NAS rears its head again

[peuce]

Some interesting reading in the latest, and previous, minutes of the AIRSPACE CONSULTATIVE FORUM on 11 August 2009

Civil Aviation Safety Authority - ACF meeting papers

Some selected excerpts of Members' feedback:

...Class E is not particularly useful. It leads to a false sense of security and inefficiency....
... Don’t exclude VFR from solutions...

The latest list of ACF Members:

Civil Aviation Safety Authority - ACF membership

Why is it, that from what I hear and read, the overall majority of Airspace Users appear to frown upon Class E Airspace and the overall majority of the Bureaucracy are in favour of it?

Are we missing something, or has a form of "Corporate Stubborn Pride" taken over and the Bureaucracy are unwilling/unable to review their idealogy?

No matter what the reasons, the reality is that the Bureaucracy is tasked with making the decisions ... less there be anarchy.... and we will just have to adapt.

[peuce]

While I was in my Sunday morning reading mood, I came across some other interesting in formation. The first is an extract from the OAR's Broome Aeronautical Study Report. Sorry it's so long, but I didn't want to be selective.

http://agencysearch.australia.gov.au...casa.gov.au%2F

Incident Reports
Australian Transport Safety Bureau (ATSB) incident data for the period 1st
July 2005 to 10th November 2008 was analysed as part of this study. 151
incident reports were submitted as having occurred within 30 NM of Broome
aerodrome with no accident or serious incidents recorded. This compares to
a total of 436 accidents, 129 serious incidents, and 23,103 incident reports
received over all of Australia for the three years 2006 to 200813.
Of the 151 reported incidents, only a small proportion (12%) of these
identified failures in following published procedures and/or communicative
errors. A summary of the ATSB reports for the period are held on file by the
OAR and are available upon request. A breakdown of the incidents revealed the following:

• 11 (7%) involved failure to follow published procedures, including failure
  to broadcast and nil carriage of mandatory radio;
• 7 (5%) involved some form of non-effective radio communications:
  o Position report not made correctly,
  o Calls made but not heard by other aircraft,
  o Frequency congestion, and
  o Incorrect frequency selection;
• 65 (43%) involved bird or animal strikes; and
• 68 (45%) involved miscellaneous reports not considered within the
  scope of this report, such as engineering malfunctions or component
  failures, loading of dangerous goods, etc.

One TCAS incident was reported for the above period (ATSB 200701231 on
20th February 2007) between a Pilatus PC-12 and a Cessna 210 which was
tracking in the opposite direction to the circuit without broadcasting
intentions.

On the bare face of it, is the expense of a Tower really justified?

Silly me, I should have looked further, as I found a quote from the WA Today paper, assuming it is correct:

Broome International Airport | Control Tower

The control tower has been the centre of a concerted campaign by businessman and aviator Dick Smith over the years.
In 2003, he pushed for Broome to get its own tower and for legislative changes to allow the airport to operate it.
A year later he claimed the tower would improve safety by "at least 20 per cent... at very little cost"

My point?

It just doesn't add up !

[Dick Smith]

Could it be that they take no notice of people who never link their real name to their views and they take notice of people who do?

Just a chance.

[peuce]

Yep, you're probably right Dick, although the ACF members might have a different opinion ...

[Ex FSO GRIFFO]

GEE....THAT's a rather 'smug' response Dick.......

p.s. Did I say 'thanks' for the redundo...??

Now a serious question for you....
Will some unannounced 'bugsmasher' in E someday cause a BIG problem for an IFR acft...????

'Just a chance....'

[OZBUSDRIVER]

Could it be that they take no notice of people who never link their real name to their views and they take notice of people who do?

As opposed to those who will wish they never heard of you when they realise the pup you have been trying to sell for over two decades.

Hey, its quite possible you may have one or two ATC who agree with you...bet they will not be tasked to take responsibility for a huge swath of Class E up at BRM...without any surveillence tools other than a set of binoes and a supply of worrybeads..as well as that FAA D tower that faces the wrong way

[Robbovic]

After TFNs latest bit of retail therapy in Scandenavia, don't be surprised if binos not needed in Broome. Has to have somewhere to try out his new toy - becoming known as "ATC on a stick". That will really make E over D interesting!

