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Congratulations to the RAAA – TCAS cost savings

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Congratulations to the RAAA – TCAS cost savings

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Old 18th Oct 2007, 08:58
  #41 (permalink)  
 
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vans said
It is my understanding that there should be no unknown aircraft in E airspace in a radar environment because all aircraft in E must be transponder equipped. In a non radar E airspace environment there also would be no unknown aircraft to an IFR aircraft if the IFR was equipped with TCAS.
I've already said twice here that mandatory fitment of transponder is NOT repeat NOT required for all aircraft types in class E:

http://www.pprune.org/forums/showpos...4&postcount=11

and

http://www.pprune.org/forums/showpos...53&postcount=4
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Old 18th Oct 2007, 09:59
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CaptainMidnight

Yes, thanks for that, technically you are correct. But in reality, what exactly in terms of risk are you worried about with your exemption list?

Quote “From the exemptions list, in addition to gliders these sports aviation types include hang-gliders, some types of ultralights, trikes and gyrocopters. I have no idea, but the number of these in the country might equal the number of light aircraft.”

Without postulating about the future, the lowest level of E airspace in Australia at the moment is 8500 ft., including that at Albury. I don’t know of too many aircraft in the above list without a proper engine-driven electrical system that would have the ability to cruise above 8500 ft, save gliders, let alone those pilots who would deliberately attempt it in E airspace in such aircraft. This is not to say that none are capable or that none would attempt it, but I think most reasonable people would conclude that a high degree of safety does in fact exist in E airspace because of the mandatory fitment of transponders in all aircraft with engine driven electrical systems capable of powering a transponder, despite the exempted list.

Notwithstanding the above, if your argument is solely about the correctness of the mandatory transponder statement and nothing else, then I will concede your point.
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Old 18th Oct 2007, 22:33
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Mr VANS,

We were specifically discussing a Class E approach service at Ballina ... not 8500ft.

Also, if you exam the traffic mix types around Ballina, I think you would be in a for a bit of a surprise.
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Old 19th Oct 2007, 02:39
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E Approach service at Ballina

With regard to a potential class E approach service at Ballina, there is already a provision in the AIP for an aircraft in Class E airspace (and class D) upon request and if so prescribed by the ATS authority, to be cleared without separation being provided in respect of a specific portion of the flight conducted in VMC. AIP Gen 3.3 (1.5) refers. It may have the potential to allow you to arrange your own separation in class E once in VMC, and particularly in the areas that you are concerned about in regard to unannounced VFR traffic, just as you would do in class G in similar circumstances. In the meantime, you may have the added protection of being kept fully aware of other IFR aircraft, because you are still theoretically in Class E airspace. Add a TCAS to your aircraft to further mitigate potential risk and you are considerably better off than in class G at the same place, at least whilst in cloud. Might work – I don’t know……over to you.
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Old 19th Oct 2007, 04:22
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TCAS

Hmmm. Where'd Dick go?
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Old 19th Oct 2007, 08:17
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vans

Hang gliders operate up to A100 regularly, particularly in Victoria. One was observed within CTA (incident a few months ago NE of Adelaide), and if you operate up to A100 in NE Victoria you can expect to be in the same airspace. The terrain height being up to 7200FT means one flying at A100 is not unreasonable.

The points I'm making & reinforcing are
  • mandatory fitment of a transponder is not required for all aircraft types to operate in class E, therefore various parties claiming that within E all traffic is known is incorrect, and
  • the liklihood of encountering such non-transponder equipped unknown traffic will increase significantly if & when class E is extended down to 700FT AGL/SFC at aerodromes.
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Old 19th Oct 2007, 11:21
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Spaz,

Hmmm. Where'd Dick go?
Maybe he is off flying somewhere not quite as anal as Australia.

Werbil
What is the big deal with class E airspace?
You really don't understand, do you. You can't argue your perfectly correct factual logic like the rest of your post, you really can't let facts spoil a good story.

Take a leaf out of Midnight's "The E of Doom" (with apologies to the author of the Eye of Doom)

The points I'm making & reinforcing are
* mandatory fitment of a transponder is not required for all aircraft types to operate in class E, therefore various parties claiming that within E all traffic is known is incorrect, and
* the liklihood of encountering such non-transponder equipped unknown traffic will increase significantly if & when class E is extended down to 700FT AGL/SFC at aerodromes.
Now, Werbil, as you and I know, that traffic is already there, but much of it doesn't have to have a transponder, because it's G (the ones wot 'ave a generator with a min. 5 watt output) but now in E they will have to have a transponder, and Midnight will suddenly know about them (provided he is not flying a little Regional -- which Australia has exempted from having a TCAS --- unlike ICAO/most of the rest of the world -- )

And what was G suddenly becomes more dangerous as E because you now have some information on traffic that you didn't have when it was G --- an unknown unknown has suddenly become a known unknown.

