Traffic Information and UNICOM v AFIS v ATC
 

Following a bit of "thread creep" on http://www.pprune.org/forums/showthr...=285543&page=5
I think this thread is long overdue.

Before I burst into print for real I'd just like to prefix by saying that this is not an "attack" on UNICOM services but more my view on what services are permitted to be offered by a UNICOM. Likewise I have no doubt that some UNICOM officers could be trained to offer an AFIS or ATC service (much like a Cessna 152 pilot can be trained to fly a twin and more), but if not then they must not step beyond their training.

The regulations specifying what can be offered by a UNICOM is contained in CAA Rule Part 139 - Aerodromes Operation and Use http://www.caa.govt.nz/rules/Rules_C...solidation.pdf
whereas the rule applying to Air Traffic Control and Aerodrome Flight Information licenses and ratings and the services that can be offered are contained in Part 65 Air Traffic Service Personnel Licenses and Ratings and Part 172 Air Traffic Service Organisations - Certification.

Interesting excerpts from Part 139 include...
139.353
(e)A person providing or operating a UNICOM service may—
(2)provide information on the preferred runway in use, as indicated by wind direction information from either a basic weather report or other appropriate meteorological information, and reports from pilots of aircraft using the aerodrome
(6)at the request of a pilot, provide information on the general location of any aircraft the UNICOM service operator has knowledge of

139.353
(f)A person providing or operating a UNICOM service must not—
(1) provide any air traffic services; or
(2) give or suggest traffic information; or
(3) initiate or derive traffic information.


My reading of these mean that UNICOM MAY NOT issue traffic information. UNICOM MAY pass on information given by pilots. UNICOM are not trainined or permitted to look out the window and "derive" traffic information - hence my statement in a previous thread that to avoid this temptation they should be in a room without windows!! Note there is no provision here for UNICOM to suggest manoeuvers (eg. SUGGEST YOU GO AROUND TO ALLOW DEPARTURES, SUGGEST YOU USE THE GRASS, etc.). UNICOM's function are to provide weather reports, RWY in use, limited flight following (like an airline or GA operator would), initiate emergency response, and PASS ON INFORMATION GIVEN BY PILOTS.

In contrast an AFIS (in addition to the UNICOM service) may
172.95(a)
(1)determine, from information received and visual observation, the relative positions of known aircraft to each other
(2)issue of advice and information, including the designation of a preferred runway, for the purpose of the safe and efficient operation of—
(i) aircraft flying in the vicinity of an aerodrome; and
(ii) aircraft operating on the manoeuvring area; and
(iii) aircraft landing and taking off; and
(iv) aircraft, vehicles, and persons, on the manoeuvring area; and
(v) aircraft on the manoeuvring area and obstructions on that area.

In brief then an AFIS can derive traffic information and pass that on.

Air Traffic Control - Aerodrome Controller in addition to the UNICOM and AFIS can issue instructions, clearances, and information to aircraft...and depending upon the Airspace Class has responsibilities to ensure separation between certain flights - check Rule Part 71 Designation and Classification of Airspace if you'd like to know exactly who gets separated from whom (it may surprise you!!).

I guess my message above is that we should all be aware of the level ov service that is permitted to be offered and if that service is below what is required then the SERVICE should be upgraded (i.e. UNICOM upto AFIS, or AFIS upto ATC) rather than providing information above what is permitted.

Slackie!

Apologies in my last thread, it wasnt a personal attack on you, more just the general concensus that i have heard in 'conversation', apologies if it came across the wrong way. :ok:

I agree, with all that you have said, not passing traffic information etc etc, and yes UNICOM should not over step their mark, however like anything i am sure that there are situations where things have been said by UNICOM at ardmore and a potential disaster has been averted!

I think you are probably right, that given how Ardmore operates, maybe an AFIS would be better such as Milford Sound?
I know that your a local operator now, so what are your thoughts? Would AR be better with no one there at all,? make UNICOM work from the bottom of the tower? or go to full AFIS?

