NAS - Common Risk Management Framework
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NAS - Common Risk Management Framework
It appears that the airspace reform debate in Australia is about to be re-opened by the previous protagonists, operating under a new legislative regime. We recently forwarded the commentary below to your Department of Transport and Regional Services. We will continue to provide comment.
We urge you to provide comments direct to the Department, both on this document, and the draft airspace policy. It is clear that the policy 'directs' certain outcomes, which will inevitably pre-dispose or pre-bias the proponent organisations, making it difficult for them to conduct the transparent and balanced risk assessments that are critical to aviation safety.
We have recently been made aware of a draft document entitled “Common Risk Management Framework for New and Changed Operational Requirements within Aviation – February 2007”, and we would like to offer these preliminary comments.
First, may we say that the goal of implementing a common protocol and understanding for managing change risk is to be commended, and is a significant step in the direction of increased safety in aviation. It is, of course, critical to change management that all of the parties affected by any particular change understand what part of their daily operation will be affected by that change, and what measures have been agreed to mitigate any risks associated with that change.
Too often in the past factors including denial of the significance of the change, misinformation about the change, wrongly targeted training, and so on, have conspired to increase the risk, rather than mitigate the risk – both through the implementation phase, and in the actual post-implementation daily operation. Whether or not the change is supported by all parties to the change, a common understanding – and a common risk mitigation focus – should, at the very least, serve to reduce the risks associated with implementing the change – and in the long run increase acceptance of the change, for a net safety benefit.
That said, we find a number of areas of concern within the document, and we offer some commentary that we trust you will take constructively.
One of the key tenets of a quality control system – which is essentially what we are talking about in aviation safety - and which underpins the ISO 9000 approach to quality management – is to “say what you do, do what you say, and be able to prove it”. It is clear that the Common Risk Management Framework document is aimed at the first part of the trilogy – saying what you intend to do. It is critical that the organisations that embrace the document must have in place structural mechanisms to be able to do what they say they will do – AND critically, to be able to prove it.
This requires that each organisation have in place a detailed and robust safety management system, and that that system complies not only with Australian and International standards and best practice – but that it is also completely transparent and auditable. Only then will the requisite levels of trust and common understanding be gained by affected parties.
The tendency in the past – not just in Australia, but globally – has been to cover or secrete those areas of risk or risk amelioration that may become contentious – no matter the fact that they have been subjected to a full and complete risk management process. As you have witnessed in past attempts to implement change, the process of change has become difficult, or impossible – not because the change was substantially significant – but because the processes around the change management were mismanaged. Much of that mismanagement came about as a result of attempts to hide information.
Sunlight is a great antiseptic, and conducting risk management processes in the open will yield far more satisfactory results that a subversive campaign.
On that issue, it is also essential that the risk management processes undertaken allow for a change to be accepted or rejected – WITHOUT fear or favour. It has been clear that there has been an agenda for change written into various government or organisational policies that REQUIRES a change to occur – rather than allowing a proposed change to be properly assessed and treated on merit. An organisational predisposition to effect a change does NOT allow a free and transparent risk management process to occur. Necessarily, the architects or implementers of change will bias the risk studies towards the change, rather than allowing the change to determine its own fate.
That does not mean that inertia should prevail in all instances – i.e., the process should allow for the fact that some affected parties will always resist change. The way to deal with that – and we find this missing in your document – is to conduct an assessment of the risks associated with the current operating system.
To our knowledge, no such complete study of ‘day-to-day’ safety and risk management in Australian airspace has been conducted – even though there is substantial evidence of systemic problems within the system. We have only superficial access to your incident data – but it is clear from what we see that there are issues relating to training, culture, maintenance, human factors, fatigue, and so on, across the gambit of actors within the system, that need to be quantified and qualified as part of a ‘whole of system’ safety audit.
Once that audit has been completed, you will be able to quantify the effect of a proposed change in absolute rather than relative terms. Seeing a net positive influence in absolute safety can have a tremendous effect on your ability to implement a proposed change that might otherwise have been resisted.
The document makes an oblique reference to the target levels of safety associated with the implementation of reduced vertical separation minima. In fact, prima facie, the implementation of RVSM apparently [and it seems from North Atlantic monitoring actually] increases collision risk. But taken in the context of overall aviation safety, the reduced height keeping tolerances, supported by better altimetry systems, and regimented monitoring and constant remediation of gross errors – plus the implementation of better traffic management systems and procedures in ATC units - actually improves overall system safety, whilst significantly enhancing capacity.
One of the points that needs to be resolved – and is addressed only tangentially in the document – is the idea of what constitutes an acceptable level of risk. ALARP in and of itself is a nebulous term, and can be used [or misused] as required, to win or defeat and argument. Unless it is supported by broadly acceptable numbers, it is an impotent goal. Some of the signatory organisations to the document have, as we understand it, already conducted a number of reviews of safety or risk targets – and most of those studies have been ‘buried’ within the organisations, because the results would not support the change agenda [refer to our previous comments]. It is critical that the signatory organisations agree to establish numerical targets for risk acceptance BEFORE setting out to justify a change agenda.
This actually works to the advantage of the organisations concerned, allowing a complete and transparent debate to take place – and allowing senior management and Boards to make solid and justifiable decisions – for OR against a particular change – in the interests of aviation safety.
There are many more specific comments that we would like to make – and we will be providing more detailed comment progressively through the coming weeks.
Thank you again for the opportunity to comment.
John Williamson
for and on behalf of
Voices of Reason
We urge you to provide comments direct to the Department, both on this document, and the draft airspace policy. It is clear that the policy 'directs' certain outcomes, which will inevitably pre-dispose or pre-bias the proponent organisations, making it difficult for them to conduct the transparent and balanced risk assessments that are critical to aviation safety.
We have recently been made aware of a draft document entitled “Common Risk Management Framework for New and Changed Operational Requirements within Aviation – February 2007”, and we would like to offer these preliminary comments.
First, may we say that the goal of implementing a common protocol and understanding for managing change risk is to be commended, and is a significant step in the direction of increased safety in aviation. It is, of course, critical to change management that all of the parties affected by any particular change understand what part of their daily operation will be affected by that change, and what measures have been agreed to mitigate any risks associated with that change.
Too often in the past factors including denial of the significance of the change, misinformation about the change, wrongly targeted training, and so on, have conspired to increase the risk, rather than mitigate the risk – both through the implementation phase, and in the actual post-implementation daily operation. Whether or not the change is supported by all parties to the change, a common understanding – and a common risk mitigation focus – should, at the very least, serve to reduce the risks associated with implementing the change – and in the long run increase acceptance of the change, for a net safety benefit.
That said, we find a number of areas of concern within the document, and we offer some commentary that we trust you will take constructively.
One of the key tenets of a quality control system – which is essentially what we are talking about in aviation safety - and which underpins the ISO 9000 approach to quality management – is to “say what you do, do what you say, and be able to prove it”. It is clear that the Common Risk Management Framework document is aimed at the first part of the trilogy – saying what you intend to do. It is critical that the organisations that embrace the document must have in place structural mechanisms to be able to do what they say they will do – AND critically, to be able to prove it.
This requires that each organisation have in place a detailed and robust safety management system, and that that system complies not only with Australian and International standards and best practice – but that it is also completely transparent and auditable. Only then will the requisite levels of trust and common understanding be gained by affected parties.