Peuce, what a wonderful example of "a little knowledge is dangerous.
----in the U.S. IFRs are separated in G Airspace.
Legally, no they are not, and there is no such thing as a "clearance" in G --- if you are in court ---- but who would knock back the help of the radar man just because you have slipped through a line on the map --- unlike here ---- "leaving controlled airspace - radar services terminated -- clear to leave this frequency" ---- or words to that effect.
You do know, do you, that in most of the lower 48, E comes down to 1200 or 750 AGL --- except in Alaska and the mountain regions G is a bit hard to find.

Maybe Dick has to get away every now and again for his sanity.

Tootle pip!!

PS: Gaunty, wakey wakey, time for an update, old chap!! ---- RAAA has been the Regional AVIATION Association of Australia for years, "Airline" got dropped not long after ANSETT became a footnote in Australian aviation history, if my memory serves me correctly. Many of your mates in the WA FIFO business are the backbone of the RAAA, and guess what, at least one is removing a couple of seats from a Dash 8, to bring it under 30 seats, to take advantage of the Australian ICAO non-compliance on (non) fitting TCAS I.

Obviously this operator does not regard a TCAS as affordable safety.
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Old 19th Oct 2007, 22:40
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Leadsled,

To quote from the Broome Airport Study, which is linked to in another thread:

The report by
Captain Beville-Anderson (2003, A Study of Airspace and Procedures in the
US NAS, Australian Federation of Air Pilots. Feb–Mar 2003) reported on an
interview with the FAA in which:

Mr Reggie Matthews, Manager Airspace and Rules Division, who is the FAA
executive with policy authority to make an interpretation on ATC regulations,
stated that FAA policy requires IFR aircraft in Class G airspace to operate on a
clearance. This policy is not documented, however Mr Matthews advised that
it is current custom and practice, both for industry and FAA, to function in this manner, and that if an interpretation was required it would come to him for decision.


and in another part of the same interview:

The FAA acknowledged that they are providing a de-facto Class E service to
IFR aircraft in Class G, and they have no intention to change.




My point is that ... all is not what it seems.
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Old 19th Oct 2007, 23:42
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Peuce,

Thank you for that, probably unknowingly, you have supported EXACTLY what I said:

FAA policy requires IFR aircraft in Class G airspace to operate on a
clearance. This policy is not documented, -------
Quite so. It is not the law.

This policy is not documented, however Mr Matthews advised that
it is current custom and practice, both for industry and FAA,-----
Quite so --- not even documented ----- " yer 'onour, this 'ere pilot broke a law wot we don't 'ave, but we rekon we should 'ave, please bang 'im in the pokie".

The FAA acknowledged that they are providing a de-facto Class E service to IFR aircraft in Class G, and they have no intention to change.
Quite so --- defacto --- practice and custom, and it works very well, too, even though it has no legal basis ---- but any such "clearance" is not enforceable at law ---- because the law does not exist.

This is a good example of why the US system works so well, as it does, common sense and cooperation, instead of rigid adherence to rigidly defined and documented ad infinitum as nauseum "rules".

American "can do" versus Australian "can't do".

I am well aware of Toaster's visit to US, for the AFAP, and report, it's in my library ---- in my opinion so typical of many by people over the years, they find the US system works really well ---- but all know "it wouldn't work here". The one that really gets me is "the culture is different" ---- and the really professionally insulting claim that Australian pilots can only work in a "culture" of detailed, prescriptive and rigid "rules".

Who was it said:" When I hear culture, I reach for my gun".

Amazing how easily and seamlessly Australian pilots adapt the the US "culture" when they are flying in the US and marvel at what a friendly, flexible and common sense system it is !!

One of the recent statements made by a "representative" not entirely un-adjacent to the AFAP, has been the claim that "see and avoid" can't work in Australia ---because "Australian pilots don't have a culture of looking out the window" . Hence the undocumented and highly suspect "pilot to pilot do it yourself ATC" that has grown up in Australia in lass G.

Even more reason why we should follow the same TCAS rules as the rest of the world.

