Merged: The Ambidji Report – CASA should get their money back!
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Merged: The Ambidji Report – CASA should get their money back!
Many readers of this forum will remember the “UTILITY OF GENERAL AVIATION AERODROME PROCEDURES TO AUSTRALIAN ADMINISTERED AIRSPACE, Report to Office of Airspace Regulation 30 June 2009”, referred to in short as the “Ambidji Report”.
From this Report came the statement that
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world. For example, there has been one mid-air in the Bankstown control zone in a forty year period – and this happened because a pilot inadvertently overshot the base turning point for landing on a runway when parallel runways were in use.
Naturally, CASA had to act on the Ambidji Report’s emotive claim that the risk was "intolerable".
I have commissioned three independent Reviews of the Ambidji Report. I paid for these reviews myself, having chosen Consultants who had no vested interest and no conflict of interest. The Consultants who reviewed the Ambidji report were:
I have placed the three Reviews on my website (see here).
Each of these Consultants disagreed with the methodology and the results of the Ambidji Report. Professor Middleton said in a separate email to me that:
In Professor Middleton’s Review itself, he states:
Chris Mills states in his Review, among other points:
Ian Bryce, who has performed risk analysis of space launching programs, states in his Review:
Readers of this website will be staggered. Can you imagine that an independent expert has stated, I repeat, that “the changes described could even increase risk”?
I suggest that everyone applies themselves to reading these Reviews.
It seems such a pity that the type of errors that were made in safety studies by Airservices Australia have now continued through to the Office of Airspace Regulation.
From this Report came the statement that
"...risks associated with GAAP operations at Bankstown, Jandakot and Moorabbin are intolerable when compared with the CASA risk criteria”.
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world. For example, there has been one mid-air in the Bankstown control zone in a forty year period – and this happened because a pilot inadvertently overshot the base turning point for landing on a runway when parallel runways were in use.
Naturally, CASA had to act on the Ambidji Report’s emotive claim that the risk was "intolerable".
I have commissioned three independent Reviews of the Ambidji Report. I paid for these reviews myself, having chosen Consultants who had no vested interest and no conflict of interest. The Consultants who reviewed the Ambidji report were:
Ian Bryce, BE, BSc
Springside Engineering
Professor Jason Middleton,
Head, Department of Aviation
University of New South Wales
Chris Mills, AM, MSc, BSc
Former Wing Commander with the RAAF
Springside Engineering
Professor Jason Middleton,
Head, Department of Aviation
University of New South Wales
Chris Mills, AM, MSc, BSc
Former Wing Commander with the RAAF
I have placed the three Reviews on my website (see here).
Each of these Consultants disagreed with the methodology and the results of the Ambidji Report. Professor Middleton said in a separate email to me that:
"There appears to be a lack of high level expertise in the evaluation of risk in this case, so that CASA OAR is perhaps less well briefed than it might be by the Ambidgi report"
In Professor Middleton’s Review itself, he states:
"An analysis made from a different perspective might easily arrive at different conclusions and recommendations...It is recommended here that the entire Ambidji report be peer reviewed by independent reviewers"
Chris Mills states in his Review, among other points:
"Conclusion. Not conducting significance tests, and immediately treating a ‘cluster’ as a ‘trend’, leads to investigations that are, in all probability, a non-sense. This activity can lead to interventions that are not necessary or justified, and usually result in imposing restrictions that have little or no relevance to the actual level of aviation safety"
Ian Bryce, who has performed risk analysis of space launching programs, states in his Review:
"Individual Risk: Given that the assumptions and the calculations for the risk contain several errors or uncertainties of factors of 0.5 or 2, the conclusions on individual risk are invalid… The claimed dramatic reductions in MACs [mid-air collisions] are without real evidence. The changes described could even increase risk"
Readers of this website will be staggered. Can you imagine that an independent expert has stated, I repeat, that “the changes described could even increase risk”?
I suggest that everyone applies themselves to reading these Reviews.
It seems such a pity that the type of errors that were made in safety studies by Airservices Australia have now continued through to the Office of Airspace Regulation.
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
It was my understanding you wanted FAA or ICAO Class D for these airports -
Thread Starter
Yes, FAA style D which will have no detrimental effect if the correct terminology and procedures are utilised.
After all. GAAP was copied off US class D.
After all. GAAP was copied off US class D.
Last edited by Dick Smith; 27th Aug 2009 at 03:01.
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Personally, Dick, I'm a little confused. If, as you state
, why would they need to change to US FAA Class D?
I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
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I think what Dick is saying is that the move from GAAP to US Class D (which he is in favour of), is a different issue to the restrictions of traffic, the increased opening hours and the staffing issues that this will create.
There is very little link between what Dick is/was arguing for, and the recommendations of this report and/or the implementation CASA has ordered.
That is my understanding of this whole mess.
There is very little link between what Dick is/was arguing for, and the recommendations of this report and/or the implementation CASA has ordered.
