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Voices of Reason and Class E

Old 6th Apr 2021, 03:05
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Voices of Reason and Class E

I can’t believe we could have a Class E thread without bringing up the wonderful wisdom of Voices of Reason and Class E of over a decade ago. Here is what he said from his post.

By the way, many people say that Voices of Reason was the late Phil Faulkner, a knowledgeable air traffic expert from Airservices.

Class E Airspace and United States Practice

We have watched with incredulity at the dangerously naive statements being made on threads in the Australian PPRuNe sites, concerning the operation of Class E airspace. Class E airspace is NOT an unsafe categorization of airspace, and is in fact used safely and effectively in substantial portions of the globe.

EACH AND EVERY transport and passenger carrying aircraft operating in the United States is required to
operate for some portion of their flight in designated Class E airspace – effectively between 18,000 feet and the upper limit of Class B, C or D airspace – or the surface for non controlled aerodromes. This equates to over 10,000 passenger-carrying flights per day, every day of the year. The Class E airspace within which they operate is in the so-called most dangerous phase of flight – climb or descent. Your national carrier is no exception.

There are in excess of 150,000 general aviation aircraft operating in the United States,
to either the visual or instrument flight rules – many many thousands per day.

There are CONSTANT interactions between IFR passenger carrying aircraft and VFR aircraft on a daily basis – with no hint that this practice is unsafe.

There are countless examples where aircraft provided with routine terminal area instructions whilst still in Class E airspace are routinely provided sequencing descending turn instructions by controllers in one breath, and VFR traffic information in the other.

We agree that Class E airspace is mostly within radar cover in the United States – probably the greater part of 95%. In that airspace, air traffic controllers positively separate IFR flights from other IFR flights – and where they can, provide traffic information on VFR flights.

Radar coverage is NOT a prerequisite for Class E airspace, and in fact in several cases the Class E airspace linking certain aerodromes
to upper airspace is not covered by radar. In that airspace, air traffic controllers positively separate IFR flights from other IFR flights – and as they cannot observe VFR, do not pass traffic unless they know by some other means. That positive IFR-to-IFR separation may, in many cases, be applied on a “one in at a time” basis. The airlines accept that mode of operation.

NOT ONE SINGLE AIRLINE in the United States is lobbying for a higher level of service in current Class E areas.

Our observation in relation
to the Australian experience has been one of giving proper effect not just to training and education, but also to the cultural change requirements. Pilots need to understand that operating in Class E airspace IS FUNDAMENTALLY DIFFERENT to the service that they have received in the past – but need to accept that this is a normal way of doing business.

Australian controllers need
to STOP being negative, embrace the concept of Class E airspace and tobeblunt, get on with it. Controllers in the United States provide services in Class E, without questioning its “safety”, day in and day out, and have done so [either as Class E, or its predecessor], for over 50 years.

NOT ONE SINGLE CONTROLLER in the United States is lobbying for a higher level of service in current Class E areas.

We are concerned that this constant questioning and second-guessing by your pilot and controller fraternity will in fact generate a safety deficiency larger that the problem you are trying
to solve. By our estimation, there is NO JUSTIFICATION for the large amount of Class C airspace presently designated in Australia, and subject to the appropriate change management processes we have previously described, you should introduce Class E airspace wherever possible.”
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Old 6th Apr 2021, 04:42
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By the way, many people say that Voices of Reason was the late Phil Faulkner
Really..............??????
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Old 6th Apr 2021, 11:52
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Strange that such a rational and knowledgeable poster would remain anonymous.
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Old 6th Apr 2021, 13:50
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Old 7th Apr 2021, 04:08
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Phil was a very respected controller and Head of ATC. I knew him quite well and followed the Voices of Reason threads. While VOR could have been Phil, I doubt it from what VOR said in the thread and what I knew of Phil's personal feelings about NAS.
It is a great pity Phil died so early. RIP.
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Old 7th Apr 2021, 06:22
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I can’t believe we could have a Class E thread without bringing up the wonderful wisdom of Voices of Reason and Class E of over a decade ago. Here is what he said from his post.
I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.