[Ex FSO GRIFFO]

ATC on a stick...???

The mind boggles.

Bit more info please Robbo....if ya can...

[peuce]

I daresay such a toy has it's place .... possibly at an aerodrome which has had no human intervention ... eg Hervey Bay?

But Broome, where the CAGRO can already advise what aircraft is where on the aerodrome ... ????

Can it provide the ability to visually separate airbone?... or within, say, about 5 -10 miles? I can just see the Controller in Brisbane swizzling that camera on a stick around ... untill he gets sea sick

[Ex FSO GRIFFO]

MAYDAY......

'Holy Shat Batman...There's a seagull crapping on my lens.....'

ATC BN rings the 'groundie' at BRM..."There's a seagull shat on my lens, get some toilet paper will ya?"
Groundie... - "Bloody idiot - by the time I get back, that bloody seagull will be miles away".......

Or as happens almost every day at Broome, usually about mid-day,
BOTH windsocks are pointing at each other......Now let me see....
Which runway will I instruct the acft to approach for....

Wot's all that 'purple stuff' over there near the approach....can't HEAR the rumbles over a camera....

Ad Infinitum.................

(Old FS Lament........I can't see 'the picture' boss.....)

I know...they WOULDN'T REALLY do that ...would they???

(Just a chance....)

OVAH.....
HO HO HO HO.....HaHaHa!!! That's almost as 'good' as........E over D..Ha Ha Ha

[ARFOR]

Leadsled

That's the point, speed limits in A/C (have a think about the new D, maybe another legislative change coming up) can clearly be waived, but it is a statutory limit in E and G.
Therefor, only the pilot in command can, on legitimate safety grounds, can determine that 250 kt below 10,000 can be exceeded.

Agreed. That’s what I was saying, in so far as E climb and descent areas below A100. If it is E, 250kts is it unless the PIC has some other issue that requires higher speed. That has nothing to do with discretionary cancellation by ATC, which will not happen in E. It can in C (and should continue in Oz ICAO D)

§ 91.117 Aircraft speed.
(a) Unless otherwise authorized by the Administrator, no person may operate an aircraft below 10,000 feet MSL at an indicated airspeed of more than 250 knots (288 m.p.h.).

Ever asked yourself why? It is simply because of the possibility of un-alerted VFR in E and US D /GAAP) below A100. Thus another efficiency reason to continue operations with ICAO D and/or C.

(b) Unless otherwise authorized or required by ATC, no person may operate an aircraft at or below 2,500 feet above the surface within 4 nautical miles of the primary airport of a Class C or Class D airspace area at an indicated airspeed of more than 200 knots (230 mph.). This paragraph (b) does not apply to any operations within a Class B airspace area. Such operations shall comply with paragraph (a) of this section.

It is my understanding that the first part [Unless otherwise authorized or required by ATC] of this rule has been omitted from the proposed MoS changes. In the new ‘CASA’ Class D, 200KT IAS – at or below 2,500FT AAL within 4 NM of the primary Class D aerodrome. If traffic conditions permit, ATC may approve a pilot's request to exceed the 200 KT speed limit to a maximum limit of 250 KT unless the pilot informs ATC a higher minimum speed is an operational requirement. Another non-US NAS [or any other country] change. Did anyone at the CASA consider that they have effectively removed ATC's [and Pilots] ability to utilise best speed control [cancelling speed restrictions] to avoid holding etc?

I agree with you that there needs to be provision for aircraft commanders to operate above 250KT’s, but what about the poor ATC who has a smaller jet/fast turbo-prop aircraft in front that could easily help out with MAX from prior to ToD all the way down to well below A100 with speeds up to 310KT’s. Does he/she have to wait for the preceding aircraft pilot to ask for a waiver?
The question of course is why? Why would the CASA ‘cherry pick’ when those cherries are important tools available to ATC [use of speed control early] in the context of efficient sequencing, and minimising delays such as avoidable holding. A cynical mind might suggest that the cherry picking is to try and reduce the incentives available in ICAO D when compared with Class E. You know, a bit like the Radar C directive, cost loading CBA comparisons between C and E.