The tendency in the past – not just in Australia, but globally – has been to cover or secrete those areas of risk or risk amelioration that may become contentious – no matter the fact that they have been subjected to a full and complete risk management process. As you have witnessed in past attempts to implement change, the process of change has become difficult, or impossible – not because the change was substantially significant – but because the processes around the change management were mismanaged. Much of that mismanagement came about as a result of attempts to hide information.
Sunlight is a great antiseptic, and conducting risk management processes in the open will yield far more satisfactory results that a subversive campaign.
On that issue, it is also essential that the risk management processes undertaken allow for a change to be accepted or rejected – WITHOUT fear or favour. It has been clear that there has been an agenda for change written into various government or organisational policies that REQUIRES a change to occur – rather than allowing a proposed change to be properly assessed and treated on merit. An organisational predisposition to effect a change does NOT allow a free and transparent risk management process to occur. Necessarily, the architects or implementers of change will bias the risk studies towards the change, rather than allowing the change to determine its own fate.
That does not mean that inertia should prevail in all instances – i.e., the process should allow for the fact that some affected parties will always resist change. The way to deal with that – and we find this missing in your document – is to conduct an assessment of the risks associated with the current operating system.
To our knowledge, no such complete study of ‘day-to-day’ safety and risk management in Australian airspace has been conducted – even though there is substantial evidence of systemic problems within the system. We have only superficial access to your incident data – but it is clear from what we see that there are issues relating to training, culture, maintenance, human factors, fatigue, and so on, across the gambit of actors within the system, that need to be quantified and qualified as part of a ‘whole of system’ safety audit.
Once that audit has been completed, you will be able to quantify the effect of a proposed change in absolute rather than relative terms. Seeing a net positive influence in absolute safety can have a tremendous effect on your ability to implement a proposed change that might otherwise have been resisted.
The document makes an oblique reference to the target levels of safety associated with the implementation of reduced vertical separation minima. In fact, prima facie, the implementation of RVSM apparently [and it seems from North Atlantic monitoring actually] increases collision risk. But taken in the context of overall aviation safety, the reduced height keeping tolerances, supported by better altimetry systems, and regimented monitoring and constant remediation of gross errors – plus the implementation of better traffic management systems and procedures in ATC units - actually improves overall system safety, whilst significantly enhancing capacity.
One of the points that needs to be resolved – and is addressed only tangentially in the document – is the idea of what constitutes an acceptable level of risk. ALARP in and of itself is a nebulous term, and can be used [or misused] as required, to win or defeat and argument. Unless it is supported by broadly acceptable numbers, it is an impotent goal. Some of the signatory organisations to the document have, as we understand it, already conducted a number of reviews of safety or risk targets – and most of those studies have been ‘buried’ within the organisations, because the results would not support the change agenda [refer to our previous comments]. It is critical that the signatory organisations agree to establish numerical targets for risk acceptance BEFORE setting out to justify a change agenda.
This actually works to the advantage of the organisations concerned, allowing a complete and transparent debate to take place – and allowing senior management and Boards to make solid and justifiable decisions – for OR against a particular change – in the interests of aviation safety.
There are many more specific comments that we would like to make – and we will be providing more detailed comment progressively through the coming weeks.
Thank you again for the opportunity to comment.
John Williamson
for and on behalf of
Voices of Reason
VOR, your posting contains a lot of good logic and rational argument – similar to your excellent post in relation to Class E airspace here.
I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.
At one moment you are saying everything should be open and transparent, and at the next moment you are giving a message that in relation to Voices of Reason the name should be completely secret and hidden – this is inconsistent.
You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective.
I have a handsome reward to help the Royal Flying Doctor Service if you are prepared to “out” yourself so your organisation or group can be of real use to Australia – see here.
Come on Voices of Reason, stand up and be counted! It is obvious that you (whether an individual or a group) have some very important skills that are needed here in Australia. You make out that you are posting from overseas and that you do not have a good knowledge of statistics in Australia. This seems very strange.
It is completely beyond comprehension to me (and to any rational person reading your post) why you would put in so much work and then hide your name. Aviation safety is simply science. It is not directly involved with national security. As you have said in your own posting, everything should be completely open and above board.
I suggest you place your next posting with the name of your organisation so you can be of real use to Australia. Also it will allow me to send off a cheque to the Royal Flying Doctor Service.
I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.
At one moment you are saying everything should be open and transparent, and at the next moment you are giving a message that in relation to Voices of Reason the name should be completely secret and hidden – this is inconsistent.
You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective.
I have a handsome reward to help the Royal Flying Doctor Service if you are prepared to “out” yourself so your organisation or group can be of real use to Australia – see here.
Come on Voices of Reason, stand up and be counted! It is obvious that you (whether an individual or a group) have some very important skills that are needed here in Australia. You make out that you are posting from overseas and that you do not have a good knowledge of statistics in Australia. This seems very strange.
It is completely beyond comprehension to me (and to any rational person reading your post) why you would put in so much work and then hide your name. Aviation safety is simply science. It is not directly involved with national security. As you have said in your own posting, everything should be completely open and above board.
I suggest you place your next posting with the name of your organisation so you can be of real use to Australia. Also it will allow me to send off a cheque to the Royal Flying Doctor Service.
Sprucegoose
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So VOR, how about becoming up front and identifying yourself so you can be effective and see if you can get involved in the necessary reform.
John Williamson
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HH
Mr Smith.
It is completely beyond comprehension to me (and to any rational person reading your post) why you simpy refuse or are just unable, to "get it" in relation to PPRuNe.
is exactly why PPRuNe works the way it does. You yourself say that;
What possible difference is it going to make should it have a series of names attached. PPRuNers are mostly grown ups who know who and who does not offer horsefeathers or cannot sustain their position without resorting to personality assasination.
Experience of the past has shown that the identification of sources here can and often does have negative and inappropriate results and also gives a protagonist the opportunity, taken often, to negatively and unecessarily personalise the debate, notwithstanding the posters point being spot on. You have been guilty of this yourself.
On one hand you use PPRuNe as a source to enhance your "usefulness" to the Aviation Regulation Review Taskforce and seem to have absolutely no problem accepting the "usefulness" of anonymous suggestions there and on the other hand you assert that the VOR can not be of any use to Australia unless they out themselves.
It should be clear to you by now that had they wished to avail the RFDS of your qualified
largesse they would have done so by now.
It is a right of PPRuNe and attempts to out a PPRuNer used to lead to banning, but you seem to have corrupted that as a principle.
Just deal with it OK.
Mr Smith.
It is completely beyond comprehension to me (and to any rational person reading your post) why you simpy refuse or are just unable, to "get it" in relation to PPRuNe.
why you would put in so much work and then hide your name
your posting contains a lot of good logic and rational argument – similar to your excellent post in relation to Class E airspace here.
I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.
I couldn’t agree more that everything should be completely open and that in the past the change has suffered from mismanagement.
Experience of the past has shown that the identification of sources here can and often does have negative and inappropriate results and also gives a protagonist the opportunity, taken often, to negatively and unecessarily personalise the debate, notwithstanding the posters point being spot on. You have been guilty of this yourself.
On one hand you use PPRuNe as a source to enhance your "usefulness" to the Aviation Regulation Review Taskforce and seem to have absolutely no problem accepting the "usefulness" of anonymous suggestions there and on the other hand you assert that the VOR can not be of any use to Australia unless they out themselves.
