Airservices Class E changes
Smashed with replies because everyone is afraid they will actually do it!
I was sent this by someone who responded, I assume it went to all 1000....
Good Morning
Airservices would like to thank all airspace users and aviation industry stakeholders that provided feedback on our initial proposal to lower the base of Class E airspace along the East Coast.
For the initial consultation period from 20 January to 15 February 2021, we received over 1,000 responses from all aspects of industry, including airlines, industry associations such as Recreational Aviation Australia (RAAus), Gliding Federation, Australian Airline Pilots’ Association (AusALPA), Aircraft Owners and Pilots Association (AOPA), Civil Air and various general aviation (GA) operators.
Your feedback is absolutely critical in deeply understanding the potential impacts on our industry. As previously communicated, we are assessing all feedback received to input into our detailed design process. In particular, the industry has highlighted the following key issues and we are revising our proposal to address the feedback:
• facilitate continued access to Class G airspace by VFR aircraft that do not meet the current transponder and radio communications fitment requirements in Class E airspace
• cater for the operational context and desired safety outcomes in Class G and Class E airspace, considering factors such as traffic mix, operational needs and characteristics of different types of airspace users and controls against threats such as terrain, engine failure or inclement weather
• avoid potential for confusion in relation to the airspace boundary reference to above-ground-level (AGL) versus above-mean-sea-level (AMSL)
• effectively manage the human factors aspect of the change, including operational complexity, workload, communication/coordination, training and education implications from both air traffic controllers and pilots’ perspectives
• reduce surveillance and communications coverage gaps within controlled airspace
• reduce the likelihood of delays on departures and arrivals
• clarify the safety case for change, with consideration to cost/benefit implications to stakeholders impacted by the proposal
• allow industry sufficient opportunity to consider and provide feedback on the details of the proposal.
We will provide an update to industry in the week starting 22 February 2021 with supporting information via our Engage platform, email communications and additional industry meetings. We will continue to consult with industry and take on board any further industry feedback on the revised proposal before proceeding with the formal Airspace Change Proposal (ACP) to be assessed by our regulator and airspace administrator, the Civil Aviation Safety Authority (CASA).
We are committed to listening to the needs of all airspace users and working with industry to develop an optimal solution to modernise our airspace architecture. We are acutely conscious of the need to minimise adverse impacts on airspace safety, access, efficiency and environmental outcomes, while being able to deliver service enhancements to operators that can already benefit from today’s modern surveillance capabilities.
Regards
SCOTT MITCHELL
A/CUSTOMER ENGAGEMENT SENIOR ADVISOR
Direct (02) 6268 4603
Mobile 0432 018 937
Email [email protected]
Remember this type of airspace works in the US so answers to these questions must be readily available.
The question is will anybody ask, or are we going to create some Australian specific abomination requiring pages of explanation, country specific training and pages of advice to ICAO about why our E airspace is different to the ICAO model?
Oh---will someone wake up CASA OAR, I understand airspace regulation is their responsibility...
I was sent this by someone who responded, I assume it went to all 1000....
Good Morning
Airservices would like to thank all airspace users and aviation industry stakeholders that provided feedback on our initial proposal to lower the base of Class E airspace along the East Coast.
For the initial consultation period from 20 January to 15 February 2021, we received over 1,000 responses from all aspects of industry, including airlines, industry associations such as Recreational Aviation Australia (RAAus), Gliding Federation, Australian Airline Pilots’ Association (AusALPA), Aircraft Owners and Pilots Association (AOPA), Civil Air and various general aviation (GA) operators.
