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NAS rears its head again

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Old 22nd Apr 2010, 04:35
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DNS

That may well be true, however believe me when I say that some political forces and face saving tactics may ensure this gets a go at BME & KTA.

As sad as it is, thats how these things happen. A bit like house insulation scheme's, water tank rebate scheme's and solar power........it sounds great and dandy, warm and fuzzy, but when some common sense gets applied its too late and its march on regardless, can't turn back now!

SQ
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Old 22nd Apr 2010, 04:37
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Dick
I dare the Class E doubters to answer this particular post in an objective way.
With all due respect, do you think it might be fair to all the folk who have asked you direct and fair questions to answer theirs first?

I am sure this would gain you the respectful answers you are seeking also.

Cheerio

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Old 22nd Apr 2010, 05:40
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LeadSled
by definition of the design principles, once the separation assurance standard is achieved, higher classes of airspace will not achieve a real reduction in risk, because the separation assurance standard is already so high. Whether you agree or not is immaterial, that is no more than your personal opinion.
ICAO Doc 9689 Chapters 5 and 6
5.2
Comparison with a reference system is a “relative” method, i.e. all the relevant characteristics of a reference system are compared with the corresponding characteristics of a reference system which has been judged to be safe. Provided that the proposed system can be demonstrated to be similar to or better than the reference system in all safety related aspects, then it also may be assumed to be safe. Clearly, the most important aspect of this approach lies in the identification of a suitable reference airspace which, for minor changes, may include the current system and the demonstration that the proposed system is sufficiently similar to justify the approach.

6.3 Whatever reference system is chosen, it must bear a sufficiently close resemblance to the proposed system for any comparison with regard to safety to be valid. The levels of air traffic service provided in the reference and proposed airspace, as defined by the ICAO airspace classifications, should be examined. The air traffic service in the proposed system should provide at least the same level of service as the reference system.
- Tower frequencies and operating positions?
- Approach and Departures frequencies and operating positions?
- Surveillance?
6.4 The minimum requirements for a reference system to be considered sufficiently similar to a proposed system are:
a) separation minima must not be less in the proposed system than in the reference system;
b) proposed means of communication and surveillance must be no worse in terms of accuracy, reliability, integrity and availability than those of the reference system;
c) frequency and duration of the application of minimum separation between aircraft must not be greater in the proposed system than in the reference system; and
d) navigation performance 9typical and non-typical) of the population of aircraft in the proposed system should be no worse in it effect on collision risk, in any dimension, than that of the aircraft in the reference system.
The previous comparisons in this thread of the US and Australian systems completely eliminates this option as a valid comparison.
Risk reduction measures
6.24 Risk reduction measures should be used when the overall risk estimate is above the predetermined threshold and when a particular element of the system is found to have a disproportionate influence on the risk, providing this can be achieved at an acceptable cost. The detailed process of risk reduction procedures by allowing the effect of changes to the various system parameters to e directly assessed.
Appendix 10 of ICAO Doc 9689 refers to the Australian Risk assessment processes.

Where are the risk assessments for YWLM, YMAV, YPKA and YBRM??

I would caution you LeadSled against quoting risk probabilities in this thread that are not reflected in the Australian and ICAO documents.
Indeed, several orders of magnitude higher ( lesser risk) than losing a complete aircraft on an auto-couples Cat II/III approach
Precision approach navigation, both ground based installations, calibration and airborne equipment installation, certification, and training is a COMPLETELY different ball park in so far as treatment of risk [IMC to very low, and avoiding meeting terrain in the wrong location] compared to airspace services risk assessment [MAC and NMAC mitigation].

ICAO Doc’s 9906 Vol 1 thru 3 set out in clear and concise term the Procedures Design and QA requirements [due the criticality of those operations close to the surface].
The risk treatments are completely different for obvious reasons, and moreover of no relevance to this discussion. Your arguments are approaching ‘the ridiculous’ when you have nothing left but to attempt to be ‘relevant’ by comparing ‘irrelevant’ structures in place to facilitate poor weather continuation of IFR flight with that of ATS and airspace services.

Seeing as you raised it, let’s explore the differences:-
or the probability of an aircraft CFIT (without regard to GPWS) during an approach (or departure) designed to current PANS/OPS standards ---- all the above have had a core element of risk management built in for many, many years.
Correct.

