CASA Class G Discussion Paper
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"theoretically impossible to collide" might be a particularly unreliable standard for aircraft maneuvering in 3 dimensions. I suspect it does actually comply with ATC separation standards, if it can be reliably determined.
Pilots have been self-separating in IMC in Australia since before Dick twiddled his first knob.
They do it by using a mix of Company procedures, maths and common sense.
If they were supposed to keep to ATC Sep Standards, they would need to complete an ATC course...or....you provide ATC to maintain the standards.
The success of their efforts can be seen by reviewing the number of collisions between IFR aircraft in uncontrolled airspace....it seems to work.
They do it by using a mix of Company procedures, maths and common sense.
If they were supposed to keep to ATC Sep Standards, they would need to complete an ATC course...or....you provide ATC to maintain the standards.
The success of their efforts can be seen by reviewing the number of collisions between IFR aircraft in uncontrolled airspace....it seems to work.
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The following is quoted from the RAAus December Newsletter......
CASA survey action required by 12 January 2018 - MULTICOM
Members are advised CASA have issued a Notice of Proposed Rule Making (NPRM) MULTICOM frequency use after the recent consultation process in which the majority of respondents indicated the MULTICOM frequency was their preferred option below 5000’ Above Mean Sea Level (AMSL). We are requesting all members complete the survey and provide a response to CASA on this important topic.
The NPRM is worded poorly, making two recommendations in one response. As one of these recommendations was not part of the original consultation process we advise members that RAAus fully supports only one part of this proposal.
CASA have proposed MULTICOM frequency 126.7 is monitored and used in uncontrolled airspace below 5000’ Above Mean Sea Level (AMSL) where there is no discrete frequency or broadcast area. Above 5000’ AMSL the area frequency would be monitored. This proposal is completely acceptable to RAAus.
The other proposal is to increase the size of a CTAF from the current recommended 10 nm to 20 nm. This is unacceptable to RAAus and its members for a variety of reasons, including the quadrupling of area requiring the CTAF frequency to be used, significantly increasing the risk of radio frequency congestion, the unavoidable inclusion of private airstrips or fields which were previously outside the CTAF, which would require aircraft to now carry radio. Further the CAAP recommends inbound traffic make relevant situationally required radio calls relative to the speed and type of operation of the aircraft. Inbound Regular Passenger Transport (RPT) aircraft routinely make calls 30-40 nm outside the CTAF, which should be continued. Accordingly, RAAus strongly objects to the portion of the NPRM to increase the size of CTAFs.
RAAus members are strongly encouraged to complete this survey, however members need to consider the difficulty presented by the NPRM combining these two questions into one response. This requires the respondent to answer no to the MULTICOM part of the proposal to avoid the increase in CTAF component. RAAus therefore recommends the following course of action by all RAAus members.
1. Follow this link CASA MULTICOM NPRM
2. Answer the identification questions as you believe appropriate
3. For the next question you will be asked if you prefer the MULTICOM and CTAF increase. Your initial answer should be “Proposal is NOT acceptable” and in the additional information box below, you should add words to the effect “I only accept the MULTICOM Proposal below 5000 feet AMSL”
4. You will be prompted during the next question to provide your answer as to why the CTAF size increase is not acceptable. RAAus recommend you provide words to the effect “There has been no safety case or risk assessment regarding the proposal to expand a CTAF size to 20 nm. This was not part of the original MULTICOM consultation process. CAAP 166 provides guidance for pilots to make appropriate calls relevant to the aircraft type and speed of operation. Expanding CTAFs to 20 nm will enlarge the potential area requiring calls by a factor of 4, potentially leading to additional congestion in CTAFs.”
5. Complete the remainder of the questions as relevant to your aircraft type and submit
RAAus has raised our concerns about the combination of the two distinct and separate questions with CASA and will continue to inform members about further progress related to MULTICOM changes in the New Year.
Members are advised CASA have issued a Notice of Proposed Rule Making (NPRM) MULTICOM frequency use after the recent consultation process in which the majority of respondents indicated the MULTICOM frequency was their preferred option below 5000’ Above Mean Sea Level (AMSL). We are requesting all members complete the survey and provide a response to CASA on this important topic.
The NPRM is worded poorly, making two recommendations in one response. As one of these recommendations was not part of the original consultation process we advise members that RAAus fully supports only one part of this proposal.
