class C.
Voices of Reason, there is a slight problem with your argument and I'm sure you know it. That is, that Airservices in putting Class C airspace in the non-radar airspace above the towers is not planning to pay the money for a terminal radar - as is required in the USA, or pay the money for extra controllers. Their plan is to use the same controller who is already flat-strapped at peak times in the Class D to also be responsible for the Class C above. Blind Freddy can see that this must reduce safety in the Class D where collision risk is highest.
For example, if a VFR aircraft turns up in the wound-back Class C airspace above Tamworth and request a clearance through part of the airspace, the controller who could be controlling airline traffic on the approach, circuit traffic, helicopters etc, then has to take attention away from the traffic close to the airport and work out how to procedurally separate an en-route VFR. I was recently talking to an expert controller and he said that would most likely be by putting a line on a map and trying to fathom out how to give the required separation if there were say an IFR Navajo coming in from a similar direction and descending through the VFR aircraft's level. This of course happens quite often in Class C airspace.
The point I'm making is that if you try and do Class C terminal airspace "on the cheap" to maximise profits, you end up substantially reducing safety in the Class D airspace below. Of course, everyone knows that's where the risk is. Look at our Australian history of collisions at Moorabbin, Coolangatta, Jandakot and Sydney - most take place close to the tower and some may have not happened if the controllers had been able to spend more time concentrating on that traffic. The Coolangatta mid-air and the Sydney airline collision are good examples.
I have been told that in the safety study, Airservices decided to take no account for the increase in risk in Class D airspace when they overload the Class D controller (I'm told quite often only one person) with the C airspace above when the wind-back takes place. Sounds to me as if this was the type of study where you include all of the evidence which supports your beliefs (ie for the wind-back) and ignore any evidence which works against your pre-conceived ideas.
By the way Voices of Reason, it has been estimated that you have spent over $100,000 in research and time on this issue. I’m told that some of your members are within Airservices and desperately running an anonymous campaign to wind back the reforms.
PPRuNe readers may also be interested in that I have recently received a letter from Gabrielle Trainor’s solicitor. He claims that Gabrielle is not doing a “dirty tricks campaign” on me and that I have defamed her by claiming this. I have written back to him suggesting that Gabrielle gives me a phone call so I can find out what all the secrecy is about. In the meantime, lots of people believe that Gabrielle Trainor is being paid by Airservices. Does anyone have any info on this?
For example, if a VFR aircraft turns up in the wound-back Class C airspace above Tamworth and request a clearance through part of the airspace, the controller who could be controlling airline traffic on the approach, circuit traffic, helicopters etc, then has to take attention away from the traffic close to the airport and work out how to procedurally separate an en-route VFR. I was recently talking to an expert controller and he said that would most likely be by putting a line on a map and trying to fathom out how to give the required separation if there were say an IFR Navajo coming in from a similar direction and descending through the VFR aircraft's level. This of course happens quite often in Class C airspace.
The point I'm making is that if you try and do Class C terminal airspace "on the cheap" to maximise profits, you end up substantially reducing safety in the Class D airspace below. Of course, everyone knows that's where the risk is. Look at our Australian history of collisions at Moorabbin, Coolangatta, Jandakot and Sydney - most take place close to the tower and some may have not happened if the controllers had been able to spend more time concentrating on that traffic. The Coolangatta mid-air and the Sydney airline collision are good examples.
I have been told that in the safety study, Airservices decided to take no account for the increase in risk in Class D airspace when they overload the Class D controller (I'm told quite often only one person) with the C airspace above when the wind-back takes place. Sounds to me as if this was the type of study where you include all of the evidence which supports your beliefs (ie for the wind-back) and ignore any evidence which works against your pre-conceived ideas.
By the way Voices of Reason, it has been estimated that you have spent over $100,000 in research and time on this issue. I’m told that some of your members are within Airservices and desperately running an anonymous campaign to wind back the reforms.
PPRuNe readers may also be interested in that I have recently received a letter from Gabrielle Trainor’s solicitor. He claims that Gabrielle is not doing a “dirty tricks campaign” on me and that I have defamed her by claiming this. I have written back to him suggesting that Gabrielle gives me a phone call so I can find out what all the secrecy is about. In the meantime, lots of people believe that Gabrielle Trainor is being paid by Airservices. Does anyone have any info on this?