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Old 7th Apr 2021, 08:41
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Is ForG this century’s answer for this century’s problem? If not, what is?

(Not ‘having a go’, alphcentauri. It is clear you know of what you speak.)
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Old 7th Apr 2021, 09:07
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"Class E is last century's answer for a modern problem.....and its obsolete."

Probably true and I don't disagree. Australia and the USA's geographic location/isolation allows for a bit of a home grown spin on ICAO airspace classification. When you take the concept to Asia, Europe and Africa, standardisation is essential and unfortunately has to cater to the lowest common denominator.
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Old 7th Apr 2021, 10:41
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Lead Balloon, I think its premature to determine an answer at this point. However, the path to a solution is not hard to follow.

1. We need an agreed upon risk framework so that risk can be determined for certain operations in to particular locations (note I have not used the term airspace). The risk model is to include, traffic mix, traffic density and CNS capability. (amongst other things).
2. We also need an agreed methodology to determine the problem we are attempting to solve.
3. We need a risk acceptance framework where by risk can be determined, assessed and accepted against the problem. Not all problems need solutions. Some risks may be acceptable provided all parties are informed.

Lets take Ballina. (None of what I am about to type is a proposal. I have used these examples to trigger a discussion. That is all)
What exactly is the problem we are trying to solve? OAR would have you believe that communications masking from Lismore and over transmission is the problem that lead to the A320/Jabiru incident. But it is known fact that the Jabiru made a transmission, and no one else transmitted at the time. The A320 was in line of sight so terrain shielding also was not at play. So what caused the incident? Is it traffic mix? Is it poor training from Jabiru or A320 crew....I genuinely don't know, but shouldn't we try to find out what the root cause was before we introduce another set of complexities and problems? Class E at Ballina, would not have prevented the incident, and neither would the broadcast zones that are being proposed. Here's the final question, do we absolutely want to prevent a Jabiru from taking out an A320? I would argue, most probably, yes. So the solution is going to have make that the priority outcome, and that may mean excluding some types of operations. So we don’t want any probability of that even happening. (stay with me, I'm going somewhere with this)

Now take Mangalore.
We really don't know yet what actually caused this accident? We may end up putting it down to bad luck? But, how do we know there is not a latent error in the airspace system that could have this happen anywhere else? (I’m sure I read a comment along that line by you somewhere, I agree by the way).
But what if this is the 1:10(-9) event. Is that ok? Should we invest time/money in trying to make a system more safe, when everybody seemed happy with the 1:10(-9) risk?
In this way we need to develop tools to determine if a) there is an latent error or, b) this is the 1:10(-9) event. If its b) we also then need the testicular fortitude to stand by the level of risk that we have accepted. I feel terrible for those 4 blokes, its sad and I hope it never happens to me. But flying has a risk, we all accept it. Its not zero. If we establish that the risk at Mangalore is as we thought it was...does it need a solution?

So take the 2 scenarios above. 2 totally different problems, with what I hope would be 2 different set of airspace performance requirements, which would lead to 2 different outcomes with 2 different associated levels of risk. How then can the same solution be applied to both locations, and the same outcome be expected? All you are doing is adding another variable to an existing set of variables that have not been assessed appropriately in the first place.....this makes the risk increase significantly.

The point being if we have a mutually agreed framework with which to assess and determine the risk of operations at a particular location, and then you have an agreed framework with which to mitigate that risk (or not) then the outcome should be valid.