Procedure design and operation [ICAO Doc’s 8071, 9137, 9157, 9184]

- Expert designers, draft
- Expert Calibration pilots test fly [in VMC of course] to check accuracy and veracity
- Approach plates promulgated, procedure commissioned
- Real time ground monitoring of NAVAID signal accuracy and serviceability
- Real time redundant power supplies [Mains, Battery, and autostart GENSET’s]
- Regular [interval dependant on criticality] flight testing calibration [in VMC]
- Real time airborne monitoring of ‘correct’ NAVAID selection
- Real time airborne monitoring of signal serviceability [flags]

All of those ‘mitigations’ enable FULL AWARENESS AT ALL TIMES of the safe useability of the procedure and therefore safe flight to close proximities with the surface, surveyed as per PANS/OPS for obstacle clearances.

Airspace design risk assessment and operation

- See PPRuNe – NAS raises it head again thread
- See ICAO Doc’s 4444, 7030, 9426, 9643, 9689, 9859, 9882, 9924, 9925, 9931 and others
- See The Act, The AAPS, The CRMF
- See the publically available volume specific Cost and Safety benefit Studies comparing Class E over D, D over D, and C over D

Red Flag – Nil Available for YWLM [RAAF N/A], YMAV, YBRM, YPKA

- See the publically available volume specific Risk Assessments comparing Class E over D, D over D, and C over D

Red Flag – Nil Available for YWLM [RAAF N/A], YMAV, YBRM, YPKA
Clearly, I am quite happy to accept the ICAO approach to risk management.
Fabulous, let’s remember that whilst we read on:-
That the basics of ICAO airspace design is not accepted by a range of pilots and ATC individuals in Australia says more about Australian aviation attitudes to modern risk management, than it says about the veracity of the basic ICAO risk management standards.
ICAO airspace design and procedure to validate is EXACTLY what pilots and air traffic controllers in Australia are demanding. It is unacceptable for you to continually misrepresent the discomfort being expressed by them. It is clear that it is not only not only being expressed by commercial aircrew and air traffic controllers, but also representatives of and individuals from within the general aviation sector. That in my book is pretty close to a full house. Does a pair of low spades then win the hand? You keep suggesting on this thread that the answer is yes, and solely because the ’slight of hand’ by the dealer at ‘Skull Casino’ is all that counts! WRONG!

Too many people have been duded for too many years to fall for that card trick anymore!
Strangely, pilots don't complain about the hazard levels in instrument procedure design, but the inherent hazards and the mitigators employed to reduce the final risk, still leave a level of risk that is not ALARP, as most of you interpret ALARP.
Strangely, as explained above, that is a load of cougar pellets. You continue to avoid the critical word within A.L.A.R.P, and that word is Reasonably. Pilots don’t complain about hazard levels in instrument procedure because the hazards are a mitigated to a point where it requires a series errors for the instrument approach flown to fail unsafe resulting in a hull loss. By contrast, as is demonstrated with regular monotony in Class E [in various countries], it does not require an error or chain of errors to fail unsafe. It is inherently less safe that D, C, B and A in ‘normal’ operation.

The fact that the fail unsafe opportunity is reduced dramatically by having VFR operating within ‘the system’ [Class D or C] where climb and descent risk is greatest to passenger transport operations, the ‘reasonable’ test comes down to this:-

1. The cost difference is demonstrably nil [Current Australian C over D practices]
2. The impost to VFR is simply using a radio and complying with a clearance
3. The opportunity of un-alerted NOT see and therefore NOT avoid is removed where pilot error is not a factor [incorrect report of altitude or position.
Indeed, there is no such thing as a SID or IAP that would not be "safer" with a higher minima, but that is not the way such design works. In fact, if you employed the same logic applied here to C over D versus E over D, there would be no low weather minima approaches, and probably no 200' CAT 1 ILS.
Wrong. For all the reasons explained above. SID’s and IAP’s are designed to be safe and as far as ‘reasonably’ possible [safe guards as listed above], error/failure tolerant. If you cannot see the difference between Instrument procedure design and safety monitoring when compared to the ‘normal’ mode failure opportunity of Class E, then I fear to say, you prove what many here are saying. You have no idea!
Whether you like it or not, CASA is bound to use a risk management approach across the board, witness the work being done by Aerosafe as a consultant to CASA, putting the meat on the bones of the basic policy of risk management.
Aerosafe, lets see:-

Aerosafe // Minimise Risk...Maximise Opportunity...

