Dick Smith's open letter to John Anderson
Thread Starter
Re the six fatalities at Benalla. Are you telling me that if the aircraft had remained in class E airspace to the IAF that the ATC would not have informed the pilot that he was tracking to a point that was over 10 miles away?
My experience is that if you are IFR in surveillance covered controlled airspace you will be told pretty quickly if you are not tracking to the cleared position.
My experience is that if you are IFR in surveillance covered controlled airspace you will be told pretty quickly if you are not tracking to the cleared position.
At the time of the accident? Yes, but that's not the point Dick.
All of the parts of the airspace system WERE NOT functioning as they should have been. ATC ignored multiple tracking alerts.
Had the airspace system functioned correctly that accident would not have happened. We needed to fix the system not create a new one.
Surveillance coverage at Ballina was available all the way to the IAF. At the time of the accident, ClassE would not necessarily have meant a different outcome.
All of the parts of the airspace system WERE NOT functioning as they should have been. ATC ignored multiple tracking alerts.
Had the airspace system functioned correctly that accident would not have happened. We needed to fix the system not create a new one.
Surveillance coverage at Ballina was available all the way to the IAF. At the time of the accident, ClassE would not necessarily have meant a different outcome.
Last edited by alphacentauri; 2nd Sep 2021 at 21:55.
Something to consider for your argument.
To analyse a safety system, you cannot prove it to be unsafe by demonstrating that another system is safer.
The accident at Benalla shouldn't have happened within the airspace system as it was at the time of the accident. The solution is not to implement a new system. The solution is to analyse the existing system to determine why (all things operating as intended) the accident happened in the first place.
If you don't determine the reasons, there is a chance that the latent error in the old system transfers to the new system. This is exactly what is occurring at Ballina right now.
Have you considered that mid air / CFIT accidents happen in the NAS system as well? What will be your argument when after introducing NAS you get the same type of accidents (and you will).
To analyse a safety system, you cannot prove it to be unsafe by demonstrating that another system is safer.
The accident at Benalla shouldn't have happened within the airspace system as it was at the time of the accident. The solution is not to implement a new system. The solution is to analyse the existing system to determine why (all things operating as intended) the accident happened in the first place.
If you don't determine the reasons, there is a chance that the latent error in the old system transfers to the new system. This is exactly what is occurring at Ballina right now.
Have you considered that mid air / CFIT accidents happen in the NAS system as well? What will be your argument when after introducing NAS you get the same type of accidents (and you will).
Hi Alpha,
Your arguments are correct however they beg some questions, who analyses the existing system, how do they do it, and will the result become available to the public? I will only address Ballina.
ATSB will undoubtedly avoid the airspace and procedures aspect, the latent issues, as they normally do. In their defence I believe that is because they lack the expertise to make the analysis and have to rely on CASA and Airservices. Both of these organisations, however, have an over-riding goal, to protect their Minister (Information source two senior CASA executives). Hence they have a vested interest in defending the status quo. This is because, by default, they are obeying their ministerial statement of expectations, and, in terms of this argument, the Airspace Act/Regulations, and the Ministerial Airspace Policy Statement. It follows that if the Minister does not tell them to do something differently, then he/she has accepted that they are operating in accordance with his/her expectations.
Airservices has refused to release the safety analysis that it claims was done to justify SFIS at Ballina. CASA should have evaluated that analysis before approving the change from their recommended CA/GRO to SFIS. Why? Because the nature of the SFIS was argued to be simply an extension of the Class G (F?) traffic information service. However, it removed the CA/GRO's capability to visually monitor the circuit area and in particular the runway. This is arguably the most critical area for safety. I would like to see how Airservices treated that removal in their safety matrix and what CASA replied. Incidentally, the last CASA OAR review of Ballina airspace was 16 Aug 2017. There is no published analysis for the latest changes by Airservices.