It should be clear to you by now that had they wished to avail the RFDS of your qualified
largesse they would have done so by now.It is a right of PPRuNe and attempts to out a PPRuNer used to lead to banning, but you seem to have corrupted that as a principle.
Just deal with it OK.
Howard Hughes, unfortunately it is not as simple as that. I understand that John Williamson is a pseudonym, or maybe he has extra talents over being one of Australia’s top country music performers! PS: Are you really the Howard Hughes? I thought he passed away.
Sprucegoose
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I am a simple man, with simple tastes, most unlike my alter ego, that is why the situation appears plain and simple to me...
Although I must declare my close association with the aforementioned organisation, in the interest of propriety!
Although I must declare my close association with the aforementioned organisation, in the interest of propriety!
Gaunty, there is nothing inconsistent about my beliefs. I have always supported the usefulness of anonymity on PPRuNe. It is obvious that many things can be posted which otherwise would not be posted. This is healthy for debate and healthy for aviation safety.
In relation to VOR, I’m simply making the point that Australian aviation is desperate to have competent, qualified people to work on the airspace changes. I cannot find any person within the realm of airspace change who makes the rational and logical comments that VOR does. Are we forever to have an “invisible” person or group telling us the best way to go about the change, but actually not have a real person who can do this work?
As I’ve said before, it is all very mysterious to me. One day I’m sure the reason will all come out!
In relation to VOR, I’m simply making the point that Australian aviation is desperate to have competent, qualified people to work on the airspace changes. I cannot find any person within the realm of airspace change who makes the rational and logical comments that VOR does. Are we forever to have an “invisible” person or group telling us the best way to go about the change, but actually not have a real person who can do this work?
As I’ve said before, it is all very mysterious to me. One day I’m sure the reason will all come out!
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Thank you for your interest, Mr Smith. We were aware of your kind and magnanimous offer to provide a cheque for $5000 to the Royal Flying Doctor Service – however, it would take a little more than that to tempt us to remove our anonymity. As has been pointed out by other respondents on this and other threads, it is anonymity that gives PPruNe its power. Yes, sometimes there are frivolous, funny and even odd postings across the network, but at times much good is done by allowing free interchange and exchange of information that would otherwise be hidden. We think that is worth a lot more than the $5000 ‘reward’ you offered.
We would, however, encourage you, in the spirit of magnanimity, to make the donation anyway – as a sort of quid pro quo for the sometimes spirited and always entertaining interchanges between us!
Now to the more serious topic of airspace reform.
Our posting regarding the need for a free and open risk management framework contained some comments about pre-biased outcomes. In particular, the posting needs to be read in conjunction with the draft policy statement that contains specific direction about airspace changes, including continued roll-out of the National Airspace System.
We think we have been clear in the past that the changes proposed under NAS are not, in and off themselves, inherently ‘dangerous’ – what we have raised concerns about is the need to carefully manage the changeover from the current operational environment, to any new operational environment.
You often cite the ‘dirt road’ versus ‘super highway’ example. Simply putting a set of stop lights on a dirt road will have little effect – unless it is carefully educated – and the country drivers affected understand what to do when they come across that stop light (there was a tragic reminder of that, we believe, just recently in country Victoria).
But even before that, a fully deployed risk management system will allow you to determine if you even need that set of stop lights.
Simply saying that something is safe, does not make it so. Simply copying an established system, even the US system, and superimposing it on Australia does not necessarily make the Australian operating environment safer. You need to properly assess the risks associated with the whole system, including pilot and controller training and procedures, the institutional and regulatory framework (which we note that you are working on), the economic framework, and so on – and then determine which parts of the system truly need to be upgraded or changed.
We are concerned that the risk framework has been framed to facilitate the introduction of a predetermined outcome – not to truly test the risks associated with operating the current system, and to identify mitigations against those risks – which MAY include elements from your ‘proven US system’, but may, as well, include other more progressive solutions.
We are not opposed to the risk framework – we would simply like to see it cast in a more neutral posture, providing an environment within which changes can be made which will decrease risk and maximise consensus.
We would, however, encourage you, in the spirit of magnanimity, to make the donation anyway – as a sort of quid pro quo for the sometimes spirited and always entertaining interchanges between us!
Now to the more serious topic of airspace reform.
Our posting regarding the need for a free and open risk management framework contained some comments about pre-biased outcomes. In particular, the posting needs to be read in conjunction with the draft policy statement that contains specific direction about airspace changes, including continued roll-out of the National Airspace System.
We think we have been clear in the past that the changes proposed under NAS are not, in and off themselves, inherently ‘dangerous’ – what we have raised concerns about is the need to carefully manage the changeover from the current operational environment, to any new operational environment.
You often cite the ‘dirt road’ versus ‘super highway’ example. Simply putting a set of stop lights on a dirt road will have little effect – unless it is carefully educated – and the country drivers affected understand what to do when they come across that stop light (there was a tragic reminder of that, we believe, just recently in country Victoria).
But even before that, a fully deployed risk management system will allow you to determine if you even need that set of stop lights.
Simply saying that something is safe, does not make it so. Simply copying an established system, even the US system, and superimposing it on Australia does not necessarily make the Australian operating environment safer. You need to properly assess the risks associated with the whole system, including pilot and controller training and procedures, the institutional and regulatory framework (which we note that you are working on), the economic framework, and so on – and then determine which parts of the system truly need to be upgraded or changed.
We are concerned that the risk framework has been framed to facilitate the introduction of a predetermined outcome – not to truly test the risks associated with operating the current system, and to identify mitigations against those risks – which MAY include elements from your ‘proven US system’, but may, as well, include other more progressive solutions.
We are not opposed to the risk framework – we would simply like to see it cast in a more neutral posture, providing an environment within which changes can be made which will decrease risk and maximise consensus.
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Observation from the peanut gallery.
It would be far more constructive if they would at least identify themselves and set up a decent dialogue directly with Mr Smith.
I see many benefits from their words of wisdom and his ability and position to gain attention and influence.
Surely that would help.
Cheers
David Brown........yes sounds like a tractor and its not fake
It would be far more constructive if they would at least identify themselves and set up a decent dialogue directly with Mr Smith.
I see many benefits from their words of wisdom and his ability and position to gain attention and influence.
Surely that would help.
Cheers
David Brown........yes sounds like a tractor and its not fake
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Mr Smith
I'll leave the first paragraph alone for the moment.
Are you prepared to accept that the;
may actually be here in Australia under your very nose or are currently expatriate for very good reasons. ??
and;
is not as mysterious as you imagine. I don't think do at all.
Are you prepared and I mean this sincerely, to accept that they may be those who are, or have been, but are no longer prepared to engage with you directly for fear of the consequences. Surely you must realise that you have, by your actions in the past, sincerely motivated or not, shut many more doors than you have opened.
Maybe and I'm not saying they are, but maybe, the VOR are one and the very same people.
For whatever you may think of it, them and the reasons they may feel they have to be anonymous, it is clear they have and their activities demonstrate it, the efficiency and safety of Australias airspace at the forefront. They have given credit where credit is due, they have demolished puffery and wishful thinking presented as fact where necessary.
Efficient and safe airspace is your goal too, why do you think they have not associated themselves with you.
That they felt it necessary to alert the International community about the hazards they perceived in the 2C implentation, (almost an exact replay of the events surrounding 2B) says clearly, to me anyway, that the lessons of the 2b implementation so carefully pointed out by them had been simply ignored, they were not being heard internally or they were being overridden in the places they should not have been.
