NAS rears its head again

[OverRun]

It seems like NAS has come back again, or maybe it never really left us.

In accordance with CASA policy the ultimate model should emulate identified best practice in the United States National Airspace System design

There has been spirited discussion about this in DG&P General Aviation & Questions forum over the last few months in the thread Class D Zones for Broome & Karratha. The latest move affects airline and RPT operations, which is why I'm raising it here.

What has emerged from the woodwork is the new NAS vision for control zones at regional airports. The first cabs off the rank are Karratha and Broome. Looking at the Airspace Change Proposal (thanks Capn Bloggs for the link), the airspace redesign elements associated with the upcoming towers there are:

• smaller than the normal Australian control zone. With a D boundary @ A025, that'll make the zone about a 8NM radius. It is a lot smaller than the A045 and 22NM radius found at regional control towers elsewhere in Australia.
• E over D airspace
• no surveillance radar

Reading back through the GA thread, there is:

• no cost saving with the small control zone
• a big backward step to unalerted see-and-avoid as the only line of defence in the zone between the current 30nm radius CAGR/S at Broome and the proposed 8nm radius zone for the control tower at Broome.

This is a DOUBLE Airspace Change Proposal – the "new" NAS airspace has been hidden (or should that be buried?) in the Airspace Change Proposal to put towers at Karratha and Broome. The tower issue was generally accepted by all. But this NAS Airspace Change Proposal is something else again. There is no safety case for this, no modelling, no justification, and no cost saving. But a big step backwards as airline and RPT mix it up with the lowest common denominator of unalerted see-and-avoid GA.

In the absense of a safety case, what I could find was in the minutes of the local GA industry consultation at Broome last month which have just come out:

asked for each chief pilot present to advise which option for the size of control area they considered safer. While the Chief Pilots raised other issues, they, when asked in turn, advised that a control area of 8nm and 2500’ at Broome was inadequate, and was less safe than 22nm and 4500’ option for class D. All stated that the CASA model would not work at Broome due to communication traffic, it was not safe, and would cause delays.

CASA have asked for comments, so here is everyone's chance:

The OAR is sympathetic to this view, but input from the wider aviation community is sought before the final airspace structure at these locations is decided upon by CASA. Stakeholders are therefore requested to provide feedback on this issue

The details and email address are here at CASA and closing date is 31st March 2010.

This has broad implications for airline and RPT operations in regional airspace. I'm posting this short summary in DG&P Reporting Points because the sneaky way that these changes are being tried on will have kept them from view of many.

[Howabout]

Good post OverRun. You are right of course - this seems to be NAS by stealth.

As with the original bastard child, no clear justification. I'd go further and add that my take is that the outcomes are preordained - make the arguments fit a pre-detrmined end-state. If this is, indeed, the case, then any 'consultation' will be little more than window dressing.

One wonders who's got hold of whose goolies. NAS created such animosity, waste and division that to revisit that dog defies logic.

But I expect it will play out like this: BME and KTA get their NAS zones and Class E. The same happens at GAAP. Now we have some regional centres, plus Avalon and the secondaries, with US airspace and others with 'non-standard' airspace (Coffs, Launy etc). The cry will go up that we need 'standardisation' and that for this reason all regional aerodromes must conform, otherwise it will be 'confusing.' So it's essential that all those other airfields (Alice included) get E over D and minuscule US-style zones.

Just a personal observation, but given the importance of NAS to some well-known aviation luminaries, they have been surprisingly quiet. I can't help wondering if the 'fix' is already in and that any comment would be seen as potentially stirring up the natives. Better to let them wake up one morning and find out they've been done over.

So, for those of you far removed from the KTAs and BMEs of this world, a word of warning. This is my own impression but KTA and BME, along with YMAV, may well be the foot in the door that will be used to justify the inevitable NAS changes to the airspace you operate in. I'm sure the regionals on the east coast will be thrilled with that outcome, but it'll be too late if what's happening in the west is ignored.

