CASA NPRM 0808OS can GA afford it?
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CASA NPRM 0808OS can GA afford it?
I have just stumbled upon some notices of proposed rule changes released on the 16th Feb.
Whilst the majority of changes seem to be "workable", i wonder will the introduction of TAWS B for IFR aircraft with 6 seats or more be the so called "straw" for some operators? In the paper it states the average cost per aircraft would be around the $23,000 mark. see:
Now some questions for those who know TAWS B , as i have very little knowledge about the system.
Would the introduction of TAWS B be "that" beneficial to GA?
Is it suited to the types of flying carried out at the GA charter level?
Are there that many CFIT accidents in GA to warrant this sort of outlay by operators?
Don't get me wrong, I'm all for improving safety and preventing accidents, but burdening operators with more costs for these sorts of systems just puts them under more pressure to survive an already cutthroat industry. The money has to come from somewhere!
also this:
What benefits are to be gained by limiting pax numbers from say 12/11 to 9? will it make a great deal of difference?
Are there other areas CASA should be looking at better rather than these?
Thoughts??
Whilst the majority of changes seem to be "workable", i wonder will the introduction of TAWS B for IFR aircraft with 6 seats or more be the so called "straw" for some operators? In the paper it states the average cost per aircraft would be around the $23,000 mark. see:
3.6.11 The costs and benefits of mandating TAWS B equipment for IFR aeroplanes
carrying 6 to 9 passengers has been assessed by CASA. Equipment and fitment costs are
forecast to be approximately $23,000 per aeroplane. Options to offset these additional
costs are under consideration by the Government. Benefits are expected to flow to the
industry from increased public confidence with this equipment fit to small aeroplanes in
which passenger operations are conducted, as the overall accident rate is expected to
reduce.
carrying 6 to 9 passengers has been assessed by CASA. Equipment and fitment costs are
forecast to be approximately $23,000 per aeroplane. Options to offset these additional
costs are under consideration by the Government. Benefits are expected to flow to the
industry from increased public confidence with this equipment fit to small aeroplanes in
which passenger operations are conducted, as the overall accident rate is expected to
reduce.
Would the introduction of TAWS B be "that" beneficial to GA?
Is it suited to the types of flying carried out at the GA charter level?
Are there that many CFIT accidents in GA to warrant this sort of outlay by operators?
Don't get me wrong, I'm all for improving safety and preventing accidents, but burdening operators with more costs for these sorts of systems just puts them under more pressure to survive an already cutthroat industry. The money has to come from somewhere!
also this:
The CEO decision to limit passenger
aeroplanes to 9 passenger seats under Part 135 may affect some operators, for example
some operators of Cessna 400 series aeroplanes. The impact is likely to be minor, if any,
as the project team members indicated these aircraft are range limited with more than 9
passengers and it is mostly impractical to roster the aeroplane for the carriage of more
than 9 passengers. It should be noted that the limitation of 9 passenger seats does not
prevent an operator from carrying two infants or children that can be accommodated on
the one passenger seat. CASA is considering a transitional period for affected operators.
aeroplanes to 9 passenger seats under Part 135 may affect some operators, for example
some operators of Cessna 400 series aeroplanes. The impact is likely to be minor, if any,
as the project team members indicated these aircraft are range limited with more than 9
passengers and it is mostly impractical to roster the aeroplane for the carriage of more
than 9 passengers. It should be noted that the limitation of 9 passenger seats does not
prevent an operator from carrying two infants or children that can be accommodated on
the one passenger seat. CASA is considering a transitional period for affected operators.
Are there other areas CASA should be looking at better rather than these?
Thoughts??
Bugsmasherdriverandjediknite
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It certainly falls withing the mandate to get rid of GA. 
As an AOC holder with the 14 seat C208B caravan on it, I think it would indeed impact quite heavily on my operation, if suddenly I have to reduce pax from 13 to 9 and then add an extra $23K worth of equipment.
I guess I will have to remove my thumb and have a look at the NPRM and see in what context it is being proposed, or if they are making any exemptions.
As an AOC holder with the 14 seat C208B caravan on it, I think it would indeed impact quite heavily on my operation, if suddenly I have to reduce pax from 13 to 9 and then add an extra $23K worth of equipment.
I guess I will have to remove my thumb and have a look at the NPRM and see in what context it is being proposed, or if they are making any exemptions.
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There have been a number of CFIT accidents in GA over the past few years.
The ATSB reports have generally recommended the fitting of GPWS/EGPWS equipment to the aircraft, but CASA have not taken action because the costs have been considered too high for minimal gain.