Some person or persons have so effectively derailed and corrupted the process that would normally have these same people leading it rather than having to influence it, that they have to resort to a respected website, whose principle driver is anonymity, they know is read by those who matter.
You have the access, surely it should not be difficult for you to find out how, who and why and to demand that the train be put firmly back on the rails.
You would have ours and their eternal gratitude should you be able to accomplish this.
I suspect they know very well who that person or persons is/are.
I suspect they understand very clearly that the absolute integrity of their reasoning and advice would not be improved by accepting the gratuitous offer of a donation to a wonderful charity by revealing themselves. IMHO your offer does none of the parties justice.
I know beyond any doubt that the very anonymity of their advice is its fundamental strength. It stands completely on its own, unassailable from any agenda, personality or political attack other than careful discussion, clear logic and fact.
I'll leave the first paragraph alone for the moment.
Are you prepared to accept that the;
competent, qualified people to work on the airspace changes
and;
I cannot find any person within the realm of airspace change who makes the rational and logical comments that VOR does.
Are you prepared and I mean this sincerely, to accept that they may be those who are, or have been, but are no longer prepared to engage with you directly for fear of the consequences. Surely you must realise that you have, by your actions in the past, sincerely motivated or not, shut many more doors than you have opened.
Maybe and I'm not saying they are, but maybe, the VOR are one and the very same people.
For whatever you may think of it, them and the reasons they may feel they have to be anonymous, it is clear they have and their activities demonstrate it, the efficiency and safety of Australias airspace at the forefront. They have given credit where credit is due, they have demolished puffery and wishful thinking presented as fact where necessary.
Efficient and safe airspace is your goal too, why do you think they have not associated themselves with you.
That they felt it necessary to alert the International community about the hazards they perceived in the 2C implentation, (almost an exact replay of the events surrounding 2B) says clearly, to me anyway, that the lessons of the 2b implementation so carefully pointed out by them had been simply ignored, they were not being heard internally or they were being overridden in the places they should not have been.
Some person or persons have so effectively derailed and corrupted the process that would normally have these same people leading it rather than having to influence it, that they have to resort to a respected website, whose principle driver is anonymity, they know is read by those who matter.
You have the access, surely it should not be difficult for you to find out how, who and why and to demand that the train be put firmly back on the rails.
You would have ours and their eternal gratitude should you be able to accomplish this.
I suspect they know very well who that person or persons is/are.
I suspect they understand very clearly that the absolute integrity of their reasoning and advice would not be improved by accepting the gratuitous offer of a donation to a wonderful charity by revealing themselves. IMHO your offer does none of the parties justice.
I know beyond any doubt that the very anonymity of their advice is its fundamental strength. It stands completely on its own, unassailable from any agenda, personality or political attack other than careful discussion, clear logic and fact.
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Allow me to apologize in advance for what will, no doubt, be a lengthy post. Reference to the number of posts I have made since my date of joining this forum should, however, be testament to the fact that my input to this place is normally minimal. This is an important topic, however. The primary reason for my low level of input is that so much of this forum seems primarily dedicated to name-calling and the hijacking of some very important issues.
It is for this reason that I cannot hold my tongue on this vital topic. I am saddened to see that the initial response to a valuable submission by VOR has degenerated into discussions of anonymity which I feel is somewhat unrelated to the core topic.
Before I continue, and in the interests of a declaration of any conflict of interest (rather than simple “big noting”), it is important that I disclose my credentials and interest in this topic. I have been involved in this dynamic industry for 30 years now and am currently an airspace user as a 747 commander for a south East Asian carrier. As an aside, I hold two aviation degrees (BAv, MSc.) which focused upon safety management, and I have been heavily involved in the LOSA program. Additionally, I am the lead Threat and Error Management instructor at my airline and I am a distance educator for RMIT in both Human Factors and Safety Management Systems. Most importantly to this topic, I retain a consultancy role as a Risk Advisor with one of Australia’s only dedicated Aviation Risk Management organizations with offices in Sydney, Asia and Washington DC.
I see two very important issues here which must remain in focus during the debate of this vital issue. They both relate to contemporary Risk Management practices. Particularly as they are applied to our industry.
Firstly, it is imperative that the definition of risk management be totally understood in any argument of this type. The Australia New Zealand Standard 4360-2004 defines risk management as “the culture, processes and structures that are directed towards the effective management of potential opportunities and adverse affects”.
The reason this definition is so important to the argument is because it highlights that the concept of risk implies both a positive and a negative paradigm, not just the negative - which is incorrectly assumed in contemporary Western society. So in defence of Mr. Dick Smith the risk of a change in the airspace arrangement in Australia brings with it the chance of great opportunity, which he has spent much time in this place attempting to explain. For this reason his views demand respect and should be encouraged to assure one half of the Risk Management process is adequately investigated.
However, before those in the “Smith camp” get too excited, the other end of the spectrum of risk defends the stance of VOR et al, who eloquently highlight the potential adverse effects of this change. This spectrum of Risk Management is of course most important to ensure the potential benefits are not the sole driver at the expense of the safety of users unaware of the potential adverse effects. This, incidentally, is the premise behind CASA’s Regulatory Policy – CEO PN001 2004 (http://www.casa.gov.au/corporat/poli...PN001-2004.pdf).
So this brings me to the second very important issue which must remain in focus during this debate. I will however rest here in the interests of not breaking the record for the longest post on this forum. Also I have just arrived in SFO and need some sleep. To be continued…
It is for this reason that I cannot hold my tongue on this vital topic. I am saddened to see that the initial response to a valuable submission by VOR has degenerated into discussions of anonymity which I feel is somewhat unrelated to the core topic.
Before I continue, and in the interests of a declaration of any conflict of interest (rather than simple “big noting”), it is important that I disclose my credentials and interest in this topic. I have been involved in this dynamic industry for 30 years now and am currently an airspace user as a 747 commander for a south East Asian carrier. As an aside, I hold two aviation degrees (BAv, MSc.) which focused upon safety management, and I have been heavily involved in the LOSA program. Additionally, I am the lead Threat and Error Management instructor at my airline and I am a distance educator for RMIT in both Human Factors and Safety Management Systems. Most importantly to this topic, I retain a consultancy role as a Risk Advisor with one of Australia’s only dedicated Aviation Risk Management organizations with offices in Sydney, Asia and Washington DC.
I see two very important issues here which must remain in focus during the debate of this vital issue. They both relate to contemporary Risk Management practices. Particularly as they are applied to our industry.
Firstly, it is imperative that the definition of risk management be totally understood in any argument of this type. The Australia New Zealand Standard 4360-2004 defines risk management as “the culture, processes and structures that are directed towards the effective management of potential opportunities and adverse affects”.
The reason this definition is so important to the argument is because it highlights that the concept of risk implies both a positive and a negative paradigm, not just the negative - which is incorrectly assumed in contemporary Western society. So in defence of Mr. Dick Smith the risk of a change in the airspace arrangement in Australia brings with it the chance of great opportunity, which he has spent much time in this place attempting to explain. For this reason his views demand respect and should be encouraged to assure one half of the Risk Management process is adequately investigated.