[ARFOR]

What is even worse, this sham is not reflective of US practice in terminal areas [above US Part 139 Class 1 airports] where significant volumes of large 'Air Carrier' aircraft operate!

Lazy, gross ineptitude on the part of those who are paid to protect the travelling public!

[apache]

hmmmm..... NAS groups been working undercover.
A certain prolific exponent of NAS has NOT been seen on this site for a while.

NAS rears its ugly head again.....

methinks we will soon hear who has been working behind the scenes.

[PLovett]

After the last round of hyperbole and unpleasantness I had occasion to speak to one of the people connected to NAS. He confirmed that it had not gone away and was still on the agenda for future implementation.

[peuce]

Support: I guess KRudd does ... it's Government Policy still ... I assume?
Pay: Us

And do you know how much it costs to establish a bunch of Controllers, and their equipment, in remote WA?

Not to mention the costs of constructing a Tinny Club

[Howabout]

DNS, unfortunately 'who will be paying' is a fact of life; left to us by the great benefactor. Free in G, manual telephone exchanges and dirt-road airspace come to mind. We then progress to a time when we had a malleable, idiot transport minister, who couldn't find his ass with both hands. Subsequently we got NAS - Swahili for 'gigantic f*ck up.'

That's done. The real issue, in the contemporary environment that we've been stuck with, involves accepting the current mad-woman's breakfast, accepting that we have to pay, but asking why we should agree to a dog of a system when we can have guaranteed separation between IFR and VFR for the same cost?

[zoics88]

aahh... tinny club Port Hedland, late 80's, friday night, emu bitter.... there was a copper moonlighting as a flying instructor, owned a cessna, would check on RBT patrol location so we could go home (party on!) 'safely' in convoy (or to the Nard!)

those were the days, my friend...

went through there a year or so ago: missus wanted to stay, nostalgia attack: lunch at the Nard soon cured that!!
on to a quiet camp at Milstream

latest within Lipservices: tower job apps for BME & KTA closed last week: around 20 applied for 3 BME positions, less for KTA. (all those young folk wanting to get off sectors, i suppose)
start date is supposedly 18 Nov 2010
Training to be done in ML, with rating check in twr simulator - WTF?

Initial BME control will be from CAGRO facility, KTA TWR may be ready in time.

BME TWR not yet passed design stage, no construction tenders pending - mooted to be first glass tower: I.E: all virtual & screen based with no paper strips.. that's some tech investment for a remote area.
don't expect miracles.... after all this is Lipservices, how may i help you?

[LeadSled]

Folks,
NAS never went away, have a look at successive Airspace Directives** in the legislation. Whether it was the Howard or present Rudd government, the basics have not changed.

CASA/OAR has to administer the legislation they are presented with, not what pprune posters think it should be.

In short --- ICAO airspace classification, with the US NAS being the prime example, as ICAO classification is based on US NAS anyway.

Perhaps it's all got a lot less to do with one Richard Harold Smith than many of you thought.

Tootle pip!!

** See the Airspace Act 2007.

[Capn Bloggs]

Oh Leadsled spare me. You do write brainwashed nonsense. Dick was THE architect of Airspace 2000, which was swallowed by the gummint of the time, and HE co-wrote NAS with Walter Dollman, I believe. That was in turn swallowed by the gummint of the day.

In short --- ICAO airspace classification, with the US NAS being the prime example, as ICAO classification is based on US NAS anyway.

Love it!

So once and for all (or have I already asked you?) why do you think that hundreds of thousands of fare-paying pax should be subjected to the unalerted See and Avoid threat of middle-level, unsurveilled E airspace?

[LeadSled]

Bloggs,
My dear chap, Dick had extremely limited influence on the contents of the original "Airspace Policy Statement" in the Airspace Act 2007, and I rather suspect, even less on the present Minister.

