Merged: The Ambidji Report – CASA should get their money back!
 

Many readers of this forum will remember the “UTILITY OF GENERAL AVIATION AERODROME PROCEDURES TO AUSTRALIAN ADMINISTERED AIRSPACE, Report to Office of Airspace Regulation 30 June 2009”, referred to in short as the “Ambidji Report”.

From this Report came the statement that


Personally, I believe that airports such as Bankstown have some of the safest procedures that I have experienced in the world. For example, there has been one mid-air in the Bankstown control zone in a forty year period – and this happened because a pilot inadvertently overshot the base turning point for landing on a runway when parallel runways were in use.

Naturally, CASA had to act on the Ambidji Report’s emotive claim that the risk was "intolerable".

I have commissioned three independent Reviews of the Ambidji Report. I paid for these reviews myself, having chosen Consultants who had no vested interest and no conflict of interest. The Consultants who reviewed the Ambidji report were:


I have placed the three Reviews on my website (see here).

Each of these Consultants disagreed with the methodology and the results of the Ambidji Report. Professor Middleton said in a separate email to me that:

"There appears to be a lack of high level expertise in the evaluation of risk in this case, so that CASA OAR is perhaps less well briefed than it might be by the Ambidgi report"

In Professor Middleton’s Review itself, he states:

"An analysis made from a different perspective might easily arrive at different conclusions and recommendations...It is recommended here that the entire Ambidji report be peer reviewed by independent reviewers"

Chris Mills states in his Review, among other points:

"Conclusion. Not conducting significance tests, and immediately treating a ‘cluster’ as a ‘trend’, leads to investigations that are, in all probability, a non-sense. This activity can lead to interventions that are not necessary or justified, and usually result in imposing restrictions that have little or no relevance to the actual level of aviation safety"

Ian Bryce, who has performed risk analysis of space launching programs, states in his Review:

"Individual Risk: Given that the assumptions and the calculations for the risk contain several errors or uncertainties of factors of 0.5 or 2, the conclusions on individual risk are invalid… The claimed dramatic reductions in MACs [mid-air collisions] are without real evidence. The changes described could even increase risk"

Readers of this website will be staggered. Can you imagine that an independent expert has stated, I repeat, that “the changes described could even increase risk”?

I suggest that everyone applies themselves to reading these Reviews.

It seems such a pity that the type of errors that were made in safety studies by Airservices Australia have now continued through to the Office of Airspace Regulation.

?

It was my understanding you wanted FAA or ICAO Class D for these airports -

Yes, FAA style D which will have no detrimental effect if the correct terminology and procedures are utilised.

After all. GAAP was copied off US class D.

Personally, Dick, I'm a little confused. If, as you state , why would they need to change to US FAA Class D?

I think what Dick is saying is that the move from GAAP to US Class D (which he is in favour of), is a different issue to the restrictions of traffic, the increased opening hours and the staffing issues that this will create.

There is very little link between what Dick is/was arguing for, and the recommendations of this report and/or the implementation CASA has ordered.

That is my understanding of this whole mess.

Dick is absolutely correct.

This is a case of CASA getting an organisation with no valid qualification to do such an analysis and this clearly shows with the methodolgy used and outcomes recommended from the flawed analysis.

You can almost be assured this was a job for the retired boys from CASA/Airservices now working within Ambidji that were given directions as to what outcome to justify.

I have a friend who got his PPL at the same time as I did in the US, then spent 3 years working in Melbourne. Th clincher for him in his decision not to fly here was the astonishing news that you needed a clearance to cross a non-active runway at a Class C airport. He would (I expect) be greatly amused that such bizarre restrictions have been extended to airports supposedly less restrictive than Class D!

I think that what has got Dick's back up is CASA trumpeting that NAS is the go, then implementing something that moves further away from the NAS model. Exactly the sort of unjustified and random restrictiveness that has grown like topsy into the system we have today. Some buffoon has used a report as science fiction as the one supporting the NAS claims to implement his personal portion of the Nanny State.

Spod, You are correct.

No offence intended, Starts with p, but I think that Dick is quite capable of responding himself. So I'd put the question again, but add a further coment about unnecessary costs, which is another issue with which I am in agreement with Dick.

Dick says: He then goes on to say that, yes he wants FAA Class D.

If former GAAP procedures were so safe and we want to avoid unnecessary costs to industry (re-training controllers, changing charts, changing pubs, mounting a pilot education campaign, priniting more glossy brochures etc) in our 'user-pays' environment, what is the point. The only conclusion that I can draw is that it's change for change sake.

With respect to the decision on GAAP, my take is that CASA thought they had to be seen to be doing 'something' (anything), given the amount of stick they take on an almost daily basis. And, like the Skippy in the truck's headlights, CASA blinked and jumped the wrong way.

