[Peetwo]

AAA response to Aviation Ombuds Scheme consultation paper?? - 

Courtesy Oz Flying:

Ombuds Scheme should Exclude Small Airports: AAA

18 October 2024



Australian Airports Association (AAA) Head of Policy and Advocacy Natalie Heazlewood today called on the Federal Government to exclude small airports from the proposed Aviation Industry Ombuds Scheme.

The scheme, announced in August as part of the ALP's Aviation White Paper, is primarily to address issues with airlines and major airports, but stands to capture smaller regional airports in its net.

“Australian airports will be constructive towards getting the balance right around a future Aviation Industry Ombuds Scheme," Heazlewood said.
“With a complex number of factors influencing aviation, it is important the ombuds scheme is realistic and ensures consumers get full and timely airfare refunds.

“Many smaller regional and rural airports often operate at a loss and are still dealing with the fallout of the Rex Airlines financial collapse.

“Smaller Australian airports should be exempt from the scheme to help safeguard their current survival, while passengers would still be covered by Australian Consumer Law."

Heazlewood also said the scheme needed to include government entities as well as the airlines and airports.

“Federal agencies, including Airservices Australia, form part of a passenger’s journey and can influence flight delays and cancellations."

“Last financial year, only 1% of these delays were caused by airports in Australia and airline refund requests remain the top complaint received by the current Airline Consumer Advocate."

Departmental consultation on the design and implementation of the ombuds scheme closed yesterday having opened on 26 August.
AAA represents 340 airports, most of which are regional airports run either by independent corporations or local councils.

The AAA submission to the Betsy's Duck-UP Fairy department:  AAA Ombuds Consultation PaperResponse - 17/10/2024

Membership of the Ombuds Scheme

To assist with the rollout of the scheme, it may be necessary for a staged rollout to be undertaken for
the airports it will be applicable to, allowing for learnings to be passed onto less well-resourced
airports that may be required to participate.

Membership by airports should be allocated by the passenger movements at each airport, e.g over 1
million passengers annually. The UK aviation Alternate Dispute Resolution (ADR) scheme currently
has 8 member airports that service over 1 million passengers annually. This scheme has seen been
successful post its implementation in 2015 wherein 80 per cent of passengers on UK flights are now
covered under the Civil Aviation Authority’s (CAA) ADR schemes.

There is merit in including a similar threshold for airport membership of 1 million passengers per year
for Australia as it would include 14 airports and cover 91.7 per cent of total passengers that are
travelling by air.

It is important that there is a threshold point to ensure that smaller regional and rural airports are not
part of this scheme as it would be a very onerous requirement for them. Passengers will still be
covered by Australian Consumer Law if there is an issue at smaller airports which needs to be
pursued.

On eligibility, AAA advocates for government agencies such Airservices to be included in the
scheme. For the 2023-2024 financial year, only one per cent of total flight delays were caused by
airports while 11 per cent of delays were attributable to Airservices.

This highlights that more than one in ten flights were delayed due to Airservices.

Given Airservices data shows that airports are responsible for one per cent of total delays, then
membership fees for the scheme should equitably be based on the rate of failure to provide aviation
services rather than a flat membership fee.

As membership of the scheme is to be targeted at aviation and accordingly the key actors who
participate in aviation should be considered...

For those interested this is Betsy's webpage for the AIOS consultation paper:

The Aviation Industry Ombuds Scheme—Consultation paper


Date published: 

17 September 2024

The Australian Government's 2024 Aviation White Paper: Towards 2050, announced the establishment of a new Aviation Industry Ombuds Scheme for Australia.

The purpose of this consultation paper is to seek input from interested stakeholders on the design and implementation of the new ombuds scheme.
 

Document  The Aviation Industry Ombuds Scheme—Consultation paper—August 2024—PDF (778.32 KB)

Document  The Aviation Industry Ombuds Scheme—Consultation paper—August 2024—DOCX (655.22 KB)

Next again, via Oz Flying:

Circuit Cap raises Hackles at Moorabbin

16 October 2024




Airservices Australia has introduced a circuit cap at Moorabbin Airport, which has attracted the anger of operators on the airport for a number of reasons.

According to documents supplied to Australian Flying, Airservices introduced a slot system on 2 October, which will restrict the circuit to five aircraft at any time, with a possible sixth if it involves no more than three circuits.

The circuit cap is believed to be one of a number of measures to combat rising operational deviations at Moorabbin when compared to the other metro Class D towered airports.

Flight Training Organisations (FTO) are asked to use an online booking system, which will facilitate the following circuit restrictions.