Quite apart from the Airspace Act, the Civil Aviation Act and the Air Navigation Act all refer to ICAO compliance, rightly or wrongly ( in my opinion a bit both, depending on the subject, but that is just opinion) Australia has had a long history of Government policy directed at meeting its obligations under the Chicago and the many other ICAO conventions.

That Australia has been out of step with ICAO on airspace matters, and is slowly being brought into step (far too slowly, in my opinion, because I accept, understand and support the risk management underpinnings of ICAO CNS/ATM --- directing the resources at the areas of greatest demonstrated risk) really should not be a surprise.

Credit should go to Dick for championing rational use of resources for CNS/ATM for so long, but it is now part of the legislative framework, which binds CASA.

Of course, it does "the cause" no harm that CASA Director of Aviation Safety John McCormick understands that the ICAO system works, and why it works, and equally understands that the many local claims of great potential danger in Australia following the ICAO/US model are just that --- unsubstantiated claims.

As for "un-alerted see and avoid", please read the history of the development of CAR 166, use of a serviceable comms radio never was optional (in law --- if not in the minds of too many pilots), but the revised CAR 166 make it quite explicit.

Tootle pip!!

[Capn Bloggs]

Good pollie answer Leddie. ICAO airpsace it is; WHAT ICAO airspace is the issue.

As for "un-alerted see and avoid", please read the history of the development of CAR 166, use of a serviceable comms radio never was optional (in law --- if not in the minds of too many pilots), but the revised CAR 166 make it quite explicit.

And the relevance of CAR 166 to E link airspace is??

[LeadSled]

Capn Bloggs,

Quite simply, the fear/probability of un-alerted see and avoid is greatly exaggerated.

This has been established by every on-the-ground survey done in recent years ---- that the claims of significant numbers of aircraft (always blamed on PPLs, but where in the few cases it happens, "professionals" are almost always the culprits) are not using radio, when operating VFR in G or E, is simply not true.

However, the revised CAR 166 spells it out so there is no "ambiguity" (not that there ever was) about use of radio for communications ----- if its serviceable, it must be used.

Tootle pip!!

PS: What ICAO Airspace? The first class of airspace that meets the design separation assurance standards, and which, by definition, proceeding beyond (ie C instead of E) provides no additional benefit for the additional CNS/ATM resources and other associated costs expended ---- in other words, "economic waste".

[ARFOR]

The first class of airspace that meets the design separation assurance standards, and which, by definition, proceeding beyond (ie C instead of E) provides no additional benefit for the additional CNS/ATM resources and other associated costs expended ---- in other words, "economic waste".

Correct!

That is the fundamental issue you and Mr Smith refuse to acknoledge, that is:-

Australian Class C, and 'full' ICAO Class D and D/C [by a tower/approach combined controller] are operated 'efficiently', when compared to US practice [where similar levels of RPT traffic with a pax seat capacity >30] at airports with similar numbers that are class C

WHY?

Lets spell it out so there are NO misunderstandings:-

1. Australian Class D and D/C towers service similar numbers of 'large RPT' aircraft as many of the US class C TMA serviced airports
2. Australian Class D and D/C towers on average service less numbers of VFR than US class C services
3. All class C terminal areas in the US are radar covered
4. Australia has no such radar saturation [except at the primaries]
5. Because of the comparatively less VFR activity at Class D and D/C locations in Australia, ATC can provide non-radar ICAO D and C services without saturation

The bottom line:-

A. Australia does not need US Class C, radar equipped, Tower and separate Approach and Departures staffing [average 30+ per terminal in the US] at regional [non-primary] ports
B. Australia does not need to force pilots [both IFR and VFR] in VMC to be 'primarily' responsible for 'see and avoid' as is the case in the US
C. Australia does not have the traffic/frequency saturation to necessitate the use of Class E [surveillance based or otherwise]
D. Australian industry cannot afford to use US Class D and C terminal area rules [due the associated ATM infrastructure required]
E. Without a similar investment in terminal area ATM infrastructure, the same radar based safety net [which Australia offsets by utilising third party active collision mitigation through ICAO D rules] used in the US would be absent in Australia, where [as already pointed out] large numbers of large RPT's operate
F. Australian industry can afford [for no extra cost above class E] to run regional tower based non-radar ICAO D and D/C instead

Both countries may claim ICAO compliance, the difference is the level and type of CTA/R service assets needed to achieve the desired sovereign legislated safety outcomes.

