DRAFT NFRM 0814OS. Broadcasts by pilots at non controlled airports.
 

More CASA stupidity.

I have just read the DRAFT NFRM. (it's not yet on the CASA website). Note if published, annex B, B3 to B7.

Defines “in the vicinity of a non controlled aerodrome as 10nm from the aerodrome and at a height above the aerodrome that “could” result in conflict with operations at the aerodrome.

But this applies if you have one serviceable VHF radio, but goes on to state, if you have two VHF radio’s, that distance is 8 minutes flying time. (120KTS =16nm)?

Strict liability offences.

Imagine being fined for failing to give a radio call when “in the vicinity” of an “aerodrome or you “could” cause conflict, but the rules for doing so are different depending on how many radio’s you have.

If you have no serviceable radio I assume you don’t have to call at all.

I am told the FAA approximate equivalent to this unique piece of Australian lunacy is covered in 80 words and ours over 1,000 words.

I may be dim (Healey, Joppich, Macca et al, shut up......) but what was so wrong with 15nm/5000ft or something similarly simple ?!?

PM

Good point, I think it should be 10miles and 3500AGL..... that is a sensible dimension for the space around a CTAF aerodrome.

FRANK

Why not join the AOPA and give them your support at objecting.

With the general idea of it, I support it, some good CTAF practices, except the dumb ideas and strict liability big stick poinetd out by Frank. Well spotted mate! :ok:

If one of you has time on your hands and knows how to get at the respective Canberra folk, it would be good to see you "improve" this document.

J:)

I believe this was left as a legacy from the previous Director. It is up to the new holder of the poison chalice to see it as dumb and affirm his hold on the reigns by chucking it out. (with the Board's permission of course).

If you, jabawhosit, are a member of that once proud organisation, why don't you give them your support. I have more pressing things to do than ameliorate their "situations".

They, can of course support my efforts by objecting.

Do you know what the definition of a non controlled aerodrome is?

Pick me! Pick me!

How about, "one that is not being controlled by an ATC"?

Collins English Dictionary: aerodrome. "a landing area,esp. for private aircraft, that is usually smaller than an airport".

CASA could describe an ALA as an aerodrome. Or any place where an aeroplane can take off or land. Depends on how they feel on the day when determining if your particular flight "could" result in conflict with operations at that aerodrome.

The outcome of this is simple. The next survivor of a mid air collision within Ten miles (or Eight minutes flying time) of a non controlled airport will be prosecuted and no doubt convicted.

Frank

At least pay me the coutresy to use my name correctly, its on the left side of every post I make.

You know full well I am not a member of the organisation and you know exactly why. No need to waste more time here.

I do believe that the general idea of better radio calls and distances etc needs fixing up. As said previously I do believe 100% the points you raise about being bad with respect to strict liability and so on.

This sums up the stupid parts.... copied from an email.
A WAC.....:ugh::ugh::ugh: Most aerodromes on a WAC do not exist, and all the bush strips that do are not printed. WAC's show roads hills and rivers and provide good sunshades for those who need them.

Lets not get too precious about identities.

The NFRM I read is in DRAFT form and needs to be attacked before it gets to be a FINAL. It's a pity that the "we" you refer to in your email snap don't push to get this DRAFT published for general comment, (you know consultation with industry), before they, as in "their" answer referred to, have it foisted upon us, strict liability and all. Has anybody asked CASA to publish it? I can't being a "leakee" and all that, but you could.

The bits about the WAC charts leave me confused to say the least. Highways are commonly used as "aerodromes" by rescue aircraft, how many calls do I need to give flying across the Nullabor.

AFIZ with a twist (or two)
 

What about keep the CTAFR and CTAF,5,000' x 15 nm or 10 minutes whichever is further

My two bob's worth for what it is.

How is it you are any different as a leakee to me....... I am not on the inside and I can assure you "they" would probably take you just as seriously as they would me. They at least know who you are! You read too much into some things and not enough into others.

As for attack the NFRM, I would suggest that you may have more time and resources at your disposal to attack this. This is right up your alley, and not mine. I would also support your efforts and ####'s effort's to turn what is another good opportunity to sort some BS out and not let it go nuts like it sounds.

As for the Nullabor........you may well be right! :ooh:

J:ok:

PS no not your real identity.......or mine....just some manners and do not try to talk down to me or others thanks. You will catch more flies with honey. Otherwise I will resort to not respecting my elders :=

http://www.casa.gov.au/rules/1998casr/139/139m01.pdf

Definition Meaning
Aerodrome A defined area on land or water (including any buildings,
installations, and equipment) intended to be used either wholly or
in part for the arrival, departure and surface movement of aircraft.

8 minutes at 180 knots = 24 miles somewhat over the top methinks and in some areas will cause all sorts of confusion as places 48 miles apart are not an oddity on the Eastern Coast so if you transit between 2 places 48 miles apart at better than 180 knots do you have to alert both ????

