Airservices Class E changes
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Low level Class E proposal
The following is doing the rounds of some organisations in reference to this ASA proposal which to date does not have any charts on display. It should be noted that some of the RAPACs have been asking for ADSB coverage at 3000 ft and a symbol on the charts where the ADSB facility is located for around two years. Nothing from ASA to date on either.
Now that CASA have moved the goal posts on how consultation is undertaken both CASA and ASA transmit but sadly there is not much listening going on. We have only seen the tip of the iceburg with this proposal and it needs to be put on the table in full, prior to moving forward. Where is the five year airspace plan that was meant to be in place by now?
Seems also that the tragic state of GA at the moment has not been considered in proposing such a change (?)
Now that CASA have moved the goal posts on how consultation is undertaken both CASA and ASA transmit but sadly there is not much listening going on. We have only seen the tip of the iceburg with this proposal and it needs to be put on the table in full, prior to moving forward. Where is the five year airspace plan that was meant to be in place by now?
Seems also that the tragic state of GA at the moment has not been considered in proposing such a change (?)
- International consistency… we are ALREADY aligned to the ICAO airspace system… it’s why we have alphabet airspace in the first place!
- Improved safety… how? Show your working, there is no safety case to answer. The result will actually be delays because of the requirement to separate aircraft without surveillance coverage. Ostensibly E airspace without active surveillance (ie radar) is LESS safe because it means that VFR aircraft are operating undetected in the airspace. IFR aircraft legally need a clearance to change route or altitude, so we are now forcing them to rely on TCAS?
- Reduced complexity… explain how. G is very uncomplex!
- Current and future needs?? Expressed by WHOM? Which operators have asked for this. Also equitable access is complete blowing snow, you need a functioning transponder and VHF to access E, you need neither in G.
- 1500AGL is hard to manage… because (shock) the terrain moves! We don’t have radio altimeters in GA aircraft. So you expect an RA or GA pilot to calculate 1500AGL for their ENTIRE route of flight?
- Maximise surveillance??? The surveillance doesn’t fully support the E airspace we already HAVE and CERTAINLY doesn’t support it to 1500AGL, there will be MASSIVE swathes of non-surveillance airspace where the controllers will have ‘nothing’ other than ‘one in, one out’ to use as a standard. Especially when you consider that ADS-B is NOT mandatory for VFR aircraft. (can you see where that is going??)
Let’s take aim at the “benefits”:
- Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management.
o Australia is already aligned with ICAO airspace ever since the demise of GAAP. Modelling on the US NAS has been shown time and again to be inappropriate, Australia does not have close to the same level of traffic, risk, ANS infrastructure or ATC staffing/sector density to support moving to a US NAS-like low level E airspace.
- Improved safety for Regular Public Transport (RPT) and other airspace users - reducing complexity for pilots and controllers.
o Adding large non-surveillance areas as class E airspace increases risk as VFR aircraft are completely unknown, making IFR aircraft reliant on un-alerted see and avoid (or TCAS) for separation. Worse these aircraft are subject to a clearance so any deviation requires a clearance request from a controller which they may not be able to facilitate if separating with other IFR traffic, terrain or radio congestion inhibits. There are no complexity issues that the addition of this airspace would solve (on either side).
- Enables enhanced surveillance service.
o There is zero increase to surveillance coverage proposed. Additional controlled airspace is not required to provide more surveillance services… these are already provided to IFR aircraft where available and VFR aircraft on request in Class G airspace.
- Class E does not restrict access for VFR aircraft.
o Incorrect. Class E airspace imposes aircraft equipment requirements that are not required for VFR aircraft in class G airspace. This would have the effect of pushing non-equipped aircraft down to very low altitudes to avoid the airspace. Also VFR aircraft may not be monitoring the area frequency so even if in surveillance coverage (and equipped, as most low level coverage will be ADS-B only) the aircraft will be completely uncontactable by ATC.
- Controlled airspace containment and separation for IFR flights.
o However due to the lack of low level surveillance coverage there will be large delays. Australian pilots are not inclined to cancel IFR like American pilots. These restrictions will likely result in forcing aircraft to operate VFR in marginal conditions to avoid these delays. Also airspace containment is moot, aircraft will STILL need to leave the E airspace to land! Moreover no operator in the effected airspace has expressed any desire to have this level of airspace containment. This also causes a large increase in ATC required knowledge as ALL approaches for ALL airports in their airspace will become required knowledge so they can correctly process IFR aircraft to leave the class E airspace on descent via an instrument approach (and any potential missed approach).
