[Peetwo]

Firies Union submission to the 20/20 inquiry - 

Via the RRAT inquiry webpages: 53 United Firefighters Union Australia (PDF 259 KB) 

Recommendations: 

1. Australia needs to change its method of cost recovery for ARFF services to properly identify the customer of ARFFS.

Adopting a cost recovery method that identifies and charges the true customer of ARFF services will remove the pressure from airlines and airport operators to reduce or remove ARFF services altogether. The Airservices Annual report states that Australia had more than 160 million passengers in 2018/19. This would allow for a very cost effective ARFFS levy system that will easily fund ARFFS as a standalone National Fire Services and return a dividend to Government. A Fire Levy on all passenger tickets would provide a fair and equitable system that recovers enough costs to provide a professional ARFF service wherever it is needed. This levy system, or passenger facilitation charge would be inexpensive enough not to be a burden on passengers and would apply at all locations deemed to require an ARFF service by a valid risk assessment. There is reason to believe that there is a willingness to pay on the part of the passenger to reduce their risk of fatality or injury. It would also be very hard to argue that a one to two dollar per ticket ARFFS levy was grossly disproportionate to the risk being mitigated. It would also pose no burden on airports airlines or small operators.

 2. Conduct a risk assessment of Australia’s 193 certified aerodromes and apply appropriate risk treatments. Implement a risk based ARFF establishment criterion. 

In collaboration between CASA, Australia’s state fire services, UFUA ARFFS experts and Airservices a wide-ranging risk assessment of Australia’s airports should be undertaken. Ideally this would begin with a bench top exercise to identify and determine the various aircraft risk factors. Aircraft size is a common factor used by other countries in determining risk. Movement numbers also indicate the level of exposure to that risk. The assessment should include whether state fire services can manage an incident involving smaller aircraft or whether supplementary equipment, training or a dedicated ARFF service is required. Upon compilation of the list of airports requiring risk treatment a location-specific risk assessment to determine the required resources should be conducted. 

3. Reinstate the ARFFS at all secondary airports at Category 2 and manage the risks of these very busy airports properly.

Moorabbin, Bankstown, Parafield, Jandakot and Archerfield should have Category 2 ARFFS services re-established as a priority. Consideration of Camden being ARFFS protected should also be determined. Norfolk Island, the Cocos Christmas Islands (Keeling) and Newcastle ARFFS should all be provided by Airservices or a National Standalone Aviation Fire Service.

4. Remove ARFFS services from Airservices and make it a standalone National Fire Service.

This would separate the Air Navigation Service Provider (ANSP) parts of the business which are more suited to private providers or business models. The National Aviation Fire service part of the business is larger than the fire services of ACT, NT and Tasmanian Fire services. It should be established as a standalone aviation fire service protecting Australia’s Airports and even Defence bases. The use of ARFFS during the bushfire crisis in 2019 shows that it Australia's general aviation industry Submission 53 can and has formed a useful surge capacity to support State fire services during major disasters and emergencies. 

5.Ensure CASA enforces proper compliance with the ICAO Standards and Recommended Practices for ARFFS.

Provide ICAO standard ARFFS coverage to all freight and nominated alternate ports and remove the remission factor allowance completely, as recommended in the ICAO SARPs. 

6. Form a National Aviation Fire Service Inspectorate either within CASA or external to CASA to ensure proper compliance with ICAO and ARFFS Regs are achieved and maintained. 

Ensure the ARFFS is inspected and regulated properly by professional current fire officers that have vast operational experience and can intervene effectively and understand what a genuine risk mitigation strategy is, and what is just spin and not unworkable in a real life ARFFS application.

Via Oz Flying: 

 

Restore ARFFS to Secondary Airports: Union
5 February 2021
Comments 0 Comments


The United Firefighters Union of Australia has called for Aviation Rescue Fire Fighting Services (ARFFS) to be restored to five of Australia's busiest general aviation airports.

In a submission presented to the Senate Inquiry into the GA Industry published today, the Aviation Branch of UFUA said that ARFFS should be available at Archerfield, Bankstown, Jandakot, Moorabbin and Parafield.

Although the movements at each airport is below the 350,000 trigger for ARFFS, UFUA believes the risk at these airports is high enough to justify the service.

"The United Firefighters Union of Australia Aviation Branch believes that the removal of ARFFS services from some of the busiest airports in Australia was a fatally flawed decision and we also believe that several people have paid for this decision with their lives in crashes that have occurred at these secondary airports since ARFFS was withdrawn," the union states in the submission.

"These critical secondary airports generating billions in revenue and employment are worth protecting properly as are our next generation of Australian aviators.

"We also believe that airports that meet the criteria for an ARFFS regardless of whether it is primarily a Defence base should be automatically provided by Airservices or a standalone Federal Government ARFFS National Aviation Fire Service removed from Airservices."
In justifying the demand to restore services, UFUA cites several reasons why the risk profile at the five capital city GA airports should be taken into account when assessing the need for ARFFS, including:

• charter operations regularly use the airports, a sector which the ATSB says is up to nine time more likely to suffer crashes
  
  
• training operations do regular circuit training, which entails the highest risk phases of flight
  
  
• GA aircraft are of lighter construction, which increases the risk of people being trapped in the event of a crash
  
  
• a high proportion of aircraft are flown by trainee pilots
  
  
• GA aircraft use avgas, which is more volatile
  
  
• the proximity of industrial parks, several of which have been built on airport land, and residential areas
  
  
• secure airside areas can delay local emergency services when access is needed.
  

UFUA believes that services have not been reinstated despite fatal accidents at some of the airports because of the cost.

"Airlines and the aviation industry in Australia, unlike those in Europe and America, tend to see services like the ARFF as an unnecessary cost to their operation," the union says. "After all nothing ever crashes in Australia.

"To illustrate how this mind set has permeated the industry it is simple to note that the current regulation allows for any Australian airport to provide a service at their location for any airports with fewer than 350,000 passengers. Few airports in Australia other than some large mine sites, though, have taken advantage of this option to mitigate their risks, even those with regular large passenger jet aircraft movements."

UFUA also says consideration should be given to restoring firefighters to Camden, Norfolk Island and Cocos Islands. The union also believes that Newcastle, which has military ARFFS coverage, should have a civilian service accountable to CASA for standards.

Airservices Australia provides ARFFS to 27 airports across the country. In the year 2019-2020, the services responded to 5491 callouts, 336 of which were aircraft incidents. A further 119 were community assistance operations.

MTF...P2 

[Peetwo]

GFA condemn Harfwit's mob on East Coast class E consult - 

Via Oz Flying: 

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Gliding Federation slams Airservices as Class E Consultation ends
17 February 2021
Comments Comments


The Gliding Federation of Australia (GFA) has criticised Airservices Australia over the consultation process used for the Class E airspace proposal.

The proposal, if implemented, would see the base of the Class E airspace between Cairns and Melbourne lowered from 8500 feet AMSL to 1500 feet AGL, removing a significant amount of Class G airspace.

Consultation on the proposal closed last Monday after only three weeks.

In a letter sent to Deputy Prime Minister and Minister for Infrastructure and Transport Michael McCormack on Monday, GFA President Steve Pegler said that the Airservices proposal lacked information and the GA community wasn't given enought time to prepare submissions.

"Engagement with Airservices Australia is usually timely and appropriate," Pegler points out. "However, in the case of this proposal to lower Class E on the east coast the GFA was surprised and alarmed that it was announced on the Airservices website without an industry warning, with only a small amount of information, and with a short time frame for consultation and a seemingly large impact on our operations.

