Full Industry Defies CASA CTAF Ruling
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Capt Midnight said:
In fact that is an extract of the present AIP, but prior to the recent change re unmarked airfields, the AIP made no mention of marked or unmarked airfields which was in accordance with the NAS introduced over a decade ago, where the MULTICOM was introduced. Much of that, it seems, those in CASA have either forgotten or were unaware of (??).
AIP ENR 1.1 para 44.1:
Quote:
Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own call-sign and, as appropriate, aircraft type, position, actual level and intentions.
The appropriate VHF frequency stated in para 44.1 is:
a. In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discrete CTAF shown (including Broadcast Area CTAF) or otherwise;
b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the Multicom 126.7; or
c. In all other cases, Area VHF.
These procedures have been in place for many (the last 10+?) years. For CASA to try and undo them now would in itself present a safety issue.
Quote:
Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own call-sign and, as appropriate, aircraft type, position, actual level and intentions.
The appropriate VHF frequency stated in para 44.1 is:
a. In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discrete CTAF shown (including Broadcast Area CTAF) or otherwise;
b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the Multicom 126.7; or
c. In all other cases, Area VHF.
These procedures have been in place for many (the last 10+?) years. For CASA to try and undo them now would in itself present a safety issue.
but prior to the recent change
The AIP is clear as to what frequency to use. As I've said - its not rocket science, and the pilots and instructors I associate with understand and comply with it.
Trying to impose a multicom across the whole country up to (say) 3500FT but of necessity needing it to be clear of CTR/CTA/CTAFs/Broadcast Areas/PRD would present its own safety issues and just complicate things further IMHO (and of course, would need a HAZID and safety case).
Captain Nomad: I concede the point you raise, however in those regional areas in most cases the common frequency is for Class G and Class E not the overlying Class A, where it is claimed light aircraft transmissions in Class G might jam a jet's call to ATC or vice versa and cause loss of life.
I don't believe the problem is as big as being made out to be, and as said, if the chatter proves to be a problem in an area or location then there are measures able to be taken.
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I don't believe the problem is as big as being made out to be, and as said, if the chatter proves to be a problem in an area or location then there are measures able to be taken.
I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.
These 3 cannot recieve ATC on the ground.
Yep, I can see how well this is going to work with 100% compliance
The rule change fixed something that wasn't broken...yet again
Yes, the measure should have been to leave it as it was....it worked.
I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.
Yep, I can see how well this is going to work with 100% compliance
The rule change fixed something that wasn't broken...yet again
The rule change fixed something that wasn't broken...yet again
I'm beyond caring.
I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.
These 3 cannot recieve ATC on the ground.
These 3 cannot recieve ATC on the ground.
So what is the problem with those aircraft when taxying making a broadcast on 135.7 like:
"ALL STATIONS, ABC C172 TAXYING AT PRIVATE STRIP 10NM EAST OF WHITTLESEA; ON DEPARTURE TRACKING TO THE NORTH BELOW 5000 OCTA".
- that's them using the most appropriate frequency per AIP;
- other aircraft on 135.7 transiting the area will hear the broadcast, and will if necessary take avoiding action or make two-way contact and arrange same;
- if the level of traffic and associated chatter at this or the other strips develops into a problem, one of the measures previously outlined will be taken.
kFolks,
Just as a reminder, EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166 --- and there is a very broad spectrum of representation at RAPACs ---- doesn't that tell you something.
As Triadic has stated so clearly, the intent of NAS over a decade ago was very clear, CAR 166 was amended for that purpose.
Again, I thing Triadic is on the money, those in CASA who are responsible for this either have forgotten the very good reason for the decisions of that time, or never knew.
One of the really great difficulties in dealing with CASA is the abysmal lack of corporate memory, hence the continual flow of answers to questions that were never asked, the continual flow of solutions to problems that do not exist.
Some of the "reinventing the wheel" that is going on in Certification is another example.
Tootle pip!!
Just as a reminder, EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166 --- and there is a very broad spectrum of representation at RAPACs ---- doesn't that tell you something.
As Triadic has stated so clearly, the intent of NAS over a decade ago was very clear, CAR 166 was amended for that purpose.
Again, I thing Triadic is on the money, those in CASA who are responsible for this either have forgotten the very good reason for the decisions of that time, or never knew.
One of the really great difficulties in dealing with CASA is the abysmal lack of corporate memory, hence the continual flow of answers to questions that were never asked, the continual flow of solutions to problems that do not exist.
Some of the "reinventing the wheel" that is going on in Certification is another example.
Tootle pip!!
EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166
I don't recall it being discussed, nor can I find any mention of CAR 166 discussions in ACT, NSW, SQLD or WA RAPAC minutes at all from the current minutes back to 2007, except when the NPRM was released for comment back in 2009.
CAR 166 discussions are only mentioned in the Victoria RAPAC minutes in July & October last year and March this year (apart from back in 2009 when the NPRM was released for comment).