For example, "FAA D", there is no such thing. FAA D is ICAO, and by notifying a difference for VFR weather minima, FAA remains ICAO compliant.

Let’s put this in to clear perspective.
FAA Airspace rules A.I.M
http://www.faa.gov/air_traffic/publi...3/aim0302.html

Note the differences between the Services provided within Class B, Class C and then read the context of the services provided in Class D i.e. no separation provided to VFR.

The US version of 'separation' is actually what Australia describe within the 'air traffic control service' definition. Read on.
The FAA Order JO 7110.65T Air Traffic Control
http://www.faa.gov/documentLibrary/media/Order/ATC.pdf
[The US equivalent of the Australian MATS]

Note, The US does not have a separate section for Class D services!
Also, have a good look at the ‘JO definitions’ for the ‘differences’ between US and ICAO practice.

The US:-

AIR TRAFFIC CONTROL SERVICE-
(See AIR TRAFFIC CONTROL.)

AIR TRAFFIC CONTROL- A service operated by appropriate authority to promote the safe, orderly and expeditious flow of air traffic.

Then separately defines ICAO [in brackets]:-

AIR TRAFFIC CONTROL SERVICE [ICAO]- A service provided for the purpose of:
a. Preventing collisions:
1. Between aircraft; and
2. On the maneuvering area between aircraft and obstructions.
b. Expediting and maintaining an orderly flow of air traffic.

Here is how the US JO caveats ‘preventing collisions’

2-1-1. ATC SERVICE
The primary purpose of the ATC system is to prevent a collision between aircraft operating in the system and to organize and expedite the flow of traffic, and to provide support for National Security and Homeland Defense. In addition to its primary function, the ATC system has the capability to provide (with certain limitations) additional services. The ability to provide additional services is limited by many factors, such as the volume of traffic, frequency congestion, quality of radar, controller workload, higher priority duties, and the pure physical inability to scan and detect those situations that fall in this category. It is recognized that these services cannot be provided in cases in which the provision of services is precluded by the above factors. Consistent with the aforementioned conditions, controllers shall provide additional service procedures to the extent permitted by higher priority duties and other circumstances. The provision of additional services is not optional on the part of the controller, but rather is required when the work situation permits.

The US ‘interpretation’ of services and additional services varies from Australia in so far as all of the US ATS system is predicated on IFR services. VFR and IFR in VMC in all classes of airspace [except Class B] pilots are [primarily] responsible for see and avoid.
Primary collision avoidance responsibility in VMC
http://www.faa.gov/air_traffic/nas_r...m_Overview.pdf

During VMC, aircraft may operate under VFR, and the pilot is primarily responsible for seeing other aircraft and maintaining safe separation.

And;

Aircraft may elect to operate IFR in VMC; however, the pilot, and not ATC, is primarily responsible for seeing and avoiding other aircraft.

Back to The FAA A.I.M
http://www.faa.gov/air_traffic/publi...5/aim0505.html

5-5-8. See and Avoid
a. Pilot. When meteorological conditions permit, regardless of type of flight plan or whether or not under control of a radar facility, the pilot is responsible to see and avoid other traffic, terrain, or obstacles.
b. Controller.
1. Provides radar traffic information to radar identified aircraft operating outside positive control airspace on a workload permitting basis.
2. Issues safety alerts to aircraft under their control if aware the aircraft is at an altitude believed to place the aircraft in unsafe proximity to terrain, obstructions, or other aircraft.

Note the totality of the substantial differences between the base line ICAO ATC Service definition, and the FAA ATC Service definitions!.

As far as ease of reading, there are advantages to some forms of US regulation. But to say that the US Airspace system is simple to understand is just not correct. It takes some effort to draw the various requirements from various documents to get the full picture of what is required, expected and available to pilots and ATC's in the US.

Without wanting to labour the point, Australia does not have the volume of VFR traffic [with the exception of the GAAP’s] to warrant the application of FAA D [including the substantial differences in roles and responsibilities for pilots and Air Traffic Controllers].

