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Rant about deleted PID NDB/VOR approach

I was about to fly the CWS based YPID VOR procedure on X-Plane. I left my plates at home, so thought I'd just get if from the ASA site. Which is when I remembered that ASA cancelled it some time ago.

I think this is a clear illustration that ASA (or is it CASA or are both in this) are not really concerned with safety. The CWS VOR & NDB beacons would have to be among the most heavily used aids for training in Australia. It is the most accessible station for aircraft based at Moorabbin, Tyabb, Tooradin and probably Lilydale, Coldstream, and possibly even Essendon.

There used to be a procedure that everyone flew. So what will happen now? In order to maintain flying standards / flying proficiency and to conduct training, its an important beacon for most Melbourne based IFR pilots.

It will still be used for training but different schools will find different procedures from other airports to use - or fly the old procedure. So, we used to have aircraft flying known, predictable patterns that helped maintain safe aircraft separation but now its a scattergun of procedures of individual choice.

The rumour mill says that the current owners of Philip Is airport don't want to pay the CASA airport survey costs for the procedure, which is why it was deleted. And that's fair enough, but surely if one of the regulators that we users pay for was intent on providing services that promote safety, they would institute an non-aerodrome approach like exists at Yarrowee?

I can't keep using the old approach forever. Does anyone have current VOR/NDB approaches at suitably high altitudes that works?

Whats wrong with using the NDB/VOR at MB, EN, LTV, BDG, BLT, MNG, SHT or AV? I used to visited each of those on IR nav ex's. I think I did one NDB at PID before it closed.

Granted it was good to use for those doing an IR in a 172 or PA28 but any of the above are within the scope of any nav from within the Melbourne area.

Licensed aerodromes

My understanding is that all approaches to non-licensed aerodromes are being withdrawn - it's not the survey that is the issue, it's the cost of keeping the aerodrome going. YLIL RNAV approaches have also been withdrawn, presumably for the same reason.

What should happen, for training etc, is that YPID NDB/VOR approach should be replaced with a CWS non-aerodrome approach like Yarowee - given that the inbound leg of both approaches puts you over water, there is no issue with continuing the descent to minimums (raised to 1360ft) then missed.

Why it should be done eco victim? Sure, there are others around but YPID as a training aid? It's the closest to Melbourne that doesn't involve stooging around in controlled airspace and stuffing other legitimate users.

MB - CTA/noise
EN - CTA/traffic/ML
AV - CTA/traffic
All the others - bloody miles away!
plus PCK - bloody dangerous!

It also serves as a way home for YTYA pilots who could break visual and track up the channel to Tyabb.

Bring back CWS/YPID approaches!

UTR.

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Does anyone have current VOR/NDB approaches at suitably high altitudes that works?

Cooma was one that was always thrown at me when IMC or when there were people airworking below. It should work just about anywhere in Australia.

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Ummm:confused:

Ummm - well maybe it's going to be? Dunno - just relaying what my source thought about certified aerodromes, obviously not quite correct!

UTR

Folks,

It's all about aerodrome certification. If the aerodrome is not a certified or registered one, ALL instrument approaches are being withdrawn ---- 'cause that's wot de rools say!!

The thought that a smart change to the rules would allow retention of how many?? Hundreds?? never seems to have been considered.

Tootle pip!!

Not doubting you UTR just confused as to the connection - why was an approach safe last month but not this month - especially a GPS RNAV which would have zero maintenance costs?

Sounds like someone at AsA is playing with his willy.

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why was an approach safe last month but not this month - especially a GPS RNAV which would have zero maintenance costs?

I'm assuming that a certified aerodrome would have someone monitoring obstacles in the approach splays. Possibly the risk with the new rules is that if no one is checking for the obstacles and reports to CASA/Airservices the changes then maybe the approach will be become dangerous overtime. Too large a risk for the regulator and chart issuer.

There would have to be some costs associated with even a GPS RNAV for in flight testing and obstacle monitoring.

Places like EN and AV its hard enough to get an ILS approach in let alone stumbling around on the NDB procedures. It would be good if they could issue training/cloud break procedures for both CWS and WON.

