The frequency to be used in the vicinity of uncharted aerodromes farce continues
Thread Starter
The frequency to be used in the vicinity of uncharted aerodromes farce continues
Those who’ve been around a while will probably remember the debate that raged about the frequency to be used in the vicinity of uncharted aerodromes. For a time there was a correct regulatory answer: The Area frequency.
But as usual the initial implementation of the decision was half-baked, there was insufficient education and, in this particular instance, air traffic controllers among some others didn’t like the answer. This led to ATSB responding to reports like “contradictory information contained in AIP concerning the frequency to be used at non-controlled airports”, lack of education about “the use of Multicom (126.7) versus Area Frequency” and “Air traffic controllers not understanding the requirement for aircraft to broadcast on the area frequency when operating to or from aerodromes which are not marked on a map”.
In response to the first of those, CASA told ATSB that, among other things:
In response to the second of those, CASA told ATSB that, among other things:
In response to the third, CASA noted that Airservices had promulgated further educational material to ensure that controllers were aware of their requirements in relation to VFR aircraft broadcasting on Area frequency. The Airservices controller educational material said, among other things:
So, after the usual confusion and mess, we finally got there: A clear rule understood by just about everyone. And clear rules understood by just about everyone are better than the alternative. But…
The clear rule was evidently not accepted by everyone. Obviously somebody whinged loud and long enough to somebody in CASA because there is now no rule. It’s been replaced by a meaningless motherhood statement that can be interpreted any way anyone likes. AIP ENR 1.1 para 9.1.7 now says:
How on Earth could that result in a “consistent and safe approach”?
The ”most appropriate frequency” in the vicinity of an uncharted aerodrome is actually the one that everyone else will assume is being used in the vicinity of that aerodrome. Remember: It’s about communicating with other people.
CASA could have backflipped and specified 126.7 instead of Area. But no: It’s now: Take your pick and just hope that everyone else has ESP. What could possibly go wrong? (I am waiting for the equivalent change to the road rules: Drivers on country roads have discretion to drive on whichever side of the road that ensures safety. That may be the right side of the road but you should be aware that oncoming drivers may have exercised their discretion the other way.)
Naturally, there is inconsistency with the text of AC 91-10v1.1. It says, with my bolding:
The clear effect of the bolded text is that the Area frequency should be used in the vicinity of uncharted aerodromes except in “limited circumstances” like the example given. That’s not the clear effect of the words in ENR 1.1 para 9.1.7.
Note 1 under the quoted text says:
No kidding.
But as usual the initial implementation of the decision was half-baked, there was insufficient education and, in this particular instance, air traffic controllers among some others didn’t like the answer. This led to ATSB responding to reports like “contradictory information contained in AIP concerning the frequency to be used at non-controlled airports”, lack of education about “the use of Multicom (126.7) versus Area Frequency” and “Air traffic controllers not understanding the requirement for aircraft to broadcast on the area frequency when operating to or from aerodromes which are not marked on a map”.
In response to the first of those, CASA told ATSB that, among other things:
CASA will use both industry education and changes to AIP to ensure a consistent and safe approach.
CASA has taken a number of steps to ensure the aviation community is aware of its policy for radio broadcasts at non-controlled aerodromes as follows:
- Amended relevant sections of the AIP;
- Revised CAAPs 166-1 and 166-2 to reflect the policy;
- Updated the relevant pages and products on its website and deleted outdated material;
- Run a campaign through nationwide seminars by CASA Aviation Safety Advisers;
- Placed articles in recent CASA Briefings – August 2014 ‘Get on the right frequency at unmarked aerodromes’ and September 2014 ‘No reports of area frequency congestion’; and
- Issued a NOTAM to raise awareness of the changes prior to their incorporation while changes have been made.
Why is that VFR aircraft broadcasting on Area VHF?
..
If, however, an aircraft is beginning a flight, approaching or flying in the vicinity of an aerodrome not depicted on aeronautical charts, the pilot must make their required broadcasts on the Area VHF frequency.