The other obvious problem with traffic information services is radio clutter. This is particularly true in Australia where pilots have been taught for years that unalerted see and avoid does not work. To keep it simple, each pilot now has to make all the recommended calls, other pilots need to respond to those calls to affect separation, and the SFIS controller has to record the calls and make judgments about how the aircraft are related to each other, and then presumably make more calls to alert the pilots. Add to this the new requirements that force VFR pilots to become "full reporting" before taxiing and the increase in the radius of the MBZ to 15NM (10NM contains 78.5 Sq NM, and 15 NM contains 176.7 Sq NM) now there is a recipe for radio congestion!
It would be interesting to see the safety score on the matrix for that and what mitigation was suggested. The rules do not seem to contain any implemented mitigation other than "let's hope nothing goes wrong" and if it does then again we can say "All of the parts of the airspace system WERE NOT functioning as they should have been". As I understand the US system, it leaves VFR pilots to concentrate on flying, navigation, and watching for traffic, not talking continuously. (Old ATC advice to young controllers - you can't think while your mouth is open) IFR flights are controlled until they must proceed visually and are provided with traffic information on VFR when it is available.
Hopefully, I have demonstrated that there are at least two potential problems with the current Australian system and indicated how the US system has already identified those issues and mitigated them. There is of course much, much more, but time and space preclude going on.
Your arguments are correct however they beg some questions, who analyses the existing system, how do they do it, and will the result become available to the public? I will only address Ballina.
ATSB will undoubtedly avoid the airspace and procedures aspect, the latent issues, as they normally do. In their defence I believe that is because they lack the expertise to make the analysis and have to rely on CASA and Airservices. Both of these organisations, however, have an over-riding goal, to protect their Minister (Information source two senior CASA executives). Hence they have a vested interest in defending the status quo. This is because, by default, they are obeying their ministerial statement of expectations, and, in terms of this argument, the Airspace Act/Regulations, and the Ministerial Airspace Policy Statement. It follows that if the Minister does not tell them to do something differently, then he/she has accepted that they are operating in accordance with his/her expectations.
Airservices has refused to release the safety analysis that it claims was done to justify SFIS at Ballina. CASA should have evaluated that analysis before approving the change from their recommended CA/GRO to SFIS. Why? Because the nature of the SFIS was argued to be simply an extension of the Class G (F?) traffic information service. However, it removed the CA/GRO's capability to visually monitor the circuit area and in particular the runway. This is arguably the most critical area for safety. I would like to see how Airservices treated that removal in their safety matrix and what CASA replied. Incidentally, the last CASA OAR review of Ballina airspace was 16 Aug 2017. There is no published analysis for the latest changes by Airservices.
The other obvious problem with traffic information services is radio clutter. This is particularly true in Australia where pilots have been taught for years that unalerted see and avoid does not work. To keep it simple, each pilot now has to make all the recommended calls, other pilots need to respond to those calls to affect separation, and the SFIS controller has to record the calls and make judgments about how the aircraft are related to each other, and then presumably make more calls to alert the pilots. Add to this the new requirements that force VFR pilots to become "full reporting" before taxiing and the increase in the radius of the MBZ to 15NM (10NM contains 78.5 Sq NM, and 15 NM contains 176.7 Sq NM) now there is a recipe for radio congestion!
It would be interesting to see the safety score on the matrix for that and what mitigation was suggested. The rules do not seem to contain any implemented mitigation other than "let's hope nothing goes wrong" and if it does then again we can say "All of the parts of the airspace system WERE NOT functioning as they should have been". As I understand the US system, it leaves VFR pilots to concentrate on flying, navigation, and watching for traffic, not talking continuously. (Old ATC advice to young controllers - you can't think while your mouth is open) IFR flights are controlled until they must proceed visually and are provided with traffic information on VFR when it is available.
Hopefully, I have demonstrated that there are at least two potential problems with the current Australian system and indicated how the US system has already identified those issues and mitigated them. There is of course much, much more, but time and space preclude going on.
Geoff,
.....supposedly the OAR, but we get the same result if we just say nobody. So why don't we just say nobody.
...there have been no methods established.