CASA have proposed MULTICOM frequency 126.7 is monitored and used in uncontrolled airspace below 5000’ Above Mean Sea Level (AMSL) where there is no discrete frequency or broadcast area. Above 5000’ AMSL the area frequency would be monitored. This proposal is completely acceptable to RAAus.
The other proposal is to increase the size of a CTAF from the current recommended 10 nm to 20 nm. This is unacceptable to RAAus and its members for a variety of reasons, including the quadrupling of area requiring the CTAF frequency to be used, significantly increasing the risk of radio frequency congestion, the unavoidable inclusion of private airstrips or fields which were previously outside the CTAF, which would require aircraft to now carry radio. Further the CAAP recommends inbound traffic make relevant situationally required radio calls relative to the speed and type of operation of the aircraft. Inbound Regular Passenger Transport (RPT) aircraft routinely make calls 30-40 nm outside the CTAF, which should be continued. Accordingly, RAAus strongly objects to the portion of the NPRM to increase the size of CTAFs.
RAAus members are strongly encouraged to complete this survey, however members need to consider the difficulty presented by the NPRM combining these two questions into one response. This requires the respondent to answer no to the MULTICOM part of the proposal to avoid the increase in CTAF component. RAAus therefore recommends the following course of action by all RAAus members.
1. Follow this link CASA MULTICOM NPRM
2. Answer the identification questions as you believe appropriate
3. For the next question you will be asked if you prefer the MULTICOM and CTAF increase. Your initial answer should be “Proposal is NOT acceptable” and in the additional information box below, you should add words to the effect “I only accept the MULTICOM Proposal below 5000 feet AMSL”
4. You will be prompted during the next question to provide your answer as to why the CTAF size increase is not acceptable. RAAus recommend you provide words to the effect “There has been no safety case or risk assessment regarding the proposal to expand a CTAF size to 20 nm. This was not part of the original MULTICOM consultation process. CAAP 166 provides guidance for pilots to make appropriate calls relevant to the aircraft type and speed of operation. Expanding CTAFs to 20 nm will enlarge the potential area requiring calls by a factor of 4, potentially leading to additional congestion in CTAFs.”
5. Complete the remainder of the questions as relevant to your aircraft type and submit
RAAus has raised our concerns about the combination of the two distinct and separate questions with CASA and will continue to inform members about further progress related to MULTICOM changes in the New Year.
[T]he unavoidable inclusion of private airstrips or fields which were previously outside the CTAF, which would require aircraft to now carry radio.
I have to say I do wonder why anyone poked this bear in the first place. Everyone that’s been paying attention already knew that it’s a stupid animal that wallows in expensive self-serving complexity that is not justified on a risk/cost benefit basis.
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Exactly, LB. "Come in spinner" seems particularly appropriate here.
My overall comments on the draft RAPAC submission I have seen are that it is too long, suffers from repetition, and does not clearly articulate the issues in terms that a Minister might understand.
I also think RAPAC and many others whose contributions I have read have been blindsided by what appears to be two clear cut choices, rather than taking a wider view.
That said, I support absolutely the concerns expressed about the proposed doubling of the radius of CTAF's. I also give conditional support to a limited change in frequencies but continue to hold grave doubts about 126.7 as the ultimate in choices for the following reasons:
1. The unmarked airfield bogey
The stated prime issue has been the decision to nominate Area frequency for those aviating at unmarked airfields outside of existing CTAF boundaries. Surely, if there is so much traffic associated with unmarked airfields the first step to improve safety is to mark more of them so pilots know they are there? Why hasn't RAPAC mentioned this?
Step 2 is to nominate 126.7 as the frequency for all ALA's that don't have a discrete other frequency, including those that are marked. There is hardly a VFR pilot flying now that doesn't have OzRunways or similar so responding to the presence of all marked strips will be routine. Licensed aerodromes are already well covered except some need to move from 126.7 to a new assigned frequency to reduce the prospect of over-transmissions. There will be few strips remaining of any substance that are not identified on the charts.
2. The best frequency Outside CTAF boundaries
My view remains that Area is the most appropriate prime frequency for VFR outside the boundaries of CTAFs, both existing and new. The reduction in unmarked fields should leave our concerns with only the least active; those that continue to be unmarked.
