[Peetwo]

Airport Noise Inquiry: AFAP AQON response to ICAO tailwind standards etc.

Via RRAT IMPACT AND MITIGATION OF AIRCRAFT NOISE webpages: Additional Documents

4  Australian Federation of Air Pilots, response to written questions from Senator Canavan, and Senator McKenzie (received 6 May 2024)

2. Question received after AFAP evidence on 15 April 2024:

• Can you please respond to evidence provided by the Brisbane Airport
Corporation, around 3pm at the public hearing on 15 April 2024, regarding
safety standards on tail and crosswind limits?

Based on the transcript from around 3pm, the AFAP assumes that the evidence provided by
the Brisbane Airport Corporation (BAC) to which the Committee refers is:

Senator COLBECK: But it's an international standard of five.

Mr Coughlan: The international standard's at five. There are airports overseas that at night
do allow higher, for noise management. But it's an individual case for that airport.

Senator COLBECK: What was the basis of your submission to increase it to seven? What
were the drivers for it, and who did you consult with?

Mr Boyle: There have actually been three applications over the last decade to restore the
10 knots—or to increase the tailwind limit. Following its removal, Airservices applied to CASA
for 10 knots. That was rejected. BAC followed up with an application for 10 knots that was
rejected around 2017. In 2022, post-opening—we now have more data on the operation of the
runways—the decision was made to submit a safety case for seven knots, as that was seen as
being a compromise between the five and the 10. We believe we would still get improvement in
SODPROPS from seven knots. The safety case was actually prepared and submitted by
Airservices, and they did consult widely. There may have been some confusion this morning
because AusALPA were consulted on the safety case twice in February 2022. They made 11
individual submissions, all in opposition to the safety case. But they were certainly—

Senator COLBECK: So the position hasn't changed?

Mr Boyle: They were certainly consulted.

Senator COLBECK: I suppose, in the safety sense, this goes to a particular perspective
in relation to a standard being a standard being a standard. That's why I asked the question about
the number of airports in Australia that have a variation to the ICAO standard and the actual
desirability of that.

Mr Boyle: To put that into context—

Senator COLBECK: I understand you're trying to resolve some problems. I get that side
of it.

Mr Boyle: In terms of standards, ICAO has around 11,200 standards across the aviation
business. If a country wishes to operate to a different standard, they file a difference with ICAO
because individual CAAs or CASAs make their own assessments. At the moment, out of that
11,200, Australia has filed 4,280 differences with ICAO—so, of the 11,000 standards, we are
different in 4,000 areas. From our perspective, we then don't understand from a risk perspective
why you would not consider an application for seven knots on its merits.

Senator COLBECK: Just because there's been a whole range filed doesn't take away from
the point about the consistency of the standard and not having to, from an operational perspective,
look at variations all the time in an operational sense. That's why I asked the specific question
about the desirability of it. Just because somebody has done it doesn't necessarily make it more
desirable.

Mr Boyle: I don't disagree with you. I think global standards are a good thing, particularly
for an industry like aviation. It is a global market or a global activity, so having consistency is
important. Having a single standard, however—five knots—that applies to a very short grass
runway in Papua New Guinea versus our 3.6 kilometre runway in Brisbane with extensive wind
measurement—air traffic control sometimes seems to be challenging, and taking a risk based
approach on an individual or airport basis seems reasonable particularly when the outcomes for
the community could be so significant.

The general thrust of BAC’s evidence appears to be that:

1. The AFAP (via AusALPA) was consulted in detail over the safety case for an increase
in the tailwind limit for Brisbane Airport; and

2. It is common and usual to move away from ICAO standards.

The AFAP’s response to the above BAC evidence is as follows:

1. As per our response to the first question, having reviewed our files, we accept that
AusALPA was aware of an intention to develop a safety case and included in industry
engagement by ALARP Solutions over what it referred to as a risk review of the proposal
for a 7kt tailwind limit which would then lead to a safety case.

2. AusALPA did not see or review the safety case and AusALPA has still not been provided
with the safety case.

3. The description of AusALPA’s consistent opposition to any move away from the ICAO
standard on tailwind limitations without significant and overwhelming justification is
accurate.

4. The evidence from BAC that of approximately 11,000 ICAO standards Australia has
filed differences to approximately 4000 ICAO standards is not a reason to file more.

5. The provision under the Chicago Convention for a nation State to file differences is
provided with an intention that there are genuine reasons for the State to do so and the
provision is not meant to be considered as an equally viable option as to the alignment
of the States regulations with the ICAO standards. Differences are meant to be the
exception, with States needing to provide reasons for this need.

6. Consistency of standards is very important for safety and the interoperability with the
rest of the world. Australia as an aviation State has a significantly greater number of
differences filed in comparison to other nations.

7. The broad characterisation of Australia having over 4000 differences to over 11,000
ICAO standards is also misleading. The vast majority of these differences are minor
wording differences that achieve the same result. Changing the tailwind limit for the
selection of a runway would be a major difference that reduces safety and is completely
different to most of the 4000 differences which are minor wording differences in our
legislation.

8. The AFAP is concerned that BAC is attempting to create plausibility for another
difference (in this instance a significant safety difference) to be filed and added to the
already excessive list of differences.

While on the subject ICAO and non-compliance with the SARPs etc., I note that last week Betsy and his merry band of FUF(s) squeaked out, with absolutely zero fanfare from the FUF or miniscule DK media spin doctors, the following request for industry feedback on the DRAFT 2024 ICAO SSP and NASP: Australia’s aviation State Safety Programme and National Aviation Safety Plan 

..We’re seeking your feedback on proposed updates to both the State Safety Programme (SSP) and the National Aviation Safety Plan (NASP). These documents outline Australia’s aviation safety oversight systems and enhancement activities.

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..The International Civil Aviation Organization (ICAO) requires each member State to implement an SSP to demonstrate its aviation safety systems and framework, in addition to a NASP outlining planned national level improvements to address identified aviation safety risks and enhance safety.

The SSP and NASP represent Australia's response to the Global Aviation Safety Plan (GASP) and the Asia Pacific Regional Aviation Safety Plan (AP-RASP), and importantly fulfil Australia's commitment to Annex 19 – Safety standards requirements under the Convention on International Civil Aviation (Chicago Convention).

The SSP and NASP are reviewed every three years to align with the review and updating cycle of the GASP and the AP-RASP.

In case you think you may have missed the announcement, here's the links for the Betsy and Dicky King MR pages:

Media resources

• Ministerial media releases and speeches
  
• Departmental media releases and speeches
  

However it was mentioned on social media:

AusGov Infrastructure
@AusGovInfra

✈️ Have your say on proposed updates to our aviation State Safety Programme and the National Aviation Safety Plan. ?These documents outline Australia’s aviation safety systems and activities.

Have your say by 31 May: https://www.infrastructure.gov.au/have-y...afety-plan

MTF...P2