Nice web page, sounds impressive, lots of Helicopter companies involved in their subscription ASN, can’t see to many ANSP, National Aviation Regulators though.

Aerosafe // Industry Case Studies
AIR TRAFFIC CONTROL
Aerosafe has conducted risk culture analysis within one of the Force Element Groups of the Royal Australian Air Force (RAAF), which manages the Air Traffic Control functions. Aerosafe developed a cultural survey, which was completed by over 85% of the organisation. The results were analysed and presented back to the senior manager of that Group to use as a basis for the development of their risk management program.
A great idea.

In the meantime, an invitational to reinvent the ARM and CRFM will be one to watch. True enough, the ARM needs a GA only tool, oh dear, wouldn’t that have saved some red faces over the ‘intolerable’ FAA D/GAAP matter.
Any bravado that might be envisaged with mitigation such as ACAS will have to take into account the vast differences between ACAS performance between two track/trajectory predictable aircraft in proper CTA and that of only half the collision pair being ACAS aware and the other using startled GA eyes to try and avoid an ACAS manoeuvring RPT. There are a whole dinner party full of these little details being compiled by various groups. Suitors will have to be full bottle on industry acceptable thresholds as well as ICAO rule compliant.

Not to worry, the ‘meat on the bones’ will have to be served up to the industry, you know the ones who will have to rely on the RMS DNA before it is given a CofA.
We simply must adopt the best risk management standards in aviation, will we ever?? I don't know, but I have been pushing such adoption since well (years) before AS/NZ 4360 Issue 1 was even published.
Have you now changed tack since you realised AS/NZ 4360 is current risk management practice that could NEVER deliver Class E above D zones? It has been a variable and flukey set of wind changes from you these last 30 odd pages.
For those of you who want to have a bit of fun with the statistical term, "vanishingly small", it may be the equivalent of zero in maths, but "vanishingly small" is never "nil", or in other words, risk can never be nil, short of abolishing the activity.
Many thanks for stating the obvious to anyone with a cranium larger than a mouse. That is the very point contributors have been arguing, the risk of un-alerted not see and not avoid in Class E is not zero, it is also not vanishingly small when considering the concentration of climbing and descending aircraft in and around terminal area airspace.
If you decline to understand/accept that, it is no skin of my nose, but it does make the probability of your arguments being accepted ( in a technical, not political sense) , dare I say it, vanishingly small.
Of the pontificating and sermon giving, you fail to understand that well read risk managers in non-aviation expert fields, but inexperienced [in aviation and ATS] omit the risk multipliers. It was blatantly obvious in the three ‘bash bidjii’ papers since called in to question.

Your friend who likes to coin your often used ‘vanishingly small’ catch cry consistently makes the same miscalculation. i.e. collision probability in 100sq miles of en-route Class E [where few if any VFR aircraft are climbing or descending through other VFR and IFR] is statistically light years away from that of every aircraft IFR and un-known VFR climbing and descending through tracks converging in the 100sq miles of airspace above and around an airport or NAVAID.

You show me ONE, just ONE risk modelling tool that properly considers the large [comparatively] and very real difference in risk exposure of no structural vertical segregation [as all are aircraft climbing and descending around airports] and I will retire from this debate.
That you might succeed at a political level, by scaring the beejesus out of politicians, does not invalidate ICAO airspace design principles, it just proves how hard modernization of anything to do with aviation is in Australia.
Political operatives/minders [and the vast majority of pilots and air traffic controllers] reading this discussion will not buy that poor attempt to twist reality. ICAO airspace design is not the issue. The issue is properly assessing and allocating the correct airspace classification. You can keep trying to spin the reality, but you must know by now there are an endless supply of us ready to stop your merry-go-round in its tracks, day in, day out.
I have also said, time and again, that aviation regulatory reform in Australia (and that includes proper risk analysis) has been blunted and reversed time and again, by sectional pressure groups, with the results for all to see.
Another Quotable quote
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Old 22nd Apr 2010, 05:59
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squawk 6969

His tired old VOR post has been answered.

Mr Smith, answered previously, here it is:-

http://www.pprune.org/dg-p-general-a...ml#post5340338

All

This is the game they play. Duck and Weave, never answer with facts, data or evidence.