"Normal consultative forums for airspace changes were not informed in advance."

Pegler stated in the letter that the GFA believed Airservices had circumvented proper consultation procedure including government guidelines.

"The absence of a Regulatory Impact Statement, with inputs from all aviation sectors, for a proposal with far-reaching impacts on access to airspace and regulatory compliance overheads, is also of concern. The government’s own regulatory best practice guidelines require stakeholder consultation and a Regulatory Impact Statement where any change in access, costs and regulatory burden for compliance and management will occur.

"This proposal will have massive cost and regulatory compliance impacts on many general, recreational and sporting aviation enterprises in Australia, with a particularly heavy impact in regional areas ...

"The information on this proposal is not sufficient in detail to thoroughly evaluate the merits and risks and provide constructive feedback at this time."

Pegler asked the minister to intervene and force Airservices to modify the consultation and regulatory change process.

The GFA was one of the first associations to speak out against the proposal, citing the need for motor gliders and tugs to use radio in Class E, carry and use transponders and the difficulty in monitoring more than one frequency.

Consultation on the proposal closed last Monday after more than 1000 submissions were made.

"Responses detailed a wide range of insights from all aspects of industry, including airlines, industry associations and general aviation operators," an Airservices spokesperson told Australian Flying.

"We are now assessing all feedback received to input into our detailed design process, and in particular are revising our proposal to address ... key issues highlighted in the feedback."

Airservices has said that issues raised in submissions include:

• continued access to Class G airspace by VFR aircraft have no transponder and/or radio
  
  
• consideration for operations where the new Class E base could result in safety being compromised due to terrain or weather
  
  
• confusion in relation to the airspace boundary reference to AGL versus AMSL
  
  
• operational complexity, workload, communication/coordination, training and education for both air traffic controllers and pilots
  
  
• reduced surveillance and communications coverage gaps within controlled airspace
  
  
• reduce the likelihood of delays on departures and arrivals
  
  
• clarify the safety case for change, with consideration to cost/benefit implications to stakeholders impacted by the proposal
  
  
• not enough time for the industry to consider the implications of the change.
  

"We are currently considering next steps based on this feedback, including how best to refine the detailed design and we will provide an update to industry in the week starting 22 February via our Engage platform," Airservices Australia said.

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MTF...P2 

[Kharon]

Testiculation (N). Testiculating (V).

Or; talking bollocks with your hands flapping. Take a few moments; turn the sound off and watch Sharp and the other 'professionals' as they calmly, quietly sit still and make their points. Then watch the Halfwit's performance; and the body language. No degree in psychology required to read that – its like watching one of those folk who stand alongside a speaker 'signing' for the deaf; or a palm tree, frantic in a gale.

Mind you; Halfwit needs to be nervous and it shows; there are some big ugly questions surrounding the ADSB roll out and the huge debt the failed, now almost redundant 'Big Sky' farce has cost – to be weighed against the benefit to the nation and the aviation industry. So far we have seen nothing worthy of mention; indeed it all seems to have been swept under the Canberra carpet.

Aye well, 20 minutes of the Halfwit's manic eyebrow waggling and testiculation, even muted, is 18 more than I can bear to watch. I do wish some one would whistle up the ATCO union chaps; I'd love to hear their side of the story and their suggestions for making the movement of aircraft efficient and cost effective. Now that I would watch - with interest. It seems passing strange to me that a powerful, efficient highly effective union would not be out front, presenting common sense to a Senate committee. Perhaps they have lost their 'courage' straps; or flatly refuse to wear pink ties. Who knows.

Toot – toot.......

[Peetwo]

The Harfwit concedes on East Coast Class E -   

Via Oz Flying:

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Airservices releases Revised Class E Proposal
17 March 2021
Comments 0 Comments

Airservices Australia yesterday released documents on a revised proposal for Class E airspace on the eastern seaboard.
Previously, Airservices' proposed lowering the base of Class E from Cairns to Melbourne to 1500 AGL, which drew a lot of criticism from the general aviation community.

The revised proposal would now see the base of the Class E lowered to either 4500, 6500 or 8500 feet AMSL depending on the terrain below.

According to Airservices, the new levels will:

• improve safety of IFR operations by providing greater control services
  
  
• minimise adverse impact on the needs of airspace users, particularly those without transponder or radio equipment and preserve greater volumes of Class G
  
  
• provide greater safety of operations outside proposed Class E airspace to avoid terrain, including a minimum of 1360 feet of Class G airspace between terrain and the base of Class E airspace
  
  
• remove potential for confusion regarding the operation of aircraft in Class E or Class G airspace, and which frequency the pilot should be on, by referencing airspace levels to AMSL
  
  
• reduce the impact of frequency transfer during critical high-workload phases of flight between area frequency and CTAF while transiting across Class E and Class G airspace.
  

Airservices says the revised proposal is in response to feedback from the industry.


"Airservices would like to thank all airspace users and aviation industry stakeholders that provided feedback on our proposal to lower the base of Class E airspace along the east coast of Australia.

"During the initial consultation period of 20 January to 15 February 2021, we received over 1,000 responses including significant feedback from general aviation operators around safety, risk, operational needs, aircraft fitment, cost/benefit and operator workload considerations."

Consultation on the revised proposal is open until 30 April on the Airservices Australia's engagement website.

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MTF...P2 

[P7_TOM]

In a tangle:-

Bring on Estimates. Old Halfwit has got himself in a hell of a tangle; all it abit over my head. However, over on the UP – HERE – there are some wise, qualified heads talking good sense with 'real' insights into the awful mess ASA have managed to bring about. Even the usual 'trolls' have been quiet while the clever folk with a handle on the dreadful state our airspace management discuss (as reasonable men do) the problems and how best to fix 'em up. The thread is a little 'bumpy' at the kick off but by the time you get to the last page; IMO, it's worth the time – NASAG made sense of it all, years ago – however.....

Estimates and minister both need to take a long hard look at the mess; it would be great to resolve these issues now, before our airways become busy again – and some of the posters on the UP thread really 'know their onions' – even the redundent multi million flop of 'One-Sky' gets a mention.

Let's see what the Estimates crew make of the 'mess' and the logical solutions. Maybe even ask the minister a couple of questions about airspace management. Can't wait...He'll probably begin by talking about the airspace between his ears.

[Peetwo]

Harfwit & CO in a Class E all of their own?? 


Chair Senator Mack questions the Harfwit in Senate Estimates...

CHAIR: I've had a significant amount of contact around this—not positive—so I'll look forward to a demonstration of how this is going to maintain activity, particularly in general aviation, and what is the demonstrated safety case, because there was also another case—anyway, I have committed to not holding things up for too long. I am very interested in this topic, and I hope you'll include me in your advice as to when you are prepared to go to CASA.

Mr Harfield : Absolutely. I will admit that, as a result of the way we initially positioned some of our wording, some of the feedback that we got did give the impression a decision had been made when that was not the intention at all. That's why we are going through the process of making sure we have taken on board over 1,000 pieces of feedback. We're now back out again, and we'll make sure you see that. After that consultation, when we get to where we want to finalise it, we will put that out for comment as well.

AusALPA call 'BOLLOCKS' on the Harfwitted, tranpsarent, monkey in the room...  : Ref - AusALPA submission to ASA on class E proposal:    

...Transparency of risk identification and feedback processes

AusALPA is concerned that Airservices is exacerbating rather than repairing the perception that Airservices is rushing ahead with significant airspace changes based on an internal agenda rather than openly and transparently adopting an incremental
Australian Airline Pilots’ Association approach that is informed by the operational experience of the airspaces users, both in identifying potential hazards and post implementation.