However, before those in the “Smith camp” get too excited, the other end of the spectrum of risk defends the stance of VOR et al, who eloquently highlight the potential adverse effects of this change. This spectrum of Risk Management is of course most important to ensure the potential benefits are not the sole driver at the expense of the safety of users unaware of the potential adverse effects. This, incidentally, is the premise behind CASA’s Regulatory Policy – CEO PN001 2004 (http://www.casa.gov.au/corporat/poli...PN001-2004.pdf).
So this brings me to the second very important issue which must remain in focus during this debate. I will however rest here in the interests of not breaking the record for the longest post on this forum. Also I have just arrived in SFO and need some sleep. To be continued…
Gaunty, you state:
No, I’m certainly not prepared to accept such a claim because it is utter rubbish. No person has ever engaged me directly and then had to fear the consequences. It is quite the opposite. I like people who engage me directly and stand by their views. In my own business they are the people I have promoted and made the most money from. During my time at CAA and CASA, they were the people I encouraged and were the most successful.
You can go on bleating this constant claim, however you will not be able to provide any evidence because it is simply not true. You can believe as long as you want that I have some type of mysterious power to affect people’s livelihoods. I don’t.
You may remember that a person made claims on this website, including the claim that she thought that I was somehow responsible for the many people who lost their jobs during the recent reform process at CASA. She retracted this statement because it was simply untrue. I had no input or involvement in any of the job changes at CASA. They had not been discussed with me directly or indirectly. In fact, a number of my good friends lost their jobs in these reforms.
I do not believe the reason that VOR remains anonymous has anything to do with the perception that I could somehow affect VOR’s future or livelihood if their name was known.
If I ever suggested to anyone in CASA, Airservices, the ATSB or the Department that someone should be demoted, removed, or not promoted I would be ignored. In fact, the most likely thing would be that the reverse of what I suggested would happen. That is why I would make no such suggestion.
You can go on forever making out that I have some type of Rasputin-like power, however it is not true. If I actually knew who VOR was (especially in relation to the comments on Class E airspace) I would be doing everything I could to make this person or people succeed. I would probably have little effect on whether this happened or not, the political process and many other circumstances would affect the result.
You can believe a myth as long as you like – it may give my ego a boost – but you would be a lot better off if your beliefs were based on fact.
Are you prepared and I mean this sincerely, to accept that there may be those who are, or have been, but are no longer prepared to engage with you directly for fear of the consequences.
You can go on bleating this constant claim, however you will not be able to provide any evidence because it is simply not true. You can believe as long as you want that I have some type of mysterious power to affect people’s livelihoods. I don’t.
You may remember that a person made claims on this website, including the claim that she thought that I was somehow responsible for the many people who lost their jobs during the recent reform process at CASA. She retracted this statement because it was simply untrue. I had no input or involvement in any of the job changes at CASA. They had not been discussed with me directly or indirectly. In fact, a number of my good friends lost their jobs in these reforms.
I do not believe the reason that VOR remains anonymous has anything to do with the perception that I could somehow affect VOR’s future or livelihood if their name was known.
If I ever suggested to anyone in CASA, Airservices, the ATSB or the Department that someone should be demoted, removed, or not promoted I would be ignored. In fact, the most likely thing would be that the reverse of what I suggested would happen. That is why I would make no such suggestion.
You can go on forever making out that I have some type of Rasputin-like power, however it is not true. If I actually knew who VOR was (especially in relation to the comments on Class E airspace) I would be doing everything I could to make this person or people succeed. I would probably have little effect on whether this happened or not, the political process and many other circumstances would affect the result.
You can believe a myth as long as you like – it may give my ego a boost – but you would be a lot better off if your beliefs were based on fact.
Last edited by Dick Smith; 19th Jun 2007 at 00:26.
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Dick,
I think I agree with VOR – but I’m no risk expert. I do think there’s a whole lot of safety areas out there that need to be looked at besides airspace. Didn’t the ATSB recently say that the average age of the GA fleet in Oz is about 25 or 30 years. If that’s an average, that means there probably some 40 or more year old GA aircraft carrying paying passengers out there – scary, no matter how good the maintenance.
Then you have this spate of accidents happening recently involving light aircraft – maybe I’m missing something – but does anyone see an increasing trend in accidents over the last year or so? It may not have anything to do with the age of the aircraft – but then again, if you look underneath it all, maybe the fact that our GA industry is in such decline, and as an industry we can’t afford to get newer aircraft, and the cost of hiring these older airplanes is so expensive, maybe we’re forcing people to fly in less regulated environments, like ultralights and so on.
And if you look at some of the recent threads, you have airlines screaming for pilots, and offering to take them on with a lot fewer hours that the old days. There’s got to be something worth looking into there.
Even Dick’s thread about changes to streamline the system is throwing up heaps of ideas, some good, some bad, that should be looked into, and which would deliver a whole lot of benefits at a lot less stress that the airspace change stuff we’ve been agonising over for nearly 20 years.
And of course my old hobby horse – who’s looking over the shoulder of the service providers. There’s heaps of safety incidents amongst controllers – and they keep saying on this forum that they’re overworked and stressed and that Airservices and Defence keep pushing for more.
Somehow I think we need to take a look at the whole picture, like VOR says. Work out where to spend the safety or productivity dollar best. After all, unlike the ‘States, we’re paying for most of the services we get – not the taxpayer.
I think I agree with VOR – but I’m no risk expert. I do think there’s a whole lot of safety areas out there that need to be looked at besides airspace. Didn’t the ATSB recently say that the average age of the GA fleet in Oz is about 25 or 30 years. If that’s an average, that means there probably some 40 or more year old GA aircraft carrying paying passengers out there – scary, no matter how good the maintenance.
Then you have this spate of accidents happening recently involving light aircraft – maybe I’m missing something – but does anyone see an increasing trend in accidents over the last year or so? It may not have anything to do with the age of the aircraft – but then again, if you look underneath it all, maybe the fact that our GA industry is in such decline, and as an industry we can’t afford to get newer aircraft, and the cost of hiring these older airplanes is so expensive, maybe we’re forcing people to fly in less regulated environments, like ultralights and so on.
And if you look at some of the recent threads, you have airlines screaming for pilots, and offering to take them on with a lot fewer hours that the old days. There’s got to be something worth looking into there.
Even Dick’s thread about changes to streamline the system is throwing up heaps of ideas, some good, some bad, that should be looked into, and which would deliver a whole lot of benefits at a lot less stress that the airspace change stuff we’ve been agonising over for nearly 20 years.
And of course my old hobby horse – who’s looking over the shoulder of the service providers. There’s heaps of safety incidents amongst controllers – and they keep saying on this forum that they’re overworked and stressed and that Airservices and Defence keep pushing for more.
Somehow I think we need to take a look at the whole picture, like VOR says. Work out where to spend the safety or productivity dollar best. After all, unlike the ‘States, we’re paying for most of the services we get – not the taxpayer.
Dick,
You said of VOR:
"You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective". (bolding added)
The contrary applies to you Dick- We know who you are and know your reputation and past conduct in this debate- Which makes you totally ineffective (or is that defective) as you have little support or respect for your views regarding airspace reform.
You said of VOR:
"You put your posting in the plural – i.e. “we”, whereas you sign off as an individual – John Williamson. You (or your group) obviously have in depth knowledge but for some strange reason you want to remain anonymous – and therefore almost completely ineffective". (bolding added)
The contrary applies to you Dick- We know who you are and know your reputation and past conduct in this debate- Which makes you totally ineffective (or is that defective) as you have little support or respect for your views regarding airspace reform.
airspace reform
Whilst I'm sure that this topic will always be an emotive issue for those who can't help themselves anyway, we would all benifit a good deal more if those who choose to reply to VOR would stick to the issue at hand an not play little games between the lines. It won't achieve anything other than aggravation.