:ok:

No offense taken...we have to be so careful in this medium to ensure that what we type isn't taken in a different vein to that intended (hence my "preamble" above. Well...as a pilot that learnt at a controlled aerodrome (PM), I must admit to preferring full aerodrome control, with AFIS applicable at some of the busier aerodromes that don't warrant full ATC (as PP did when I was learning - showing my age here!!). I like to know what traffic is around me and prefer to get clearances into the CTA with AA CONTROL to do my training rather than risking it with all and sundry in the training areas. The aircraft I fly isn't particularly suited to maintaining a full AND EFFECTIVE lookout, and the training often takes much of my attention. By operating within controlled airspace I am relying on at least traffic information to alert me to other VFR aircraft in my vacinity, and separations with other IFR aircraft. Final responsibility for collision avoidance still rests with me (as the pilot), but at least I am in a better position to know when other aircraft are approaching. The danger that the UNICOM guys face is that if they "offer advice" outside of their "brief"/training/responsibility then they become part of the "ensuing court of enquiry" when the sh!t hits the fan.

This is important for airshows. I flew into the Tyabb airshow once and was not only directed on where and how to join the circuit (prior to show opening). I was also directed for take-off and cleared to takeoff. I know for a fact that the guy on the unicom is not qualified to perform this kind of action so he would no doubt be opening himself for liability in the event of an incident.

Slackie

so back to what originally got me going on this one, the statement regarding unicom reporting the number of aircraft in the circuit.

your quote of pt 139 indicates that this is acceptable
(6)at the request of a pilot, provide information on the general location of any aircraft the UNICOM service operator has knowledge of

I wonder how many accidents over the years have been averted by having aunicom service?

6080ft

The issue is how UNICOM get the information or "knowledge". UNICOM are not trained nor permitted to issue traffic information. UNICOM are only permitted to answer questions based upon what a pilot reports NOT what UNICOM observe. UNICOM may not issue information that may be erroneous or misleading. As soon as one aircraft fails to report clear of the circuit or runway then the information that UNICOM hold is no longer valid and so should not be issued as "number in the circuit" (for example).

If you want a service that is permitted to issue this kind of information then you should lobby for AFIS or the return of ATC. Personally it doesn't particularly bother me what sort of service is at AR as it is no longer the manically busy place it used to be

Relate it back to the pilot license...are you saying that a student pilot should be able to carry passengers, just because they appear to be able to handle an aircraft ok?? Should a PPL be able to fly a 747 full of passengers because he has taken off and landed the Microsoft version???

Squawk7700...yes same thing happened to me at a SportAvex at Matamata a couple of years back...

Taken from the booklet entitled "UNICOM" - an air ground radio communication facility for Australian Aerodromes (published January 1992 and issued by the Civil Aviation Authority).

UNICOM (Universal Communications) is an air/ground radio communication facility to provide advice on local conditions such as weather information, runway in use and known traffic at some non-controlled aerodromes in Australia. The services provided by Unicom may include:

(a) ordering fuel;

(b) providing estimated times of arrival and departure;

(c) aerodrome information;

(d) information concerning the maintenance and servicing of aircraft including the ordering of parts and materials urgently required;

(e) passenger requirements;

(f) general weather reports.

These services will normally be available during the times the Unicom is listed as operating.

The Unicom operator is solely responsible for the accuracy of any information passed on to an aircraft, and the use of the information obtained from a Unicom is at the discretion of the pilot in command.

Weather reports, other than simple factual statements, may not be provided by Unicom operators unless they are properly authorised under Civil Aviation Regulation 120.

Unicom services must be licensed by the Department of Transport and Communications (DoTaC).

It would be interesting to know if people providing services such as these are trained about what they are NOT allowed to do, otherwise they could easily, and to them, quite logically, ramp up their service level without realising the legal position they are in. I'll bet the Tyabb radio operator thought that he was doing a great job! (Incidentally under a duty of care scenario it would be interesting to speculate on where you would stand if you can do something, i.e see traffic, but don't pass it on because some silly book says so!)

I agree with the leave them in a room with no windows, or at least just the office window, otherwise they are bound to think they were given such a magnificent view of the airfield and circuit area for a reason! It is common sense to let the refueller or airline agent talk to pilots on the radio about weather and anything else he sees going on, but as soon as you train them and give them what to all intents and purposes is control tower, then that is what they will become. It's human nature to want to do your best.

Anybody doing UNICOM anywhere (OZ or NZ) should make sure they are covered by indemnity insurance. You don't have to have stuffed up to have legal action taken against you, and how are you going to fund a defence?