In reviewing Airservices design and implementation safety case documents supplied to us under FOI provisions, we were disappointed to find significant parts of risk management discussions with industry representatives and others were redacted, far beyond anything vaguely associated with protection of personal privacy. The level of redaction indicates that the default Airservices position in regard to public exposure of the design and implementation safety cases for airspace changes is one of secrecy rather than the provision of transparent primacy to aviation safety.

AusALPA also notes that the consultation process for this latest proposal has bypassed ASTRA, the primary consultative body for these sorts of proposed changes. That decision is incomprehensible, especially given the level of industry representation and commitment to ASTRA, as well as the quality of advice demonstrably available.

Furthermore, the window for public consultation for such a far-reaching and significant change is inappropriately short, particularly at a time when many affected industry people are displaced from their primary occupations and desperately trying to survive. Coupling the short comment period with the very fact that Airservices intends to submit an ACP within 7 days of comment closure inexorably leads to the conclusion that Airservices has no intention or capacity to change the proposal to reflect industry feedback.

A number of our members have commented negatively on the attitude of Airservices representatives at the webinar intended to explain the proposed changes. They expressed to us the view that the process was box-ticking a consultation process for changes that, regardless of industry feedback, would be in place by December this year.

AusALPA considers the whole approach to this critical consultation to be arrogant, unsustainable and incompatible with appropriate aviation service provider governance.

We also note that, unlike many other agencies within the Transport and Infrastructure portfolio, Airservices does not publish stakeholder commentary or submissions. We view such public exposure of feedback by other agencies as a very positive feature of improving those agencies’ contribution to the Open Government initiatives of the Commonwealth government and we strongly recommend that Airservices reviews its somewhat recalcitrant view towards public scrutiny of its safety-related decision making...

...Conclusions


AusALPA does not support the proposal to lower the base of Class E airspace to 1,500ft AGL in medium and high density enroute airspace between Cairns and Melbourne in December 2021 and believes that a significant rethink is required. The proposal should be withdrawn.

The Design and Implementation Safety Cases for this proposal (and all elements of the AMP) should be made public and redacted only to the minimum extent required to protect individual (but not corporate) privacy.

Many, if not most, of the touted benefits of this proposal are more hubris than of substance. In some cases, the likely outcomes are the opposite of what is suggested.

The proposal continues what seems to be a myopic rush to install Class E as the default Australian airspace but without the subtleties and operational maturity of the US NAS system upon which it is based.

AusALPA has seen nothing in the way of post implementation reviews (with particular emphasis on the flight operations aspects) of the existing pockets of Class E with lowest levels of 700ft and 1200ft AGL. The current proposal should not be implemented in the absence of such reviews, given the significant consequences of the proposed changes.

We consider 1500ft AGL to be an inappropriate choice for the lowest level of the proposed Class E airspace.

Our previous comments about the management and direction of Airservices airspace projects remain apposite...

Hmm...hopefully AusALPA are keeping an active brief on this with Chair Mack and the RRAT committee??

MTF...P2 

[Peetwo]

Advance on YMNG, Class E; & back to ToRs - 

For my UP Chocfrog nominee POTW, I refer to this Advance post...  

Advance

After 25 pages of posts on this subject can we get back to a very simple proposition indeed:


The function of ATC is to prevent collisions between aircraft.

Aircraft in VMC are (usually) able to see and avoid other aircraft, particularly if given relevant traffic.

Aircraft in IMC can NOT self separate under most circumstances even if they are given traffic.

Mangalore was a prime demonstration of this truth.

The aircraft were given traffic.

An aircraft on an instrument approach is legally required to fly the approach as published (or to go around, climbing but not deviating from the lateral confines of the published approach).

An aircraft on an IFR departure, particularly a training one is firstly required to have a pre-determined safe route to reach LSALT so is at least to some degree and maybe wholly constrained against lateral manoeuvering.

And is likely dealing with a simulated engine failure or such since that is what IFR training is all about.

Intelligent people responsible for safe aircraft operations in developed countries have determined that ATC must provide separation for all aircraft operating in IMC since they can not always do it themselves.

Airservices fails to grasp this simple concept.

This may be in part because Airservices no longer employ qualified, current IFR pilots who can tell the ATC staff what is required.

CASA, and OAR, as I have previously demonstrated are not compliant with their legal requirements.

I support the implementation of the US system of airspace classification and usage.... all of it.... the way they do it in the USA, not some local invention by those who do not know how to do it right.

Some folk on here like Dick, Geoff Fairless and LeadSled have the picture, fortunately.

Further, I have demonstrated why it is less costly (less workload) for ATC to provide separation than to provide traffic.

Why is the history of aviation in this country such that safety improvements only occur when there are enough dead bodies to cause an outcry? 

Ref: https://www.pprune.org/pacific-general-a...st11022636

MTF...P2 

[Kharon]

Hold the Choc Frog:-

I'll see your Advance Choc Frog nomination and raise you an Alphacentauri.

The 'Voice of Reason' thread on the UP is worth following, if just for the lack of 'agenda'  ridden bollocks and personal bias.  Solid common sense is always worth consideration.

Alpha :- “Lead Balloon, I think its premature to determine an answer at this point. However, the path to a solution is not hard to follow.

1. We need an agreed upon risk framework so that risk can be determined for certain operations in to particular locations (note I have not used the term airspace). The risk model is to include, traffic mix, traffic density and CNS capability. (amongst other things).
2. We also need an agreed methodology to determine the problem we are attempting to solve.
3. We need a risk acceptance framework where by risk can be determined, assessed and accepted against the problem. Not all problems need solutions. Some risks may be acceptable provided all parties are informed.



Lets take Ballina. (None of what I am about to type is a proposal. I have used these examples to trigger a discussion. That is all)
What exactly is the problem we are trying to solve? OAR would have you believe that communications masking from Lismore and over transmission is the problem that lead to the A320/Jabiru incident. But it is known fact that the Jabiru made a transmission, and no one else transmitted at the time. The A320 was in line of sight so terrain shielding also was not at play. So what caused the incident? Is it traffic mix? Is it poor training from Jabiru or A320 crew....I genuinely don't know, but shouldn't we try to find out what the root cause was before we introduce another set of complexities and problems? Class E at Ballina, would not have prevented the incident, and neither would the broadcast zones that are being proposed. Here's the final question, do we absolutely want to prevent a Jabiru from taking out an A320? I would argue, most probably, yes. So the solution is going to have make that the priority outcome, and that may mean excluding some types of operations. So we don’t want any probability of that even happening. (stay with me, I'm going somewhere with this)

Now take Mangalore.
We really don't know yet what actually caused this accident? We may end up putting it down to bad luck? But, how do we know there is not a latent error in the airspace system that could have this happen anywhere else? (I’m sure I read a comment along that line by you somewhere, I agree by the way).
But what if this is the 1:10(-9) event. Is that ok? Should we invest time/money in trying to make a system more safe, when everybody seemed happy with the 1:10(-9) risk?
In this way we need to develop tools to determine if a) there is an latent error or, b) this is the 1:10(-9) event. If its b) we also then need the testicular fortitude to stand by the level of risk that we have accepted. I feel terrible for those 4 blokes, its sad and I hope it never happens to me. But flying has a risk, we all accept it. Its not zero. If we establish that the risk at Mangalore is as we thought it was...does it need a solution?