Tootle pip!!
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Old 20th Oct 2007, 00:46
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Leadsled,
Try looking at it from the point of view of us dumb aussies who haven't flown in the U.S.
It turns out that the yanks are providing a dodgy brothers control service in uncontrolled airspace ... because their "official" system obviously doesn't work.
Now you guys are telling us that we must be more flexible and take on a dodgy system ... as our official sytem. That is, we should fly into a bit of airspace and, depending on the mood, workload and interest of the controller at the time, we'll either get a traffic service, a separation service or, perhaps, no service.
The yanks HAVE to do that ...because their system is saturated and close to busted.
We don't.
I still feel that we are intelligent enough to produce a workable "official" system ... even if we have to begrudgingly revert to simplicity and go back to Controlled and Uncontrolled Airspace, with AFIZs at the Ballinas and Broomes. ...

Last edited by peuce; 20th Oct 2007 at 02:16.
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Old 20th Oct 2007, 04:46
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No no no. If it is the way it is done and expected, it may as well be law. Exactly the reason why a work to rule is illegal industrially. You are expected to do what is expected of you even if it is not the rule.
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Old 20th Oct 2007, 06:34
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Peuce,

Get yourself a diagram of US airspace, and see how little G airspace exists, except in Alaska.

To slightly oversimplify, in the "lower 48", all airspace above 1200' AGL (750' where there is an instrument approach) is Class E to the base of A. Far and away the great volume of airspace below the high level A is E.

Class B is confined to the major HCRPT hubs, generally topping out at 10,000, the lateral extent of the B "inverted wedding cake" is quite small, compared the steps into any towered airport here, whether C or D. C is generally a simple zone around airports that rate it, D similar but smaller and usually but not only GA/Commuter airfields.

Part of Toaster's problem with the AFAP report referred to was the problem of "divided by a common language", and questions asked in Australian were heard/interpreted in US, the US answers were translated into Australian, to the yank, his or her bum is a very different thing to your bum. To Toaster's distress, his interviewees didn't understand his continual queries about "mandatory" procedures.

Nobody denies the huge problems of ATC in the US, but they are problems of success, and the growth of traffic volumes around the major hubs, and the economic cost problems for airlines through these major hubs. FAA is not without serious management problems, but that's hardly unknown in CNS/ATM or CASA here, is it? As recently admitted in Congressional hearing in Washington by the ATA, the two biggest causes of airline delays are lack of real estate --concrete, and airline scheduling, followed by weather disrupting schedules.

None of this has much impact on other than the major hubs, and the long suffering pax, for the bulk of other than HCRPT the system is far from broke.

On this occasion I agree with Tobzalp, where an aircraft receiving an ATC "E" service (and it will only be in the vicinity of an airfield -otherwise it wouldn't be likely to be below 1200/750 AGL, except in an emergency) and it goes into G, there is nothing unlawful about continuing the service --- whereas, under Australian law, it is not really clear-cut. However, I think it is probable that the legal history here would support the US practice.

I recall coming into YSSY one evening, on right base for 34L, at 1500'. As we crossed the centreline headed for Stanwell Tops, I waited a few minutes then something along the lines of:
"Approach, PX-XXX, Abeam Coalcliff, maintaining 1500, leaving controlled airspace, advise frequency", there was no reluctance to getting us back to where we should have been, ie; continuing the service in G.

All that remarks along the lines of "---revert to simplicity and go back to Controlled and Uncontrolled Airspace, with AFIZs at the Ballinas and Broomes. ..." prove is that the ICAO risk management approach to provision of CNS/ATM services services has never taken root here, despite the acceptance of a risk management approach to "safety" in Australian industry generally. This reluctance to use hard numbers, and prefer untested and highly coloured assertions, is well in evidence in the various papers that are the basis of the JCP, ASTRA / ABIT etc.

The airline industry here simply cannot afford the cost of services that provide no measurable benefit, and providing CNS/ATM services beyond that necessary to achieve separation assurance standards is waste, but waste that has to be paid for ---- or if you prefer, unaffordable safety --- because it is no additional risk mitigation for the cost.

As a pilot, in the clashes between the "pilots" and the beancounters, only on rare occasions would I not back the beancounters, that way the company is more likely to survive and hopefully prosper --- they don't have the emotional involvement that makes formal risk assessment so difficult for pilots.

If anybody has any doubts about emotional involvement colouring views on air safety, have a look at the Flight Safety Foundation paper of about March 2003,( give or take a year and a month) about Australia's air safety record (such as it is).

Having said that, I must make it clear that I support TCAS as per FAA/ICAO, and it is here, now, with STCs for every relevant aircraft on the Australian register, at known costs, unlike ADS-B IN, which is only going to be another input to TCAS for HCRPT anyway ---- for the foreseeable future.