*sigh*
Here's the rub. Having no establised methods to assess the existing system, and; to be frank, no will to analyse the existing system, industry are then supposed to take the OAR seriously when they say "we have done a risk assessment at Ballina, and we believe SFIS is the way to go"
Oh, how we all laughed........not going to be funny when they kill someone........amateurs
who analyses the existing system
how do they do it
will the result become available to the public?
Here's the rub. Having no establised methods to assess the existing system, and; to be frank, no will to analyse the existing system, industry are then supposed to take the OAR seriously when they say "we have done a risk assessment at Ballina, and we believe SFIS is the way to go"
Oh, how we all laughed........not going to be funny when they kill someone........amateurs
Alpha,
The process for analysing and changing airspace in Australia is contained in the Airspace Act, Regulations, and Ministerial policy statement (AAPS). None of these documents authorise CASA to introduce a Broadcast Area into Class G or any other type of airspace.CASA seems to have the authority to follow or ignore administrative law as it sees fit. Due, no doubt, to lack of oversight by the responsible Department and the Minister.
According to the AAPS the airspace, as it is configured should be Class F not G, better still Class D with a locally-owned and operated Control Tower:
How CASA arrived at the decision to allow an airspace configuration not authorised by their legislation, that is, Class G/Broadcast Area/FIS, to be implemented we will never know unless someone in the Senate RRAT asks the question, or an FOI request is made.
I am really pleased, however, to see that we are on the same page.
The process for analysing and changing airspace in Australia is contained in the Airspace Act, Regulations, and Ministerial policy statement (AAPS). None of these documents authorise CASA to introduce a Broadcast Area into Class G or any other type of airspace.CASA seems to have the authority to follow or ignore administrative law as it sees fit. Due, no doubt, to lack of oversight by the responsible Department and the Minister.
According to the AAPS the airspace, as it is configured should be Class F not G, better still Class D with a locally-owned and operated Control Tower:
- Class F: IFR and VFR flights are permitted. All participating IFR flights receive an air traffic advisory service and all flights receive a flight information service if requested.
How CASA arrived at the decision to allow an airspace configuration not authorised by their legislation, that is, Class G/Broadcast Area/FIS, to be implemented we will never know unless someone in the Senate RRAT asks the question, or an FOI request is made.
I am really pleased, however, to see that we are on the same page.
They've used that for many years.
(1)CASA may:
(4)If CASA gives a direction, it must publish a notice setting out the details of the direction in AIP or NOTAMS.
(a) designate an aerodrome as an aerodrome at which broadcast requirements apply; and
(b) designate airspace within defined horizontal and vertical limits as an area in which broadcast requirements apply.
(3)CASA may give directions specifying:(a) the broadcast requirements that apply; and
(b) the radio frequency on which broadcasts must be made;
at a particular aerodrome, or in a particular area, designated under subregulation (1).(4)If CASA gives a direction, it must publish a notice setting out the details of the direction in AIP or NOTAMS.
And thus the cosmic cycle continues...
CM is correct. Any class of airspace can theoretically be the subject of a designation under 99A. It's about mandatory blabbing in the designated area, not about the class of the airspace in that area. It's been used many times because, as we know, more blabbing equals more safety. However, come the year 2003 99A will be repealed.
And another 'blast from the past' was GF's epiphany about class F.
It astounds me that there's anyone left who doesn't realise that airspace arrangements and procedures in Australia are determined by the JMSUAYGA Procedure.
CM is correct. Any class of airspace can theoretically be the subject of a designation under 99A. It's about mandatory blabbing in the designated area, not about the class of the airspace in that area. It's been used many times because, as we know, more blabbing equals more safety. However, come the year 2003 99A will be repealed.
And another 'blast from the past' was GF's epiphany about class F.
It astounds me that there's anyone left who doesn't realise that airspace arrangements and procedures in Australia are determined by the JMSUAYGA Procedure.
Thread Starter
Problem with calling it Class F is that under ICAO class F has no requirement for VFR to have radio and we in Australia are obsessed with VFR having mandatory radio requirements!
The same "problem" arises with even greater force in calling it "G". But Australia has never been averse to notifying ICAO of the odd difference here and there.