I used to look forward to reading these discussions but I'll go away and not read this one for a few weeks, or months if need be, and when I do choose to, hopefully I will be able to get something out of it and not feel like I'm watching a Simpsons episode, one that no doubt I've seen countless times before.
Grow up kiddies and play nicely - it ain't all just about you!
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Here, Here Atlas Shrugged. I'm with you on that point! 
I'm also not going to get anymore rest on this layover so I'll continue with my previous post.... which I hope brings us back to the core of the thread.
So, following on from my previous post…..
The second very important issue which must remain in focus during this debate relates to the timing of the Risk Management process. I believe this to be at the core of VOR’s post.. Let me explain.
Traditionally our industry has tackled safety through the valiant efforts of folk using safety systems which have been primarily built upon the premise of leaning from our mistakes. This has developed into what we know as Error Management. Admirable, but flawed. The weakness in this system is that we are dealing with the past. The error has already occurred and we rely on contingency planning to reduce the consequence of the error (if it is detected) and awareness, through human factors training, to reduce the likelihood of error – somewhat unsuccessfully.
The answer to a safer system, I believe (and it seems VOR and his colleagues believe), is the implementation and integration of Risk Management into the safety management system. In this way we can influence the future not just deal with the past. The result is that the “what ifs” are considered, investigated and treated rather than waiting to act upon the “what now”. To date the closest our industry is to this, in most cases, is through the use of Threat Management. An important move forward.
So what does this add to the debate on the topic in question?
Just as VOR et al insist, the only way a process of identifying, analysing, evaluating and treating the risk of airspace change in Australia is to apply this Risk Management process BEFORE the changes are enacted. This is the only way the efficacy of the process can stand up to scrutiny and the process itself becomes fit for purpose.
Additionally, and perhaps most importantly, 40% of the time spent within the Risk Management process should be dedicated to the initial step of “Setting the Context” for the analysis. This requires continual consultation and communication with the stakeholders involved. Without this the result can simply become a plethora of motherhood statements on only some of the risks with no effective mitigation strategies emerging.
As a consequence the same respect I suggested was due to Mr. Smith et al should be afforded to VOR, Gaunty and others who’s input, as airspace users and therefore stakeholders, is mandatory. I guess this place is not always the ideal forum for this given the hijacking that takes place from time to time. I'm sure Atlas Shrugged would agree with me here!
In conclusion, should the decision to affect change be enacted and the system itself changed prior to the use of a viable Risk Management framework, simply because there is a perceived requirement to change (as VOR has pointed out), then we are destined to continue down a path of being reactive rather than proactive in the vital process of keeping our industry, and its airspace, safe.
I vote for the former.
I'm also not going to get anymore rest on this layover so I'll continue with my previous post.... which I hope brings us back to the core of the thread.
So, following on from my previous post…..
The second very important issue which must remain in focus during this debate relates to the timing of the Risk Management process. I believe this to be at the core of VOR’s post.. Let me explain.
Traditionally our industry has tackled safety through the valiant efforts of folk using safety systems which have been primarily built upon the premise of leaning from our mistakes. This has developed into what we know as Error Management. Admirable, but flawed. The weakness in this system is that we are dealing with the past. The error has already occurred and we rely on contingency planning to reduce the consequence of the error (if it is detected) and awareness, through human factors training, to reduce the likelihood of error – somewhat unsuccessfully.
The answer to a safer system, I believe (and it seems VOR and his colleagues believe), is the implementation and integration of Risk Management into the safety management system. In this way we can influence the future not just deal with the past. The result is that the “what ifs” are considered, investigated and treated rather than waiting to act upon the “what now”. To date the closest our industry is to this, in most cases, is through the use of Threat Management. An important move forward.
So what does this add to the debate on the topic in question?
Just as VOR et al insist, the only way a process of identifying, analysing, evaluating and treating the risk of airspace change in Australia is to apply this Risk Management process BEFORE the changes are enacted. This is the only way the efficacy of the process can stand up to scrutiny and the process itself becomes fit for purpose.
Additionally, and perhaps most importantly, 40% of the time spent within the Risk Management process should be dedicated to the initial step of “Setting the Context” for the analysis. This requires continual consultation and communication with the stakeholders involved. Without this the result can simply become a plethora of motherhood statements on only some of the risks with no effective mitigation strategies emerging.
As a consequence the same respect I suggested was due to Mr. Smith et al should be afforded to VOR, Gaunty and others who’s input, as airspace users and therefore stakeholders, is mandatory. I guess this place is not always the ideal forum for this given the hijacking that takes place from time to time. I'm sure Atlas Shrugged would agree with me here!
In conclusion, should the decision to affect change be enacted and the system itself changed prior to the use of a viable Risk Management framework, simply because there is a perceived requirement to change (as VOR has pointed out), then we are destined to continue down a path of being reactive rather than proactive in the vital process of keeping our industry, and its airspace, safe.
I vote for the former.
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Thread drift!
Thread title: NAS - Common Risk Management Framework
Play the ball - not the man - or a little "moderating" may be in order!
Tail Wheel
Thread title: NAS - Common Risk Management Framework
Play the ball - not the man - or a little "moderating" may be in order!
Tail Wheel
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Clive,
To a large extent we agree with your synopsis, and focus on pre-emptive action in risk management. We have no doubt that we could engage here in a substantial and meaningful discussion on the whole issue of inculcated risk management cultures.
There are many examples of organisations and industries that have realised the benefit of moving to a lead safety model rather than relying on the traditional lag analysis.
As an example in our own industry, we understand that the international airline organisation IATA has pressed this whole issue through its IOSA program, spilling membership, and refusing to re-admit member airlines unless they not only subscribe to an integrated risk and safety management system [say what you do], but also demonstrate both a commitment to that program [do what you say] – and demonstrate results [prove it].
That is what we would have liked to see in the Common Risk Management Framework – not simply a manual on how to evaluate risk and treat it – but how to inculcate a complete risk and safety management culture – not just in the regulator, not just in the service provider, but across the whole spectrum of aviation.
Once that is truly embedded, debates about changes to airspace, changes to procedures, changes to practices, can be held [mostly] without the passionate polarisation that has taken place in the past.
Our other point is that the Framework document appears to be a ‘post hoc ergo proctor hoc’ – or ‘the end justifies the means’ – salve to a predetermined policy of change. That is, the change protagonists have decided to go ahead with an agenda – and to ‘prop it up’ with a means of justifying the changes. This is a ‘circular cause and consequence’ argument, as you know doubt would agree, Clive.
As we have said previously, simply ‘saying something is so does not make it so’.
We also agree with you, Clive, when you say that a risk management framework is not just about tracking the negatives. It is about finding opportunities for system improvement - not just in areas of safety, but across the spectrum.
But coming back to the point of this thread.
We were simply alerting the readers of PPRuNe to the apparently disguised fact that processes were in train that will inevitably lead to the same endless debates that were held last year, and the year before, and the year before…..and that providing detailed comments to draft documents now might circumvent those debates.