- Fosters equitable access for airspace users.
o Airspace access to Class G airspace is already equitable by default. Class E imposes equipment requirements for VFR aircraft and potential traffic issues for IFR aircraft.
- Caters for current and future needs of airspace users.
o What known need that has been expressed by any airspace user group?
- Improved use and value of existing investments (e.g. ADS-B, ACAS).
o More airspace (that Airservices can charge for) is not a reason to increase airspace. ADS-B is only mandated for IFR aircraft, meaning that literally half the traffic will not be visible to ATC. Controllers will have NO awareness that their clearance may have actually increased the collision risk.
o ACAS IS A SAFETY NET, NOT A SEPARATION TOOL! (Note also ACAS may not be used as a factor in airspace design).
- Facilitates Continuous Descent Operations.
o False, CDO is inhibited by this proposal as ATC will be required to separate well below existing surveillance coverage so aircraft will be held up to allow departing aircraft. Also the airspace proposed doesn’t enhance CDO any more than the current structure as the aircraft will STILL need to leave class E airspace on descent, just doing this at a much lower level (and potentially being delayed by the inflexibility of non-surveillance separation standards which will be basically a ‘one in, one out’ service without a tower being present (which is how the extant non-radar airspace is able to operate with some level of efficiency.
- Improved safety… how? Show your working, there is no safety case to answer. The result will actually be delays because of the requirement to separate aircraft without surveillance coverage. Ostensibly E airspace without active surveillance (ie radar) is LESS safe because it means that VFR aircraft are operating undetected in the airspace. IFR aircraft legally need a clearance to change route or altitude, so we are now forcing them to rely on TCAS?
- Reduced complexity… explain how. G is very uncomplex!
- Current and future needs?? Expressed by WHOM? Which operators have asked for this. Also equitable access is complete blowing snow, you need a functioning transponder and VHF to access E, you need neither in G.
- 1500AGL is hard to manage… because (shock) the terrain moves! We don’t have radio altimeters in GA aircraft. So you expect an RA or GA pilot to calculate 1500AGL for their ENTIRE route of flight?
- Maximise surveillance??? The surveillance doesn’t fully support the E airspace we already HAVE and CERTAINLY doesn’t support it to 1500AGL, there will be MASSIVE swathes of non-surveillance airspace where the controllers will have ‘nothing’ other than ‘one in, one out’ to use as a standard. Especially when you consider that ADS-B is NOT mandatory for VFR aircraft. (can you see where that is going??)
Let’s take aim at the “benefits”:
- Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management.
o Australia is already aligned with ICAO airspace ever since the demise of GAAP. Modelling on the US NAS has been shown time and again to be inappropriate, Australia does not have close to the same level of traffic, risk, ANS infrastructure or ATC staffing/sector density to support moving to a US NAS-like low level E airspace.
- Improved safety for Regular Public Transport (RPT) and other airspace users - reducing complexity for pilots and controllers.
o Adding large non-surveillance areas as class E airspace increases risk as VFR aircraft are completely unknown, making IFR aircraft reliant on un-alerted see and avoid (or TCAS) for separation. Worse these aircraft are subject to a clearance so any deviation requires a clearance request from a controller which they may not be able to facilitate if separating with other IFR traffic, terrain or radio congestion inhibits. There are no complexity issues that the addition of this airspace would solve (on either side).
- Enables enhanced surveillance service.
o There is zero increase to surveillance coverage proposed. Additional controlled airspace is not required to provide more surveillance services… these are already provided to IFR aircraft where available and VFR aircraft on request in Class G airspace.
- Class E does not restrict access for VFR aircraft.
o Incorrect. Class E airspace imposes aircraft equipment requirements that are not required for VFR aircraft in class G airspace. This would have the effect of pushing non-equipped aircraft down to very low altitudes to avoid the airspace. Also VFR aircraft may not be monitoring the area frequency so even if in surveillance coverage (and equipped, as most low level coverage will be ADS-B only) the aircraft will be completely uncontactable by ATC.
- Controlled airspace containment and separation for IFR flights.
o However due to the lack of low level surveillance coverage there will be large delays. Australian pilots are not inclined to cancel IFR like American pilots. These restrictions will likely result in forcing aircraft to operate VFR in marginal conditions to avoid these delays. Also airspace containment is moot, aircraft will STILL need to leave the E airspace to land! Moreover no operator in the effected airspace has expressed any desire to have this level of airspace containment. This also causes a large increase in ATC required knowledge as ALL approaches for ALL airports in their airspace will become required knowledge so they can correctly process IFR aircraft to leave the class E airspace on descent via an instrument approach (and any potential missed approach).