TAWS B is significantly cheaper than TAWS A. If the NPRM goes ahead, then the most common TAWS B solution will most likely be a Garmin 530W, which not only meets the TAWS B requirements, but adds a new VHF Comm, a new VOR and a TSO'd C146a GPS.
Is $23,000 a lot of money? Yes.
Is it that much extra compared to the maintenance on an old Comm/VOR? Not really.
Did it just save my business money if I managed to get in to an airfield with an RNAV approach with lower minimums compared to the NDB approach? Absolutely! (And my customers are happier!)
Will spending $23,000 bring my mate back from a CFIT accident a few years ago? No, but it might stop me losing another friend - in which case it's the cheapest $23,000 I ever spent.
The ATSB reports have generally recommended the fitting of GPWS/EGPWS equipment to the aircraft, but CASA have not taken action because the costs have been considered too high for minimal gain.
TAWS B is significantly cheaper than TAWS A. If the NPRM goes ahead, then the most common TAWS B solution will most likely be a Garmin 530W, which not only meets the TAWS B requirements, but adds a new VHF Comm, a new VOR and a TSO'd C146a GPS.
Is $23,000 a lot of money? Yes.
Is it that much extra compared to the maintenance on an old Comm/VOR? Not really.
Did it just save my business money if I managed to get in to an airfield with an RNAV approach with lower minimums compared to the NDB approach? Absolutely! (And my customers are happier!)
Will spending $23,000 bring my mate back from a CFIT accident a few years ago? No, but it might stop me losing another friend - in which case it's the cheapest $23,000 I ever spent.
$23k ?? How come?
Any of the CFIT accidents that I am aware of would most likely have been prevented by the use of a Garmin 296 with the terrain warning turned on. So OK, its not TSO'd and therefore you can't rely on it in an IFR situation.
A TSO146a Garmin 530W will do the trick - and does not cost $23k. The 430W will also do it, but it does not have the aural warning that the 530 does, so 530W or better is probably the go.
I have flown around a lot with terrain warning in the G430 in the Bo. If you pay attention to the warnings you are unlikely to be a victim of GFIT.
You can fly down the Hinchinbrook Channel at 500' paying attention to the terrain warning on the G430/530 and you will not hit anything!
...... but a Garmin 296 could have prevented the Lockhart R prang!
Dr
PS: Hang on a minute ....... if the plan for ADSB had gone ahead, all or most of the aircraft affected by this proposal would have got heavily subsidised G530W, which includes terrain warning, anyway! Now who was responsible for scuttling that proposal?
Any of the CFIT accidents that I am aware of would most likely have been prevented by the use of a Garmin 296 with the terrain warning turned on. So OK, its not TSO'd and therefore you can't rely on it in an IFR situation.
A TSO146a Garmin 530W will do the trick - and does not cost $23k. The 430W will also do it, but it does not have the aural warning that the 530 does, so 530W or better is probably the go.
I have flown around a lot with terrain warning in the G430 in the Bo. If you pay attention to the warnings you are unlikely to be a victim of GFIT.
You can fly down the Hinchinbrook Channel at 500' paying attention to the terrain warning on the G430/530 and you will not hit anything!
...... but a Garmin 296 could have prevented the Lockhart R prang!
Dr
PS: Hang on a minute ....... if the plan for ADSB had gone ahead, all or most of the aircraft affected by this proposal would have got heavily subsidised G530W, which includes terrain warning, anyway! Now who was responsible for scuttling that proposal?
Bugsmasherdriverandjediknite
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And how useful would it be on a Van........ being a single. IFR is a big job for that aircraft, as it will require ASETPA, so CFIT is unlikely as most will be flown VFR.
Last edited by the wizard of auz; 24th Feb 2009 at 06:34.
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Well it's an NPRM, have a read and submit feedback if you're operating VMC. Wouldn't be a bad suggestion - would be a buggar if you've only got one 430/530, it goes U/S and the aircraft is unusuable. At least then operators would have the option of flying VMC while the unit is repaired/replaced.
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You suggested exactly what I submitted. 
Makes me feel better knowing I am not the only one thinking along those lines.
Makes me feel better knowing I am not the only one thinking along those lines.
Would synthetic vision on the Garmin G1000 suite satisfy the TAWS B rquirement?
Why havent they mandated multi-probe CHT/EGT units on 6 cyl turbo engines.
Not to mention fuel totalizers.
Why havent they mandated multi-probe CHT/EGT units on 6 cyl turbo engines.