Next time you hear a broadcast on the Area VHF frequency, consider whether the aerodrome in question is depicted on aeronautical charts (WAC, VNC, VTC, ERC, TAC). The aircraft may be complying with AIP requirements.
..
If, however, an aircraft is beginning a flight, approaching or flying in the vicinity of an aerodrome not depicted on aeronautical charts, the pilot must make their required broadcasts on the Area VHF frequency.
Next time you hear a broadcast on the Area VHF frequency, consider whether the aerodrome in question is depicted on aeronautical charts (WAC, VNC, VTC, ERC, TAC). The aircraft may be complying with AIP requirements.
The clear rule was evidently not accepted by everyone. Obviously somebody whinged loud and long enough to somebody in CASA because there is now no rule. It’s been replaced by a meaningless motherhood statement that can be interpreted any way anyone likes. AIP ENR 1.1 para 9.1.7 now says:
In the vicinity of uncharted aerodromes, pilots have discretion to use the most appropriate frequency that ensures safe operation. This may be 126.7. However, pilots should be aware that transiting aircraft will be monitoring Area VHF. To ensure mutual traffic awareness, it is recommended that pilots using an alternative frequency also monitor Area VHF.
The ”most appropriate frequency” in the vicinity of an uncharted aerodrome is actually the one that everyone else will assume is being used in the vicinity of that aerodrome. Remember: It’s about communicating with other people.
CASA could have backflipped and specified 126.7 instead of Area. But no: It’s now: Take your pick and just hope that everyone else has ESP. What could possibly go wrong? (I am waiting for the equivalent change to the road rules: Drivers on country roads have discretion to drive on whichever side of the road that ensures safety. That may be the right side of the road but you should be aware that oncoming drivers may have exercised their discretion the other way.)
Naturally, there is inconsistency with the text of AC 91-10v1.1. It says, with my bolding:
There are additional risks associated with operations at aerodromes or ALAs that are not published on an aeronautical chart. Under limited circumstances, such as multiple aircraft using the same uncharted ALA outside a CTAF or Mandatory Broadcast Area, it may be appropriate for the pilots involved to monitor and broadcast on a frequency other than Area VHF (such as the CTAF or 126.7 MHz). However, pilots undertaking these operations should be aware that overflying traffic will be on Area VHF and are likely to be unaware of the uncharted aerodrome / ALA. Hence, the safety benefits of 'alerted' 'see-and-avoid' may not be achieved. It is recommended that pilots at uncharted aerodromes using a frequency other than Area VHF also monitor Area VHF.
Note 1 under the quoted text says:
The intent is to ensure broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring.
Airservices hates the area frequency advice as they can't have half the east coast combined frequencies under one ATS officer if there's regularly 50 broadcasts going on across the region. 126.7 is no fix as no one in their right mind will listen to that frequency unless they have to lest they want to go deaf from over transmissions. Under the right atmospherics you can hear aircraft from 300nm away and that is a lot of airfields on the East coast. Flying RPT from the flight levels into a 126.7 port you just cant monitor the frequency that far out, it will just give you a headache.
Thread Starter
It wasn't "advice" or "policy". It was a rule in AIP.
It wouldn't surprise me if it was undone because it was inconvenient to Airservices. After all, that's what the rules are about.
It wouldn't surprise me if it was undone because it was inconvenient to Airservices. After all, that's what the rules are about.
Perhaps it would be easier if they changed it so that all charted AD's had a discrete frequency other than 126.7. Obviously with the amount of AD they would run out so they could do what they do in some places and if there are multiple aerodromes close to each other they could share a frequency ( dependent on traffic volume).
That way, you avoid the problem of people just assuming some aerodrome's CTAF is 126.7 when it isn't, and all uncharted/ AD not in ERSA could be on 126.7 and there would be no confusion on what FQ to use.
That way, you avoid the problem of people just assuming some aerodrome's CTAF is 126.7 when it isn't, and all uncharted/ AD not in ERSA could be on 126.7 and there would be no confusion on what FQ to use.