It is important at this time for all to resist the temptation to be drawn in to emotive or frustration driven responses that take the focus off the nuts and bolts. Keep it factual, and when they repeat rubbish that has been answered previously, find the link and post the answer again.

Just keep doing that

DNS I'm getting a sniff of the same

Keep up the good work all
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Old 22nd Apr 2010, 06:07
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squawk6969

It is a total waste of time answering the questions. I have said numerous times that experts have told me that Class C airspace IS safer than E if it is correctly manned and the proper tools are given to Air Traffic Controllers.

If the Class C is manned by an already overloaded Controller for the Class D airspace below, it is most likely that the safety of the total system will be reduced.

The experts tell me that is because the risk close to a runway is greater than in the link airspace further away from the runway.

The experts say to me – and it seems to fit in with commonsense – that if an Air Traffic Controller’s concentration is taken away from where the collision risk is greatest, that an accident is more likely to happen.

The experts tell me that the only reason the US has Class E over D is so safety can be improved because of the facts stated above.

When I mention what the experts have told me and what reflects airspace design in many other countries, I am told by a small number of Air Traffic Controllers in Australia that in their case, they can handle the Class C airspace – at huge volumes – as well as the Class D airspace without any extra manning (normally just one Controller) and without any reduction in safety.

Well, of course, they would say that (to use the Mandy Rice-Davies defence), however I’d rather use commonsense and logic.

As I’ve said, I support Class C airspace if it has a proper approach radar facility and adequate Controllers.

It is quite clear - there is a Minister’s Directive telling Airservices where they are to have Class C airspace above D to provide an approach radar facility and the proper manning.

The very fact that this Directive still remains and has not been reversed shows that there are many people who know that if you are to provide Class C airspace and give a high level of safety, you cannot do it at no cost.
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Old 22nd Apr 2010, 06:33
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What the experts tell you sounds great in theory. However I am not convinced. And the questions that remain unanswered may well help me decide.

It seems to me from listening first hand to tower ops at a Class D location with C above it, that while your claim they are too busy to handle the C above it is in fact not that bad at all, and in fact handling the flow from higher up makes it safer up there and at the coal face.

I have sampled this from the other side of the fence and it seems to work smooth also, both VFR and IFR.

So unless the questions of others are addressed fairly, it seems your claims from what experts tell you, while very plausable indeed, do not stack up against what I have seen first hand as an observer and participant.

You could do the same if you asked them nicely.

SQ
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Old 22nd Apr 2010, 06:40
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Dick,

Well, you would say that ....

If the Class C is manned by an already overloaded Controller for the Class D airspace below, it is most likely that the safety of the total system will be reduced.
By that logic ... If the Class E is manned by an already overloaded Controller for the Class D airspace below, is it also most likely that the safety of the total system will be reduced?

The experts say to me – and it seems to fit in with commonsense – that if an Air Traffic Controller’s concentration is taken away from where the collision risk is greatest, that an accident is more likely to happen.
By that logic ...would it not also be the case for the Class E Controller?

I am told by a small number of Air Traffic Controllers in Australia that in their case, they can handle the Class C airspace – at huge volumes – as well as the Class D airspace without any extra manning (normally just one Controller) and without any reduction in safety.

Well, of course, they would say that (to use the Mandy Rice-Davies defence), however I’d rather use commonsense and logic.
So, you'll believe your "experts", but not Australian Controllers?
I hope your "experts" aren't lying Controllers also?

As I’ve said, I support Class C airspace if it has a proper approach radar facility and adequate Controllers.
Why don't you also put that caveat on Class E airspace? Doesn't it need Controllers or facilities?
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Old 22nd Apr 2010, 07:04
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History

Mr Smith

You would remember when you were the Chairman of the then Civil Aviation Authority, there was much discussion regarding ICAO regulation, and Australian compliant legislation regarding the definition of:-

Air Traffic Control Service

Do you remember [you must] a letter to:-

ALL ATC STAFF,

[authored by the then Deputy Chief Executive A F Rainbird],

dated 18 June 1990.

The subject:- "SEE AND AVOID" - AMENDMENT OF REGULATIONS

CAR 98 (1) and CAR 163A featured.