 (go to article link)
 
Helicopter circuits are restricted to three aircraft and low-level operations will be counted as airborne.

Arrivals will be limited to two aircraft if there are more than two already in the circuit.

Aircraft wanting to enter the circuit without a booking slot can do so, but only if the maximum number already in the circuit has not been reached and there are no valid bookings for the empty slots.

Aircraft with valid booking are required to call for a start clearance no less than 20 mins before the booked slot.

However, flying schools at Moorabbin say the circuit cap has created a number of problems, including:

• pre-flights are being rushed to ensure slots aren't missed
  
• low-time solo students are being asked to remain outside the CTR when there is no published holding procedures
  
• extra fuel needs to be carried in case of holding
  
• fuel truck availability is impeding the ability to hit slot times
  
• students may not be able to be sent solo the moment they are ready because an adjacent slot may not be free
  
• long queues at the holding points make it hard to hit slot times and burns fuel unnecessarily.
  

"Slots are great for the airlines," one FTO told Australian Flying, "but no good for student pilots!"

Royal Victorian Aero Club (RVAC) CEO Paul Daff wrote to Airservices Australia, expressing the club's concerns.

"These operational restrictions imposed by Airservices does [sic] not foster growth of general aviation," he said, "instead it creates the need for holding fuel due to congestion inbound and limits the otherwise productive capital investment of aircraft and airport infrastructure.

"I am disappointed that these restrictions were imposed with limited consultation (a requirement of Section 10 of the Air Services Act 2005). Unfortunately, no discussions were held with myself, our President or our Head of Flying Operations or Head of Operations.

"In addition, having spoken to a number of counterparts at other training schools, they have similarly expressed concerns as to have not being consulted on the matter."

Daff said he believed the real reason behind the circuit cap is to combat a rising number of reports to Airservices' Corporate Integrated Reporting and Risk Information System (CIRRIS), which collects data on safety, environment and risk management issues.

"The solution implemented represents a single minded focus on a single outcome, to reduce the number of CIRRIS reports," Daff said. "The simplest solution has been adopted, reduce the number of movements. Full stop. Job done.

"It does not take into account the vagaries of weather or the demand side of the equation, economic imperatives or any of the unintended consequences of this reduction (including the pointless burning of more fuel).

"Without a doubt, these restrictions will lead to job losses across the Moorabbin Precinct. All flight schools and the airport itself will see a reduction in revenue and profitability. The uncertainty created will lead to a reduction in investment across the airport."

Daff also pointed out that the vast majority of the operational deviations–Airservices requirements, route adherence, mandatory calls missed–are unlikely to be corrected by a cap on movements.

An Airservices Australia spokesperson told Australian Flying yesterday that the caps were not necessarily permanent, but could form the basis of similar procedures for other Class D metro airports in the future.

"As with all Airservices Australia’s implementation strategies, a Post Implementation Review will be conducted once data has been compiled on the Traffic Management Strategy (TMS)," the spokesperson said.

"If there has been an improvement, the strategy can be adjusted. We are also seeking inputs from the local operators to input into the PIR. The Circuit Booking System was in place prior to Airservices’ TMS beginning on 30 September and has long been widely used by industry."

Airservices also admitted the caps were in response to operational problems at Moorabbin.

"Each Metro D aerodrome is reviewed independently," the spokesperson said. "Moorabbin has more operational deviations per number of aircraft movements than any other Metro D aerodrome.

"Rather than cap daily movements, Airservices’ TMS is designed to smooth out the peaks in demand to provide greater predictability and certainty of operations and provide for overall safer airspace for our users.

"Airservices will conduct a Post Implementation Review, which will include input from local operators.

"If the safety benefits are realised, a TMS may form a broader organisational safety strategy for other Metro D aerodromes."

A CASA spokesperson said that no directive was given to Airservices to impose the circuit restrictions, unlike the caps that were introduced at all metro Class D airports in 2009 during the shift from General Aviation Aerodrome Procedures (GAAP) to Class D.

In that instance, circuits were capped at six, but inbound aircraft were given priority.

"We request an immediate postponement of the mitigations until appropriate consultations can be had with the airport, CASA, the minister and the local stakeholders including all operators," Daff said.

"We also request the mitigations be appropriately risk assessed and Airservices openly consider alternative mitigations that may be proposed by other stakeholders.

"In addition, and due to the uncertainty that Airservices has now created, it is imperative that Airservices clearly articulates its plan for the provision of air traffic management at Moorabbin over the coming years, and how it intends to meet the growing demand."

Airservices Australia has said it did consult with airport operators through the TMS in September and will engage further later this year.

MTF...P2