Kerg

Cooma is higher than it needs to be, the missed approach Cowes and it takes slower SE aircraft a fair way South over Bass Straight.

I spent a couple of hours last night in front of the tele with the Jepp books. I was looking for an approach that:
A) does not overfly Cowes
b) starts below 4,000 ft (arbitrary - but why go higher than you need especially because it gets into the MB - FLI route).
c) does not go too far south over water (ie no 2 / 3 min legs South)
d) has better clearance to the restricted airspace than the old procedure
e) does not go below about 1700ft (ie the 220 ft spot height plus 1,500) and definitely above the old height above the aid(1,400 ft)

In order of preference, here is my list:
Tennant Creek NDB - A (use the NDB pattern for VOR as well)
Tamworth NDB-A or VOR-A
Hughendon NDB or VOR RWY12
Winton NDB-RWY12 (use the NDB pattern for VOR as well)
Southern Cross NDB-A (use the NDB pattern for VOR as well)

So far I've invested only 2 hours or so in this. The question still remains; In the interest of safety training, why won't CASA / ASA put in a the small amount of work required to create an non runway procedure by either modifying the old PID procedure or making a new one based on (say) the Tennant Creek one?

Chuck, i'm with you!!! I fail to see how an approach can be considered unsafe (or whatever they reckon it is) just because the aerodrome at the end of it is not certified or registered.

Sounds like someone at AsA or CASA is conducting a butt covering exercise .... Worried about legal action or copping it in the chops during an accident investigation should someone conduct the approach and prang at the end of it.

Without looking into the rules ..... where does that leave the likes of the RFDS or some other operators who may have specific approaches (RNAV) made up for their own use into some uncertified aerodromes.

It is not an Airservices issue but CASA, related to MOS 139.

Quote:

139.030 Aerodromes with non-precision approach runways to be
certified or registered
(1) A person must not operate an aerodrome to which subregulation (3)
applies if the aerodrome is not a certified aerodrome or a registered
aerodrome.
Penalty: 10 penalty units.
(2) An offence against subregulation (1) is an offence of strict liability.
(3) This subregulation applies to an aerodrome that:
(a) is available for public use; and
(b) has a non-precision approach runway.

And yes, it is to do with the owners of certified and registered aerodromes being required to have a monitoring system in place, unlike lower aerodrome categories.

Quote:

Subpart 139.E Obstacles and hazards
139.350 Monitoring of airspace
(1) The operator of a certified aerodrome or a registered aerodrome must
monitor the airspace around the aerodrome for infringement of the
obstacle limitation surfaces by:
(a) any object, building or structure; or
(b) any gaseous efflux having a velocity exceeding 4.3 metres per
second.
(2) The monitoring must be in accordance with the standards set out in
the Manual of Standards.

Further info, agenda item 5.6: http://www.casa.gov.au/wcmswr/_asset.../vic100422.pdf

I knew I wasn't going crazy!

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AIP DAP LILYDALE (YLIL) ENTRY
DELETE RNAV-N(GNSS),
DUE PROCEDURE NOT AVBL
FROM 02 150051 TO PERM

Like I said, someone playing with his willy

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06 July 2010

CASA strongly recommends that, where terrain permits, NPA procedures be provided as they enhance the safety and efficiency of aircraft operations

CAAP 89P-1(1) Aug 1999 (General 1.3)

CASA strongly recommends that aerodrome operators avail themselves of the benefit of GPS technology

CAAP 89P-1(1) Aug 1999 (General 1.50)

Mr. Kim Jones (CASA, manager Airways & Aerodromes Branch) states in his letter of 12May 2009 “CASR 139.030 could be interpreted to mean that aerodromes without straight in approaches do not have non-precision approach runways and therefore do not need to be registered or certified. However CASR definitions show that this is not the intention of the regulation.”

He then goes on to say that “Regardless of the interpretation of 139 my concern is with CASR173. This CASR regulates the design of instrument approach procedures, with obstacle clearance the primary safety consideration in developing (designing ed.) and maintaining them.”

Now the matter is out in the open.