Not to mention fuel totalizers.
Last edited by nomorecatering; 24th Feb 2009 at 11:13.
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It will be very interesting how the proposals with affect VFR C208s. My first glance suggests it will be VERY expensive - it's on the list to look at and comment.
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Skydiving ops won't be effected because jumpers are considered bags not pax. I would have thought there were rules about throwing the bags out the door at 10000 feet, but apparently not.
This does look like another stupid CASA reaction to LHR doesn't it?
Walrus
This does look like another stupid CASA reaction to LHR doesn't it?
Walrus
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TAWS B is significantly cheaper than TAWS A. If the NPRM goes ahead, then the most common TAWS B solution will most likely be a Garmin 530W, which not only meets the TAWS B requirements, but adds a new VHF Comm, a new VOR and a TSO'd C146a GPS.
Did it just save my business money if I managed to get in to an airfield with an RNAV approach with lower minimums compared to the NDB approach? Absolutely! (And my customers are happier!)
Did it just save my business money if I managed to get in to an airfield with an RNAV approach with lower minimums compared to the NDB approach? Absolutely! (And my customers are happier!)
Thats a lot of spondula's for the poor operator with a fleet of them, and there are a lot of them still around.
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More scudrunning??
This is obviously admirable and great theory. In fact it is another thing to discourage IFR flying in Australia, and will result in more scudrunning and probably CFITs because people will try to avoid the cost.
We have a crazy culture that tells pilots that IFR flying is very difficult and expensive and only the big operators should be doing it.
This sort of thinking can lead to very undesireable things, and was probably a factor at Lockhart river. IFR flying should be simplified and encouraged if we want to reduce scudrunning.
There is a seneca (or the remains of it) on a mountain in South Australia which was a near new, IFR equipped aircraft owned and flown by a businessman who could afford a rating and flew quite a lot. He did not have an instrument rating and died from a CFIT when trying to use VFR techniques in moderately cloudy weather.
We have a crazy culture that tells pilots that IFR flying is very difficult and expensive and only the big operators should be doing it.
This sort of thinking can lead to very undesireable things, and was probably a factor at Lockhart river. IFR flying should be simplified and encouraged if we want to reduce scudrunning.
There is a seneca (or the remains of it) on a mountain in South Australia which was a near new, IFR equipped aircraft owned and flown by a businessman who could afford a rating and flew quite a lot. He did not have an instrument rating and died from a CFIT when trying to use VFR techniques in moderately cloudy weather.
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CFIT means Head in Sand!
Interesting to note that the ATSB web site cites: “The FAA examined 44 CFIT accidents that occurred between 1985 and 1994 in the US to aircraft with six to 10 passenger seats. Of the 44 aircraft, 11 were powered by turbojets and 33 were powered by turboprops. None of the aircraft were fitted with a GPWS system. Computer modelling techniques used to analyse the data showed that had GPWS been fitted, 33 accidents could have been prevented; had enhanced GPWS been fitted, 42 accidents could have been prevented.” That is a lot of dead people who probably valued their lives at more than $23K!
As avionics become more advanced and affordable why shouldn’t we take advantage of the improved safety offered? The TAWS-B+ includes display as well as aural warnings. The ‘visuals’ provide the first line of defence. Range it down to 5 – 10 miles for take-off and approach / landing then day or night, regardless of the weather, you are provided with a safe flight path if handicapped by engine failure. Further, the high and low peak elevations are also displayed along with conflicting terrain. Just steer away from the red!
TAWS-B provides five warning modes: terrain clearance, imminent impact, premature descent alert, excessive sink rate and negative climb after take-off. Even blind Freddy would be a survivor!
I’m sure operators would rather upgrade the fleet with low cost safety devices than confront the loss and ongoing litigation arising from just one fatal accident.
As avionics become more advanced and affordable why shouldn’t we take advantage of the improved safety offered? The TAWS-B+ includes display as well as aural warnings. The ‘visuals’ provide the first line of defence. Range it down to 5 – 10 miles for take-off and approach / landing then day or night, regardless of the weather, you are provided with a safe flight path if handicapped by engine failure. Further, the high and low peak elevations are also displayed along with conflicting terrain. Just steer away from the red!
TAWS-B provides five warning modes: terrain clearance, imminent impact, premature descent alert, excessive sink rate and negative climb after take-off. Even blind Freddy would be a survivor!
I’m sure operators would rather upgrade the fleet with low cost safety devices than confront the loss and ongoing litigation arising from just one fatal accident.