Last I heard from an AD operator indemnity insurance cost around $A60k per year.

Can anyone tell me what level of training/qualification UNICOM operators are required to have? I'm assuming there is some level of requirement! Do they have to be aviation document holders of any sort? Or can they be someone that just lurks around airports a lot and has some idea of what goes on? Info please.

Kiwblue -

To become a certified UNICOM operator in NZ you must hold either a pilot licence or an Air Traffic Control licence, if so then you have 50hrs on job training....
If you are Civilian, ie no formal aviation qulifications then 100hrs training on job.

Piston Broke - In New Zealand, you cannot be personally 'sued' especially if you work under a company as an employee, if you are a sole trader/ Company owner then yes, in which case you would surely have indemnity cover as a responsible business owner....or have everything in a trust :) :E

:ok:

So has slippery dick read the opening post yet.......
oh that's right, he's stuck somewhere in oodnawoopwoop with a vehicle full of buggered electronics awaiting rescue isn't he :)

Just in case you missed this on another thread:
http://www.ministers.dotars.gov.au/m...139MV_2007.htm

Sorry for the Oz thread drift folks
 

.
and
.
Wonder where one might obtain a copy of the 'extensive assessment'?
.
Two locations where facilities already exist .. i.e. Du FS Unit and WG Twr
.
Wonder if the requirements for other 'Unicoms' will involve windowed facilties :E
.
Part 71? :rolleyes:
.
... wonder who and how this is being paid for .. and who are the trainees/appointees? .... hope they are locals to be retained and trained!
.
Re NZ and Ardmore
.
I am led to believe our current GM ATC (OZ) was the Ardmore chief when the TWR ATC service was removed (stand to be corrected :E ) .... perhaps some of your questions could be asked directly to him .... he might be home to the land of the long white cloud soon, and in a position to comment officially and directly :ok: :E
.
Karma .... ain't it wonderful :}

Official Requirements for UNICOM Service Operator
 

FL440...although the qualifications that you state maybe the requirements of the operators of AR UNICOM, they are above the official requirements...
Part 139 states
139.355 Requirements for UNICOM Service Operators
A person operating a UNICOM service must be—
(1) trained and assessed as competent to the level of the flight radio telephony requirements of a private pilot licence or equivalent; and
(2) trained and assessed as competent to meet the requirements of the services offered; and
(3) given written evidence of the scope of their authorisation to operate the service

None of this requires a PPL or ATS License...but a FRTO (to use the radio) and Met Observers certificate (if reporting weather conditions), but I believe the AWIB does this automatically (could be wrong here?!).

Slackie - Gday! I do beleive you are correct!

Awib is acredited by metservice, but UNICOM operators can still give weather report if they have an issued licence as this falls under Basic Weather Reports, normal rules apply for pilots using it, ie cant use it to decide on alternates etc

If UNICOM wanted to do METAR's etc then yes, they would need to do the Met part 174 (from memory) training :ok:

Slackie, do you think that UNICOM at AR are too proactive?

It's not that they are "too proactive", its just that for pilots that are unfamiliar with exactly what UNICOM responsibilities are (and that appears to be many pilots), those pilots may mistake advice for an instruction or worse.

Ok, understandably!

Ok, so heres the next problem, when does a pilot who is unfamiliar with ATC/ AFIS/UNICOM know when they are over stepping the mark....i know the answer is in training, but a difficult subject to cover, im sure you understand, you train ATC operators at Airways, so its a subject un to its own, and yet for pilots its everyday stuff and probably not covered well enough do you agree? I remember many a student being 'afraid of controlled airspace' yet later you realise its a blessing :)

Again though, UNICOM is covered as part of FRTO, as is ATC and AFIS, and again i understand that FRTO doesnt mean that you understand everything about ATC services! Hell, ive got alot more flying time than most of the 'learning' / 'recreational' pilot genre and i still learn what ATC can and cant do all the time.

Difficult eh!

:ok:

hmmm... thanks for that Slackie. It ain't particularly encouraging to realise that the authoritative voice on the other end of the UNICOM freq is solely trained and qualified to spell 'New Plymouth' phonetically...

Good thread. Lesson there for many I reckon.