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Gee Dick,
Not one word in response to the idea of setting up a Dick Smith trust for young aspiring pilots.
Well, Dick, we can certainly see that you aren't really interested in invigorating GA. More like some sort of Don Quixote complex and the airspace reform windmill.
Not one word in response to the idea of setting up a Dick Smith trust for young aspiring pilots.
Well, Dick, we can certainly see that you aren't really interested in invigorating GA. More like some sort of Don Quixote complex and the airspace reform windmill.
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That is, that Airservices in putting Class C airspace in the non-radar airspace above the towers is not planning to pay the money for a terminal radar - as is required in the USA, or pay the money for extra controllers. Their plan is to use the same controller who is already flat-strapped at peak times in the Class D to also be responsible for the Class C above. Blind Freddy can see that this must reduce safety in the Class D where collision risk is highest.
Your previous statements to the effect that a quiet frequency are indicative of low workload are another example of your apparent lack of knowledge of airspace and ATC issues. (The facts that you were referring to an oceanic sector, whose primary means of communication are CPDLC and third party HF showed conclusively that you have no idea.)
As you seem to be unaware of the factors which affect ATC workload, complexity ands safety, is it not time that you recommended to the minister that the ARG include professional air traffic controllers and pilots who have working knowledge of the system they are trying to reform.
Of course, everyone knows that's where the risk is. Look at our Australian history of collisions at Moorabbin, Coolangatta, Jandakot and Sydney - most take place close to the tower and some may have not happened if the controllers had been able to spend more time concentrating on that traffic. The Coolangatta mid-air and the Sydney airline collision are good examples.
I have been told that in the safety study, Airservices decided to take no account for the increase in risk in Class D airspace when they overload the Class D controller (I'm told quite often only one person) with the C airspace above when the wind-back takes place.
By the way Voices of Reason, it has been estimated that you have spent over $100,000 in research and time on this issue. I’m told that some of your members are within Airservices and desperately running an anonymous campaign to wind back the reforms.
In the meantime, lots of people believe that Gabrielle Trainor is being paid by Airservices. Does anyone have any info on this?
I am sure you would agree that these matters are very important and the truth should be told. I look forward to your response, but will not be holding my breath.
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Mr Smith,
Thank you for your inputs.
First, you are probably correct in assuming that had we been paid for our time in providing inputs here, and particularly at the rates being paid to consultants like Wes Willoughby, we would have been entitled to a substantial amount of money.
However, like you, we provide our time and information free of charge, and only in the interests of safety.
Surprisingly, we do not have “members” in Australia – in fact we do not have formal members anywhere in the world. We act as a group of like-minded individuals, with a range of skills, and provide safety advice where we believe it to be appropriate.
We have a number of contacts in Australia and other countries who provide us factual information, in exactly the same way that you indicate that you contact specialists in the United States.
You make some interesting observations about risk associated with Class C, D and E over non-radar towers.
Let us make one thing absolutely and perfectly clear. There is absolutely NO requirement for the provision of radar control in Class C airspace. The majority of the world’s designated Class C airspace is actually outside of radar coverage. That the United States has chosen to place radar control services in Class C terminal airspace is most likely a function of traffic densities and complexities.
Let us also state again, for the record, that Class D airspace in the United States rarely extends beyond the visual range of a tower controller – that is to say that any aircraft calling a controller at the boundary of Class D airspace is most likely able to be visually identified by the affected controller. That is NOT the case in Australia.
Now to your attempt at erudite argument on the subject of risk.
Before NAS, a tower controller at any one of the ten non-radar towers [perhaps with the exception of Maroochydore] provided services to aircraft in the Class D airspace immediately around the tower, to 4,500 feet AMSL, and in the overlying Class C airspace to varying levels and distances.