That is my understanding of this whole mess.
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Dick is absolutely correct.
This is a case of CASA getting an organisation with no valid qualification to do such an analysis and this clearly shows with the methodolgy used and outcomes recommended from the flawed analysis.
You can almost be assured this was a job for the retired boys from CASA/Airservices now working within Ambidji that were given directions as to what outcome to justify.
This is a case of CASA getting an organisation with no valid qualification to do such an analysis and this clearly shows with the methodolgy used and outcomes recommended from the flawed analysis.
You can almost be assured this was a job for the retired boys from CASA/Airservices now working within Ambidji that were given directions as to what outcome to justify.
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I have a friend who got his PPL at the same time as I did in the US, then spent 3 years working in Melbourne. Th clincher for him in his decision not to fly here was the astonishing news that you needed a clearance to cross a non-active runway at a Class C airport. He would (I expect) be greatly amused that such bizarre restrictions have been extended to airports supposedly less restrictive than Class D!
I think that what has got Dick's back up is CASA trumpeting that NAS is the go, then implementing something that moves further away from the NAS model. Exactly the sort of unjustified and random restrictiveness that has grown like topsy into the system we have today. Some buffoon has used a report as science fiction as the one supporting the NAS claims to implement his personal portion of the Nanny State.
I think that what has got Dick's back up is CASA trumpeting that NAS is the go, then implementing something that moves further away from the NAS model. Exactly the sort of unjustified and random restrictiveness that has grown like topsy into the system we have today. Some buffoon has used a report as science fiction as the one supporting the NAS claims to implement his personal portion of the Nanny State.
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No offence intended, Starts with p, but I think that Dick is quite capable of responding himself. So I'd put the question again, but add a further coment about unnecessary costs, which is another issue with which I am in agreement with Dick.
Dick says:
He then goes on to say that, yes he wants FAA Class D.
If former GAAP procedures were so safe and we want to avoid unnecessary costs to industry (re-training controllers, changing charts, changing pubs, mounting a pilot education campaign, priniting more glossy brochures etc) in our 'user-pays' environment, what is the point. The only conclusion that I can draw is that it's change for change sake.
With respect to the decision on GAAP, my take is that CASA thought they had to be seen to be doing 'something' (anything), given the amount of stick they take on an almost daily basis. And, like the Skippy in the truck's headlights, CASA blinked and jumped the wrong way.
Dick says:
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
If former GAAP procedures were so safe and we want to avoid unnecessary costs to industry (re-training controllers, changing charts, changing pubs, mounting a pilot education campaign, priniting more glossy brochures etc) in our 'user-pays' environment, what is the point. The only conclusion that I can draw is that it's change for change sake.
With respect to the decision on GAAP, my take is that CASA thought they had to be seen to be doing 'something' (anything), given the amount of stick they take on an almost daily basis. And, like the Skippy in the truck's headlights, CASA blinked and jumped the wrong way.
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No offence taken Howbout. I look forward to Dick's response... Maybe in a thread about US Class D vs GAAP rather than one about the validity of the Ambidji report. Maybe you could start it?
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The Facts Please Dick
Dick:
For your information, in the last 40 years there have been exactly 5 (maybe 6) instances of MACs at Bankstown airport or Bankstown airspace, viz:
1971: C182/C150 (non fatal)
1974: DH104/PA30 (fatal)
1975: PA30/C182 collision (non-fatal)
2002 : PA28/TB9 (fatal)
2008 : C152/Liberty XL (fatal)
Even your experts have mentioned this fact in their reports. Don't you read what you pay for?
That doesn't sound like an independent review to me! Whilst it is good for overall aviation safety that you have taken the personal initiative to solicit more reviews of this very important subject, please don't try and snowball us by implying its an independent review. It's a bit like Philip Morris hiring consultants to confirm that smoking cigarettes has no adverse health impacts on young children.
Sounds like you are implying CASA's consultant MAY HAVE a conflict of interest. If so what is it? You should be aware from your own experience inside CASA that all government bodies undertake extensive evaluation processes to ensure they are protected from potential COI accusations.
For example, there has been one mid-air in the Bankstown control zone in a forty year period – and this happened because a pilot inadvertently overshot the base turning point for landing on a runway when parallel runways were in use.
1971: C182/C150 (non fatal)
1974: DH104/PA30 (fatal)
1975: PA30/C182 collision (non-fatal)
2002 : PA28/TB9 (fatal)
2008 : C152/Liberty XL (fatal)
Even your experts have mentioned this fact in their reports. Don't you read what you pay for?
I have commissioned three independent Reviews of the Ambidji Report. I paid for these reviews myself
....having chosen Consultants who had no vested interest and no conflict of interest.
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Frank
Technically it did not happen in the GAAP, however if you consider that it has been pushed home hard in the recent safety education that even when you are transiting in proximity of the GAAP zone you should do certain things, and at the reporting points you are still not actually in the GAAP, you may need to encompass a little more real estate into the study, if you want to have a true picture.