Surely you can see the wood for the trees on this. There are so many reasons why existing Australian C or D over D is better for all concerned. Safety, costs of provision [tower verses en-route], efficiency, workload for both ATC and Pilots [IFR and VFR]. Lets not forget [as quoted earlier] the Airspace process ‘requirements’ within Australian Airspace legislation and policy.

[B] However, safety criteria must be premised on the basis of the effect on aircrew, other safety critical staff, the travelling public and the community.

The highest priority will be given to solutions which seek to eliminate the negative risk.

It is simply not fair to saddle Pilots and Air Traffic Controllers with inappropriate rulesand procedures, with incompatible ATS infrustructure, when they are not ‘necessary’!

This aspect of the changes goes to the very point of those two maxims above.

Are pilots who will fly the system, and Air Traffic Controllers and Flight Service Officers who will provide it being properly served?

One wonders!

To pick you up on a previous point regarding equity of priority.

Give priority for use of the manoeuvring area or airspace to:
a. an aircraft in a state of emergency, including being subjected to unlawful interference
b. a mutli-engined aircraft which has suffered the loss of an engine and has not been subjected to an emergency phase
c. an aircraft known to have suffered failure of radio communication
d. an aircraft that has declared itself a MERCY flight
e. an aircraft participating in Search and Rescue (SAR), Medical (MED 1), Flood or Fire Relief (FFR) flights or is operating as a Hospital Aircraft (HOSP)
f. an aircraft operating under police callsign POLAIR RED (or
FEDPOL RED) and engaged in operations where life is at risk
g. an aircraft engaged in the personal transport of:
1. Heads of State or of Government; or
2. other selected dignitaries on official visits to Australia; or
3. the personal transport of the Governor-General or the Prime
Minister.
Apply the following priorities under normal circumstances:
a. A landing aircraft, in the normal course of operation, has priority for the use of the landing area over a departing aircraft if the departing aircraft cannot take-off with the prescribed separation standard.
b. Landing and taking-off aircraft have priority for the use of the landing area over taxiing aircraft.
c. An aircraft which is first able to use the manoeuvring area or desired airspace in the normal course of operation has priority.

In Australia there is no priority delineation between IFR, VFR, Commercial or Private. The only point of difference occurs when VFR ‘pop-up’ on the edge of CTA/R with no ‘planning’ warning.

[ARFOR]

Another gentle reminder. Get those submissions in.

info_oar @ casa.gov.au [<--- take out the spaces either side of the @]

The clock is ticking!

[LeadSled]

ARFOR,

Ever asked yourself why? It is simply because of the possibility of un-alerted VFR in E and US D /GAAP) below A100.

The answer is no, because I know where the "250kt" rule came from ---- the early days of jets, when the majority of airline traffic in the US were big pistons. The limit was imposed to reduce ATC problems with the huge speed disparity between the new fangled jets and 049/749/1049/DC-4,6,7/Convair 240/340/Martin202 etc and B707/DC-8.

Please understand that the US "250 kt" rule is a statutory rule, ATC has no legal power to vary it, only the PIC on genuine safety grounds.

As for the rest of the humongous post, with all due respect, to suggest that separation and safety are not primary functions of US ATC, is playing word games with selected definitions and quotes.

The formal US position is that US D is ICAO D, with the earlier mentioned difference. CASA (rightly or wrongly) takes the same view.

Your could raise similar "differences" with ICAO by looking at other FAA legislation (the "difference" between "air commerce" and "air navigation" as in the Civil Aviation Act 1988) --- but anybody who doesn't think "safety" is right at the top of FAA priorities should read again.

Tootle pip!!

PS: The facts, as opposed to fiction, is IFR gets absolute priority over VFR --- regardless of the "nominal" position --- and the situation is getting worse, not better, in my on-the -ground (should that be In-the-air) experience.

[Capn Bloggs]

Found on the internet, written by a pommie ATC:

Class E Airspace
Class E airspace is rather a white elephant and is the least-common active classification of airspace in the UK. The reason for this is most likely a nonsensical rule included in its specification, which is that while IFR flights have to get a clearance from ATC before entering Class E airspace, VFR flights do not!