So take the 2 scenarios above. 2 totally different problems, with what I hope would be 2 different set of airspace performance requirements, which would lead to 2 different outcomes with 2 different associated levels of risk. How then can the same solution be applied to both locations, and the same outcome be expected? All you are doing is adding another variable to an existing set of variables that have not been assessed appropriately in the first place.....this makes the risk increase significantly.

The point being if we have a mutually agreed framework with which to assess and determine the risk of operations at a particular location, and then you have an agreed framework with which to mitigate that risk (or not) then the outcome should be valid.

We are not ready for solutions yet.

Well said that man. {I reckon the budget could stretch to two Choc Frogs.}

[Peetwo]

Dear John...L&Ks Dick Smith - 

Finally catching up...  

Via AOPA Oz: 

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DICK SMITH ISSUES OPEN LETTER TO FORMER AVIATION MINISTER MR JOHN ANDERSON

April 8, 2021 By Benjamin Morgan



Published by Mr Dick Smith, 6th April 2021.

OPEN LETTER TO MR JOHN ANDERSON
FORMER MINISTER FOR TRANSPORT AND REGIONAL SERVICES 1998 – 2005

Dear John

RE:  15 FATALITIES FROM THE LACK OF AIRSPACE REFORM

I am writing this open letter to you as I am amazed to hear that you are preparing to stand for preselection for a National Party seat in the Senate.  Surely this can’t be so.

The aviation industry was part way through a major reform program when you took over as the responsible Minister.  These reforms had been started under Labor Minister Kim Beazley, who was well informed, involved and supportive of the necessary changes.  Further important reforms including the multi-million dollar cost saving portable Emergency Locator Transmitter approval took place under John Sharp.

When you became Minister, the reforms were stopped in their tracks.

As the longest serving Minister responsible for aviation (some six years and seven months) you had the duty  to continue with the reforms that would have improved airspace safety and enabled Australia to be a world leader in flight training, inbound aviation tourism, charter operations, maintenance and manufacturing.

You didn’t take that opportunity, you did the opposite.  Your lack of action has done immeasurable damage to the Australian aviation industry.

In relation to airspace, as the responsible Minister you issued a press release with great fanfare on 13 May 2002, announcing your Government’s decision to change to the National Airspace System (NAS) based on the proven US airspace model (see attached).

If implemented, this would have resulted in airline aircraft remaining in controlled airspace at airports like Ayers Rock and Ballina, rather than the less safe system that we have today – where airline pilots have to call other pilots while in cloud, and try to arrange “separation” so they don’t collide with each other.  No other country in the world has such an unsafe system.

There are now 15 deaths that most likely can be attributed to your failure to introduce the NAS reforms as decided by your Government.  There were six fatalities at Benalla on 28 July 2004, three fatalities at Mt Hotham on 8 July 2005, two at Coffs Harbour on 20 September 2019 and four at Mangalore on 19 February 2020.

Other than the media release, you showed no support for the airspace reform plan.  Just as importantly, you did not allocate the time required to familiarise yourself with the proposal so you had the confidence to “sell” it.  That was the prime reason the NAS safety upgrades did not take place.

Could it be that your bureaucratic advisers recommended that you not become informed on airspace because when people died in accidents, you couldn’t be held responsible?  If so, it has certainly worked.

I wonder if at the time your bureaucrats advised, “Minister, hear nothing, know nothing, do nothing, say nothing and we will protect you.” 

As the Brittany Higgins situation has recently shown this type of lack of accountability still continues in Canberra today.  You were clearly a master at it.

You made further announcements that you were going to introduce reforms, however nothing was ever done.  In November 1999, a year after you were appointed the Minister for Transport, you issued a press release stating:

“A new regulatory framework will make it possible for new operators to provide a control tower and rescue and firefighting services in competition with Airservices Australia.  We will phase in competition for these services.”

In your next six years as the Minister for Transport responsible for aviation, you did nothing to ensure that the competition changes came in – they haven’t to this day.  Small country towns, such as Ballina, do not have the higher level of safety that could be achieved with a locally operated air traffic control tower.  At the present time, airline aircraft are blundering around in cloud, with pilots attempting to avoid a collision with other planes in an unsafe 1930s type system that is unique in the world.

Rather than show leadership and “sell” the advantages of your proposal, you said nothing.  To this day, there are no locally owned air traffic control towers in Australia.  In the USA, 50% of towered airports are operated under contract.  Competition in these services reduces costs so it means more airports can receive the upgrade with a resultant increase in safety.

On 31 August 2004, you gave Airservices Australia, your air traffic control body, a written legally binding Ministerial direction (attached) requiring them to install an approach radar control service at places like Coffs Harbour if they were going to change the Class E airspace to “road block” Class C.  This safety direction is still current, has never been complied with and you have never explained why.

On 25 November 2004, you reversed parts of the NAS airspace introduction and created giant “road blocks” in the sky over country airports like Coffs Harbour and Tamworth but without the radar upgrade.  This has now resulted in multiple fatalities.  Nowhere else in the world is there similar “road block” airspace.

On 20 September 2019, aviator Jeffrey Hills and his son Matty had departed Murwillumbah in their Mooney aircraft and were heading to Taree at a safe height above the mountains when they were refused permission to fly through the “road block” airspace above Coffs Harbour.  They were forced to descend into the bad weather and mountains below.  They crashed into a mountainside and both Jeffrey and Matty were killed.[b] [/b]

The Australian Transport Safety Bureau report on this horrific and needless fatal accident implied that the Air Traffic Controller and the pilot were responsible and made no mention that you had reversed the NAS airspace and put the “road block” in place.  Then again their investigators would know that they would have limited career prospects if they told the truth and laid the blame on even an ex-minister.

I only remained the Chairman of the CASA Board for 18 months under your Ministership.  My fellow Board members and I looked for direction from you in relation to the necessary reforms that needed to be done to improve the safety of airspace and to stop the continuing destruction of the general aviation sector.  We got no support from you at all.

I resigned as Chairman on 22 March 1999 because it became obvious to me that you would not support the necessary reforms

Not long after my resignation, you introduced a Bill that abolished the Board.  This is what it said:

“The Bill abolishes the CASA Board and retains CASA as an independent statutory authority, thereby providing the Minister with stronger and more direct control over CASA’s governance and accountability in the areas of CASA’s policy directions and priorities…”

In fact, it’s clear you abolished the Board for the opposite reason.  You didn’t want the Board to recommend changes for which you could be held accountable.  Could there be any other reason?  In the next two years that you operated as Minister without the CASA Board, there were no reforms.

As you are aware, the Labor Government reinstated the CASA Board on 1 July 2009, nearly six years after you abolished it.

You will no doubt remember when I called you to advise that I had asked the CASA CEO to step down, as it was clear that he was not a reformer who would bring in the necessary changes.  You were apoplectic and said that you would not support such action.

How different you were to the Prime Minister, John Howard.  At the same time I was Chairman of the Centenary of Federation Council and I advised the Prime Minister that the CEO was not suitable for the position.  Mr Howard gave me immediate support and we replaced the CEO with a person who would competently manage the program.

Undoubtedly the greatest damage you inflicted on the industry took place on 5 October 2000 when, as the Minister responsible for Aviation, you made the following media announcement:

“I don’t think that we should ever regard aviation safety as what is affordable … safety is something which has the highest priority.  It is not a question of cost.” 