Our intention is not to shut down talk of airspace reform. We live in a constantly evolving world, and aviation has to evolve if it is to survive. But that evolutionary path would be a lot smoother if the foundations for decision making were actually built in ‘show me’ bedrock – not in ‘trust me’ shifting sands.
Two last points to Mr Smith.
Dick, you choose to selectively quote posts that we have made to this forum, without showing the entire context – in particular a reference to comments we made about Class E airspace. We would be happy to amplify any of those comments, but this is not the appropriate thread.
We also note, Dick, that you have chosen not to respond to our request earlier in this thread that you go ahead and make the payment to the RFDS – as we understand the Australian way, it would only be the fair thing to do.
To a large extent we agree with your synopsis, and focus on pre-emptive action in risk management. We have no doubt that we could engage here in a substantial and meaningful discussion on the whole issue of inculcated risk management cultures.
There are many examples of organisations and industries that have realised the benefit of moving to a lead safety model rather than relying on the traditional lag analysis.
As an example in our own industry, we understand that the international airline organisation IATA has pressed this whole issue through its IOSA program, spilling membership, and refusing to re-admit member airlines unless they not only subscribe to an integrated risk and safety management system [say what you do], but also demonstrate both a commitment to that program [do what you say] – and demonstrate results [prove it].
That is what we would have liked to see in the Common Risk Management Framework – not simply a manual on how to evaluate risk and treat it – but how to inculcate a complete risk and safety management culture – not just in the regulator, not just in the service provider, but across the whole spectrum of aviation.
Once that is truly embedded, debates about changes to airspace, changes to procedures, changes to practices, can be held [mostly] without the passionate polarisation that has taken place in the past.
Our other point is that the Framework document appears to be a ‘post hoc ergo proctor hoc’ – or ‘the end justifies the means’ – salve to a predetermined policy of change. That is, the change protagonists have decided to go ahead with an agenda – and to ‘prop it up’ with a means of justifying the changes. This is a ‘circular cause and consequence’ argument, as you know doubt would agree, Clive.
As we have said previously, simply ‘saying something is so does not make it so’.
We also agree with you, Clive, when you say that a risk management framework is not just about tracking the negatives. It is about finding opportunities for system improvement - not just in areas of safety, but across the spectrum.
But coming back to the point of this thread.
We were simply alerting the readers of PPRuNe to the apparently disguised fact that processes were in train that will inevitably lead to the same endless debates that were held last year, and the year before, and the year before…..and that providing detailed comments to draft documents now might circumvent those debates.
Our intention is not to shut down talk of airspace reform. We live in a constantly evolving world, and aviation has to evolve if it is to survive. But that evolutionary path would be a lot smoother if the foundations for decision making were actually built in ‘show me’ bedrock – not in ‘trust me’ shifting sands.
Two last points to Mr Smith.
Dick, you choose to selectively quote posts that we have made to this forum, without showing the entire context – in particular a reference to comments we made about Class E airspace. We would be happy to amplify any of those comments, but this is not the appropriate thread.
We also note, Dick, that you have chosen not to respond to our request earlier in this thread that you go ahead and make the payment to the RFDS – as we understand the Australian way, it would only be the fair thing to do.
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Very interesting thread; combine this document (see link) http://www.dotars.gov.au/aviation/ai..._Framework.pdf with the airspace policy document (mentioned elsewhere) in the same area of the information supa highway (Dotars) and you can draw most of the elements together.
NAS is fully back on the agenda and rightly or wrongly we are going to go through substantial change again.
The problem I see is that we are here and we are going there. But where are the people there going? Why charge full steam ahead to get where noone wants to be? The European model is to have two classes of airspace by 2015; isn't that where we just came from?
There would appear to be no way to model the current risk (due to lack of imperitiveness) and thus any assessment is against the change and the change alone at each increment; but who is assessing the whole?
Class E is safer than G, Class C is safer than E etc. Is it so black and white?
Consultation is the key; but who is 'invited' to the process; are they going to be individually based (secret squirrell style) or industry wide meetings (yeh ha!, and take forever)
Is the lack of progression anything to do with a class of airspace? Can anyone resonably argue lack of financial progression because of the classes of airspace restricting their business. Well perhaps we will see that with Class E at 1200AGL; all those IFRs getting a one in one out service.
Back on topic, the risk and the framework needs to be effectively managed. The proposal must not determine the outcome; but like all change processess will anyone ask the real questions before making the changes?
Let's see whether dates and agenda's are determined before risk analysis or consultation; if they (dates and characteristics) are determined before we begin then we are behind the eight ball again.
NAS is fully back on the agenda and rightly or wrongly we are going to go through substantial change again.
The problem I see is that we are here and we are going there. But where are the people there going? Why charge full steam ahead to get where noone wants to be? The European model is to have two classes of airspace by 2015; isn't that where we just came from?
There would appear to be no way to model the current risk (due to lack of imperitiveness) and thus any assessment is against the change and the change alone at each increment; but who is assessing the whole?
Class E is safer than G, Class C is safer than E etc. Is it so black and white?
Consultation is the key; but who is 'invited' to the process; are they going to be individually based (secret squirrell style) or industry wide meetings (yeh ha!, and take forever)
Is the lack of progression anything to do with a class of airspace? Can anyone resonably argue lack of financial progression because of the classes of airspace restricting their business. Well perhaps we will see that with Class E at 1200AGL; all those IFRs getting a one in one out service.
Back on topic, the risk and the framework needs to be effectively managed. The proposal must not determine the outcome; but like all change processess will anyone ask the real questions before making the changes?
Let's see whether dates and agenda's are determined before risk analysis or consultation; if they (dates and characteristics) are determined before we begin then we are behind the eight ball again.
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Hi SM4 Pirate,
You need to very careful about making statements about the relative safety of various airspace classes. On the whole, perceptions and realities regarding the safety [or otherwise] of a particular class of airspace come from there practical and actual application around the world – not their intended application.
ICAO developed the ‘alphabet airspace system’ to address safety issues relating to increasing levels of VFR traffic – particularly in busy terminal areas – operating amongst IFR aircraft.
The intent was to create a uniform risk environment for IFR flights – that is, to ensure, to the extent possible, that IFR flights would not be subject to significantly varying levels of risk across their gate to gate operation – whilst also allowing as much flexibility as possible to allow VFR operations to continue.
The intent was that an airspace authority would determine appropriate risk tolerance levels – then put in place various levels of service, or levels of restriction, to ensure that risk was reduced to as low as reasonably practicable, and spread uniformly across the system.
Rather than have a myriad of rules, service options, or restrictions, ICAO chose to develop a set of codified airspace classifications. We have given you a more detailed synopsis of the development process in past postings – but to summarise, ICAO took the best [or worst] from several Contracting States, and initially developed a 5 tiered system [Class A to Class E] – which was later redeveloped as a 7 tier system [Class A to Class G] of airspace classification.
Unfortunately, the panel of experts that was set up by ICAO to develop this framework was prorogued before it had time to develop the guidance material for application of the airspace classification system. Draft material was, however, developed, and though it is difficult to access, we have seen the material. You may access the material through Australia’s representatives to ICAO [the papers are not available on-line - ask them to search for hard copy working papers of the ICAO Visual Flight Operations Panel 1985-1990].
The panel envisaged operation of the system like this.
A State would determine an acceptable risk level for aviation operations within its airspace. This allowed a small level of flexibility for States to set different risk targets based on their current operation – and also to allow a transition to lower risk levels over a period of time.