We are not ready for solutions yet.
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Old 7th Apr 2021, 10:59
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Thanks, alpha. We can but dream.
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Old 12th Apr 2021, 13:16
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Alpha, this is the most reasonable post on here, I have to say. the Airservices proposals are red herring as no one has defined the actual issue/s that need fixing. Your post also brings to the fore the age old question about what is acceptable in terms of risk. If 10 *-9 is what we are aiming for, it is very low but it means there is still a chance of the risk eventuating. But does it pass the pub test? My opinion is that yes it does, but when it comes to the public who are mostly informed through sensationalised media, they would say any accident is unacceptable - illogical when you compare the road toll. It’s for this reason that both CASA and Airservices are always going to be on hiding to nowhere because the public is who the politicians are answerable to, not aviators. So where to from here? In my view, and dare I say, industry, the regulator and ANSP need to come together to agree on a best achievable outcome when it comes to risk appetite and then try and convince the government AND opposition that this can be the only way forward. It’s only then will we be able to have acceptable regulation that doesn’t destroy the industry. For the nay sayers, I get this is idealistic and shock horror that someone would suggest such a thing, but I’m at a loss otherwise.

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Old 13th Apr 2021, 00:37
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Agreed Flying Higher,

If 10 *-9 is what we are aiming for
That's the problem, we actually don't know what we are aiming for. I would argue that we are not aiming for the same risk level in all airspace. This needs to be determined! Airservices/CASA proposed solutions assume that the risk is the same (this assumption is made because they role out the same solutions)....its not.

How can we have solutions, when we have not identified the problem, or its extent?

Cheers, α


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Old 13th Apr 2021, 01:02
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If class E is last centuries answer to airspace classification what is this centuries answer?

This is a serious question! Do you think Australia should lead the way with this new category?
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Old 13th Apr 2021, 01:10
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We haven't determined this centuries problem/s yet, nor have we determined what level of risk we are prepared to accept in a solution. All we are doing is proposing solutions that are looking for the problems and increasing the complexity of the airspace.

No reason why Australia can't lead the way, it needs to be a performance based airspace classification system. The problem is going be finding people who have an ability to free their minds of last centuries' thinking.

α
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Old 13th Apr 2021, 02:35
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We want the highest level of risk reduction we can afford. Pretty simple really.
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Old 13th Apr 2021, 02:55
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alphacentauri - your words, on the surface, seem very reasonable. They are however not soundly based and I will try to unpack all of that with my comments:
Post number 1

I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

The "reason" for airspace (I assume you mean airspace classes) has not, as you claim, changed over the last 20 or 50 years. Technology has moved on but in some ways that has increased, not decreased, the risk. There are now more aircraft, even GA has high-performance jets and navigation accuracy has eliminated what ATCs used to call "the big sky theory" (that is even if separation was non-existent, the aircraft would probably miss each other).

The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

Quite correct, that is why there are different classes of airspace. ICAO standards contain some requirements but most are imposed nationally in accordance with local needs.


Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.

This is incorrect, the US NAS has hardly changed in the 30+ years I have been watching. It is basically a large "bathtub" of Class E with higher standard classes embedded where they are needed.



I can't belive that after all this time, you still think that a 20+ year old airspace solution is still valid, considering the technological advances in navigation, surveillance and communications. The problem you (amongst others) have is that you still think the reason for airspace is that same reason it was all those years ago. Technology and the airspace user dynamic has moved on. The reason for airspace has changed, and the answer is moving away from the airspace classification system.

ICAO, not Dick, believes that the current airspace solution is fit for purpose, with the exception of unmanned aircraft, about which there is currently a lot of discussion.



The solution is airspace with performance requirements for operation. This includes surveillance/comms/service requirements for the ANSP, as well as equipage requirements for operators. In order to get to these requirements we only need consider one fundamental question. What do we need airspace for? (i.e what problem are we trying to solve). The reason for airspace at Ballina / Mangalore / The Pilbara is not the same. Therefore the solution at each location is not/will not be the same.

This is precisely the process used to derive the type of airspace, from the internationally agreed list, that is need for a given location. National authorities then impose aircraft equipment requirements on top of the basics based on "what do we need the airspace for?" Obviously, Sydney/Ballina/Pilbara are different, that is why we have different airspace classes.