Tootle pip!!
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Old 20th Oct 2007, 07:09
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Sorry, I'm a bit thick. I still don't get what you want Australia to adopt.

Granted, the U.S. (except Alaska) has minimal G Airspace ... and they separate inside it. We have a ****load of G Airspace ... do you want us to separate in it? Or only near the edges? Or, only when "appropriate"?

Considering some of the current coronial and air safety investigations going on ... which are delving into every word and punctuation mark of the documents ... I don't think ASA is brave enough to say "go for it boys ...you decide when to separate". Equally, I don't believe that Australian Controllers are willing to put their peckers on the chopping block.

The obvious solution is to replace all G Airspace with E Airspace, everyone who can ... get a transponder, RPTs get a TCAS.

Then we start running into surveillance problems, procedural separation, delays... Back to square 1
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Old 20th Oct 2007, 08:07
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Peuce,

This thread started out discussing why Australia doesn't require some aircraft, such as the SAAB340, to have TCAS, why Australia does not conform to ICAO requirements, and many of us think it would be justified for Australia to catch up with the rest of the world.

At least one pilot union and the RAAA have been demanding all aircraft, or all aircraft around a CTAF(R) have a Mode A/C transponder ---- but what's the point if at least one aircraft does not have TCAS.

Tootle pip!!
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Old 21st Oct 2007, 05:05
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Thumbs up

Ed Zackery LeadSled!

I was based in the US some years back for 6 months and experienced flying in all levels of their airspace up to FL490. There was no TCAS fitted to the aircraft I was in at the time, so I was probably blissfully unaware of what I didn’t know, but I do know that their system worked extremely smoothly and nothing was too much trouble for the US controllers. Surely there is someone here (Leadsled?) who can enlighten us to exactly how the US controllers handle separation of IFR traffic in E airspace when there may be non-transpondered hang gliders floating around at A100, (CaptainMidnight). There is no doubt that they do handle it, and handle it well. However, in Australia the main objection to the application of more E airspace, particularly potential E approach services to the lower levels (Ballina) seems to be that of the very possibility of having a close encounter with this non-transpondered traffic whilst being vectored to avoid other IFR traffic. How exactly is it done and why is it that we cannot do the same? C’mon Dick put your head back in here and explain please. I’m sure those who object to E would find it difficult to continue their arguments in the face of a reasonable and workable explanation to the fear they have of E being an unacceptable risk, particularly in the lower levels.

There is some level of thread drift in this discussion though!
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Old 21st Oct 2007, 10:56
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Just on the Ballina bit:

I go in and out of Ballina/Lismore frequently. SSR coverage doesn't begin until about 1300', so the "Class E" controller couldn't "see" circuit traffic anyway (there's ab initio GA & RAA training at YBNA). I can't see any safety advantage in keeping incoming IFR traffic on a different frequency to the CTAF circuit traffic until they're about in the circuit - unless the YBNA Class E FRQ will be the same as the frequency used in the circuit....and I don't think ATC want to hear all the circuit calls....

On a practical basis, CTAF-R here works - the lighties and RAA keep out of the way of the RPT and the IFR guys 'n' gals know each other's there (either from the preceding ATC or from their CTAF BCST) and keep out of each other's way, so why is class E needed? The only real IFR "overlaps" in crappy wx are between the GNSS RNAV approaches for YBNA RWY 06 & YLIS RWAYs 15/33.
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Old 22nd Oct 2007, 08:02
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A) YMMM/YBBB C4610/07 (SPA) 10152335
B) 0711171824 C) 0711240914
D) HJ
E) HANG GLIDER CROSS COUNTRY COMPETITION 40 HANG GLIDERS OPR WI 110NM OF GULGONG POSN 3218S 14934S (12NM N OF MUDGEE)
SFC TO F130
110NM radius takes in a bit of territory, and its Class E base 8500 immediately to the east of MDG.

And we regularly see NOTAMs re gliders operating in G & E up to FL245 (the base of Class A), nil transponder and normally not talking to ATC.

I would also be interested to find out if nil transponder gliders, hang gliders, gyrocopters etc. etc. can operate in class E in the U.S., particularly where it is down to SFC.
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Old 22nd Oct 2007, 09:08
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Midnight,

Why not have a look at the FAA AIM, it's all on the web, and convince yourself that what I am about to say is correct.

Except for the 30nm transponder veil centred on the airports justifying Class B airspace, there is no transponder requirement for ANY VFR in E, below 10,000 ft.