J
Technically it did not happen in the GAAP, however if you consider that it has been pushed home hard in the recent safety education that even when you are transiting in proximity of the GAAP zone you should do certain things, and at the reporting points you are still not actually in the GAAP, you may need to encompass a little more real estate into the study, if you want to have a true picture.
J
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Starts with P, thanks. I see where you're coming from with respect to GAAP vs US D, but Dick made the comment up-front in this thread that I quoted previously:
But he now appears to be advocating the imposition of unnecessary costs by changing a 'proven system' that provides 'some of the safest procedures that I have experienced in the world,' with US Class D. Once again, Dick raised this, not me. So, once again, I ask to what end, other than pursuing some ideological end-state that will have dubious safety outcomes (if Dick is correct regarding
So what we're left with is more change fatigue, increased costs and dubious safety benefits, if Dick is correct when he says
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
Thread Starter
Clarification: When I initially approached staff at the University of New South Wales to commission a Review of the Ambidji Report, I offered the University payment of up to $2,000 to cover associated cost. To date, the University has elected not to receive payment, however my offer stands.
And to others, I was clearly referring to mid airs "in the bankstown control zone".
And to others, I was clearly referring to mid airs "in the bankstown control zone".
Last edited by Dick Smith; 27th Aug 2009 at 06:08.
Thread Starter
Howabout,
To change to US Class D at Bankstown and other GAAP airports there is no measurable cost. This will then mean that all non-radar tower airports will have the same simple procedures – as per the USA and Canada.
Some will claim that in Australian GAAP airports we do not provide a separation service between IFR aircraft when in VMC. If one or other of the pilots uses the correct terminology, in US Class D a separation service is not provided.However if both pilots believe that safety requires full IFR separation in VMC they can get it.
I say again, by moving to US Class D at all of our non-radar tower airports we will standardise the system throughout Australia; reduce the ridiculous frequency clogging of a VFR departure call at non-GAAP Class D towers and make other improvements.
To change to US Class D at Bankstown and other GAAP airports there is no measurable cost. This will then mean that all non-radar tower airports will have the same simple procedures – as per the USA and Canada.
Some will claim that in Australian GAAP airports we do not provide a separation service between IFR aircraft when in VMC. If one or other of the pilots uses the correct terminology, in US Class D a separation service is not provided.However if both pilots believe that safety requires full IFR separation in VMC they can get it.
I say again, by moving to US Class D at all of our non-radar tower airports we will standardise the system throughout Australia; reduce the ridiculous frequency clogging of a VFR departure call at non-GAAP Class D towers and make other improvements.
Dick, I think that the Bankstown data is not the only location that has had questionable data incorporated into the report. They seem to have included off GAAP and a MAC during MBZ procedures at Jandakot in their analysis.
As operators, we need to know exactly what the impact of the introduction of Class D (US type or otherwise) is going to have on our ability to continue function. There are quite a few GA schools around at the moment thinking this might well be the final nail in the coffin.
Is there any truth to the rumour that our new CASA director came up with the magic number of 6 in the circuit because that is what the military use?
As operators, we need to know exactly what the impact of the introduction of Class D (US type or otherwise) is going to have on our ability to continue function. There are quite a few GA schools around at the moment thinking this might well be the final nail in the coffin.
Is there any truth to the rumour that our new CASA director came up with the magic number of 6 in the circuit because that is what the military use?
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Sorry Dick, but that doesn't cut it. I quote again:
Why change if the system was so good? Your words!
And I disagree that there will be 'no measurable cost.' Every change we experience has a 'measurable cost.'
However, I think you have taken some unjustified criticism regarding independent analysis. While I do not know two of the gentlemen, I have certainly read a risk dissertation by Mr Chris Mills that he produced some time ago on 'Parachuting Through Cloud.' It was tabled at a RAPAC and, while I'm not a risk management expert, I thought it was a very fine piece of work.
In short, and regardless of whether he was paid or not, his analysis has stood the test of time. Accusations that he'd give you an answer that you want, because you paid him, are, in my opinion, grossly unfair.
That does not alter the fact that US D vs GAAP is a waste of time and resources. I remind you again:
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.
And I disagree that there will be 'no measurable cost.' Every change we experience has a 'measurable cost.'
However, I think you have taken some unjustified criticism regarding independent analysis. While I do not know two of the gentlemen, I have certainly read a risk dissertation by Mr Chris Mills that he produced some time ago on 'Parachuting Through Cloud.' It was tabled at a RAPAC and, while I'm not a risk management expert, I thought it was a very fine piece of work.
In short, and regardless of whether he was paid or not, his analysis has stood the test of time. Accusations that he'd give you an answer that you want, because you paid him, are, in my opinion, grossly unfair.
That does not alter the fact that US D vs GAAP is a waste of time and resources. I remind you again:
Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world.