That statement was both dishonest and irresponsible.  Dishonest because you knew (or should have known) that you were responsible for both national and international (ICAO) air safety regulations that are prescribed at quite different levels because of cost and affordability.  You also completely undermined the professionals within the Civil Aviation Safety Authority whose jobs were to perform cost and benefit studies so that the always limited safety resources could be effectively allocated.

Your irresponsible statement also allowed a small group of bureaucrats within CASA to change the reform program; from one directed at harmonising with the best and most efficient proven world practices, to one of increasing red tape and a “one-way ratchet” of more restrictions and complexity regardless of cost.  It is still happening to this day and is the prime reason the Australian General Aviation industry has nearly been destroyed.

As the longest serving Minister responsible for aviation, you have no record of achieving any of the much needed airspace and regulatory reforms.  If you look at your Wikipedia entry or search for your name in Google it is as if you were never responsible or even involved in the multi-billion dollar Australian aviation industry at all.  There is not one entry that lists even one achievement, let alone your support in any way for the much needed reforms.

Fortunately the present Minister responsible for the Aviation portfolio, Michael McCormack has been involved for over two years in a move to get CASA to support the safer NAS policy so that low level controlled airspace can be introduced at Ayers Rock to help prevent a Mangalore type fatal collision.

John, in relation to the Senate, why don’t you support someone new having a go?  Wouldn’t the best contribution you could make to the National Party, and the future of our country, be to seek out the most promising young candidate you can find, and support her for preselection?

Perhaps you could also use your influence to help facilitate the finalisation of the NAS airspace reforms before we have further unnecessary fatalities!

Yours faithfully

DICK SMITH

---

..Fortunately the present Minister responsible for the Aviation portfolio, Michael McCormack has been involved for over two years in a move to get CASA to support the safer NAS policy so that low level controlled airspace can be introduced at Ayers Rock to help prevent a Mangalore type fatal collision...

Hmm...interesting?? But how long will it take for the present Miniscule to actually do anything?? 

MTF...P2 

[Peetwo]

Civil Air take on the Harfwit's One Pie rationalisation??

Via the SMH: https://www.smh.com.au/national/nsw/plan...57jwn.html

---

Plan to shift half of Sydney’s air traffic controllers to Melbourne

By Matt O'Sullivan
April 26, 2021 — 5.00am

Aircraft flying through all but a small part of greater Sydney’s airspace would be handled by a control centre in Melbourne under a controversial plan partly aimed at cutting costs by shifting up to half the city’s air traffic controllers to Victoria.

Airservices Australia’s plan to relocate up to 65 air traffic controllers to Melbourne from its terminal control unit at Sydney Airport is contained in internal briefing documents seen by The Sydney Morning Herald and The Age.



One of Airservices’ justifications for the shift is a need for “more cost-efficient solutions” due to the financial strain on the aviation industry from the COVID-19 pandemic. The federal corporation’s documents say the “transfer of services” to Melbourne will help it “avoid the costs of significant infrastructure replacement” in Sydney.

The building at Sydney Airport where the 65 air-traffic controllers are based is “nearing [the] end of life”, and there is no guarantee the long-term lease on it will be extended when it expires in 2034 because the site is designated for commercial use. It also argues “deeper pools of skilled professionals” are available only at its larger facilities such as those in Melbourne.

The controllers who work in the terminal control unit at Sydney Airport use radar control screens to sequence and separate aircraft in an area stretching from Shellharbour in the south, the Central Coast in the north, Katoomba in the west and out above the Tasman Sea.

The relocation would directly affect 65 of 130 air traffic controllers in Sydney. It would not impact those in the control tower at Sydney Airport who guide aircraft within about seven kilometres of the tarmac. Greater Sydney’s airspace is easily the country’s busiest.



Civil Air, the union representing air traffic controllers, said it was concerned about the plan and it would be on the agenda of a national executive meeting on Wednesday.

“We have been through this on previous occasions and it has not stood up to scrutiny for various financial, operational and technical issues,” Civil Air executive secretary Peter McGuane said.

An air traffic controller, who spoke on condition of anonymity, said most of those affected in Sydney did not want to relocate.

A major concern is controllers in Melbourne will not be as familiar with Sydney’s geography, which could potentially impact on small aircraft.

“It is not so much the international or domestic aircraft – it is the general aviation community. Those are the scariest emergencies for us because we are dealing with less trained pilots and older aircraft. The knowledge of the controller becomes such a key factor,” the controller said.



Sydney has up to 650 aircraft movements a day, which is not far off an average of about 850 before the pandemic hit last year.

“Traffic is increasing already and most of the controllers think the window they have targeted [to relocate] has already closed,” the controller said.

The terminal control unit at Sydney Airport also manages aircraft arriving at and departing from Richmond, Bankstown and Camden airports, in concert with the control towers at each of those locations.

Airservices expects to make a final decision in June about the shift, a process which would take about two years to complete.

Airservices confirmed it was in the “initial stages” of consulting staff on the future of the Sydney control unit, adding there would be “no required job losses”.

“The management of terminal area airspace from major air traffic service centres is safe and a model used around the world,” a spokeswoman said.

She said Sydney’sairspace would continue to be managed by specialist controllers with a deep understanding of it. “The only thing that will change is the location of this service,” she said.

Airservices said the investigation into the feasibility of integrating the Sydney unit into the Melbourne air traffic service centre was driven by the pandemic.

“It is also important that Airservices strives to keep air traffic control costs as low as possible to assist the aviation industry’s recovery from COVID-19,” the spokeswoman said.

Over the past two decades, terminal control services for Canberra, Gold Coast, Adelaide and Cairns have been centralised in Melbourne and Brisbane.

---

MTF...P2 

[Kharon]

Flight 'Service'.

In primus, I acknowledge my complete ignorance on the management of airspace; and have absolutely no idea how the boffins work it out and set up their networks and etc.

However I have worked in it for many a long year – in different countries. There is always a little 'something' which can be a trap for young players, but, by and large the AIP (or similar) usually sorts out any differences noted. Should that fail,then there is usually a helpful soul about who can explain the way things are, thus avoiding embarrassment.

'We' have been following the UP thread relating to Ballina with interest; been some top quality discussion there by folk who have a much better handle on the intricacies than the average bear. Nicely done.

But I wonder if in our rush to 'hi-tech' computerised systems and all the toys we have discarded what I thought was a very good system – just speculating here. Back when we had Flight Service Units and flight plans and position reports we pretty much knew where everyone was, when they would be at a certain position, how high they were and their estimate for the same field as you were headed for. It may have been 'costly' but it was rock solid.

There is a safety case to support a return to some of the past notions. Personalty, the thing which is always a concern at the back of my addled mind is the 'silent minority' i.e. those who say nothing. Three very close calls – serious ones – and a fair number  of 'that could have been nasty' ones, all without any sort of 'notification' - beg the question – are there holes in our famous cheese? 

One of the best 'systems' I've used is the Sydney radar advice to IFR approaching Bankstown from the West; OCTA and accurate traffic information until you enter the Bankstown zone; it works just fine. Could a similar system be provided to Ballina? Or, will the jet traffic ease off when the Gold Coast works are finished? The notion of RPT traffic self separating from 'known' aircraft is IMO problematic; but self separating from 'unknown' traffic  - or non reported traffic is a recipe for trouble. TCAS and all that helps – but it can be costly when a profile has to be 'modified' to avoid conflict. One may operate into a field 50 times without a care in the world, then you arrive one day when the Tupperware is out to play – that's fun. But I digress.