Class E is last century's answer for a modern problem.....and its obsolete. Voices of Reasons' post has not aged well and I think you'll find that large pieces of airspace in the US are not as they were when that post was written, nor is ATC or user sentiment.

I can assure you (past chair IFATCA standing committee 4) Class E is universally hated by the world's ATCs; this is mainly because the majority, outside of the USA, are used to hard lines of delineation between controlled and uncontrolled airspace. None operate anything other than a FIS in class G and I guarantee that most would be appalled by having mandatory traffic information to IFR in Class G. How can you do that, they would ask. I would ask, if you know where the IFR aircraft are why don't you separate them?



Post Number 2

1. We need an agreed upon risk framework so that risk can be determined for certain operations in to particular locations (note I have not used the term airspace). The risk model is to include, traffic mix, traffic density and CNS capability. (amongst other things).

See Australian State Safety Program 2021



2. We also need an agreed methodology to determine the problem we are attempting to solve.

See Australian State Safety Program 2021



3. We need a risk acceptance framework where by risk can be determined, assessed and accepted against the problem. Not all problems need solutions. Some risks may be acceptable provided all parties are informed.

CASA requires risk assessments for all changes, airspace or otherwise. The process is similar to AS ISO 3100:2018; risks are determined, assessed, categorised, mitigated, and should be accepted by an accountable person. As you say, some risks are classified as acceptable but should still be recorded and watched for change.



Lets take Ballina. (None of what I am about to type is a proposal. I have used these examples to trigger a discussion. That is all)

What exactly is the problem we are trying to solve? OAR would have you believe that communications masking from Lismore and over transmission is the problem that lead to the A320/Jabiru incident. But it is known fact that the Jabiru made a transmission, and no one else transmitted at the time. The A320 was in line of sight so terrain shielding also was not at play. So what caused the incident? Is it traffic mix? Is it poor training from Jabiru or A320 crew....I genuinely don't know, but shouldn't we try to find out what the root cause was before we introduce another set of complexities and problems? Class E at Ballina, would not have prevented the incident, and neither would the broadcast zones that are being proposed. Here's the final question, do we absolutely want to prevent a Jabiru from taking out an A320? I would argue, most probably, yes. So the solution is going to have make that the priority outcome, and that may mean excluding some types of operations. So we don’t want any probability of that even happening. (stay with me, I'm going somewhere with this)

I have first-hand experience and I believe that the root cause is trying to operate a multi-purpose airport in a moderately trafficked airspace without the supporting ATS infrastructure. I am on record with CASA and the ATSB as recommending a Class D airspace solution with a small ATC Tower. Class E instead of G should be the overlying airspace because ATC has (or should have) surveillance of all IFR aircraft.



Now take Mangalore.

We really don't know yet what actually caused this accident? We may end up putting it down to bad luck? But, how do we know there is not a latent error in the airspace system that could have this happen anywhere else? (I’m sure I read a comment along that line by you somewhere, I agree by the way).

But what if this is the 1:10(-9) event. Is that ok? Should we invest time/money in trying to make a system more safe, when everybody seemed happy with the 1:10(-9) risk?

In this way we need to develop tools to determine if a) there is an latent error or, b) this is the 1:10(-9) event. If its b) we also then need the testicular fortitude to stand by the level of risk that we have accepted. I feel terrible for those 4 blokes, its sad and I hope it never happens to me. But flying has a risk, we all accept it. Its not zero. If we establish that the risk at Mangalore is as we thought it was...does it need a solution?

I agree, however most authorities in the rest of the world try to protect IFR flights with controlled airspace. The deaths of these pilots may have been prevented if ATC was able to intervene, this is being proactive. A cost/benefit study 30 years ago may have determined that the cost of the ATC equipment was very high compared to the risk. Today however we know that ATC can actually see IFR aircraft on their surveillance displays and if not a few more ADS-B receivers are not expensive. So now the cost/benefit study would come to a different conclusion.