- Fosters equitable access for airspace users.
o Airspace access to Class G airspace is already equitable by default. Class E imposes equipment requirements for VFR aircraft and potential traffic issues for IFR aircraft.
- Caters for current and future needs of airspace users.
o What known need that has been expressed by any airspace user group?
- Improved use and value of existing investments (e.g. ADS-B, ACAS).
o More airspace (that Airservices can charge for) is not a reason to increase airspace. ADS-B is only mandated for IFR aircraft, meaning that literally half the traffic will not be visible to ATC. Controllers will have NO awareness that their clearance may have actually increased the collision risk.
o ACAS IS A SAFETY NET, NOT A SEPARATION TOOL! (Note also ACAS may not be used as a factor in airspace design).
- Facilitates Continuous Descent Operations.
o False, CDO is inhibited by this proposal as ATC will be required to separate well below existing surveillance coverage so aircraft will be held up to allow departing aircraft. Also the airspace proposed doesn’t enhance CDO any more than the current structure as the aircraft will STILL need to leave class E airspace on descent, just doing this at a much lower level (and potentially being delayed by the inflexibility of non-surveillance separation standards which will be basically a ‘one in, one out’ service without a tower being present (which is how the extant non-radar airspace is able to operate with some level of efficiency.
While I, and others, have been pushing for this for about 30 years, I am loathe to get involved. Why, because if it is to be done then it needs the same rules, same procedures and same pilot habits that make the US Class E work.
We have already been told the base will be 1500 Feet AGL, why? The purpose of Class E in the US is to safeguard the flight of IFR aircraft, particularly in IMC. The base is therefore generally 1200 AGL where an IFR aircraft should be visual, 700 feet AGL associated with an airfield approach, and ground level where there is an approach minimum below 700 feet. And if that makes your mind boggle, I have seen it, it works! Originally the Class E (Originally VFR exempt airspace) was contained within corridors called Federal Airways, leading from the Class A (Originally PCA or Positive Control Airspace) down to particular airfields, we have a bastardised version from Melbourne to Ballarat. It only became more widespread with the proliferation of airfields that could support IFR operations and with the surveillance that had to follow to ensure safety. Surveillance was never a prerequisite for Class E, and neither was transponder fitment. If you have ever wondered, that is why they have transponder veils around their busiest hubs. to ensure transponder fitment where it is essential to safety. (And yes a VFR pilot can get a special clearence through a transponder veil if required)
I am sure that CASA OAR and Airservices understand all of this, so a I am predicting a dog's breakfast that will eventually be knocked back by industry because it is so restrictive. The result will be what we have now, which I suspect the DIRD establishment (or Deep State) is really after.
We have already been told the base will be 1500 Feet AGL, why? The purpose of Class E in the US is to safeguard the flight of IFR aircraft, particularly in IMC. The base is therefore generally 1200 AGL where an IFR aircraft should be visual, 700 feet AGL associated with an airfield approach, and ground level where there is an approach minimum below 700 feet. And if that makes your mind boggle, I have seen it, it works! Originally the Class E (Originally VFR exempt airspace) was contained within corridors called Federal Airways, leading from the Class A (Originally PCA or Positive Control Airspace) down to particular airfields, we have a bastardised version from Melbourne to Ballarat. It only became more widespread with the proliferation of airfields that could support IFR operations and with the surveillance that had to follow to ensure safety. Surveillance was never a prerequisite for Class E, and neither was transponder fitment. If you have ever wondered, that is why they have transponder veils around their busiest hubs. to ensure transponder fitment where it is essential to safety. (And yes a VFR pilot can get a special clearence through a transponder veil if required)
I am sure that CASA OAR and Airservices understand all of this, so a I am predicting a dog's breakfast that will eventually be knocked back by industry because it is so restrictive. The result will be what we have now, which I suspect the DIRD establishment (or Deep State) is really after.
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Why, because if it is to be done then it needs the same rules, same procedures and same pilot habits that make the US Class E work.
And if that makes your mind boggle, I have seen it, it works!
I am sure that CASA OAR and Airservices understand all of this
so a I am predicting a dog's breakfast that will eventually be knocked back by industry because it is so restrictive.
Originally Posted by Mclimit
Class C over D towers is pointless when there is Class E surrounding the C, what's the point?
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To provide separation for all aircraft in the descent phase.
Originally Posted by Mclimit
Then get rid of Class D towers, quit the pantomime that is Class D towers in Australia, replace them with Class C.
Your getting off the subject but for the record Class D was based, by ICAO, on the Air Traffic Zone (ATZ) that is considered to surround an aerodrome witha Tower. One of Australia's problems with Class D is that that term was never used here so no-one understands what Class D is suposed to be.