Your feedback is absolutely critical in deeply understanding the potential impacts on our industry. As previously communicated, we are assessing all feedback received to input into our detailed design process. In particular, the industry has highlighted the following key issues and we are revising our proposal to address the feedback:
• facilitate continued access to Class G airspace by VFR aircraft that do not meet the current transponder and radio communications fitment requirements in Class E airspace
• cater for the operational context and desired safety outcomes in Class G and Class E airspace, considering factors such as traffic mix, operational needs and characteristics of different types of airspace users and controls against threats such as terrain, engine failure or inclement weather
• avoid potential for confusion in relation to the airspace boundary reference to above-ground-level (AGL) versus above-mean-sea-level (AMSL)
• effectively manage the human factors aspect of the change, including operational complexity, workload, communication/coordination, training and education implications from both air traffic controllers and pilots’ perspectives
• reduce surveillance and communications coverage gaps within controlled airspace
• reduce the likelihood of delays on departures and arrivals
• clarify the safety case for change, with consideration to cost/benefit implications to stakeholders impacted by the proposal
• allow industry sufficient opportunity to consider and provide feedback on the details of the proposal.
We will provide an update to industry in the week starting 22 February 2021 with supporting information via our Engage platform, email communications and additional industry meetings. We will continue to consult with industry and take on board any further industry feedback on the revised proposal before proceeding with the formal Airspace Change Proposal (ACP) to be assessed by our regulator and airspace administrator, the Civil Aviation Safety Authority (CASA).
We are committed to listening to the needs of all airspace users and working with industry to develop an optimal solution to modernise our airspace architecture. We are acutely conscious of the need to minimise adverse impacts on airspace safety, access, efficiency and environmental outcomes, while being able to deliver service enhancements to operators that can already benefit from today’s modern surveillance capabilities.
Regards
SCOTT MITCHELL
A/CUSTOMER ENGAGEMENT SENIOR ADVISOR
Direct (02) 6268 4603
Mobile 0432 018 937
Email [email protected]
Remember this type of airspace works in the US so answers to these questions must be readily available.
The question is will anybody ask, or are we going to create some Australian specific abomination requiring pages of explanation, country specific training and pages of advice to ICAO about why our E airspace is different to the ICAO model?
Oh---will someone wake up CASA OAR, I understand airspace regulation is their responsibility...
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The leading question now is; are they going to try and stick with the published implementation schedule, or delay it until they come up with something that might work?
I would be nice if their sample WAC had a legend on it or an explanation of sorts, unless I’m missing something obvious.
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How about seeing the low level radar and ADSB coverage, and of course the VHF coverage at circuit altitude and on ground.
It is obvious that ASA have not considered this as they have been asked for 3000ft ADSB coverage for over two years. What about a list of locations where there is an ADSB facility or better still a symbol on the charts for same??
ASA seem to be doing their best to back out of the original proposal, however the risk analysis/safety case must be on the table. They also need to cancel the proposed timeline (implement in Dec 21) and put that to one side until all the other questions are answered to the satisfaction of industry.
It is obvious that ASA have not considered this as they have been asked for 3000ft ADSB coverage for over two years. What about a list of locations where there is an ADSB facility or better still a symbol on the charts for same??
ASA seem to be doing their best to back out of the original proposal, however the risk analysis/safety case must be on the table. They also need to cancel the proposed timeline (implement in Dec 21) and put that to one side until all the other questions are answered to the satisfaction of industry.
5000ft coverage and station locations here https://www.airservicesaustralia.com...ds-b-coverage/
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5000ft coverage and station locations here https://www.airservicesaustralia.com...ds-b-coverage/
The scale of the 5000ft coverage diagrams is not good enough.
I am not saying you are wrong, just clarifying your thoughts;
when you say “For what ASA had proposed 5000ft is not good enough” are you saying the proposal is flawed based on the ADSB coverage at 5000 ft published by AsA OR is it the definition of the published maps inadequate and the fact we do not have coverage diagrams below 5000?
/
In essence are you saying the info from AsA is inadequate OR the current ADSB coverage is inadequate to do what is proposed?
Thank you,
Gf
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Gentle Flyer....
To clarify, I believe the ASA proposal has been undertaken in haste, hence the many holes in it and the huge industry response. For the proposal to work they must have adequate either Radar/SSR or ADSB coverage at those locations that have significant IFR traffic. Industry has not been given that information and in fact for some locations, I would be surprised if ASA knew what it was.