The procedure was designed by International Air Crewing (IAC) in 1999 who at that time were a CASA approved Procedure Designer. Further the design was thoroughly vetted and test flown in accordance with the procedures of CASR173 and relevant CAAP’s by Ian Mallet of CASA. CASA authorized Air Services publications and Jeppesen to publish the approach plates and the ERSA entry.

Although the original intent was to provide for an NPA approach to an NPA runway RWY18 GPS the approach was truncated at the circling minima and designated as LIL GPS-C pending a new OLS survey for the runway.
This is in accordance with the provisions of CASR 139 MOS 12.5 (allowing for an NPA straight in approach when there is no NPA runway (as at YLIL) but only to a circling minima.)

It should be noted that CASR139 12.8 says that only aerodromes that are certified or registered can have NPA runways. It does NOT say that only certified or registered aerodromes can have an NPA approach.

The very fact that CASR139 12.5 and 12.8 exist prove that it is the intent of the regulation to permit a GPS approach to non certified or registered aerodromes but only to a circling minima.

Turning to the issue with CASR173 which Mr. Jones acknowledges as his prime concern.

CASR 173 and the CAAP’s require Procedure Designers to assess the Obstacle Location Surfaces (OLS) for the approach using published “tall structures” data bases together with a ground survey in the vicinity of the final approach area. This was done in accordance with CASA procedures at the procedure design stage. In addition the Procedure Designer has to accept on-going responsibility for maintaining the safety of the approach in the face of possible penetration of the OLS by development under the OLS.

To assist in maintaining the safety of the approach the aerodrome operator (Lilydale Airfield P/L ) has accepted in writing that it is responsible to advise the Procedure Designer of any threats to the OLS. The operators of YLIL are in a better position than most in monitoring threats and actual construction activity under our OLS because we operate HJ 365 days a year in our circuit area and adjacent training area which encloses the whole of the NPA approach airspace. We are therefore in a good position to meet our obligation to our Procedure Designer to pass on threats to our OLS. There have been threats and they have been dealt with by the aerodrome operator before the OLS was affected.

In March 2006 IAC ceased to be a Procedure Designer and the relevant material for YLIL was handed over to Air Services who are now the Procedure Designers. From that date on, Air Services became the Procedure Designer and became responsible for the on-going maintenance of the NPA procedure for YLIL. Our legal responsibility in regard to the OLS remains with the Procedure Designer. In response to our request in July 2009 Air Services did an air survey of the approach areas.

In summary, The approach for YLIL was designed in accordance with CASR173 and it is maintained in accordance with the CAAPS’s of CASR173.

The debate over the LILYDALE GPS-C is a result of CASA’s assertion that the maintenance requirements for the procedure required under CASR173 can only be met if the aerodrome for which the Procedure was designed is either certified or registered. What about the numerous approaches where there is no aerodrome? Who is legally obligated to monitor the approach surfaces and report to the Procedure Designer? On approaches such as Polo Flat, Warburton, PID, YWE, VRD and several others there is either no aerodrome, or no operator, or if there is an operator there is no arrangement in place to observe threats to an OLS let alone report them.

In the case of YLIL, CASR139 12.5 prohibits an approach in IMC below the circling minima. This reduces the need for security of the final approach surface because the pilot (like a NVFR pilot) is in a position where he can see and decide not to land from the safe height of the circling minima. Because of CAR 92.1(d) the responsibility is placed on the pilot to obtain the necessary information from the Aerodrome Operator to assess whether it is likely to be safe to continue in VMC to land once he reaches the circling minima.

In answer to this CASA has said “what about the pilot who does a practice approach and does not need to seek info from the operator.” Our answer to that scenario is to place a note on the Plate requiring pre-arrangement with the operator before using the approach.

CASA also tried to say that the information to be exchanged under CAR92.1 (d) was confined to the state of the surface of the aerodrome and nothing about the approaches. Anyone who has read CAR92.1(d) will see that that is ridiculous.

We draw the attention of RAPAC that there are clauses in CASR139 permitting agreed exemptions.

And finally.