It's a small area, 5 NM, within which an aerodrome, or as the rest of the world calls them, Local, controller can manouvre aircraft visully to de-conflict witin the circuit and maintain runway separation and efficiency. Clearnces were never involved, another Australian problem, simply call the Tower and do what the Local controller asked. Join downwind, left/right base, follow a Bonanza, clear to land etc. That is all US Class D Towers do.
Australian Class D Towers either have too little airspace, BK, AF and so on, or too much, all the regional Airports with Towers.
Personally I have no problem with Class C steps over a Class D ATZ/CTR, provided it is managed by a Centre and not by an Aerodrome controller in a Tower.
It's a small area, 5 NM, within which an aerodrome, or as the rest of the world calls them, Local, controller can manouvre aircraft visully to de-conflict witin the circuit and maintain runway separation and efficiency. Clearnces were never involved, another Australian problem, simply call the Tower and do what the Local controller asked. Join downwind, left/right base, follow a Bonanza, clear to land etc. That is all US Class D Towers do.
Australian Class D Towers either have too little airspace, BK, AF and so on, or too much, all the regional Airports with Towers.
Personally I have no problem with Class C steps over a Class D ATZ/CTR, provided it is managed by a Centre and not by an Aerodrome controller in a Tower.
At many airfields (possibly most in regional areas), ATC isn't able to be contacted on the ground. So if this change goes ahead, on an IFR flight plan, we would have to stay below 1500ft until a clearance can be negotiated? If so that would rule out a lot of IMC departures such as calculating terrain clearance in the splay (from ERSA) etc. We would need to stay within the circling area, get a clearance, and then depart which i think would raise the risk factor quite a bit if cloud was below 1500ft? Or is there another option i am missing?
Not an IFR pilot so how does AIP 1.4 - 9 Class G IFR radio requirement "2-way continuous" work at these airfields?
HF I suppose, however the US allows the use of telephones in such circumstances:
HF I suppose, however the US allows the use of telephones in such circumstances:
- IFR Clearances Off Uncontrolled Airports
- Pilots departing on an IFR flight plan should consult the Chart Supplement U.S. to determine the frequency or telephone number to use to contact clearance delivery. On initial contact, pilots should advise that the flight is IFR and state the departure and destination airports.
- Air traffic facilities providing clearance delivery services via telephone will have their telephone number published in the Chart Supplement U.S. of that airport's entry. This same section may also contain a telephone number to use for cancellation of an IFR flight plan after landing.
- Except in Alaska, pilots of MEDEVAC flights may obtain a clearance by calling 1-877-543-4733.
Mr Approach...Usually departing into Class G airspace so don't need a clearance even when IFR and so can depart, when at altitude establish coms with ATC and get a clearance if needed. If a clearance is required at 1500 feet, and there is cloud at 1000...that would be a problem that doesnt seem to have an easy solution.
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Mr Approach...Usually departing into Class G airspace so don't need a clearance even when IFR and so can depart, when at altitude establish coms with ATC and get a clearance if needed. If a clearance is required at 1500 feet, and there is cloud at 1000...that would be a problem that doesnt seem to have an easy solution.
Most people flying regionally on IFR plans having to phone to get a clearance above circuit height is a great solution to a problem we don't currently have and will certainly enhance safety. Apart from those that forget to phone and so now tool around below 1500 in the circuit feet trying to get a clearance, those that couldn't get phone reception or get through to ATC who will be far busier doing the same, and ATC now giving possible IFR traffic for aircraft that may not have even started engines everywhere and so cluttering up frequencies even more, i think its perfect.I am not totally against the idea but it really needs to just be in high traffic areas where there is coms with ATC on the ground. Needing a clearance above circuit height in many places would be a backward step in terms of air safety for the above reasons.
Last edited by extralite; 26th Jan 2021 at 21:30.
Hi Extralite - I assumed from your post that you were IFR and required to depart in IMC for a penetration of Class E at 1500 feet AGL also in IMC. Under US rules you would get the clearance on the ground via HF or telephone and it would come with a altitude limit and clearance expiry time.
In your latest post you talk about being in VMC below 1500 Feet AGL. In the US if VMC existed a pilot would depart under the VFR having completed traffic checks on the CTAF or area frequency, and then contact ATC airborne for the clearance. By this time they would have seen your ADS-B response and, provided there was no other IFR aircraft to separate you with, issued a clearance, including a discrete transponder code.