With those realities in mind, which of the two countries 'system safety' outcomes would you consider superior? and why?

[Dog One]

Leadie

Why did Airservices put a portable radar in at Launceston after the near miss between the Virgin 737 and Tobago in E outside of radar. Why is it still there? The education process must be complete, you understand how it works, and by the sounds of it, you would be happy operating high capacity RPT aircraft in this environment.

In the Broome case, the 30nm CTAF(R) is replaced by a 8nm radius CTR, with the tower controller handling both the CTR and surrounding E airspace. If that is the US way of doing things, let them do it, and let us design the airspace in accordance with ICAO, providing a mantle of safety to Australian fare paying passengers. History shows that the US way has dented lots of metal and killed many passengers.

[89 steps to heaven]

Leadsled and all.

Lets clear up a misconception. There is no such thing as ICAO airspace. There is an ICAO classification of airspace in which certain levels of ATS are provided. It is up to each countries regulator to determine where each classification is used.

Each country has requirements that suit the number of users, amount of airspace available, geography, infrastructure, political restraints, culture and training. What works here is not necessarily suitable for another country. Same applies, what works in the USA may not work here, but if it was to work, the whole system needs to be implemented, starting with culture and training. Changing airspace should be the last step.

[Howabout]

Bloggs? Are you an idiot, man? - talk about a fundamentalist, backward looking Neanderthal. Can't you see the connection? We are talking a dog called controlled E over controlled D and the fact that controlled C can be provided at the same cost. And you obfuscate and claim that CAR 166 has no relevance.

Well, for my money, Leady is right on the beam. In reference to controlled airspace, controlled terminal areas, and control zones, Leady rightly quotes CAR 166.

Off the CASA website, in case you want to check about radio procedures in controlled airspace:

166 Operating in vicinity of a non-controlled aerodrome

Jeez, get it right will ya!

DUH-OH!

Furthermore, in addition to some previous digging we've done, here's a stringing together of a few quotes (some previously posted) that will give the lawyers a field day if it ever comes to a class action.

A. The CASA Avalon 2008 study:

1.4.3 The cost of the provision of a Class C air traffic control service is the same as that of a Class D or E service. However, the Class C service provides significantly greater risk mitigation to passenger transport aircraft against VFR aircraft threats than that provided by Class D and Class E.

B. The Alice study in 2010, in reference to the maintenance of the current airspace architecture:

It is important to note that the study may make recommendations based on existing and projected data. The following comment as summarised by Justice Gibbs of the High Court of Australia has been considered while conducting the study:

Where it is possible to guard against a foreseeable risk which, though perhaps not
great, nevertheless cannot be called remote or fanciful, by adopting a means which
involves little difficulty or expense, the failure to adopt such means will in general be
negligent.

C. The Launceston study of 2009:

Just mysteriously disappeared off the CASA website, but I've saved the point I wanted to make - will post that one tomorrow.

And, like the famous raffle for a block of flats in Tasmania, a set of steak knives and the K-TEL record stacker, there's more.

[LeadSled]

89 steps,

Lets clear up a misconception. There is no such thing as ICAO airspace. There is an ICAO classification of airspace in which certain levels of ATS are provided. It is up to each countries regulator to determine where each classification is used.

Please reread my posts, I have referred to ICAO airspace classifications, not "ICAO airspace".

As for a few more misconceptions, perhaps we should have given the airspace classifications colour names or something other than anything that implies (in ICAO risk management terms) different "levels of safety". ie that A is safer than B etc.