Last edited by CaptainMidnight; 11th May 2015 at 01:57.
Midnight,
Perhaps Triadic can help.
I certainly contributed to the N.Qld. discussions, and was made aware of other discussions that all came to the same conclusion, resulting, as I understand it, in a letter to CASA, but as far as I know, all the RAPACs were polled on the issue.
Nothing changes the fact that the long standing AND INTENDED interpretation has been upended by CASA, without any meaningful consultation, and apparently without any knowledge or understanding of the background to the long standing usage.
As Triadic say, more than a decade.
Nothing can justify what CASA has unilaterally done.
Tootle pip!!
Perhaps Triadic can help.
I certainly contributed to the N.Qld. discussions, and was made aware of other discussions that all came to the same conclusion, resulting, as I understand it, in a letter to CASA, but as far as I know, all the RAPACs were polled on the issue.
Nothing changes the fact that the long standing AND INTENDED interpretation has been upended by CASA, without any meaningful consultation, and apparently without any knowledge or understanding of the background to the long standing usage.
As Triadic say, more than a decade.
Nothing can justify what CASA has unilaterally done.
Tootle pip!!
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As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.
When the matter was raised with the OAR for discussion at the RAPACs it was rejected as not being an airspace matter.
For about the last year, all of the Industry RAPAC Convenors have been canvassed and included in a string of emails on the matter. There have over this time been a number of attempts to table the MULTICOM for discussion, but the subject has been rejected by the OAR.
Discussions have been held out of session as the OAR has refused to include the subject at the RAPACs and therefore it is unlikely you will find mention in the minutes, even when it was discussed, even briefly. The management of the OAR have to take responsibility for this debacle. Even correspondence from CASA has not addressed the subject in any detail or the safety issues that have been raised. As if they just don’t want to know?
Things seem to be changing somewhat since the new DAS entered the building and the MULTICOM has been subject to some further discussion of late. One can only hope that those responsible for this change are directed to place the matter on the table for open discussion, especially with the RAPACs.
When the matter was raised with the OAR for discussion at the RAPACs it was rejected as not being an airspace matter.
For about the last year, all of the Industry RAPAC Convenors have been canvassed and included in a string of emails on the matter. There have over this time been a number of attempts to table the MULTICOM for discussion, but the subject has been rejected by the OAR.
Discussions have been held out of session as the OAR has refused to include the subject at the RAPACs and therefore it is unlikely you will find mention in the minutes, even when it was discussed, even briefly. The management of the OAR have to take responsibility for this debacle. Even correspondence from CASA has not addressed the subject in any detail or the safety issues that have been raised. As if they just don’t want to know?
Things seem to be changing somewhat since the new DAS entered the building and the MULTICOM has been subject to some further discussion of late. One can only hope that those responsible for this change are directed to place the matter on the table for open discussion, especially with the RAPACs.
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Ok,
Reword it to, The decision made. should have been...........
Out here in the Yarra Valley, we have several strips that are within the Lilydale/Coldstream (or Yarra Valley if you like) CTAF. They have an overlying CTAF...or if you wish to be pedantic, are inside the Yarra Valley CTAF, and therefore should operate on 119.1
By saying they have no 'overlying ctaf' I also mean other airspace classes, except G. In G under the current rule, they should be on the Area Freq...
Quoting Captain Midnight, and myself
You are correct, ATC won't hear them. The crux is that the lil guy on the ground cannot hear ATC as well. He would be clueless that he is Tx over the top of ATC..the jet over the top can certainly hear him! Its that info suppressed by a guy trying to comply with the rules that generates a problem.
His compliance with the rules, especially so close to a control zone, means that he is likely to transmit over important information intended for people that need it.
Says it all really
Yes, the measure should have been to leave it as it was....it worked.
Raising the questions: what was "the measure" and what did it do that "worked"?
Raising the questions: what was "the measure" and what did it do that "worked"?
What in heaven's name does "no overlying CTAF" mean?
By saying they have no 'overlying ctaf' I also mean other airspace classes, except G. In G under the current rule, they should be on the Area Freq...
Quoting Captain Midnight, and myself
I know of 3 unmarked strips within the Melbourne Basin, that have no overlying CTAF and their location puts them on 135.7...there are probably more.
These 3 cannot recieve ATC on the ground.
So it is unlikely ATC will hear them, and 135.7 is FIA SFC - base of CTA.
So what is the problem with those aircraft when taxying making a broadcast on 135.7 like:
These 3 cannot recieve ATC on the ground.
So it is unlikely ATC will hear them, and 135.7 is FIA SFC - base of CTA.
So what is the problem with those aircraft when taxying making a broadcast on 135.7 like:
His compliance with the rules, especially so close to a control zone, means that he is likely to transmit over important information intended for people that need it.
As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.
They are, however, generally combined so that an ATC controlling CTA (remember that one?) also has the Class G frequencies merged.