One of the "tricks of the trade" in the US is this use of VMC at low level whenever it exists, because it speeds the process up dramatically. A pilot can also use it on arrival by cancelling IFR but retaining traffic advisories. This cancels all requirements to be processed via the airfield instrument approach. This can also be done while retaining IFR status by calling the airfield in sight, the controller will then issue a visual approach.
Another Australian idiosynchracy has been the re-introduction of the concept of IFR category/VFR procedures. I believe Airservices thought they were doing everyone a favour so that a pilot did not have to cancel VFR when an IFR clearence was not available. (BK comes to mind). However all they did was screw up the training for Class E that our schools were providing by superimposing a purely Australian procedure over the top of the ICAO classification. If Class E is to work this is another anomoly that has to be eliminated. The major one, of course, is for the requirement for VFR aircraft to carry a transponder or Integrated Traffic Awareness Beacon (TABS).
As I posted above, I doubt that the establishment within DIRD, CASA and Airservices will be able to grasp these issues and the whole idea will fail.
In your latest post you talk about being in VMC below 1500 Feet AGL. In the US if VMC existed a pilot would depart under the VFR having completed traffic checks on the CTAF or area frequency, and then contact ATC airborne for the clearance. By this time they would have seen your ADS-B response and, provided there was no other IFR aircraft to separate you with, issued a clearance, including a discrete transponder code.
One of the "tricks of the trade" in the US is this use of VMC at low level whenever it exists, because it speeds the process up dramatically. A pilot can also use it on arrival by cancelling IFR but retaining traffic advisories. This cancels all requirements to be processed via the airfield instrument approach. This can also be done while retaining IFR status by calling the airfield in sight, the controller will then issue a visual approach.
Another Australian idiosynchracy has been the re-introduction of the concept of IFR category/VFR procedures. I believe Airservices thought they were doing everyone a favour so that a pilot did not have to cancel VFR when an IFR clearence was not available. (BK comes to mind). However all they did was screw up the training for Class E that our schools were providing by superimposing a purely Australian procedure over the top of the ICAO classification. If Class E is to work this is another anomoly that has to be eliminated. The major one, of course, is for the requirement for VFR aircraft to carry a transponder or Integrated Traffic Awareness Beacon (TABS).
As I posted above, I doubt that the establishment within DIRD, CASA and Airservices will be able to grasp these issues and the whole idea will fail.
Many operators particularly airlines do not permit changing to VFR. That's why the procedure is rarely used here.
"Hi Extralite - I assumed from your post that you were IFR and required to depart in IMC for a penetration of Class E at 1500 feet AGL also in IMC. Under US rules you would get the clearance on the ground via HF or telephone and it would come with a altitude limit and clearance expiry time."
But this isn't the USA and we have so little traffic compared to most areas of the USA. It works fine as is..Quite a lot of aircraft are not HF equipped. I know mine aren't. So assuming we wanting to go IMC sometime in the climb, we will need a clearance. It is back to a phone call, if i can get through (some areas don't have good phone coverage on all networks) to ATC for a clearance. As per my post, having most IFR aircraft in regional areas on the phone getting clearances and then the frequency becoming cluttered as traffic information passed on for every aircraft that has phoned in the last 20 minutes or whenever it is, is a backwards step making flying just that more complex again. I would also guess there might be a bit of cloud busting while aircraft are "VMC" and so VFR until the getting a clearance in the climb.
The more i think about it, the sillier the idea is unless it is for the coastal strip where traffic is higher and contacting ATC on the ground easier. Still patchy though. Tyagrah airfield, only about 30k's from the Gold Coast, doesnt have ATC on the ground for example.
But this isn't the USA and we have so little traffic compared to most areas of the USA. It works fine as is..Quite a lot of aircraft are not HF equipped. I know mine aren't. So assuming we wanting to go IMC sometime in the climb, we will need a clearance. It is back to a phone call, if i can get through (some areas don't have good phone coverage on all networks) to ATC for a clearance. As per my post, having most IFR aircraft in regional areas on the phone getting clearances and then the frequency becoming cluttered as traffic information passed on for every aircraft that has phoned in the last 20 minutes or whenever it is, is a backwards step making flying just that more complex again. I would also guess there might be a bit of cloud busting while aircraft are "VMC" and so VFR until the getting a clearance in the climb.
The more i think about it, the sillier the idea is unless it is for the coastal strip where traffic is higher and contacting ATC on the ground easier. Still patchy though. Tyagrah airfield, only about 30k's from the Gold Coast, doesnt have ATC on the ground for example.
where I am I need to get to about 3500ft to get ATC AND transponder interrogations. I dont think the air ambulances and the Coulson Boyz would be impressed. The change does nothing for us.