Between 1969 and 1979 15 people were killed in 3 accidents to aircraft inbound to the Yarra Valley from the North. YLIL is in the foothills of the Great Divide and is the only air port in the area capable of handling cabin class aircraft. Due to the prevailing SW winds cloud frequently builds up on the hills to the North. Inbound VFR pilots should climb over the cloud but if they do then they will be in C airspace. AirServices will usually refuse a clearance over the top to a VFR aircraft. The pilot, being so close to home, is tempted to squeeze between the trees and the cloud.

During the 80’s at least 3 pilots were observed at YLIL removing leaves and branches from their under-carriages. We can assume more of the same has occurred at YMMB.

When GPS approaches became available the owners of YLIL jumped at the chance to add to safety of our customers and the utility of our aerodrome.
There are now 44 IFR aircraft based at YLIL flown by approx 60 IFR pilots. They are now unimpressed with our Regulator.

20 days ago Winter struck. “Special VFR techniques” have had to be used to get back into YLIL on 5 occasions. These have involved flying in decidedly poor visibility under cloud while cleared at “not above 1000ft” over terrain which rises to 1100ft as one tracks from circa PLE towards YLIL.

This is an un-rehearsed activity, the pilot does not know just where he will be vectored. To all but experienced pilots, very familiar with the area, this activity, while legal, is unprofessional and dangerous.

By contrast pilots using the LIL GPS-C could descend to 1010ft using a safe proven procedure (probably rehearsed) which delivers them into familiar terrain (at least for the majority of users).

Any activity which requires great skill and experience and which cannot be rehearsed is prone to accident. This is not what civilian flying should be about.

The Manager Aerodromes & Airways said to me on 23Dec2009 “I am so worried about the continued use of the NPA at Lilydale where someone might hit an obstacle (unknown, un-notified-ed) that I can’t sleep at night.”

I would suggest that there is a negligible chance that such an unknown un-notified obstacle would exist and even less chance that someone would fly into it.

What was even more amazing was his statement that “If I were to agree now to registering YLIL by 29Jan2010 then my (allegedly dangerous) NPA would instantly be OK (presumably safe) and (presumably) he would again be able to sleep at night!

Nevertheless compared to the miniscule chance of an aircraft hitting an object while executing an NPA into non registered YLIL, and in the light of the disasters in the 1970’s and last week’s adventures, the occurrence of another disaster is by comparison almost a certainty.

Of course it will be pilot error, but the coroner will be looking for contributing factors.

I look to the support of RAPAC to persuade CASA to re-instate the GPS NPA-C for Lilydale.

To answer the original question, this was in the minutes:

Quote:

The IAP for Phillip Island has been submitted to Airservices Procedures Design Group for progression and implemention.

Re YLIL. Clearly the aerodrome operator doesn't want to upgrade to registered classification but I haven't read here and elsewhere exactly why - presumably the costs are high?

One problem I see with the YWE type of approach is what's happening at BLT - the local flight school is exerting its dominance on the aid so much that it wants all ENR aircraft to be on local BLT QNH for separation purposes due to the high volume of VFR/IFR aircraft transitioning via or air working over the aid. BLT is even establishing its own AWIS for this purpose and obliging ENR aircraft to use it.

I appreciate this is done for safety but requiring ENR aircraft to switch to BLT QNH while transiting YWE on area QNH/frequency is ridiculous. If I am not air working over the aid, why should I be compelled to conform ? Area QNH on area frequency is area QNH. The school does not own the aid and besides it's 14 nm away from BLT. Obviously they are not stopping at the recent amendment for the YWE plate for airwork to be conducted in Day VMC only - just to make it more convenient for their students. :=

Capt. Thanks. I understand that essentially ASA deleted the chart on some sort of instruction from CASA.

But, this makes my question more pertinent because there can be no interdepartmental finger pointing. The Safety Regulator responsible for training, pilot proficiency and safety has deleted 2 approach procedures on aids that must surely be one of the 2 or 3 most heavily used for training & currency in Australia. They could have deleted the leg from the aid to the airport and made a non airport based procedure (like Yarrowee), but it has been removed entirely. I see this as CASA acting detrimentally to safety.