The AMbidji report also recommended no changes to GAAP in the short to medium term....and then the CASA comes out with the directive.

No offence taken Howbout. I look forward to Dick's response... Maybe in a thread about US Class D vs GAAP rather than one about the validity of the Ambidji report. Maybe you could start it?

The Facts Please Dick
 

Dick:

For your information, in the last 40 years there have been exactly 5 (maybe 6) instances of MACs at Bankstown airport or Bankstown airspace, viz:

1971: C182/C150 (non fatal)
1974: DH104/PA30 (fatal)
1975: PA30/C182 collision (non-fatal)
2002 : PA28/TB9 (fatal)
2008 : C152/Liberty XL (fatal)

Even your experts have mentioned this fact in their reports. Don't you read what you pay for?

That doesn't sound like an independent review to me! Whilst it is good for overall aviation safety that you have taken the personal initiative to solicit more reviews of this very important subject, please don't try and snowball us by implying its an independent review. It's a bit like Philip Morris hiring consultants to confirm that smoking cigarettes has no adverse health impacts on young children.

Sounds like you are implying CASA's consultant MAY HAVE a conflict of interest. If so what is it? You should be aware from your own experience inside CASA that all government bodies undertake extensive evaluation processes to ensure they are protected from potential COI accusations.

This didn't happen in the GAAP did it?

I think some of those midairs you listed off QSK? occured at the inbound reporting points, and at least one was a formation flying incident.

Frank

Technically it did not happen in the GAAP, however if you consider that it has been pushed home hard in the recent safety education that even when you are transiting in proximity of the GAAP zone you should do certain things, and at the reporting points you are still not actually in the GAAP, you may need to encompass a little more real estate into the study, if you want to have a true picture.

J

Starts with P, thanks. I see where you're coming from with respect to GAAP vs US D, but Dick made the comment up-front in this thread that I quoted previously:

But he now appears to be advocating the imposition of unnecessary costs by changing a 'proven system' that provides 'some of the safest procedures that I have experienced in the world,' with US Class D. Once again, Dick raised this, not me. So, once again, I ask to what end, other than pursuing some ideological end-state that will have dubious safety outcomes (if Dick is correct regarding So what we're left with is more change fatigue, increased costs and dubious safety benefits, if Dick is correct when he says

Clarification: When I initially approached staff at the University of New South Wales to commission a Review of the Ambidji Report, I offered the University payment of up to $2,000 to cover associated cost. To date, the University has elected not to receive payment, however my offer stands.

And to others, I was clearly referring to mid airs "in the bankstown control zone".

Howabout,

To change to US Class D at Bankstown and other GAAP airports there is no measurable cost. This will then mean that all non-radar tower airports will have the same simple procedures – as per the USA and Canada.

Some will claim that in Australian GAAP airports we do not provide a separation service between IFR aircraft when in VMC. If one or other of the pilots uses the correct terminology, in US Class D a separation service is not provided.However if both pilots believe that safety requires full IFR separation in VMC they can get it.

I say again, by moving to US Class D at all of our non-radar tower airports we will standardise the system throughout Australia; reduce the ridiculous frequency clogging of a VFR departure call at non-GAAP Class D towers and make other improvements.

Dick, I think that the Bankstown data is not the only location that has had questionable data incorporated into the report. They seem to have included off GAAP and a MAC during MBZ procedures at Jandakot in their analysis.

As operators, we need to know exactly what the impact of the introduction of Class D (US type or otherwise) is going to have on our ability to continue function. There are quite a few GA schools around at the moment thinking this might well be the final nail in the coffin.

Is there any truth to the rumour that our new CASA director came up with the magic number of 6 in the circuit because that is what the military use?

Sorry Dick, but that doesn't cut it. I quote again:

Why change if the system was so good? Your words!

And I disagree that there will be 'no measurable cost.' Every change we experience has a 'measurable cost.'

However, I think you have taken some unjustified criticism regarding independent analysis. While I do not know two of the gentlemen, I have certainly read a risk dissertation by Mr Chris Mills that he produced some time ago on 'Parachuting Through Cloud.' It was tabled at a RAPAC and, while I'm not a risk management expert, I thought it was a very fine piece of work.

In short, and regardless of whether he was paid or not, his analysis has stood the test of time. Accusations that he'd give you an answer that you want, because you paid him, are, in my opinion, grossly unfair.

That does not alter the fact that US D vs GAAP is a waste of time and resources. I remind you again:

How, A hint,it's about the extra safety from having one standard system for non radar towers throughout Australia.

Or are you suggesting we change all the non GAAP airports to GAAP?

And what will the extra cost be? Separating IFR from IFR in VMC when both pilots want the extra safety?

Compared to the whole catastrophe the cost is small.