We do not know what the ADSB coverage is at 3000ft because ASA have not provided that info. We do not even have a list of locations where there is an ADSB facility to help work it out ourselves. For Class E to work at low levels and to avoid procedural separation with associated delays, I suggest that the existing Class G procedures work ok and there is no real need to drop E to 1200 agl unless there is appropriate surveillance at the lower levels. If that can't be done, and the risk justifies it, then the answer is a class D tower at those locations that have traffic to justify it. Maybe there is only one such location in the whole J curve?
when you say “For what ASA had proposed 5000ft is not good enough” are you saying the proposal is flawed based on the ADSB coverage at 5000 ft published by AsA OR is it the definition of the published maps inadequate and the fact we do not have coverage diagrams below 5000?
We do not know what the ADSB coverage is at 3000ft because ASA have not provided that info. We do not even have a list of locations where there is an ADSB facility to help work it out ourselves. For Class E to work at low levels and to avoid procedural separation with associated delays, I suggest that the existing Class G procedures work ok and there is no real need to drop E to 1200 agl unless there is appropriate surveillance at the lower levels. If that can't be done, and the risk justifies it, then the answer is a class D tower at those locations that have traffic to justify it. Maybe there is only one such location in the whole J curve?
Last edited by triadic; 18th Feb 2021 at 04:33. Reason: typo
What terrain clearance requirements will be placed upon ATC? If they will have nothing better than Grid LSALT this will be unworkable. They’ll need to separate above 1500 AGL but can’t “vector” (assign headings) below the GRID LSALT. It will require more specific radar terrain clearance charts for the whole of the east coast “J curve”. Currently they can’t even use 25NM Aerodrome minimum safe altitude charts for heading assignments
Can we also talk about VHF coverage across The Great Australian Bugger All?
The number of times I have been sent to HF because VHF coverage is minimal...
BUT, at the same time / height / location, I still have coverage on my (Telstra) mobile, and could phone them with position updates, if required.
Instead we get the joy that is HF (honestly, I have more chance of winning Lotto than Readability 5 on HF).
The number of times I have been sent to HF because VHF coverage is minimal...
BUT, at the same time / height / location, I still have coverage on my (Telstra) mobile, and could phone them with position updates, if required.
Instead we get the joy that is HF (honestly, I have more chance of winning Lotto than Readability 5 on HF).
Wish ScurvyDDog was still posting. Would be very interested to hear what the people behind the screens have to say. The argument is if the technology is capable to supply the correct information, what the tinpushers are made to do with the technology wrt sector sizes, and now how accurate the terrain data is...which is a bloody joke for an argument because we have had DEM data down to 5m grids freely available from GeoScience Australia since 2011. This all smells of politics and arse covering.
There are so many issues in play here but I will try and comment on just two:
1. Can Airservices ATC deal with this proposal - clearly not! The sectors are set up to provide current services, not this proposal. If ATC is to provide a Class E approach control service to any one of the airports included in the proposal then each controller has to have the ability to concentrate on that task (smaller display area) while having information pertinent to the pilot at his/her finger tips. Airservices itself proclaims the requirement to utilise modern information delivery techniques. I know, for a fact, that weather info from an AWS can be uploaded to an ATC position - but it costs money. Furthermore if there happen to be two or more aircraft utlising this service (e,g. Mangalore) then who is watching the rest of the sector's airspace.
2. This proposal has been undertaken in haste and Airservices do not know what they are doing - Airservices is a body corporate established under Commonwealth law to provide air traffic services in Australian airspace, they work for the Minister. (And recover all the costs and provide a dividend to the Commonwealth). If they have disingenuously circulated a proposal that they know to be unworkable then this is a political scandal of the highest order, for which the Minister needs to take responsibility.
For the record - Airservices is not the responsible Government entity for the approval of airspace changes, that role is given to CASA under the Airspace Act 2007 (" This Act binds the Crown in each of its capacities.") . Airservices is perfectly entitled to propose to CASA that there should be an airspace change, but CASA is responsible for ensuring the following:
(a) protection of the environment;
(b) efficient use of that airspace;
(c) equitable access to that airspace for all users of that airspace.