Do you still maintain you are unaware of why Australian air traffic controllers cannot provide FAA style Air Traffic Services?

Moreover, do you also maintain that ‘preventing collisions’ [as per ICAO] is not the role of air traffic controllers in VMC, rather pilots [all] should 'see and avoid'?

As you [and your alter ego mjbow] would say:-

I look forward to your advice
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Old 22nd Apr 2010, 07:10
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Peuce

It’s clear that you simply don’t understand a proper, well-designed airspace system. You state

By that logic ... If the Class E is manned by an already overloaded Controller for the Class D airspace below, is it also most likely that the safety of the total system will be reduced?
Absolutely not! Because in a properly designed system the Class E airspace is manned by Controllers in the Centre. That’s for obvious reasons – it’s there 24 hours per day, not just for the hours of the local tower.

Peuce, fascinating to find that you have absolutely no understanding of how the NAS airspace system works.

I’ll say it again.

In NAS, Class E is not operated by the local Controller in the tower. It is operated by the centre – yes, even in non-radar airspace.
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Old 22nd Apr 2010, 07:25
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Mr Smith said:-
you have absolutely no understanding of how the NAS airspace system works

I’ll say it again.

In NAS, Class E is not operated by the local Controller in the tower. It is operated by the centre – yes, even in non-radar airspace.
So glad you said it again [for the record] Mr Smith

It is you who has no idea how the US NAS works.

Where are the assessments of high level en-route sector controllers ability to add terminal area procedural Class E to their already huge workload?

Yes, won't touch that will you
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Old 22nd Apr 2010, 07:27
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Dick,

Well, it's no wonder I
simply don’t understand a proper, well-designed airspace system.
Where is it? We used to have one... but it's gone. Trying to keep up with the interminable changes is sapping.

However, putting your condescension aside, where what will be provided from is only conjecture at this stage ... unless I've missed something.

Please point me in the right direction please.
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Old 22nd Apr 2010, 07:35
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ARFOR Yes I will touch it.

If the assessments have not been done in Australia that's not my responsibility.

I have alway's supported proper ATC staffing levels.

And if Aussie ATC's cannot provide the safer FAA style service with 24 hour approaches in E then update the rules so you can.
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Old 22nd Apr 2010, 07:40
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proper ATC staffing levels
What are they? Can someone please tell ASA (there's is a reason they've got the nickname airnoservices australia)
But more staff means more money, that will dent ASA profit.

You cant just dump more airspace, more traffic, more complicated procedures on the same amount of staff (or lack thereof). Thats not safe.
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Old 22nd Apr 2010, 08:03
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It only took a couple of hours to nail the state of play. Childs play

Mr Smith

Quite aside from the huge volume of unanswered [by you people] discussion points, you never disappoint when the heat is on
If the assessments have not been done in Australia that's not my responsibility.
Disgraceful. YOU [and your 2.5 side kicks] have been informed of the systemic problems with adopting the US NAS. It is not about The rules [I note with interest you duck the CAR 'prevent collisions' issue] . The US rules are not needed in Australia. Imagine forcing pilots to 'see and avoid' in VMC when it is not necessary. That is why the CAR regulatory changes were knocked back in 1990, the same applies today, 20 years later.

With reagrd resourcing, YOU [and your 2.5 side kicks] also know that enforcing Centre E to low level in Australia is neither US NAS compliant, nor reasonable given the airspace structures in Australia.

The AIG and APG know, as do the CASA. There will be nowhere to hide for any of them, least of all the Minister.

One last question of you:-
I have alway's supported proper ATC staffing levels.
Will you lobby for proper assessments, and ensure the safest possible [subject to CBA and RA] system is put in place by CASA for Australian industry?

Can you live with whatever outcome that might be?

Once again, I look forward to your advice
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Old 22nd Apr 2010, 08:15
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Dick, in reference to the following:

As I’ve said, I support Class C airspace if it has a proper approach radar facility and adequate Controllers.

It is quite clear - there is a Minister’s Directive telling Airservices where they are to have Class C airspace above D to provide an approach radar facility and the proper manning.

The very fact that this Directive still remains and has not been reversed shows that there are many people who know that if you are to provide Class C airspace and give a high level of safety, you cannot do it at no cost.
The 'directive,' as I recall, was signed off by a Minister that I believe you may have described as being (not the exact words) 'the worst Transport Minister we've ever had.' I don't agree with that entirely; I just thought he was an amiable dolt.