Originally Posted by MMM345
all uncharted/ AD not in ERSA could be on 126.7 and there would be no confusion on what FQ to use.
Thread Starter
Capn Bloggs nails the conundrum the only logical answer to which - no matter how unpalatable to some - is the use of Area in the vicinity of uncharted aerodromes (that aren't inside a BA or within 10nms of a charted aerodrome). That is why the rule was made. But now... farce.
Unfortunately regulatory motives moved from the safest most sensible option to the most cost effective solution for the overseers. Safety is only something CASA will force on the operators at any cost, but when it comes to running safe airspace, then it becomes 'affordable safety'.
I regularly operate from farm strips, strips not marked on charts (including my own) and clearings where there is no airstrip. I would suggest there is no solution. A broadcast on area from many places I operate would be meaningless because all I could do is give a reference and a town name most pilots would not have heard of. If I broadcast I might as well say "all stations (at my) Granny's farm".
My solution: Look, look and look some more, listen on the area. As others have suggested, 126.7 is unworkable because of the sheer volume of often totally unnecessary broadcasts by pilots who often don't even bother to properly identify where they are.
The conundrum really is; how do we shut up the meaningless running commentaries we consistently hear on CTAF and 126.7? The conclusion I have reached is that we can't. Pilots simply are convinced that a running commentary at an empty airstrip is somehow a safe thing to do. At a recent CASA safety seminar where this was supposed to be debated the delegates from CASA effectively stymied the debate by announcing prior to it starting that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight. To the majority of participants this simply endorsed their running commentaries that often block others transmissions..
My solution: Look, look and look some more, listen on the area. As others have suggested, 126.7 is unworkable because of the sheer volume of often totally unnecessary broadcasts by pilots who often don't even bother to properly identify where they are.
The conundrum really is; how do we shut up the meaningless running commentaries we consistently hear on CTAF and 126.7? The conclusion I have reached is that we can't. Pilots simply are convinced that a running commentary at an empty airstrip is somehow a safe thing to do. At a recent CASA safety seminar where this was supposed to be debated the delegates from CASA effectively stymied the debate by announcing prior to it starting that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight. To the majority of participants this simply endorsed their running commentaries that often block others transmissions..
In the UK there is a discrete frequency allocated for use when approaching or transitting airfields which otherwise have no frequency allocated.
The service is called 'Safetycom' and it's on 135.480 mHz and is strictly for that purpose and NOT for 'air to air' chat.
Surely you have enough frequencies available in your country to be able to allocate a discrete frequency even on 25 kHz channels without using 8.33 kHz ones
The service is called 'Safetycom' and it's on 135.480 mHz and is strictly for that purpose and NOT for 'air to air' chat.
Surely you have enough frequencies available in your country to be able to allocate a discrete frequency even on 25 kHz channels without using 8.33 kHz ones
Last edited by chevvron; 16th Nov 2022 at 10:04.
In the UK there is a discrete frequency allocated for use when approaching or transitting airfields which otherwise have no frequency allocated.
The service is called 'Safetycom' and it's on 135.480 mHz and is strictly for that purpose and NOT for 'air to air' chat.
Surely you have enough frequencies available in your country to be able to allocate a discrete frequency even on 25 kHz channels without using 8.33 kHz ones
The service is called 'Safetycom' and it's on 135.480 mHz and is strictly for that purpose and NOT for 'air to air' chat.
Surely you have enough frequencies available in your country to be able to allocate a discrete frequency even on 25 kHz channels without using 8.33 kHz ones
If there was only a frequency that everyone in the 'area' is supposed to be on and listening to.... Oh that's right Airservices combined all those as well with repeaters so you can over-transmit someone in Bamaga while taxiing on King island.
Thread Starter
I regularly operate from farm strips, strips not marked on charts (including my own) and clearings where there is no airstrip. I would suggest there is no solution. A broadcast on area from many places I operate would be meaningless because all I could do is give a reference and a town name most pilots would not have heard of. If I broadcast I might as well say "all stations (at my) Granny's farm".