There is a certain level of risk associated with this configuration, and yes, you could well be correct in saying that when the controller is very busy, risk levels change. That is to be expected, and is the nature of risk and risk analysis. So, since Class D airspace was introduced in Australia in 1997, there has been a determinable level of risk associated with non-radar tower services. You might even argue that 8 years of operating experience is enough to demonstrate that there have been no incidents as a result of that configuration, and the risk is acceptable.
Under NAS, you designed a changed configuration, which retained Class D airspace in exactly the same dimensions, but reclassified Class C as Class E.
A changed level of risk is now in play – you must agree.
Without conducting a detailed mathematical study, let’s look at the probable scenario. This is the exercise you would do to ensure the mathematical answer is in the right ballpark – a little like knowing that 2x3 is 6, so 2.2 x 3.1 is likely to be about 7, not 5.
What has changed?
The controller does exactly the same in Class D – so we would say, not change in that risk component. In Class E, the controller separates the IFR flights – so no change in that number. In class E, the VFR flights effectively become invisible to the controller, so no service provided, workload probably decreases, and yes, the level of overall risk that is managed by the controller comes down.
Now look at the whole picture. The pilot operating in Class D airspace – effectively no change – so the risk stays the same. The VFR pilot in Class E does not have to talk to the tower –or even monitor the frequency – so the pilot is denied “party line” or third party conflict management and is forced to rely on see and avoid. Risk goes up. The IFR pilot is separated from other IFR flights. Risk is constant. The IFR pilot is denied “party line” or third party conflict management reference VFR flights. Risk goes up.
So we have controller related risk going down, and pilot related risk going up. Instinct and experience tells us that there would be a net increase in risk. The Airservices’ safety case apparently concurs with this assumption.
As we have said, the safety case alone is not the deciding factor in most cases. Unless the risk is well within the intolerable range, if the benefit outweighs the risk, it may be viable to make the change. Airservices would need to demonstrate a benefit higher than the increased risk. If the risk level is actually in the intolerable range, as was indicated in press releases that we have seen, then it is incumbent upon a service provider to manage that risk back down to an acceptable level.
Given that Airservices is willing to wait until November to make the necessary changes, we doubt that the risk levels are truly intolerable – if that were indeed the case, Airservices should and could act immediately to mitigate risk. It is more likely that there is insufficient cost benefit to justify the retention of the risk change.
Thank you for your inputs.
First, you are probably correct in assuming that had we been paid for our time in providing inputs here, and particularly at the rates being paid to consultants like Wes Willoughby, we would have been entitled to a substantial amount of money.
However, like you, we provide our time and information free of charge, and only in the interests of safety.
Surprisingly, we do not have “members” in Australia – in fact we do not have formal members anywhere in the world. We act as a group of like-minded individuals, with a range of skills, and provide safety advice where we believe it to be appropriate.
We have a number of contacts in Australia and other countries who provide us factual information, in exactly the same way that you indicate that you contact specialists in the United States.
You make some interesting observations about risk associated with Class C, D and E over non-radar towers.
Let us make one thing absolutely and perfectly clear. There is absolutely NO requirement for the provision of radar control in Class C airspace. The majority of the world’s designated Class C airspace is actually outside of radar coverage. That the United States has chosen to place radar control services in Class C terminal airspace is most likely a function of traffic densities and complexities.
Let us also state again, for the record, that Class D airspace in the United States rarely extends beyond the visual range of a tower controller – that is to say that any aircraft calling a controller at the boundary of Class D airspace is most likely able to be visually identified by the affected controller. That is NOT the case in Australia.
Now to your attempt at erudite argument on the subject of risk.
Before NAS, a tower controller at any one of the ten non-radar towers [perhaps with the exception of Maroochydore] provided services to aircraft in the Class D airspace immediately around the tower, to 4,500 feet AMSL, and in the overlying Class C airspace to varying levels and distances.
There is a certain level of risk associated with this configuration, and yes, you could well be correct in saying that when the controller is very busy, risk levels change. That is to be expected, and is the nature of risk and risk analysis. So, since Class D airspace was introduced in Australia in 1997, there has been a determinable level of risk associated with non-radar tower services. You might even argue that 8 years of operating experience is enough to demonstrate that there have been no incidents as a result of that configuration, and the risk is acceptable.