Surely in this day and technological age; we could provide airspace access to VFR and IFR both and provide the basic 'advisory' service the old FSU did; to me it all seemed so simple then – file a plan, tell 'em where you were, and what time you expected to be at Kickatinalong – then you were advised the F27 was due at 00:00 o'clock – tune into the CTAF, have a quick 'sort out' and bingo – instant peace and harmony – mostly.

Air Services seem to be mostly concerned with 'budget' these days and 'tech stuff'. All well and good – but – I say their fundamental purpose is to develop a system which keeps everyone on the same page – late afternoon, rain and cloud, just getting visual and picking your way through the low stuff and showers, wet windscreen etc. – you can't always see enough to  'self separate'. All attention on the task in hand – you may even miss the muffled squawk of the itinerant student trying to call a base turn.

Anyway – just my uneducated two bob's worth on what seems to be a basic, straight forward problem – one of stopping aircraft banging into each other, being bogged down in politics and KPI. My Aunt Pru always said you can't charge for pearls if you're selling pig's ears.

Toot – toot. Yes, yes I know, back in my box right.......

[Peetwo]

RAOz a voice of reason? 

Via each way Hitch:

---

 

RAAus pushes for National Airspace Strategy
4 May 2021
Comments 0 Comments

Recreational Aviation Australia (RAAus) has called for the government to develop a National Airspace Strategy to ensure all users have equal access to Australian skies.

The call was contained in RAAus' response to Airservices Australia's second proposal to lower the base of Class E on the eastern seaboard, which was submitted last Friday. RAAus has rejected the revised proposal stating that Airservices has still not established a reason for the change.

"The establishment of a National Airspace Strategy would provide a ‘roadmap’ or similar, for government, its agencies and industry, to work towards in assuring that an acceptable level of risk is achieved in relation to airspace design and operational procedures.

"Furthermore, RAAus maintains the firm position that where an airspace risk warrants airspace design changes, that a proven and noncomplex design criterion should be applied wherever possible and that it must–by law–be done in accordance with the Australian Airspace Policy Statement (AAPS) and the Airspace Act 2007."

RAAus said a National Airspace Strategy would determine the equipment required for airspace categories well in advance, to enable airspace users to prepare for change and ensure no-one is disadvantaged by "poor planning or an inadequate safety case by government or its agencies."

RAAus recommended also that their members be allowed access to controlled airspace as part of that strategy and also called for a review of the effectiveness of the Australian Strategic Air Traffic Management Group (ASTRA).

In supporting their rejection of the revised proposal that would see the base of Class E lowered from 8500 to either 6500 or 4500 feet AMSL with a minimum terrain clearance of 1360 feet, RAAus stated that some aircraft don't have the panel space to install a transponder as would be required in Class E, and called for Electronic Conspicuity (EC) devices to be a permitted alternative.

The organisation also criticised Airservices for not supplying a valid safety case and accused it of designing airspace to suit its own needs.

"It is the contention of RAAus that this unique and overly complex airspace design proposal will introduce further risk for all airspace users whilst not meeting the requirement to provide equitable use of airspace, as prescribed under the Australia Airspace Policy Statement 2018.

"This proposal introduces a clumsy and overly complex design without being clear on the issues it is trying to address.

"It is simply an impractical concept to expect aircraft to climb and descend to remain outside of the Class E based upon a design that aligns with existing ATC sector boundaries, communication and surveillance coverage and terrain, rather than mitigating against specific risks.

"In other words, the design meets the objectives of the designer rather than the user."

The consultation period for the proposal closed last Friday 30 April. More information is on the Airservices Australia engagement website.

---

MTF...P2 

[Peetwo]

TICK TOCK..Benalla, Mangalore, Ballina...NEXT?? 

Geoff Fairless (via the UP) provides an excellent, objective analysis of the Airservices Class E Elephant in the Sky...  :

Hi Alpha,

Your arguments are correct however they beg some questions, who analyses the existing system, how do they do it, and will the result become available to the public? I will only address Ballina.

ATSB will undoubtedly avoid the airspace and procedures aspect, the latent issues, as they normally do. In their defence I believe that is because they lack the expertise to make the analysis and have to rely on CASA and Airservices. Both of these organisations, however, have an over-riding goal, to protect their Minister (Information source two senior CASA executives). Hence they have a vested interest in defending the status quo. This is because, by default, they are obeying their ministerial statement of expectations, and, in terms of this argument, the Airspace Act/Regulations, and the Ministerial Airspace Policy Statement. It follows that if the Minister does not tell them to do something differently, then he/she has accepted that they are operating in accordance with his/her expectations.

Airservices has refused to release the safety analysis that it claims was done to justify SFIS at Ballina. CASA should have evaluated that analysis before approving the change from their recommended CA/GRO to SFIS. Why? Because the nature of the SFIS was argued to be simply an extension of the Class G (F?) traffic information service. However, it removed the CA/GRO's capability to visually monitor the circuit area and in particular the runway. This is arguably the most critical area for safety. I would like to see how Airservices treated that removal in their safety matrix and what CASA replied. Incidentally, the last CASA OAR review of Ballina airspace was 16 Aug 2017. There is no published analysis for the latest changes by Airservices.

The other obvious problem with traffic information services is radio clutter. This is particularly true in Australia where pilots have been taught for years that unalerted see and avoid does not work. To keep it simple, each pilot now has to make all the recommended calls, other pilots need to respond to those calls to affect separation, and the SFIS controller has to record the calls and make judgments about how the aircraft are related to each other, and then presumably make more calls to alert the pilots. Add to this the new requirements that force VFR pilots to become "full reporting" before taxiing and the increase in the radius of the MBZ to 15NM (10NM contains 78.5 Sq NM, and 15 NM contains 176.7 Sq NM) now there is a recipe for radio congestion!

It would be interesting to see the safety score on the matrix for that and what mitigation was suggested. The rules do not seem to contain any implemented mitigation other than "let's hope nothing goes wrong" and if it does then again we can say "All of the parts of the airspace system WERE NOT functioning as they should have been". As I understand the US system, it leaves VFR pilots to concentrate on flying, navigation, and watching for traffic, not talking continuously. (Old ATC advice to young controllers - you can't think while your mouth is open) IFR flights are controlled until they must proceed visually and are provided with traffic information on VFR when it is available.

Hopefully, I have demonstrated that there are at least two potential problems with the current Australian system and indicated how the US system has already identified those issues and mitigated them. There is of course much, much more, but time and space preclude going on. 

MTF...P2 

[Peetwo]

Join the dots...

Reference above post:

Hi Alpha,

Your arguments are correct however they beg some questions, who analyses the existing system, how do they do it, and will the result become available to the public? I will only address Ballina.

ATSB will undoubtedly avoid the airspace and procedures aspect, the latent issues, as they normally do. In their defence I believe that is because they lack the expertise to make the analysis and have to rely on CASA and Airservices. Both of these organisations, however, have an over-riding goal, to protect their Minister (Information source two senior CASA executives). Hence they have a vested interest in defending the status quo. This is because, by default, they are obeying their ministerial statement of expectations, and, in terms of this argument, the Airspace Act/Regulations, and the Ministerial Airspace Policy Statement. It follows that if the Minister does not tell them to do something differently, then he/she has accepted that they are operating in accordance with his/her expectations.

Airservices has refused to release the safety analysis that it claims was done to justify SFIS at Ballina. CASA should have evaluated that analysis before approving the change from their recommended CA/GRO to SFIS. Why? Because the nature of the SFIS was argued to be simply an extension of the Class G (F?) traffic information service. However, it removed the CA/GRO's capability to visually monitor the circuit area and in particular the runway. This is arguably the most critical area for safety. I would like to see how Airservices treated that removal in their safety matrix and what CASA replied. Incidentally, the last CASA OAR review of Ballina airspace was 16 Aug 2017. There is no published analysis for the latest changes by Airservices.