In my opinion, he was conned because he was thick. The argument, in my view, would have gone something like this:
  • Minister, in the US there is no Class C airspace that is not serviced by radar.
  • Consequently, you can't have Class C without radar.
  • Therefore, Minister, if Airservices requires Class C airspace at those locations, it must install radar.
Once again, my opinion, but the deception was in the second point, and the amiable dolt swallowed it; just as he was meant to.

From my perspective, Dick, the so-called 'radar direction' letter was a very neat piece of manoeuvring. I do admire the way it was done, but let's admit it; the amiable dolt could have been sold a bridge in Sydney 'going cheap.'

Radar with Class C was never the desired end-state from my perspective, despite the letter; and this is where the plot was extremely neat. The end-state was always E over D at places like Launy, Coffs and Alice. The 'radar direction' letter, that the amiable dolt signed off on, was designed (in my opinion) to put an additional cost impost on Airservices, thereby forcing them to reverse the reversal and reinstitute E after the NAS 2b rollback.

Radar Class C was never the end-state was it Dick? It was forcing Airservices to reinstitute E to avoid the 'mandatory' radar that the amiable dolt was convinced is necessary if you have Class C.

Once again Dick, I do admire the thought processes that went into that one. But it must have been like shooting the proverbial 'fish in the barrel.'

The last point I'd make is that, in a 'first-world' country, maybe we should spend the money and introduce radar services at some of these locations. However, that is not tied to what I regard as a duplicitous strategy to con an amiable dolt.

There is no connection between Class C and the need for radar services. If there is, please refer me to the appropriate reference in ICAO SARPS.

I suppose, Dick, that this will just be another question (conveniently) left unanswered.

Last edited by Howabout; 22nd Apr 2010 at 08:46.
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Old 22nd Apr 2010, 08:58
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Nailed it in one, Howabout.

C needs radar. I don't think soooooo...
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Old 22nd Apr 2010, 09:11
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Howa, my reasoning is slightly different.

If C is required to give the minimum required level of safety it is clear that VFR are required to be separated from IFR.

The only way of providing this separation safely when the aircraft are not visual to the controller is by using approach radar ie primary and secondary.

Class C under the US NAS requires approach radar. We have a similar standard of living to the USA and a similar high value of life - then we can afford a similar level of safety equipment.

Class C without radar is a sham as a VFR aircraft can transit the airspace without detection by ATC.

Why thinking controllers would want C without radar and adequate staffing is beyond me.

Maybe they consider their jobs as some type of charity position.
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Old 22nd Apr 2010, 09:19
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The only way of providing this separation safely when the aircraft are not visual to the controller is by using approach radar ie primary and secondary.
And the safety stats for Australian non-radar D/C towers would be?

In three groups:-

- ATC errors
- Pilot errors
- Violations of controlled airspace

I look forward to your advice again
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Old 22nd Apr 2010, 09:23
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This would most likely mean that C was not required in the link airspace - which would fit in with the safety studies.

And if C is required in the lower risk link airspace then B would be reqired in the higher risk terminal airspace below.
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Old 22nd Apr 2010, 09:24
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Dick,

You have gotta be joking?!

Class C without radar is a sham as a VFR aircraft can transit the airspace without detection by ATC.
You reckon a VFR not complying with one of THE most basic rules of the sky, not to enter controlled airspace without a clearance, is a sham, but requiring me to look out of the window in the same location to avoid the same VFR in E isn't? Your arguments become more farcical as time goes on, Dick.

So here we are, in a bugsmasher, in the middle of Australia (very complex airspace there and at KTA/BME...not), and we inadvertently fly through the C steps. I find that very unlikely. Much much more unlikely than a "Free in GE" pilot would deliberately fly through non-radar E talking to no-one and scaring the willys out of me when he (hopefully) pops up on TCAS.

Fortunately I think most pilots, VFR included, are responsible enough not to transit through C without a clearance, radar or not. Perhaps it is only the "Free in GE" brigade who think that scooting thru procedural C would be the norm.

C never has required a radar. Think outside the square, you fundamentalist. Non-radar C, totally ICAO compliant, provides a very cost-effective (dare I say it, affordable safety) airspace regime that protects the fare-paying passenger.
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