So take the 2 scenarios above. 2 totally different problems, with what I hope would be 2 different set of airspace performance requirements, which would lead to 2 different outcomes with 2 different associated levels of risk. How then can the same solution be applied to both locations, and the same outcome be expected? All you are doing is adding another variable to an existing set of variables that have not been assessed appropriately in the first place.....this makes the risk increase significantly.The point being if we have a mutually agreed framework with which to assess and determine the risk of operations at a particular location, and then you have an agreed framework with which to mitigate that risk (or not) then the outcome should be valid.

You mention again "airspace performance requirements", I am not sure what you mean by this. The variables you mention have been assessed many times all over the world, this is what led to the proliferation of different types of airspace, brought together by ICAO as the classes. Why do you think Australian problems are any different to anyone else's problems?



We are not ready for solutions yet.

I disagree, we do not need to re-invent the wheel, or worse, some Australian odd-ball solution like CA/GRS. Outback USA is very similar to outback Australia but with a hundred times more aircraft movements. Let's learn from others for once....


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Old 13th Apr 2021, 04:45
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Geoff, with respect, you just made most of my points for me.
  • No I did not mean airspace classes. If modern technology has increased the risk, why are we proposing an airspace solution that was developed decades ago in an environment where that technology did not exist? Airspace classes are not going to solve these problems. The only organizations left on the planet who don't understand this are ICAO and the regulators. The UTM framework that is under development start down the exact path I'm discussing.
  • ICAO classes of airspace do not set performance requirements. As in, how do we determine that a piece of airspace is meeting the demand being placed on it? We have no tools for this, its why the OAR cannot determine why the airspace at Melbourne is Class C, or whether it should be something else (like Class B). Its Class C because it always has been.
  • The US NAS has not changed, you are correct. But its use has and now the FAA are being presented with the same problems. US NAS is obsolete.
  • See Australian State Safety Program 2021, I had a quick read. There isn't anything in there that opens the door to the type of thinking required to solve these problems. The draft document exists for the sole purpose of protecting the minister, it offers nothing as a solution.
​​​​​
I am on record with CASA and the ATSB as recommending a Class D airspace solution with a small ATC Tower. Class E instead of G should be the overlying airspace because ATC has (or should have) surveillance of all IFR aircraft.
Is the root cause analysis, risk assessment and mitigation for your determination of this also on record? Where is the supporting evidence? Why does it need to be Class D? What methodology did you use to determine this?

You mention again "airspace performance requirements", I am not sure what you mean by this.
How do you determine if a particular piece of airspace is doing the job (meeting the performance) it has been designed for? You need a set of performance criteria to assess this against. Where are these documented? And no the ICAO airspace classification is not what I am referring to.

CASA requires risk assessments for all changes, airspace or otherwise.
You and I both know they will not, and cannot adequately perform this risk analysis

Obviously, Sydney/Ballina/Pilbara are different, that is why we have different airspace classes.
. I didn't mention Sydney. But the current airspace at Mangalore/Ballina/Pilbara are exactly the same, CLASS G. The solution being proposed (Class E) is also the same. How can this be if the problem at all three locations is completely different?

The variables you mention have been assessed many times all over the world, this is what led to the proliferation of different types of airspace, brought together by ICAO as the classes
No they haven't. ICAO classes of airspace were first published in 1990. There has not been a significant change to them in 30 years. Technology and aircraft performance on the hand has developed 10 fold.

...we do not need to re-invent the wheel....
my point is, we don't even know if we need a wheel.

With respect to your knowledge and experience Geoff, and it is highly respected, it won't be the traditional solutions of the past that solve the modern technological problems of the future.