The other obvious problem with traffic information services is radio clutter. This is particularly true in Australia where pilots have been taught for years that unalerted see and avoid does not work. To keep it simple, each pilot now has to make all the recommended calls, other pilots need to respond to those calls to affect separation, and the SFIS controller has to record the calls and make judgments about how the aircraft are related to each other, and then presumably make more calls to alert the pilots. Add to this the new requirements that force VFR pilots to become "full reporting" before taxiing and the increase in the radius of the MBZ to 15NM (10NM contains 78.5 Sq NM, and 15 NM contains 176.7 Sq NM) now there is a recipe for radio congestion!

It would be interesting to see the safety score on the matrix for that and what mitigation was suggested. The rules do not seem to contain any implemented mitigation other than "let's hope nothing goes wrong" and if it does then again we can say "All of the parts of the airspace system WERE NOT functioning as they should have been". As I understand the US system, it leaves VFR pilots to concentrate on flying, navigation, and watching for traffic, not talking continuously. (Old ATC advice to young controllers - you can't think while your mouth is open) IFR flights are controlled until they must proceed visually and are provided with traffic information on VFR when it is available.

Hopefully, I have demonstrated that there are at least two potential problems with the current Australian system and indicated how the US system has already identified those issues and mitigated them. There is of course much, much more, but time and space preclude going on. 

An now this:

Mangalore aeronautical study

Overview

The Office of Airspace Regulation (OAR) is conducting an aeronautical study of the Mangalore area in Victoria as outlined in the terms of reference, provided below.

The study will review the airspace within a 25 nautical mile area of Mangalore, including nearby aerodromes, Puckapunyal, Graytown, Euroa and Locksley Field, up to 8500 feet above mean sea level.

The OAR will be looking at traffic types and density from over the last 5 years and considering the feedback from the Australia Transport Safety Bureau’s report into the mid-air collision that occurred in 2020, should the final report be released before the conclusion of the study.

The study will evaluate the suitability of the airspace, including efficient use, equitable access for all users, appropriateness of the airspace classification and the existing services and facilities provided by the air navigation service provider.

Documents for review

You can view the terms of reference and a copy of the consultation below. 
If you would like to provide further feedback, please email OAR@casa.gov.au. Feedback submitted by email will be considered but cannot be published publicly. 

Further information about airspace regulation and the airspace change process is available on the CASA website.

Why your views matter

Why we are consulting

We would like to hear your experiences about flying in the Mangalore area and how proposed future airspace change may affect you.

In the consultation, we will ask questions relevant to the airspace and provide you with an opportunity to share further feedback.

What happens next?

Once the consultation has closed, we will register and review each submission received through the online response form. We will make all submissions publicly available on the Consultation Hub, unless you request your submission remains confidential. We will also publish the final report on our website.

Information about how we consult and how to make a confidential submission is available on the CASA website.

To be notified of any future consultations, subscribe to our consultation and rulemaking mailing list.

Plus EWH, via the LMH:

Following the on-schedule implementation of Surveillance Flight Information Service (SFIS) at Ballina last month, a similar service due to go live at Mangalore this week didn't happen at all. Instead, CASA launched a review of the airspace; not a common occurence for an airport that has no RPT and no tower. Right now I am asking myself what this review is going to reveal. It will show that Mangalore is a busy training airport in an area of heavy sport and recreational traffic situated at an aviation pinch-point that is difficult for through traffic to avoid if the weather over the ranges is unsuitable. Mountains to the east, prohibited airspace to the west; Mangalore is the only safe way through. Airservices thought SFIS was the answer, but that makes radio mandatory, which angried-up the glider pilots that use the region as their playground. Spies keep telling me that consultation didn't go so well, which has delayed the SFIS date and prodded CASA into the review. But what can it change? One thing that would go a long way to easing congestion would be to remove or relocate the VOR. The Melbourne region used to have VORs at places like Yarrowee, Cowes and Wonthaggi where training schools could go to practice VOR procedures. They're gone now, leaving Mangalore or Avalon as the most practical options, and even they have issues with booking slots. Most schools prefer Mangalore, which draws more traffic to the pinch-point. Airservices, CASA and the industry as a whole needs to address this issue and find a solution that results in less demand on that VOR. And for that matter, they could have a look at the need for VOR training full stop.

Hmm...I wonder how far off the final report is for ATSB AAI AO-2020-12 (the fatal Mangalore midair collision)? 

---

Status: Active 


Phase: Final report: Internal review 

Investigation progress update published 24 February 2021

The investigation into the mid-air collision involving Piper PA-44-180 Seminole VH-JQF and Beech D95A Travel Air VH-AEM near Mangalore, Victoria, on 19 February 2020, is continuing.

The investigation is currently in the ‘Examination and analysis’ phase. During this phase, evidence is reviewed and evaluated to determine its relevance, credibility and relationship to other evidence and to the occurrence.

ATSB investigators have so far gathered and analysed numerous information sources including:

• on-site aircraft examination at the two sites where the aircraft were located
  
  
• witness statements
  
  
• weather observations and forecasts
  
  
• recorded flight data
  
  
• aircraft component inspection
  
  
• operational and maintenance documents
  
  
• personnel licence and medical records
  

Further analysis is occurring on:

• airspace and air traffic control procedures
  
  
• visibility from both aircraft
  

Last update 29 July 2021

---

I do believe there is much..much MTF - 

[Peetwo]

Join the dots - Part II

Slight drift here but to begin I'd like to go to a CASA quote extracted from the JSCT (Joint Standing Committee on Treaties) inquiry report into airservices treaties with Thailand, Timor-Leste, PNG:

Australian air operators and pilots are reminded to check all available and authoritative information about potential safety and security threats to flights before conducting operations in, over or near areas of armed conflict or turmoil. Air operators and pilots should determine if National Aviation Authorities or other government agencies have issued any notices, advisories, bulletins, warnings or other safety information about activities that may pose risks to flights in particular geographic regions or airspace. These should be assessed along with any relevant travel advisories from the Department of Foreign Affairs and Trade.

It is the responsibility of air operators and pilots to consider this kind of information and to make informed decisions about when, and whether, to operate into or over particular areas where local situations and circumstances may pose unacceptable risks. Operators and pilots are always required to be familiar, and to comply, with the applicable aviation laws of other countries in which they conduct operations.

Lastly, the ICAO, is compiling information promulgated by states regarding risks to civil aircraft arising from conflict zones. CASA reminds Australian air operators and pilots considering operations into or over problematic areas to pay attention to all current safety notices and bulletins, including from the following sources—and we have provided links: the ICAO conflict zone information repository; the USFAA prohibitions, restrictions and notices; and the European Aviation Safety Agency safety bulletins as well.

Fair bit of irony when you flip that statement and consider international pilots/operators contemplating launching into Australian airspace and then flipping to the Airservices AIP GEN 1.7 (notified differences to ICAO), only to find a link to this explanatory note: https://www.airservicesaustralia.com/aip...y_note.pdf 

Following that along eventually -   - the unwitting pilot will discover the relevant ASA webpage which has multiple links leading to over 1600 pages of notified differences to ICAO - GOOD LUCK with that!...  

Coming back to the UP on the suddenly announced CASA OAR review of the Mangalore Airspace with a question, will we now have to notify a difference to ICAO with a newly defined classification of airspace - ie the SFIS?