Putting my grandpa hat on, I remember many years ago having an ATC sit in on my FS console for a famil, and him being amazed at all the radio chatter on the Area Freq. "How do you put up with that for a whole shift?"
Just so I can understand what "full industry defiance of the CASA CTAF ruling" means, is it just that everyone is using 126.7 as the default frequency for strips that aren't marked on the charts?
If so, and that's the safer approach, why all the fuss? All this protest would seem to be so much sound and fury, signifying nothing, given that everyone is ignoring CASA and continuing to do the safer thing.
When something in aviation doesn't make sense to me, I immediately get a whiff of the stench of politics or industrial relations or some other nefarious explanation.
What is all this really about?
Don't tell me: "Safety".
If so, and that's the safer approach, why all the fuss? All this protest would seem to be so much sound and fury, signifying nothing, given that everyone is ignoring CASA and continuing to do the safer thing.
When something in aviation doesn't make sense to me, I immediately get a whiff of the stench of politics or industrial relations or some other nefarious explanation.
What is all this really about?
Don't tell me: "Safety".
the jet over the top can certainly hear him!
As I said earlier, how Airservices manages its frequencies and operating positions (i.e. resulting in retransmitting FIA onto frequencies used for CTA and vice versa) is not your problem. You need to comply with CAR 166 and AIP. If you don't, in the event of an incident, CASA may skin you -
I also make the point that the retransmission situation is not the fault of ATC. Its the result of their having to deal with staffing & workload constraints imposed on them by Airservices.
I think it is more about the majority of the GA community exercising 'Common Sense' and doing the practical thing.
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I'm certain most aren't talking on Area Freq's at unmarked strips however they are certainly listening, myself included. I used to transmit rolling calls from mine when I first started flying & only ever got one reply from a Cathay Pacific at a FL overhead advising that I shouldn't be a problem for him. Over the years I simply dispensed with it & use my eyes (& still my ears) now.
Last weekend a group of 12 aircraft flew to a farm strip just outside of Tamworth & we all agreed before departing that we would communicate on MULTICOM. It worked well & Brisbane & everyone else (except for the other NW airfields using 126.70) weren't bothered by us. Just made sense to all involved & we did discuss the fact it was not what was required.
I am organising a fly in to a private unmarked on charts strip shortly & I have advised everyone to use 126.70. Why? Expecting maybe 40 or 50 AC to arrive during a 1 hour period. Imagine the congestion on Area Frequency during that period. Certainly no doubt 90% of them will have dual monitoring anyway & be listening still on area.
Just seems to be common sense to me but maybe I (& others) have it wrong
Last weekend a group of 12 aircraft flew to a farm strip just outside of Tamworth & we all agreed before departing that we would communicate on MULTICOM. It worked well & Brisbane & everyone else (except for the other NW airfields using 126.70) weren't bothered by us. Just made sense to all involved & we did discuss the fact it was not what was required.
I am organising a fly in to a private unmarked on charts strip shortly & I have advised everyone to use 126.70. Why? Expecting maybe 40 or 50 AC to arrive during a 1 hour period. Imagine the congestion on Area Frequency during that period. Certainly no doubt 90% of them will have dual monitoring anyway & be listening still on area.
Just seems to be common sense to me but maybe I (& others) have it wrong
Expecting maybe 40 or 50 AC to arrive during a 1 hour period.
Contact your local CASA area office, advise them of the situation and ask for a discrete CTAF to be allocated. There are frequencies reserved for fly-ins, airshows etc. Given the discrete frequency and in particular the level of traffic, CASA would issue a NOTAM ("INCREASED TFC IN THE XXX AREA DUE FLY-IN etc.".).
It is - unwise - to decide to not comply with published rules and procedures. In the event of an incident .........
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Contact your local CASA area office, advise them of the situation and ask for a discrete CTAF to be allocated. There are frequencies reserved for fly-ins, airshows etc. Given the discrete frequency and in particular the level of traffic, CASA would issue a NOTAM ("INCREASED TFC IN THE XXX AREA DUE FLY-IN etc.".).
I know one person with an airstrip at his house where an ATO decided it was a good place to have students demonstrate precautionary searches - to his and his neighbor's displeasure.
Any significant danger of collision at an unmarked strip is with other traffic using the strip or others in the same area - not with traffic in cruise on the area frequency.
There are existing measures to deal with that sort of situation.
Which of the hourly rates do you think CASA would levy for such an application, the $130 p/h or does it need expert technical consideration, at $190 p/h, and for how many hours. As I assume you know, it is not just a matter of applying to Airservices.
Why don't you just accept the fact that CASA has got it wrong, as a Prince of Process yourself, you should understand that CASA did NOT undertake the process they should have, including a safety case for such a fundamental change in "interpretation" of CAR 166.
That OAR ( or whatever it is called now) have put so much effort into assuring the matter is not "officially" discussed should tell you something.
Tootle pip!!