What we have at Ballina is closer to Class F than it is to G.
i don’t believe the class of airspace is the problem - for the record I quote my post on the BNA thread....
i don’t believe the class of airspace is the problem - for the record I quote my post on the BNA thread....
It’s not the airspace that is the problem. It is the failure of many pilots, including instructors to understand the required procedures appropriate to the circumstances. It is also a failure of CASA to ensure that such procedures are taught and examined to a level which will help ensure the level of communications is undertaken in such a way the risks are minimised. It used to be covered under “airmanship” but seems that is not taught any more?
Isn't all 'G' in Australia 'closer' to F than G? AIP GEN 3.3 at para 3.3.7.2 says that:
So I'm not sure it's all about pilots not understanding and using correct procedures.
That said, the paragraph immediately before the one I quoted effectively says that the service is a 'workload permitting' one. Perhaps part of the education process should be to make clearer that it's a 'Clayton's' traffic information service for IFR. Maybe that's why Australia calls it G rather than F...
Traffic information
...
In Class G airspace, a traffic information service is provided to IFR flights about other conflicting IFR and observed VFR flights except:
a. An IFR flight reporting taxiing or airborne at a non-controlled aerodrome will be advised of conflicting IFR traffic that is not on the CTAF; and
b. An IFR flight inbound to a non-controlled aerodrome will be advised of conflicting IFR traffic until the pilot reports changing to the CTAF.
...
In Class G airspace, a traffic information service is provided to IFR flights about other conflicting IFR and observed VFR flights except:
a. An IFR flight reporting taxiing or airborne at a non-controlled aerodrome will be advised of conflicting IFR traffic that is not on the CTAF; and
b. An IFR flight inbound to a non-controlled aerodrome will be advised of conflicting IFR traffic until the pilot reports changing to the CTAF.
That said, the paragraph immediately before the one I quoted effectively says that the service is a 'workload permitting' one. Perhaps part of the education process should be to make clearer that it's a 'Clayton's' traffic information service for IFR. Maybe that's why Australia calls it G rather than F...
"Clayton's"? In 30 years of providing a traffic service I have never once been unable to provide all IFR-IFR traffic. Sometimes it's impossible to provide detailed directed traffic on multiple VFR aircraft to multiple IFR aircraft, there just isn't time. You might be a skygod, I'm not.
Understood, Le P. I'm not a 'skygod' either.
I don't know too many IFR pilots who understand that the IFR/IFR traffic information service in G in Australia is effectively 'workload permitting'. Maybe the pilots involved in the Mangalore tragedy made an assumption that turned out to be invalid?
I don't know too many IFR pilots who understand that the IFR/IFR traffic information service in G in Australia is effectively 'workload permitting'. Maybe the pilots involved in the Mangalore tragedy made an assumption that turned out to be invalid?
Indeed. And if we had a half-way competent safety regulator and an independent and half-way competent transport safety investigator, the attendant risks would be ringing alarm bells and mitigating actions would be recommended and taken. But this is 21st century Australia.
Re AIP GEN 3.3 - 4 para 3.3.7.1 stating "A traffic information service is provided, depending on higher priority duties of the controller etc.".
Certainly in the days of FS when they managed "OCTA", traffic info to IFR (and RPT & MLJ) wasn't workload permitting, it was mandatory to provide it (MATS said something like "Traffic information shall be provided to etc.").
I suspect the revised text came in when FS disappeared and ATC took over their airspace, with some ATC sectors also being responsible for separation in the overlying CTA, which I assume someone decided was a higher priority than the provision of traffic info in Class G.
Certainly in the days of FS when they managed "OCTA", traffic info to IFR (and RPT & MLJ) wasn't workload permitting, it was mandatory to provide it (MATS said something like "Traffic information shall be provided to etc.").
I suspect the revised text came in when FS disappeared and ATC took over their airspace, with some ATC sectors also being responsible for separation in the overlying CTA, which I assume someone decided was a higher priority than the provision of traffic info in Class G.
Perhaps the 'hard-hitting' objectively independent investigation of the Mangalore tragedy by the ATSB will recommend reinstatement of FS? Nothing would surprise me these days.