The whole intent of the separation assurance standard is that all airspace is equally safe, with the level of CNS/ATM and airspace classification matched to the traffic levels. A smart country will not provide services more than needed to satisfy the risk management criteria --- and don't come the furfy that C is no more costly to run than E ---- it doesn't come out that way when ALL costs are included.

Perhaps that is why E airspace is so common around the world??

Would I be happy to operate HCap RPT in E, of course I would, and did for many years, and not limited to US/Canada, either.

Nor was much of the E radar, is is claimed by so many of you to be necessary. And by the way, in somewhat bigger aircraft than B737. Likewise, extensive operations, over many years, of the same aircraft in G and F (yes, F, used to be some around).

As to the Gibbs HC decision on "duty of care", which has been a staple of Civilair for years.

There is a most useful later HC decision which contains the best definition of "safe" of all the "legal" definitions I have read, which make it clear there is no such thing as "absolutely safety". Further that safe cannot mean "absolutely safe", but this case defines "safe" in very sensible risk management terms ----- and which make it quite clear that Government risk management policies (not limited to matters airspace) are lawful, when a bush lawyer's reading of the Gibbs decision suggests otherwise.

Without this latter decision, and some subsequent supporting decisions, the application of such as AS/NZ 4360 Risk Management standards in Australian industry, including the aviation industry, would be legally fraught.

Tootle pip!!

PS: Suggested reading --- the four elements that must be satisfied for a "duty of care" to exist, and the legal effect of statute law modifying whether a duty of care exists in a particular circumstances ----- and in particular, whether a controller has a duty of care to provide positive separation to all "known traffic" --- as claimed by Civilair ---- contrary to the provisions of the airspace regulations, which may not require all known traffic to be separated in a particular classification of airspace.

[ferris]

Arefor. An excellent post.
Leadsled- Im interested to know why you think providing a procedural C service is more costly than E? Why is that a furphy? Furthermore, unless you are a true Dycophant and believe that C, instead of E, is overservicing- what possible reason could you have for wanting E instead of C?

E does, indeed, cost the same as C (in the Australian environment). Read Arfor's post. E requires a controller, radio equipment, and a console. These are the only elements you need to provide a C service in a low density environment such as oz. What am I missing? I know Smith keeps trying to run the argument that you need radar to provide C- but that simply isnt the case (in a low density environment).

Im sorry, but a "freedom of the skies" argument for VFRs is not sensible or justifiable in a low density environment. C does not provide a burden large enough to VFRs to outweigh the increased risk to the paying public. Dick-o-fy all you want, but thats it.

[ARFOR]

Howabout

Interesting regarding the 'disappearance' of the YMLT report on the OAR site. Good thing many had downloaded a copy

Leadsled

and don't come the furfy that C is no more costly to run than E ---- it doesn't come out that way when ALL costs are included.

In the Australian regional airport context, what are the cost of provision differences between C and E?

Without this latter decision, and some subsequent supporting decisions, the application of such as AS/NZ 4360 Risk Management standards in Australian industry, including the aviation industry, would be legally fraught.

Has AS/NZ 4360 been applied to recent regional airspace 'directions'?

but this case defines "safe" in very sensible risk management terms ----- and which make it quite clear that Government risk management policies (not limited to matters airspace) are lawful

Correct! Perhaps you might point us towards copies of the 'very sensible risk management' processes in these regional airspace cases?

whether a controller has a duty of care to provide positive separation to all "known traffic" --- as claimed by Civilair ---- contrary to the provisions of the airspace regulations, which may not require all known traffic to be separated in a particular classification of airspace.

I am not aware that Civilair Australia is saying:-

a controller has a duty of care to provide positive separation to all "known traffic"

The airspace rules in Australia entrust controllers operating class D airspace with preventing collisions. That does not by definition always require a 'Separation Standard', nor does it imply a see and avoid open slather. As has been explained numerous times!

Ferris

Apologies, posted my response before reading yours. Doubled up