My solution: Look, look and look some more, listen on the area. As others have suggested, 126.7 is unworkable because of the sheer volume of often totally unnecessary broadcasts by pilots who often don't even bother to properly identify where they are.
The conundrum really is; how do we shut up the meaningless running commentaries we consistently hear on CTAF and 126.7? The conclusion I have reached is that we can't. Pilots simply are convinced that a running commentary at an empty airstrip is somehow a safe thing to do. At a recent CASA safety seminar where this was supposed to be debated the delegates from CASA effectively stymied the debate by announcing prior to it starting that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight. To the majority of participants this simply endorsed their running commentaries that often block others transmissions..
My solution: Look, look and look some more, listen on the area. As others have suggested, 126.7 is unworkable because of the sheer volume of often totally unnecessary broadcasts by pilots who often don't even bother to properly identify where they are.
The conundrum really is; how do we shut up the meaningless running commentaries we consistently hear on CTAF and 126.7? The conclusion I have reached is that we can't. Pilots simply are convinced that a running commentary at an empty airstrip is somehow a safe thing to do. At a recent CASA safety seminar where this was supposed to be debated the delegates from CASA effectively stymied the debate by announcing prior to it starting that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight. To the majority of participants this simply endorsed their running commentaries that often block others transmissions..
Some folks have forgotten - or maybe never learned - that:
- Sometimes a broadcast adds nothing to safety.
- Sometimes a broadcast detracts from safety.
- Sometimes we're mixing it with aircraft with no radio or one tuned to the wrong frequency (but, as a consequence of the most recent development in this farce, who'd know what the 'correct' frequency is for use in the vicinity of an uncharted aerodrome?)
CASA's attitude at the Seminar is disappointing but - sadly - unsurprising. I reckon they're the 'meat in the sandwich' on uncharted aerodrome frequency issue if the most recent development in this farce was a consequence of Airservices' human resources management practises.
Thread Starter
Is anyone aware of the process through which CASA went to justify the change that's now embodied in ENR 1.1 para 9.1.7? Any public consultation? Any education campaign? Any safety incidents caused by the use of Area frequency for operations in the vicinity of uncharted aerodromes?
Thanks A Bob,
Re 'that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight.'.......
Could this also be construed as allowing a pilot to not make any calls, as they were not thought to be 'necessary' for the safety of their flight?
(Bring back FS I say.........)
Re 'that pilots were within their rights to make any CTSF broadcast they thought necessary for the safety of their flight.'.......
Could this also be construed as allowing a pilot to not make any calls, as they were not thought to be 'necessary' for the safety of their flight?
(Bring back FS I say.........)
Originally Posted by Clinton
Is anyone aware of the process through which CASA went to justify the change that's now embodied in ENR 1.1 para 9.1.7?
I think that the original CASA rules were the best. If the airport was on the charts, use the unique CTAF for the location (if allocated) or in other cases, the Multicom, 126.7, otherwise stay on Area, keep your trap shut and your eyeballs out.
Thread Starter
Thanks Vag. I see from the “Summary of Consultation” that the “Future direction” foreshadowed what’s now happened: “The AIP will be simplified and less prescriptive about the frequency to use at those aerodromes that are uncharted.” The perfect bureaucratic answer to competing opinions, which answer is given the Orwellian description ‘simplification’ and results in an increased risk to aviation safety compared with the pre-existing rule.
I’d be interested in who constitutes “the industry”, Capn Bloggs, as my observation is that different parts of it often disagree as to what the rules should be. (Not that I’m pressing you for a definition.)
In any event, it’s just bizarre to me that these kinds of decisions seem to be a popularity contest rather the result of cold, hard logic. It’s like consulting on the speed limit to be set on a particular stretch of road.
CASA’s original decision to mandate Area as the frequency to be used in the vicinity of uncharted aerodromes was based on cold, hard logic (just as your view and mine - and others’ - are based on cold, hard logic). Given that the ultimate aim is to “ensure broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring” - because that is the only way in which the broadcasts will serve their safety purpose - there was (and I and it seems you say remains) only one answer to the question as to which frequency to use to achieve that aim and serve the safety purpose in the vicinity of uncharted aerodromes.