Under NAS, you designed a changed configuration, which retained Class D airspace in exactly the same dimensions, but reclassified Class C as Class E.
A changed level of risk is now in play – you must agree.
Without conducting a detailed mathematical study, let’s look at the probable scenario. This is the exercise you would do to ensure the mathematical answer is in the right ballpark – a little like knowing that 2x3 is 6, so 2.2 x 3.1 is likely to be about 7, not 5.
What has changed?
The controller does exactly the same in Class D – so we would say, not change in that risk component. In Class E, the controller separates the IFR flights – so no change in that number. In class E, the VFR flights effectively become invisible to the controller, so no service provided, workload probably decreases, and yes, the level of overall risk that is managed by the controller comes down.
Now look at the whole picture. The pilot operating in Class D airspace – effectively no change – so the risk stays the same. The VFR pilot in Class E does not have to talk to the tower –or even monitor the frequency – so the pilot is denied “party line” or third party conflict management and is forced to rely on see and avoid. Risk goes up. The IFR pilot is separated from other IFR flights. Risk is constant. The IFR pilot is denied “party line” or third party conflict management reference VFR flights. Risk goes up.
So we have controller related risk going down, and pilot related risk going up. Instinct and experience tells us that there would be a net increase in risk. The Airservices’ safety case apparently concurs with this assumption.
As we have said, the safety case alone is not the deciding factor in most cases. Unless the risk is well within the intolerable range, if the benefit outweighs the risk, it may be viable to make the change. Airservices would need to demonstrate a benefit higher than the increased risk. If the risk level is actually in the intolerable range, as was indicated in press releases that we have seen, then it is incumbent upon a service provider to manage that risk back down to an acceptable level.
Given that Airservices is willing to wait until November to make the necessary changes, we doubt that the risk levels are truly intolerable – if that were indeed the case, Airservices should and could act immediately to mitigate risk. It is more likely that there is insufficient cost benefit to justify the retention of the risk change.
VOR
In analysing the ‘ball park’ change in risk from C to E over D, you assert, among other things, that:
My understanding of Dick’s point is that because the controller’s workload is reduced – that is, she doesn’t have to work the VFRs in E that would otherwise have been C – the controller can concentrate on separation in the Class D where, according to Dick, the collision risk is comparatively higher. In other words, the D controller can do more than she would otherwise be able to do to keep the D traffic separated. You acknowledge the workload point, then confuse me a little when you say:
You also say:
With the greatest respect, and without suggesting DickNAS is anything other than a debacle, I hope Airservices’ safety case isn’t based on “instinct”.
In analysing the ‘ball park’ change in risk from C to E over D, you assert, among other things, that:
The controller does exactly the same in Class D – so we would say, not change in that risk component. … The pilot operating in Class D airspace – effectively no change – so the risk stays the same.
… the VFR flights effectively become invisible to the controller, so no service provided, workload probably decreases, and yes, the level of overall risk that is managed by the controller comes down.
So we have controller related risk going down, and pilot related risk going up. Instinct and experience tells us that there would be a net increase in risk.
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Creampuff,
You are correct in saying that "instinct" is not a very good risk assessment proof. What we were trying to say was that it makes sense that the Airservices safety case would show that changing Class C to Class E would increase risk. We are sorry if we oversimplified the case.
You need to be able to intuit a result, as well as prove it mathematically, so that you can have confidence in that mathematical result.
The fact remains that Class E over D is a higher overall risk configuration that Class C over D.
You are correct in saying that "instinct" is not a very good risk assessment proof. What we were trying to say was that it makes sense that the Airservices safety case would show that changing Class C to Class E would increase risk. We are sorry if we oversimplified the case.
You need to be able to intuit a result, as well as prove it mathematically, so that you can have confidence in that mathematical result.
The fact remains that Class E over D is a higher overall risk configuration that Class C over D.
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The fact remains that Class E over D is a higher overall risk configuration that Class C over D.
I'll start a petition for traffic lights and a police presence at every corner, too.
Fly safely now.
NOtimTAMs
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I'll start a petition for traffic lights and a police presence at every corner, too.
Thanks for your input.