Cheers, α
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Old 13th Apr 2021, 06:01
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Alphacentauri - great posts - absolutely agree with discussion airspace systems rather than classes. A good case example is the work going into autonomous cars - there will be no 'airspace class' for them as the hive will be left to sort it out - an airspace system if you will. How long it takes to get there is another question but ultimately it will have to - society will demand it. TCAS is another great example - works irrespective of airspace class but is an airspace system.

The risk framework can ultimately be developed by looking at a simple financial equation - the cost of not mitigating a risk vs the cost of mitigation. The cost of mitigation can be determined easily enough (unless Airservices are managing the implementation....). The cost of not mitigating is what actuaries are paid to do and is no different to the process of determining your insurance policies. The key item is the cost of life. Various organisations attempt to quantify the cost of life including here in Oz where the government in 2014 valued 1 life at $4.2m. ("Best Practice Regulation Guidance Note: Value of statistical life"(PDF). Department of the Prime Minister and Cabinet. December 2014 - with thanks to Wikipedia for the link).

So using the two examples above.

Mangalore - allowing for inflation plus arguably some additional costs relating to ATSB investigations, emergency services responses, destroyed aircraft, and intangibles like reputational damage (yeah I know - could be used to manipulate any answer you want) - lets say 4 casualties + extras = $20m in todays money. Lets also say that Managalore was a 1 in 20 year event - or even 1 in 50. What solution exists that costs $1m or even $400k? per annum?). (I know - mandated, federally funded ADSB-IN transponders for all IFR aircraft? Enough overtime to staff a second set of eyes at ML CTR watching YMNG during training hours? Enough to establish a new control position including frequencies etc during YMNG training hours?)

Ballina - hasn't happened yet but lets assume that sometime in the next 90 years - call it a 1 in 100 year event given we've gotten through the last 10 unscathed. At a cost of, say, $5m * 120 people plus a new airbus plus etc gets you close to $700m. What could you do at Ballina for $7m per year? Quite a bit I imagine. Extend the model to all similar airports in Oz and say its a 1 in 50 year incident and you have $14m/pa to spend across all similar airports. Going to pay for several new ATC positions plus increased radar coverage where required?

So the ability to price risk around human lives exists - agree or disagree with it. But it's far from perfect as statistics and particularly risk assessments I often find are geared to generate the desired answer particularly by manipulating the likelihood of an event. The distribution & skew of the costs of not mitigating are also horrendously vague - but it shouldn't be beyond the wit of man (or Airservices or ORR) to develop the framework based on fairly common methodologies and good worldwide data on expected accident rates that have good data behind them due to the nature of aviation investigation and reporting.

UTR
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Old 13th Apr 2021, 07:52
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It’s so (so) refreshing to read some expert and objective analyses and discussion.

So the ability to price risk around human lives exists - agree or disagree with it. But it's far from perfect as statistics and particularly risk assessments I often find are geared to generate the desired answer particularly by manipulating the likelihood of an event. The distribution & skew of the costs of not mitigating are also horrendously vague - but it shouldn't be beyond the wit of man (or Airservices or ORR) to develop the framework based on fairly common methodologies and good worldwide data on expected accident rates that have good data behind them due to the nature of aviation investigation and reporting.
Hear bloody Hear!
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Old 13th Apr 2021, 09:13
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Originally Posted by alphacentauri View Post
I would argue that we are not aiming for the same risk level in all airspace.
I think we are aiming for the same risk level in all airspace. What will vary is the surveillance, the communications, the procedures but surely the target level of safety should be the same. There may be some ATC equipment that is installed for efficiency, examples being PRM at Sydney, Ground Radar at Sydney (and Brisbane, Melbourne, Perth).

One of the major problems is determine the value of life. AsA tried to close Camden Tower but no-one could agree on the value of life. If its AUD $4.2m indexed for CPI (or any other figure) from 2014 then this should be agreed and then used in the calculations.

Last edited by missy; 13th Apr 2021 at 10:39. Reason: typo
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