Presumably, that is why CASA settled on the pre-existing rules to which you referred and vigorously defended them (as can be seen in the ATSB investigations, links to some of which I posted earlier). And it appears that the drafters of the AC provision I quoted earlier continue to take the same view, because the language in the AC is to the effect that Area should be used except in some “limited” circumstances.
So let’s test whether the “simplified” rule achieves the aim of “ensur[ing] broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring”.
Question: When you exercise your discretion as to the frequency to use for broadcasts in the vicinity of an uncharted aerodrome, how do you know that all other pilots will be exercising their discretion in the same way in the vicinity of that aerodrome?
Answer: You don’t know.
QED.
I’d be interested in who constitutes “the industry”, Capn Bloggs, as my observation is that different parts of it often disagree as to what the rules should be. (Not that I’m pressing you for a definition.)
In any event, it’s just bizarre to me that these kinds of decisions seem to be a popularity contest rather the result of cold, hard logic. It’s like consulting on the speed limit to be set on a particular stretch of road.
CASA’s original decision to mandate Area as the frequency to be used in the vicinity of uncharted aerodromes was based on cold, hard logic (just as your view and mine - and others’ - are based on cold, hard logic). Given that the ultimate aim is to “ensure broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring” - because that is the only way in which the broadcasts will serve their safety purpose - there was (and I and it seems you say remains) only one answer to the question as to which frequency to use to achieve that aim and serve the safety purpose in the vicinity of uncharted aerodromes.
Presumably, that is why CASA settled on the pre-existing rules to which you referred and vigorously defended them (as can be seen in the ATSB investigations, links to some of which I posted earlier). And it appears that the drafters of the AC provision I quoted earlier continue to take the same view, because the language in the AC is to the effect that Area should be used except in some “limited” circumstances.
So let’s test whether the “simplified” rule achieves the aim of “ensur[ing] broadcasts are made on a frequency that other aircraft in the vicinity will be monitoring”.
Question: When you exercise your discretion as to the frequency to use for broadcasts in the vicinity of an uncharted aerodrome, how do you know that all other pilots will be exercising their discretion in the same way in the vicinity of that aerodrome?
Answer: You don’t know.
QED.
Thread Starter
As a mature adult, what is your answer to this question, Vag:
When you exercise your discretion as to the frequency to use for broadcasts in the vicinity of an uncharted aerodrome, how do you know that all other pilots will be exercising their discretion in the same way in the vicinity of that aerodrome?
Logic has a way of being logical, irrespective of the age and maturity of the proponent.
When you exercise your discretion as to the frequency to use for broadcasts in the vicinity of an uncharted aerodrome, how do you know that all other pilots will be exercising their discretion in the same way in the vicinity of that aerodrome?
Logic has a way of being logical, irrespective of the age and maturity of the proponent.
Thread Starter
That seems to me to be the unassailably correct answer to the question.
The next question is:
If there is scope for pilots to exercise the discretion in different ways in the vicinity of the same uncharted aerodrome, is that ‘safer’ or ‘less safe’ than if one frequency e.g. the applicable Area frequency - were mandated?
It seems to me that the unassailably correct answer to that question is: ‘less safe’. Do you agree? That was the conclusion to which CASA came when it mandated the Area frequency and defended the decision in the face of reports to the ATSB.
So the next question is:
What is the justification for the change? It can’t be ‘safety’. Is it that the original mandate was ‘unpopular’?
The next question is:
If there is scope for pilots to exercise the discretion in different ways in the vicinity of the same uncharted aerodrome, is that ‘safer’ or ‘less safe’ than if one frequency e.g. the applicable Area frequency - were mandated?
It seems to me that the unassailably correct answer to that question is: ‘less safe’. Do you agree? That was the conclusion to which CASA came when it mandated the Area frequency and defended the decision in the face of reports to the ATSB.
So the next question is:
What is the justification for the change? It can’t be ‘safety’. Is it that the original mandate was ‘unpopular’?