Based on those acceptable risk levels, States would assess the levels of risk that IFR flights would be exposed to in various phases of flight, over various sectors, and in various operating environments.
Taking into account the existing or planned infrastructure available within any particular operating environment [communications capability, surveillance capability, navigation infrastructure, air traffic service infrastructure, etc] the State would find the ‘nearest fit’ airspace classification system elements that would satisfy the risk equations.
It was recognised that some options would fit better than others, and that some elements of one classification, mixed with some elements of another classification, would be a better option [e.g., some parts of Class D, and some parts of class C – for a Class C-lite] – but States were to be encouraged to adopt a ‘whole’ classification.
The next step was to rationalise the application, so that a State didn’t have hundreds or thousands of small blocks of airspace in close proximity with different classifications.
Inevitably, this rationalisation would partially defeat the ‘uniform risk’ expectation – but the end result would be a system with ‘smooth transitions’ between risk areas – not abrupt changes.
Bear in mind that the whole classification system was about uniform risk exposure for IFR flights [in relation to other IFR flights, or in relation to an IFR – VFR conflict]. At the time, ICAO was not particularly interested in risk to VFR operations.
It should also be noted that ICAO did not factor infrastructure in the classification system – for example it did not require radar for any particular class of airspace. The presence [or otherwise] of radar was a factor in the determination of risk exposure as a precursor to choosing an airspace classification.
So, arguments that say that Class C airspace MUST be serviced by radar, or that Class C towers MUST have radar, are, to be blunt, plain wrong.
So what has this to do with the current thread?
The point that we have been trying to make through this thread, and in the past, is that a Common Risk Management Framework must have as one of its objectives an agreed tolerable level of risk – and a means by which to measure and treat such risk.
Once that agreed risk level is established [and agreed by all stakeholders], a thorough risk analysis must be conducted to determine what levels of risk exist across the country. Only then can discussions be had on ameliorating that risk.
Risk amelioration strategies may include changes to procedures or practices [including changes to airspace classifications], or changes to infrastructure – including extension of surveillance capabilities, enhanced navigation infrastructure, and so on.
This is when airspace policy statements should be made – AFTER an open analysis of risk and risk objectives.
Because of the ad-hoc way in which the ICAO airspace classification system has been introduced in Australia, and around the world, you will inevitably have areas where the levels of risk are well below target levels – simply because a lot of infrastructure and rules effort has been focused. This should not mean that this becomes the de-facto risk target. Neither does it mean that service levels should be reduced to drop to a uniform risk level – unless the cost benefit is substantial.
This is a debate that will need to take place in a truly mature consultative environment.
One of the best foundation stones to that maturity is a robust and transparent risk management framework that allows ALL of the arguments to be put, and accepts that there may be a number of ways to achieve a strategic objective. Such a framework is a guiding tool for making choices, not a pacifier for decisions already made.
You need to very careful about making statements about the relative safety of various airspace classes. On the whole, perceptions and realities regarding the safety [or otherwise] of a particular class of airspace come from there practical and actual application around the world – not their intended application.
ICAO developed the ‘alphabet airspace system’ to address safety issues relating to increasing levels of VFR traffic – particularly in busy terminal areas – operating amongst IFR aircraft.
The intent was to create a uniform risk environment for IFR flights – that is, to ensure, to the extent possible, that IFR flights would not be subject to significantly varying levels of risk across their gate to gate operation – whilst also allowing as much flexibility as possible to allow VFR operations to continue.
The intent was that an airspace authority would determine appropriate risk tolerance levels – then put in place various levels of service, or levels of restriction, to ensure that risk was reduced to as low as reasonably practicable, and spread uniformly across the system.
Rather than have a myriad of rules, service options, or restrictions, ICAO chose to develop a set of codified airspace classifications. We have given you a more detailed synopsis of the development process in past postings – but to summarise, ICAO took the best [or worst] from several Contracting States, and initially developed a 5 tiered system [Class A to Class E] – which was later redeveloped as a 7 tier system [Class A to Class G] of airspace classification.
Unfortunately, the panel of experts that was set up by ICAO to develop this framework was prorogued before it had time to develop the guidance material for application of the airspace classification system. Draft material was, however, developed, and though it is difficult to access, we have seen the material. You may access the material through Australia’s representatives to ICAO [the papers are not available on-line - ask them to search for hard copy working papers of the ICAO Visual Flight Operations Panel 1985-1990].
The panel envisaged operation of the system like this.
A State would determine an acceptable risk level for aviation operations within its airspace. This allowed a small level of flexibility for States to set different risk targets based on their current operation – and also to allow a transition to lower risk levels over a period of time.
Based on those acceptable risk levels, States would assess the levels of risk that IFR flights would be exposed to in various phases of flight, over various sectors, and in various operating environments.
Taking into account the existing or planned infrastructure available within any particular operating environment [communications capability, surveillance capability, navigation infrastructure, air traffic service infrastructure, etc] the State would find the ‘nearest fit’ airspace classification system elements that would satisfy the risk equations.
It was recognised that some options would fit better than others, and that some elements of one classification, mixed with some elements of another classification, would be a better option [e.g., some parts of Class D, and some parts of class C – for a Class C-lite] – but States were to be encouraged to adopt a ‘whole’ classification.
The next step was to rationalise the application, so that a State didn’t have hundreds or thousands of small blocks of airspace in close proximity with different classifications.
Inevitably, this rationalisation would partially defeat the ‘uniform risk’ expectation – but the end result would be a system with ‘smooth transitions’ between risk areas – not abrupt changes.
Bear in mind that the whole classification system was about uniform risk exposure for IFR flights [in relation to other IFR flights, or in relation to an IFR – VFR conflict]. At the time, ICAO was not particularly interested in risk to VFR operations.
It should also be noted that ICAO did not factor infrastructure in the classification system – for example it did not require radar for any particular class of airspace. The presence [or otherwise] of radar was a factor in the determination of risk exposure as a precursor to choosing an airspace classification.
So, arguments that say that Class C airspace MUST be serviced by radar, or that Class C towers MUST have radar, are, to be blunt, plain wrong.
So what has this to do with the current thread?
The point that we have been trying to make through this thread, and in the past, is that a Common Risk Management Framework must have as one of its objectives an agreed tolerable level of risk – and a means by which to measure and treat such risk.
Once that agreed risk level is established [and agreed by all stakeholders], a thorough risk analysis must be conducted to determine what levels of risk exist across the country. Only then can discussions be had on ameliorating that risk.
Risk amelioration strategies may include changes to procedures or practices [including changes to airspace classifications], or changes to infrastructure – including extension of surveillance capabilities, enhanced navigation infrastructure, and so on.
This is when airspace policy statements should be made – AFTER an open analysis of risk and risk objectives.
Because of the ad-hoc way in which the ICAO airspace classification system has been introduced in Australia, and around the world, you will inevitably have areas where the levels of risk are well below target levels – simply because a lot of infrastructure and rules effort has been focused. This should not mean that this becomes the de-facto risk target. Neither does it mean that service levels should be reduced to drop to a uniform risk level – unless the cost benefit is substantial.
This is a debate that will need to take place in a truly mature consultative environment.
One of the best foundation stones to that maturity is a robust and transparent risk management framework that allows ALL of the arguments to be put, and accepts that there may be a number of ways to achieve a strategic objective. Such a framework is a guiding tool for making choices, not a pacifier for decisions already made.