I followed a link to the RAPAC minutes which shows that ASA are at least guilty of extreme tardiness. Deletion of the PID approach has been on the agenda for some years, yet nothing was done. After the approach was deleted, creation of a new airport independent approach was put on ASA's work list in about January 2010. As the Ruddster says " fair shake of the sauce bottle" How long does it take? Once again, there is no visible sign that ASA are acting in the interests of safety rather than Bureaucratic ease.

I have no specifc knowledge on that one. I do know that after a procedure is designed they have to schedule a flight test, and I believe a national priority system operates.

I suggest an email to the address on this page (its not a correction but your question will get to the right section):

Airservices Australia - Contacts - Corrections to Aeronautical Charts and Documents

I'm going to dredge this up again. Off for the MECIR test again tomorrow and nearly two years since my last rant and there is still no training approach published for Cowes. Its been on the Air Services Australia worklist since January 2010 - 2 years and 2 months. How long does it take? What are we paying these guys for?

Need the money for all the new managers mate!

Very much doubt it will happen in a hurry, or probably ever.

From the July 2011 RAPAC minutes:

Quote:

Nick Borley provided a brief time frame, which at best would be approximately one year. He mentioned that the process had to fit into Airservices Australia’s work schedule and had to follow the AIRAC cycle. The Chair also mentioned the concerns with regards to ownership of the IAP and the ownership of the obstacle reporting. Until this aspect with regards to allocated responsibilities has not been satisfactory addressed, Airservices Australia, who under normal circumstances would be responsible, would be reluctant to install the IAP.

It's my understanding that CASA set the work schedule for this sort of thing, not Airservices. Airservices is licensed by CASA as a procedure designer, but the program is set by CASA and Airservices work in accordance with that.

Yes, but at the end of the day our government instrumentalities have collectively acted to degrade safety by removing practice IFR procedures from probably the most used training area in Australia.

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Its been on the Air Services Australia worklist since January 2010 - 2 years and 2 months. How long does it take? What are we paying these guys for?

Has it? Are you sure about that?

And you aren't actually paying AsA for this service. Airways fees don't cover design of new procedures, or updates to old ones. They are done under contract arrangments with the aerodrome or operator, and they assume the responsibility for obstacle reporting, etc by being a registered aerodrome. If this falls over the procedure is withdrawn.

In short, you want a practice approach at CWS someone is going to have cough up the money for it.

I don't agree with it, but that is the way it is

Slight thread drift here, but something Old Akro said made me think [a worry, I know!]

Due to the limitations of an aircraft I fly for MECIR renewals, it's easier this time around to fly a VOR in the aircraft and do the rest in a sim. However, we were looking at using a non-airport VOR with an appropriate procedure.

To my amazement, I was told we can't do this "as the candidate will not have an expectation of landing at an airport following the letdown." Duh:ugh: Who has done an aircraft NPA/ILS as the sole letdown and not had an engine failure and missed approach??:confused:

Thus, the renewal is going to cost a lot more in a different aircraft just so it can be done at an airport with an on-field aid. Is this;
[1] a NSW thing,
[2] general policy, or
[3] yet another single ATO/FOI interpretation?

G'day ;)

Feather #3,
Give some consideration to the criteria for accuracy at minima , including the bit about "---- and no unusual maneuvering to land" or words to that meaning, likewise runway visual reference in a circle to land.

As to several other posts, CASA sets the standards, but doesn't dictate any "work schedules" to establish procedures, that's AsA or anybody else with the appropriate Part 173 approvals.

Tootle pip!!

One other thing to consider is that they are planning to decommission 170 navaids Australia wide within the next 3 yrs. And yes, that does include some navaids at International airports as well as regional.

I would say that persuing publication of practice navaid approaches may fall on deaf ears, because there won't be that many left soon. I haven't seen the list but would think it highly likely that CWS would be on it as it currently serves no purpose other than a departure transition for ML. This can easily be replaced with a waypoint

I've found YIVL NDB work well at CWS.
Starts at 5100 , minima 3200 and outbound leg is to the NE so mostly over land thus SE friendly.

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Good point, and you are correct, CWS is not in the backup network so it will be decommissioned by the end of 2016.