Sure, Dick specifically wrote about incidents 'inside the Bankstown control zone'. But I think the argument to include the 2RN collision last year in the data is a valid one. OK, it's technically not in the 'GAAP' airspace itself - but inbound reporting points are an integral part of the way the GAAP system works. A complete review of GAAP safety needs to take the whole set of procedures into account, which I think includes the bits about how you get into that particular type of airspace.

I think that is a good thing....unless I am missing something important about a departure call.

Would have saved the embarassment of having made one on departing YBMC one evening that the tower did not hear it.....I did make one as Chimbu Chuck will recall......perhaps the FTDK's failing electrics were to blame! :cool:

Departure calls at CTAF/GAAP/D into any G is really a waste of radio waves!

Dick: Your "1 MAC in 40 years" comment still doesn't stack up. Apart from the 2RN accident, all the other listed MACs occurred in the Bankstown control zone (circuit area).

Frank Arouet:You're correct in that it was technically outside the control zone however it could be argued that, as both aircraft were conforming to a recognised IRP and one of the 2RN aircraft was in contact with the tower, they were operating under GAAP.

People people please....

Can we keep the Class D vs GAAP arguments elsewhere.

What is of issue here is the issue of one consulting company that has been around for a long while creating a document that has been swallowed hook line and sinker by CASA.

A report of such magnitude should be peer reviewed and more than one group involved. Dick has done this. Yes he may have a vested interest in a different outcome but please ignore this.

It is a process that is at fault.

And as a parting thought for you - who audits the auditors? Methodologies aside, they are not always right.

Dick, we have fenced on this before.

Leave it like it is (was) and there's no extra cost to industry. Any change will involve cost! Sorry, I cannot agree that changing from a 'proven system' to something else is justified because the 'cost is small.' Define 'small.'

To quote you:

If those procedures are, truly, that safe, then where is the logic of changing to US D? 'Standardisation' just doesn't cut it if the procedures at GAAP are 'safe.'

Your words, not mine.

Could it be that some are missing the elephant in the room?

Ambidji indicated that the 'risk was intolerable when compared to the CASA risk criteria' (paraphrased).

If the actual experience of operating Bankstown and the other GAAP airports for the last 30 years shows that in practice, accidents and serious incidents are not occuring as forecast by the risk model, then mabe, just maybe, CASA's risk model is wrong.

Dick - maybe rather than getting a bunch of non-aviation, but still academic and Australian, types to look at the Ambidji report, it might be better to get the FAA to do an analysis of Bankstown against the US criteria and settle the matter once and for all.

They could model Bankstown as a GAAP airport - and then as a US style Class D airport.

I don't propose you fund it, but surely CASA could seek FAA's assistance. At the very least it would expose some of CASA's risk gurus to world's best practice.

It might also be useful to get CASA to send their risk model to the FAA for evaluation and attenuation.

I agree, however from my experience the CASA OAR will not allow any FAA advisors to be involved in any way.

The "it wasn't built here" syndrome.

Howabout, with GAAP they only 80% copied the FAA class D system. I would prefer a like model that gives the advantages to all non radar towers in Australia.

Why won't you answer my point re the safety advantages of standardisation?

Rhterrke Atnyeneteke, nice handle.

No; the validity of the 'report' is now a secondary issue. Regardless of the validity, or otherwise, of the Ambidji report, Dick has stated categorically that:

He instigated this debate.

Do I doubt the validity of the findings? - hell yes.

But Dick has not come back with an explanation as to the divergence between his (laudable) sentiment of no extra, unnecessary costs to industry and his comment that:

By the way Rhterrke Atnyeneteke, you come across as a bit of a school marm.

Dick, God bless you; because you never answered my questions regarding your comments on GAAP and reconciled them with 'unnecessary costs on industry' for questionable safety gains.

Ambidiji Report
 

I guess there is little disagreement about the reliability of the report itself. Recent changes which have been introduced, are in my view not justifiable give that the methodology used is flawed.

Nevertheless, I find it surprising that very little information about traffic movement or factual data on frequency congestions has been mentioned. It was briefly mentioned only in the survey and had a high response rate, but not discussed or any detailed recommendations where made. I would argue that while air traffic congestions is not the primary risk of MAC's, however the attempt to deal with such risks by CASA and Airservices is problematic.

The subsequent changes which have been introduced (limitations of aircraft in the cts) among others are unlikely to have significantly implications for safety risks as they currently stand. Yet holding outside a GAAP ZONE with no where to go, is asking for trouble.

Firstly, it would also be prudent to keep in mind that most pilots operating at BK are some of the most vunerable of pilot populations - those that are learning to fly. Therefore any restrictions on A/C allowed into the GAAP zones increases the likelihood of congestion among reporting point. This is hardly sensible. Moreover, considering also the closure of Hoxton Park and the occasional film shooting of Top Gear at Camden, one wonders where aircrafts are supposed to go, when things go wrong.