Radar assisted conflict avoidance on Area is available to VFR and I have had the benefit of it on at least a couple of occasions. If someone is departing their unmarked ALA at some obscure location, how the heck will the passing pilot know if it is relevant to her? Does the departing pilot tie up the frequency (126.7 now being used by all and sundry) with a detailed description of their location....GPS coords, distance and bearing from, plan including height and track and the state of the nation? That's not helpful to the myriad of other people "listening" to the frequency. I suggest many will just switch off, either mentally or literally.
3. No radio VFR and single listening watch
The issue of no radio flights isn't resolved by this change but it may very well lead to mandated radio which would be difficult for a number of old aircraft (and pilots?). Perhaps that would suit CASA's aspirations?
A lot of us are flying with radios that do not have dual watch. I'm one of those at the present time and I know my strong preference is to fly with Area away from CTAF's. I will upgrade when I can but Area will continue to be my first choice.
4. Area boundaries marked
The stuff circulating about this is beyond belief. I happily change frequencies moving across boundaries whether Area or CTAF and so is just about everyone else. And I certainly don't want to see an increase in the amount of E at the expense of G which is getting heaps of lobbying support from the biggies even though I run a Tx mode C.
5. Increased CTAF volume and definition.
Ridiculous! Totally unworkable as even next door's donkey would tell them.
Leave the bloody thing alone...change just increases the hazards of non-compliance due confusion, anyway.
Personally, I prefer the 10 NM distance with an ETA circuit rather than a specified time to circuit. The Kingair arriving at 200 knots knows exactly where I am, anyway.
Kaz (stoking the fire)
My overall comments on the draft RAPAC submission I have seen are that it is too long, suffers from repetition, and does not clearly articulate the issues in terms that a Minister might understand.
I also think RAPAC and many others whose contributions I have read have been blindsided by what appears to be two clear cut choices, rather than taking a wider view.
That said, I support absolutely the concerns expressed about the proposed doubling of the radius of CTAF's. I also give conditional support to a limited change in frequencies but continue to hold grave doubts about 126.7 as the ultimate in choices for the following reasons:
1. The unmarked airfield bogey
The stated prime issue has been the decision to nominate Area frequency for those aviating at unmarked airfields outside of existing CTAF boundaries. Surely, if there is so much traffic associated with unmarked airfields the first step to improve safety is to mark more of them so pilots know they are there? Why hasn't RAPAC mentioned this?
Step 2 is to nominate 126.7 as the frequency for all ALA's that don't have a discrete other frequency, including those that are marked. There is hardly a VFR pilot flying now that doesn't have OzRunways or similar so responding to the presence of all marked strips will be routine. Licensed aerodromes are already well covered except some need to move from 126.7 to a new assigned frequency to reduce the prospect of over-transmissions. There will be few strips remaining of any substance that are not identified on the charts.
2. The best frequency Outside CTAF boundaries
My view remains that Area is the most appropriate prime frequency for VFR outside the boundaries of CTAFs, both existing and new. The reduction in unmarked fields should leave our concerns with only the least active; those that continue to be unmarked.
Radar assisted conflict avoidance on Area is available to VFR and I have had the benefit of it on at least a couple of occasions. If someone is departing their unmarked ALA at some obscure location, how the heck will the passing pilot know if it is relevant to her? Does the departing pilot tie up the frequency (126.7 now being used by all and sundry) with a detailed description of their location....GPS coords, distance and bearing from, plan including height and track and the state of the nation? That's not helpful to the myriad of other people "listening" to the frequency. I suggest many will just switch off, either mentally or literally.
3. No radio VFR and single listening watch
The issue of no radio flights isn't resolved by this change but it may very well lead to mandated radio which would be difficult for a number of old aircraft (and pilots?). Perhaps that would suit CASA's aspirations?
A lot of us are flying with radios that do not have dual watch. I'm one of those at the present time and I know my strong preference is to fly with Area away from CTAF's. I will upgrade when I can but Area will continue to be my first choice.
4. Area boundaries marked
The stuff circulating about this is beyond belief. I happily change frequencies moving across boundaries whether Area or CTAF and so is just about everyone else. And I certainly don't want to see an increase in the amount of E at the expense of G which is getting heaps of lobbying support from the biggies even though I run a Tx mode C.
5. Increased CTAF volume and definition.
Ridiculous! Totally unworkable as even next door's donkey would tell them.
Leave the bloody thing alone...change just increases the hazards of non-compliance due confusion, anyway.
Personally, I prefer the 10 NM distance with an ETA circuit rather than a specified time to circuit. The Kingair arriving at 200 knots knows exactly where I am, anyway.