Although higher classes of airspace impose increasing requirements on the controller for keeping aircraft apart, the controller is still free to refuse entry to an aircraft that may come into conflict with others. This provision/get-out is partially absent in Class E airspace. VFR flights can come and go as they please. Thankfully, controllers only have to give IFR flights traffic information about these unruly VFR interlopers. They are only required to actually separate IFR flights from each other.

There are only three small areas of Class E airspace in the UK. The areas of other classifications number in the dozens or hundreds.

[ARFOR]

Leadsled
Apologies for the ‘humongous’ previous post, but we do need to put these theories in to ‘proper’ context rather than ramble on with a load of hot air

In contrast, you will be relieved that this post will be short and blunt.

I know 250kts in the US is a statutory rule, ATC has no legal power to vary it, only the PIC on genuine safety grounds. That is the point, why would you employ US ‘airspace’ and ‘rules’ when Australia can continue to utilise ICAO [in the same fashion it has for years], and classifications D through A where speed limits are not necessary.

to suggest that separation and safety are not primary functions of US ATC, is playing word games with selected definitions and quotes.

I suggested no such thing. Read the rules, and understand why the US have those rules, i.e. VFR densities in VMC.

but anybody who doesn't think "safety" is right at the top of FAA priorities should read again.

See previous. No one is saying safety is not top of priorities for FAA. The difference is how they manage that safety, and why. Read the legislation.

Re: Priorities

The facts, as opposed to fiction, is IFR gets absolute priority over VFR --- regardless of the "nominal" position

No, IFR are known about well before they enter a specific volume of airspace:-
- Flight plan
- Point to point ATC SAR co-ordination

Most VFR are not until they call approaching the CTA/R steps.

and the situation is getting worse, not better, in my on-the -ground (should that be In-the-air) experience.

Given the way this discussion has progressed, of course you are going to try that on, otherwise you would have nothing at all to say!

[Capn Bloggs]

Leadsled,

The answer is no, because I know where the "250kt" rule came from ---- the early days of jets, when the majority of airline traffic in the US were big pistons. The limit was imposed to reduce ATC problems with the huge speed disparity between the new fangled jets and 049/749/1049/DC-4,6,7/Convair 240/340/Martin202 etc and B707/DC-8.

Wrong. It was exactly as ARFOR suggested: introduced by the FAA to help See and Avoid after the midair between DC-9 N1063T and a Beech Baron at 4500ft.

Mixing jets and bugsmashers, relying on See and Avoid is just plain DUMB.

[KittyKatKaper]

warning: thread drift

For a long time I thought that the 250kt limit below A100 was due to problems that old radar-heads had in resolving targets above around that speed.
However the hazards of shortened conflict-resolution times and bird strikes below A100 are also valid. (damage is proportional to kinetic energy, which equals mass times velocity squared) (old thread Origin of the 250 knots below 10,000 ft rule [Archive] - PPRuNe Forums)

I suspect that the original reason has been lost in the mists of time, but why? would anyone wants lots of high-speed traffic in a terminal (sic) zone ? shudder

[werbil]

I've had one classic experience of the priority of IFR over VFR. On a 12 minute sector (VFR charter) I was held for just under 20 minutes so that two IFR jets could land even though I was the first aircraft to enter the zone and there was no other conflicting traffic. I watched both of them land whilst being held in the left base position as they completed visual right circuits - I must admit it is was quite enjoyable watching the approaches and landings from that position.

So why such a long hold for just two jets to land - there is no parallel taxiway so they both had to go to the end of the runway, turn and taxi back to the beginning of the runway to exit. The controller was relatively new to the tower. IMO there was plenty of time to land before the first jet or in between the first and second without delaying either jet as I would have been able to exit on one of the taxiways without backtracking. I doubt that ATC would have appreciated the effect on profitability for my company for that sector as a result of the holding.

[Hornet306]

For all you below A100 speed hoons

Just to remind you what else you can hit that's not controlled or self announcing, have a read of this: http://www.atsb.gov.au/publications/...601590_001.pdf
NB Aircraft design limits.

[divingduck]

Werbil

Do they still have the old chestnut "significant economic benefit" to more than one following aircraft in the docs in OZ?

That could explain why you were moved for two a/c...