If Airservices wishes to change airspace, it is able to lodge an Airspace Change Proposal (ACP) to CASA, CASA are then required to:
1. Can Airservices ATC deal with this proposal - clearly not! The sectors are set up to provide current services, not this proposal. If ATC is to provide a Class E approach control service to any one of the airports included in the proposal then each controller has to have the ability to concentrate on that task (smaller display area) while having information pertinent to the pilot at his/her finger tips. Airservices itself proclaims the requirement to utilise modern information delivery techniques. I know, for a fact, that weather info from an AWS can be uploaded to an ATC position - but it costs money. Furthermore if there happen to be two or more aircraft utlising this service (e,g. Mangalore) then who is watching the rest of the sector's airspace.
2. This proposal has been undertaken in haste and Airservices do not know what they are doing - Airservices is a body corporate established under Commonwealth law to provide air traffic services in Australian airspace, they work for the Minister. (And recover all the costs and provide a dividend to the Commonwealth). If they have disingenuously circulated a proposal that they know to be unworkable then this is a political scandal of the highest order, for which the Minister needs to take responsibility.
For the record - Airservices is not the responsible Government entity for the approval of airspace changes, that role is given to CASA under the Airspace Act 2007 (" This Act binds the Crown in each of its capacities.") . Airservices is perfectly entitled to propose to CASA that there should be an airspace change, but CASA is responsible for ensuring the following:
(a) protection of the environment;
(b) efficient use of that airspace;
(c) equitable access to that airspace for all users of that airspace.
If Airservices wishes to change airspace, it is able to lodge an Airspace Change Proposal (ACP) to CASA, CASA are then required to:
- review the ACP to:
- ensure sufficient information and supporting analysis is available to assess the ACP in terms of safety, efficiency, equitable access, economic and cost impact, national security and if the change is realistic and achievable
- ensure a robust safety case exists to support it. At minimum, this should include a risk assessment (see below for further detail). However, depending on the size and scale of the proposal, further detail including an analysis of the current operating environment and key existing safety issues should be included. Additionally, evidence of consideration of the impact of the change should be provided
- ensure appropriate stakeholder consultation has occurred and evidence of that consultation is supplied with the submission
- ensure the proposed start date leaves adequate time for processing, analysis and further stakeholder consultation
- ensure a risk assessment appropriate to the size and complexity of the proposal is included. The risk assessment should take into account the types of aircraft involved, the density of air traffic, the meteorological conditions, topography and such other factors as may be relevant
- check there are no airspace/aircraft operation implications for Environment Protection and Biodiversity Conservation Act 1999 Matters of National Environmental Significance, noting that aviation safety is always the top priority
- ensure a Regulatory Impact Statement (cost: benefit analysis) is included for major change proposals which considers the cost implications for all airspace users.
- review the safety case to determine if a residual risk remains for airspace users
- advise the ACP proponent if the information supplied is adequate to progress the application to assessment or if further information is required
- assess the ACP in accordance with current legalisation, policy and procedures
- conduct additional stakeholder consultation on the proposal (as necessary)
- assemble the supporting legal and aeronautical documentation to give effect to the ACP
- advise the proponent if the ACP is approved or not approved.
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You are absolutely correct re your lotto comment. The highest readability on hf for anyone is readability 4 if conditions are absolutely perfect. The norm is 3 or less. At the moment with half of the transmitters and receivers not working it’s a challenge for everyone.
Keep in mind that when an HF operator does not answer you over HF - they may be busy on the phone talking to pilots like outnabout who have better mobile reception than hf reception.
Depending on the time of day, there may be only one HF operator servicing the entire suite of domestic frequencies, plus answering the phones incl SARTIMES.
Keep in mind that when an HF operator does not answer you over HF - they may be busy on the phone talking to pilots like outnabout who have better mobile reception than hf reception.
Depending on the time of day, there may be only one HF operator servicing the entire suite of domestic frequencies, plus answering the phones incl SARTIMES.
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This is at the direction of the Minister , so it is ultimately for political not practical reasons