After all this,

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...If the aerodrome is not a certified or registered one, ALL instrument approaches are being withdrawn ..

what has happened. There are still more than a few uncertified and unregistered aerodromes with instrument approaches.

So what is the real reason for pulling approaches at random?

Eocvictim, which unregistered aerodrome/s still has an approach?

Pretty sure you will find that only registered airfields have one and if they don't, they are being withdrawn pretty quick smart. The reason is in the regs, as only registered airfields are required to maintain surveillance for obstacles and clear OLS approach areas. Unregistered airfields are not required to do this and the issue is then who carries the blame if an aircraft hits something un notified in the approach?

I'm not going to list them all but a couple that come to mind, Margaret River (updated Jan 2012), Kataning (updated Aug 2011). Both well after change of regs. Looking at the plates for these there have been some significant changes, so unless the plan is to certify these ADs and they've been given a continuance to retain the original approaches in the interim (that'd be a first) I suspect there is more to it than a simple, "the rules say so".

Another year and there is still no published approach for the CWS NDB or VOR.

How long does it take? Surely having different people adapting a variety of other procedures is not in the best interests of safety.

Why won't Air Services Australia act in the interests of safety through proficiency and training by publishing a procedure?

Might just add some clarification here:

1) Neither PID nor LIL are on our current worklist, not sure where that info comes from.

2) The design of approaches is not free nor funded by airways charges. They are done under contract with the aerodrome. So in effect you are not paying for anything.

3) CASA will not let us publish approaches to non registered aerodromes. This is because the regs require a registered aerodromes to actively monitor the obstacle environment. It is difficult to maintain the integrity of an approach without the aerodrome being registered.

Not saying it's right, but that's the way it is.

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Given both of these approaches were to a circling MDA (and in YLIL's case it was 950 ft or so) does anyone really think an obstacle was just going to pop up that would impinge on this?

I think a dose of reality needs to prevail!

Sorry Akro, responded to a previous post.

Why is this a fault with Airservices? The approach at CWS was withdrawn because PID is unregistered and no party was actively monitoring for obstacles. This came as a directive from CASA. The other reason is that the approach did not meet the straight in criteria in PANS-OPS. Some have pointed to other unregistered aerodromes with approaches. All currently unregistered aerodromes with approaches have registered their intent to register with CASA. The timeframe for this is up to CASA. Nevertheless once they have had enough dragging the chain, they issue Airservices with an instruction to withdraw the procedures

Moving forward, in order to get the approach put in you are looking at approx $15k for flight validation. Who is going to pay for it? Then you have to overcome the issues listed above for Casa to give authority to publish.....then the navaid is being ripped out of the ground in 3 yrs.....put simply, it's not going to happen.

You have to be mindful of the current regulatory climate. CASA have just recruited a stack of new aerodrome inspectors that see the regs as black and white. There is no grey anymore. Add to that recent political issues with CASA and you will find that the appetite for risk....any risk....at CASA is extremely low.

Alpha

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Bevan, the circling minima only gave you 295ft clearance over the tallest obstacle. Considering an UN-notified twr can be up to 360ft agl, there goes your obstacle clearance and would pose a danger for the approach. How will you know of this obstacle if no one is watching.

You will get your reality when someone smacks into it.

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A practice approach (like YWE) was minuted as being on AsA's worklist at RAPAC with (if memory serves) a target completion date. So, what happened?

And the real question is in what universe is $15k a reasonable cost? Especially since a training procedure can be above the grid minima.

At the moment different people use different procedures. Many still use old copies of the PID approach while others select high altitude approaches. How is it safe to be having aircraft flying different procedures on the same beacon.

RAPAC Meeting 28 July 2011 item 5.3 it was tabled that AsA would publish a VMC only IAP in a timeframe of approximately 1 year.

So, what happened??

Why is the Yarrowee VOR approach a VMC only approach even though at the minima, you are still something like 1000'agl. Its not like a developer is going to build a 1000 foot building under it over night.

If you had your own airstrip, how much would it cost to have 2 GPS approaches designed and certified, including area survey etc.