A few weeks back, 3 events in 3 days causing delays and runway closure made me think twice about sending my students to the T/A.

my 2 cents worth
j

Howabout , debating with you is like debating with my daughter when she was 14.

I will try again, I believe that Bankstown has some of the safest procedures I have seen in the world. One of the reasons for this is that the procedures were copied- but not exactly- from class D airports in the USA.

I want all non radar tower airports in Australia to follow- but more closely- that used in class D airports in the USA.

Then I believe we will receive the benefits all across Australia.

You seem to think that just because I believe that our GAAP procedures give a high level of safety that this cannot be improved upon .

I believe that going "the full monty" the system will even be better.

That's why I support the CASA decision to go to FAA style class D at all our non radar towers.

It seems to me Dick wants all the towers to become the same, so you can make them all ICAO D, FAA D or all GAAP.

All GAAP wont be acceptable = NO GOOD

ICAO D = Great for the existing D, but unworkable for the current GAAPs so NO GOOD

FAA D = Less service for the RPT/IFR in the current D environs and not so much different from GAAP anyway, so no real gains and some real losses....So NO GOOD

What is there to be gained here then???? :ugh:

Who comes up with these studies? And why do they get whisked into reality without a really good industry wide consultation.

I think someone sold the new CASA head a good sugar coated study in the aftermath of a serious accident and without taking time to digest it all acted on it. ooops! :ooh:

How about we ditch the departure calls from D into G, and go back to ICAO D and GAAPs.....But employ some more ATC's for :mad: sake! Stop wasting money on studies and BS and put it at the coal face!

J:sad:

Feel free to correct me where I am confused coz i am bound to be!:bored:

So, Dick, let me see if I'm correct.

The official Government position is still that NAS, based on US practice, is policy.

CASA stated at the most recent Senate hearings that they are following Government policy.

The head of the OAR at CASA said that he is committed to implementing NAS which is based on US practice and is Government policy.

And you are saying that CASA will NOT engage US experts to help NAS implementation, or to do a risk assessment or to compare procedures?

I REALLY think that you should be canvassing the powers that be to get them to DIRECT CASA's OAR to seek FAA assistance and sort this out.

I'm with you, Dick - let's get some experts in here to tell us what the US would do at places like Bankstown.

Mr Smith,

If what you say is correct, perhaps you might explain what you feel the 20% of FAA D comprises of that was not adopted for Australian GAAP?
Where have CASA stated that? When did they consult the industry? All we have seen formally from CASA is the Instrument which states Class D, not FAA D or DS D, and an AIC stating clearly ICAO D. Australia is an ICAO signatory, are you asking the DoAS, CASA and the minister to sign off on a non-ICAO, non-compliant, less safe form of D?

Why not retain GAAP (where Scheduled Passenger Transport Operations do not occur), and ICAO D (where Scheculed Passenger Transport Operations do occur)!

Nil cost, no reduction in safety, gives GA the traffic throughput they need at GAAP's, and retains International Standards protection for RPT at towered airports elsewhere!

What I will be interested to see, as a current GAAP controller is the following.

Will we all get procedural approach ratings, as is the case at the other "D" towers?

Will the GAAP's as they are now get normal class D airspace, rather than the differring airspaces we currently have (for example JT 3nm rad, 1500'AMSL, BK Weird due to YSSY airspace, MB 3nm 2500'AMSL etc etc)?

What will be our requirements with parrallel runways as they are too close together for simops in class D?

There are a few other things but those ones have my interest at the moment.

Clinton, I do not know of any class D airport in the USA which has two required entry points as we have at BK.

That's why my initial post referred to the control zone.

Remove the two compulsory reporting points and follow the proven safe FAA system and you have my support- especially if all non radar tower procedures are standardised.

AIRFOR, current government policy is clearly for the FAA nas system.

It will bring substantial advantages to Australian aviation. That's why it was selected.

FAA style D gives exceptionally safe outcomes for thousands of RPT passengers in the USA. Why would'nt it be the same here?

Keeping a system straight forward, standardised and simple for VFR pilots is the best way to go in my experience.

AWOL, under the FAA system the class D tower controllers do not have procedural ratings- the IFR separation comes from the Centre- a far superior and safer system as the service is provided 24 hours per day.

That's why we need this safer NAS system here.

It will mean that RPT jets actually get a proper service at places like Launy or Hamilton Island even when the tower is not operating.

Let's hope the Government NAS policy comes in before the inevitable CFIT.

Dick,

One of my points, several posts ago, was that CASA was stampeded into a bad decision by the inordinate pressure that is applied from without.

Secondly, I agree your contention that things could be improved - they always can be. But, if the following holds true:

;

then maybe the solution is to seek a decent fix that involves fine-tuning (with no appreciable costs to industry) rather than wholesale change (with associated costs to industry).