This is really silly stuff, what happened to common sense 10 miles inbound for low performance < 120 knots and 15 miles for high performance.

Seemed easy to me and has stood the test of time.

My bolding and underlining.

CASA Please take note;

I "intend" to use my plot of land that is 8 nm from a regular RPT route, but more than 10nm of an RPT aerodrome, but in class G airspace, and I may "intend" to operate up to FL150 depending on whether I feel like it or not for aerial work or aerobatics. I own a Sopwith Zot aircraft that has a cruise speed of 90 Kts. I am thinking of buying a better wireless next year.

Please issue a NOTAM to this effect as soon as possible to prevent anybody who "could" be a conflict to my operations.

I am also installing floats to my aircraft and I may "intend" to operate anywhere up and down the East or west Coast of Australia.

What was that you say? It's up to the pilot who "could" be in conflict" to make him/ herself aware.

I see, common sense really.

Where the radio calls are mandatory, then the boundaries of the CTAF should be clearly defined, and printed on the relevant maps also.
(3000', or 5000' if you must, and tailor shaped to suit the terrain, aerodrome, IFR approaches, etc.)

At the aerodromes where NORDO aircraft are allowed to operate, leave the calls to airmanship.

The adoption of this draconian and uniquely Australian requirement shows that we are no closer to a rationalized regulatory environment in aviation. In fact this is another indication that the ‘regulatory reform’ program is being manipulated in a way that we ‘reform’ the regulations right back to what we had prior to reform beginning. We all should be gravely concerned.

We will now have regulated back into existence the two tiered system of MBZ’s and CTAFs that we tried to do away with, albeit by using the seemingly innocuous name of CTAF and CTAFR’s. Now CASA has the power to prosecute pilots that have no possible way of complying with this unique requirement in certain circumstances.

Far more troubling to every pilot and industry professional is the way in which CASA has ignored the Aviation Policy Statement, CASA’s CEO Directives, the NAS (2c) Post Implementation Review and the Ambidji report findings.

Contrary to the Airspace Policy Statement mandated by the Airspace Act 2007 and contrary to the CEO of CASA’s directive dated 18th of June 2007 CASA has made a regulation that is simply not supported by its stated objectives in these documents



And from the Airspace Policy Statement mandated by that Act.


Here are some remarks made by PCR Australia in its Post Implementation Review of NAS 2c.



The NPRM is not supported by a measurable drop in safety. This NPRM is not supported by any identified safety need.

Yet it is required to be assessed "against the contribution it will make to aviation safety". Clearly this was not done or at best ignored.


The Ambidji Group CTAF v CTAF-R final report finds that the FAA uncontrolled airport CTAF procedures while only recommended and not mandatory experienced an extremely high level of compliance and safety that is supported by “a plethora of education and guidance material”.

PIR findings indicated that training and education was significantly inadequate and rated mention 6-1 compared to regulations in the document. Nearly every submission made by stakeholders pointed to inadequate training. The review strongly advised of the need to seek expert guidance on completely new training material.

Not once did the PIR make reference to the lack of regulated mandatory radio calls being responsible for failures of safety at CTAF airports. It is clear from the Ambidji report that CTAF radio procedure coupled with traffic pattern compliance was key to keeping separation incidences low both in Australia and world wide.

Why did they subject the industry to a regulation that by their own studies have shown will yield no safety benefit. Is it because this is ‘the Australian way’?

Are we so predisposed to overly prescriptive measures that CASA rushes to regulate that which would be more effectively served by better education and training? I think so.

The concern I have is that even though the Green Paper has stated that CASA should get through the regulatory reform process in the next 2 years, we are going to take the old ways, run them through the ‘reform’ process and come out the other end with a rehash of what we tried to move away from.

Have we really moved on from the two tiered system of MBZ and CTAF or have we merely done away with the MBZ name and mandated it right back into existence through 'reform’?

Selective Quoting
 

mjbow2,

Your second quote from the AAPS merely referenced the decision taken by the Government in 2002. The efficacy of that decison has been debated here and in other places ad nauseaum. To use that as objective support for your argument against the changes in the Draft NFRM is a little disingenuous.

However, you quite rightly point out that this goes someway to returning to the two level MBZ/CTAF system. I haven't had time to refer to the PCR report again but I recall at the time of reading that there was a significant theme in the report of industry questioning the need for the NAS 2c changes in the first place. Perhaps those same industry types have convinced CAS/OAR of the need to revert part of the way back to what we had. What was so wrong with them in the first place that they needed changing? It certainly would have avoided most of the debate we have had since.

To those who have read the draft NFRM. Has it been decreed by CASA that aircraft carrying a radio in a CTAF not designated under CAR 166A (i.e not a CTAF [R]) must make the appropriate broadcasts and is that decree contained in any changes to the regulations and/or legislative instrument(s)?

Oh no, lord help us. Australians and non controlled airspace. Let the pedantic wailing and nit picking begin. Get over it guys, the rest of the world has.