There are some variations to this for active TSRA ---- but this is Homeland Security stuff, not generally permanent, and not FAA, whose general "rule" is above.

The ADS-B NPRM makes more or less the same provisions.

Tootle pip!!
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Old 22nd Oct 2007, 09:33
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So LeadSled, are we to presume then that in the US “E” airspace we have all types of IFR traffic being vectored to avoid collisions with each other amongst a possible army of unknown non-transponder traffic below 10,000ft?

You guys have never had it so good in Australian “E” – what are you worried about???????????
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Old 22nd Oct 2007, 09:35
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Midnight,
To save you the trouble of looking, from the current AIM.
--------------------------------------------------------------------------
The Class B veil.
Mode C Veil. The airspace within 30 nautical miles of an airport listed in Appendix D, Section 1 of 14 CFR Part 91 (generally primary airports within Class B airspace areas), from the surface upward to 10,000 feet MSL. Unless otherwise authorized by ATC, aircraft operating within this airspace must be equipped with automatic pressure altitude reporting equipment having Mode C capability.

However, an aircraft that was not originally certificated with an engine-driven electrical system or which has not subsequently been certified with a system installed may conduct operations within a Mode C veil provided the aircraft remains outside Class A, B or C airspace; and below the altitude of the ceiling of a Class B or Class C airspace area designated for an airport or 10,000 feet MSL, whichever is lower.


3-2-6. Class E Airspace

a. Definition. Generally, if the airspace is not Class A, Class B, Class C, or Class D, and it is controlled airspace, it is Class E airspace.

b. Operating Rules and Pilot/Equipment Requirements:

1. Pilot Certification. No specific certification required.

2. Equipment. No specific equipment required by the airspace.

3. Arrival or Through Flight Entry Requirements. No specific requirements.

c. Charts. Class E airspace below 14,500 feet MSL is charted on Sectional, Terminal, and IFR Enroute Low Altitude charts.

d. Vertical limits. Except for 18,000 feet MSL, Class E airspace has no defined vertical limit but rather it extends upward from either the surface or a designated altitude to the overlying or adjacent controlled airspace.

e. Types of Class E Airspace:

1. Surface area designated for an airport. When designated as a surface area for an airport, the airspace will be configured to contain all instrument procedures.

2. Extension to a surface area. There are Class E airspace areas that serve as extensions to Class B, Class C, and Class D surface areas designated for an airport. Such airspace provides controlled airspace to contain standard instrument approach procedures without imposing a communications requirement on pilots operating under VFR.

3. Airspace used for transition. There are Class E airspace areas beginning at either 700 or 1,200 feet AGL used to transition to/from the terminal or en route environment.

4. En Route Domestic Areas. There are Class E airspace areas that extend upward from a specified altitude and are en route domestic airspace areas that provide controlled airspace in those areas where there is a requirement to provide IFR en route ATC services but the Federal airway system is inadequate.

5. Federal Airways. The Federal airways are Class E airspace areas and, unless otherwise specified, extend upward from 1,200 feet to, but not including, 18,000 feet MSL. The colored airways are green, red, amber, and blue. The VOR airways are classified as Domestic, Alaskan, and Hawaiian.

6. Offshore Airspace Areas. There are Class E airspace areas that extend upward from a specified altitude to, but not including, 18,000 feet MSL and are designated as offshore airspace areas. These areas provide controlled airspace beyond 12 miles from the coast of the U.S. in those areas where there is a requirement to provide IFR en route ATC services and within which the U.S. is applying domestic procedures.

7. Unless designated at a lower altitude, Class E airspace begins at 14,500 feet MSL to, but not including, 18,000 feet MSL overlying: the 48 contiguous States including the waters within 12 miles from the coast of the 48 contiguous States; the District of Columbia; Alaska, including the waters within 12 miles from the coast of Alaska, and that airspace above FL 600; excluding the Alaska peninsula west of long. 160°00'00''W, and the airspace below 1,500 feet above the surface of the earth unless specifically so designated.

f. Separation for VFR Aircraft. No separation services are provided to VFR aircraft.

--------------------------------------------------------------------------
And it all works just fine, as long as your not a passenger caught up in delays around the 12 Class B airports. Then it's hell.

And more concrete is the biggest part of the answer to the delays. In Sydney we have water problems, population has trebled since the last dam was built, as far as I can recall, the new Denver is the only new major airport in 30 or so years, and I have no idea how many times movements have multiplied since than, it more than treble, much more.

Tootle pip!!
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