Kaz (stoking the fire)
I respectfully agree with all the points you make, kaz. Could not have said it better myself. [Bowing emoticon]
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[T]he unavoidable inclusion of private airstrips or fields which were previously outside the CTAF, which would require aircraft to now carry radio.
Within 20 NM around Shepparton, we have a number of unmarked, low use airstrips which would become radio required because they fell within the volume of the CTAF and all would be using 118.8, not 126.7.
But what would happen at Wahring? Currently within 10 NM of Mangalore but also within 20 NM of Shepparton.
As I'm flying the 29 NM from Shepp to Mangalore, do I change frequency at 20 NM FROM Shepp or when 20 NM from Mangalore?
OMG...what a clusterfark!
I suppose they will fix it by mandating ADSB for VFR.
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Do you honestly think that a mustering aircraft flying out of A station in the Upper Gascoyne would give a departure call?
Or that anyone would hear it?
Kaz
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Clearly this is an overstatement of the current situation in that radio is only mandated at Reg, CERT and a few other CTAFs ...which are mainly those with RPT.
Do you honestly think that a mustering aircraft flying out of A station in the Upper Gascoyne would give a departure call?
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OMG...what a clusterfark!
It needs to be pointed out that a CTAF is a procedure and not a block of airspace. The 20nm CTAF is therefore a dream.... You would think the OAR would know this?
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OzRunways has a 10 mile ring which when expanded to the near the screen edge is pretty good reference for my speed. If 20 miles were introduced, the map becomes more difficult to read.
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Note that the topography covered by the new procedure is 4x the area covered by the current requirement ie 400 sq miles!
Kaz
If I’m taxiing to take off from my strip in G and do a scan from horizon to horizon, what’s the risk in me taking off without broadcasting? I’m allowed to do it in a no-radio aircraft, and there could be no-radio aircraft in the area anyway. If it’s acceptably ‘safe’ for me and others to operate no-radio in the vicinity using our Mark I eyeballs alone, it must be acceptably ‘safe’ for me to decide that there is no substantial risk in deciding there is no point in broadcasting a taxi call.
And when I’m flying home, who the f*ck cares that I’m the only aircraft inbound to my own property?
The only realistic scenario that could cause inordinate amounts of noise on Area and unusual risk is the ‘fly in’ event at a strip that’s not marked on the charts. In that scenario Airervices and CASA should be able to arrange the publication of a NOTAM, in a timely fashion, that promulgates a discrete frequency for CTAF procedures as well as letting everyone else know what’s on and where. I’m sure there’ll be a perfectly nonsensical bureaucratic reason for this being too difficult.
But what would happen at Wahring? Currently within 10 NM of Mangalore but also within 20 NM of Shepparton.
As I'm flying the 29 NM from Shepp to Mangalore, do I change frequency at 20 NM FROM Shepp or when 20 NM from Mangalore?
As I'm flying the 29 NM from Shepp to Mangalore, do I change frequency at 20 NM FROM Shepp or when 20 NM from Mangalore?
OMG...what a clusterfark!
May Jesus pee in a bucket, what are these useless wombats on???
Like kaz, I'll continue to monitor Area, I've seen too many examples where they've been able to supply converging traffic to VFR.
The only realistic scenario that could cause inordinate amounts of noise on Area and unusual risk is the ‘fly in’ event at a strip that’s not marked on the charts. In that scenario Airervices and CASA should be able to arrange the publication of a NOTAM, in a timely fashion, that promulgates a discrete frequency for CTAF procedures as well as letting everyone else know what’s on and where. I’m sure there’ll be a perfectly nonsensical bureaucratic reason for this being too difficult.
It does require organisers of such events to contact CASA and request a NOTAM and use of the discrete frequency.
1. The unmarked airfield bogey
The stated prime issue has been the decision to nominate Area frequency for those aviating at unmarked airfields outside of existing CTAF boundaries. Surely, if there is so much traffic associated with unmarked airfields the first step to improve safety is to mark more of them so pilots know they are there?
The stated prime issue has been the decision to nominate Area frequency for those aviating at unmarked airfields outside of existing CTAF boundaries. Surely, if there is so much traffic associated with unmarked airfields the first step to improve safety is to mark more of them so pilots know they are there?
However it is my understanding that the RAPAC reps in attendance rejected that as an ongoing solution, and instead were focused on the introduction of the low level MULTICOM.