Back to the discussion...

Geoff Fairless

Alpha,


The process for analysing and changing airspace in Australia is contained in the Airspace Act, Regulations, and Ministerial policy statement (AAPS). None of these documents authorise CASA to introduce a Broadcast Area into Class G or any other type of airspace.CASA seems to have the authority to follow or ignore administrative law as it sees fit. Due, no doubt, to lack of oversight by the responsible Department and the Minister.

According to the AAPS the airspace, as it is configured should be Class F not G, better still Class D with a locally-owned and operated Control Tower:

• Class F: IFR and VFR flights are permitted. All participating IFR flights receive an air traffic advisory service and all flights receive a flight information service if requested.
  

To make decisions CASA OAR is supposed to follow the process described in the AAPS. They have not done so in this instance by allowing Airservices to do the consultation but keep their risk assessment a secret.

How CASA arrived at the decision to allow an airspace configuration not authorised by their legislation, that is, Class G/Broadcast Area/FIS, to be implemented we will never know unless someone in the Senate RRAT asks the question, or an FOI request is made.

I am really pleased, however, to see that we are on the same page.

---

CaptainMidnight

CAR 1988 99A authorises CASA to designate an area in which specified broadcast requirements apply.


They've used that for many years.

(1)CASA may:
(a) designate an aerodrome as an aerodrome at which broadcast requirements apply; and
(b) designate airspace within defined horizontal and vertical limits as an area in which broadcast requirements apply.
(3)CASA may give directions specifying:
(a) the broadcast requirements that apply; and
(b) the radio frequency on which broadcasts must be made;
at a particular aerodrome, or in a particular area, designated under subregulation (1).

(4)If CASA gives a direction, it must publish a notice setting out the details of the direction in AIP or NOTAMS.

---

Lead Balloon

And thus the cosmic cycle continues...


CM is correct. Any class of airspace can theoretically be the subject of a designation under 99A. It's about mandatory blabbing in the designated area, not about the class of the airspace in that area. It's been used many times because, as we know, more blabbing equals more safety. However, come the year 2003 99A will be repealed.

And another 'blast from the past' was GF's epiphany about class F.

It astounds me that there's anyone left who doesn't realise that airspace arrangements and procedures in Australia are determined by the JMSUAYGA Procedure.

---

Dick Smith

 Problem with calling it Class F is that under ICAO class F has no requirement for VFR to have radio and we in Australia are obsessed with VFR having mandatory radio requirements!

---

Lead Balloon

Problem with calling it Class F is that under ICAO class F has no requirement for VFR to have radio and we in Australia are obsessed with VFR having mandatory radio requirements!

The same "problem" arises with even greater force in calling it "G". But Australia has never been averse to notifying ICAO of the odd difference here and there.

---

cogwheel

What we have at Ballina is closer to Class F than it is to G.



i don’t believe the class of airspace is the problem - for the record I quote my post on the BNA thread....

It’s not the airspace that is the problem. It is the failure of many pilots, including instructors to understand the required procedures appropriate to the circumstances. It is also a failure of CASA to ensure that such procedures are taught and examined to a level which will help ensure the level of communications is undertaken in such a way the risks are minimised. It used to be covered under “airmanship” but seems that is not taught any more?

---

Lead Balloon

Isn't all 'G' in Australia 'closer' to F than G? AIP GEN 3.3 at para 3.3.7.2 says that:

Traffic information
...
In Class G airspace, a traffic information service is provided to IFR flights about other conflicting IFR and observed VFR flights except:

a. An IFR flight reporting taxiing or airborne at a non-controlled aerodrome will be advised of conflicting IFR traffic that is not on the CTAF; and

b. An IFR flight inbound to a non-controlled aerodrome will be advised of conflicting IFR traffic until the pilot reports changing to the CTAF.
So I'm not sure it's all about pilots not understanding and using correct procedures.

That said, the paragraph immediately before the one I quoted effectively says that the service is a 'workload permitting' one. Perhaps part of the education process should be to make clearer that it's a 'Clayton's' traffic information service for IFR. Maybe that's why Australia calls it G rather than F...

---

le Pingouin

"Clayton's"? In 30 years of providing a traffic service I have never once been unable to provide all IFR-IFR traffic. Sometimes it's impossible to provide detailed directed traffic on multiple VFR aircraft to multiple IFR aircraft, there just isn't time. You might be a skygod, I'm not.

---

Lead Balloon

Understood, Le P. I'm not a 'skygod' either.


I don't know too many IFR pilots who understand that the IFR/IFR traffic information service in G in Australia is effectively 'workload permitting'. Maybe the pilots involved in the Mangalore tragedy made an assumption that turned out to be invalid?

---

le Pingouin

IFR/IFR traffic has ever been thus but the circumstances where it can't be provided due workload are pushing once in a career type levels.

---

Lead Balloon

Indeed. And if we had a half-way competent safety regulator and an independent and half-way competent transport safety investigator, the attendant risks would be ringing alarm bells and mitigating actions would be recommended and taken. But this is 21st century Australia.

---

CaptainMidnight

Re AIP GEN 3.3 - 4 para 3.3.7.1 stating [i]"A traffic information service is provided, depending on higher priority duties of the controller etc."[/i].

Certainly in the days of FS when they managed "OCTA", traffic info to IFR (and RPT & MLJ) wasn't workload permitting, it was mandatory to provide it (MATS said something like [i]"Traffic information shall be provided to etc."[/i]).


I suspect the revised text came in when FS disappeared and ATC took over their airspace, with some ATC sectors also being responsible for separation in the overlying CTA, which I assume someone decided was a higher priority than the provision of traffic info in Class G.

---

Lead Balloon

Perhaps the 'hard-hitting' objectively independent investigation of the Mangalore tragedy by the ATSB will recommend reinstatement of FS? Nothing would surprise me these days.

---

Geoff Fairless

I stand by my statement.


CASA OAR does not operate under the 1988 CAR, they were created as a stand-alone office within CASA and are governed entirely by the ICAO-compliant Airspace Act and Regulations. Section 11A of the CAR 1988 does, however, require the rest of CASA to operate in accordance with the above act and regulations or advise the Minister why they are not so doing.

Those laws do not include resorting to ancient CARs such as 99A, or Part 139 - CA/GRS or the Airspace legislation would say so.

Once again we see CASA, including OAR, not understanding their own legislation, or if they do, being too clever by half in their continued endeavours to re-create the "OCTA" of the pre-TAAATS era.

As many have written, in many different threads, they are a law to themselves.

MTF...P2 

[Peetwo]

Join the dots - Part III: Hooded Canary returns to ASA

Via the ASA Media pages: https://www.airservicesaustralia.com/new...ces-board/

Airservices welcomes the appointment of former Australian Transport Safety Bureau (ATSB) Chief Commissioner, Mr Greg Hood, to the Board. Mr Hood was appointed by Deputy Prime Minister and Minister for Infrastructure, Transport and Regional Development, the Hon Barnaby Joyce MP, and will serve as Deputy Chair for the next three years commencing 8 September 2021.


Airservices Chairman John Weber and the rest of the Board acknowledged the extensive aviation experience Mr Hood would bring at a time when Airservices and the aviation industry were responding to challenges such as COVID-19 and opportunities being presented by technology such as drones.

“On behalf of myself and the Board, I sincerely welcome Mr Hood to Airservices. He has a wealth of knowledge and experience in aviation and safety, and we look forward to his contribution at this critical juncture,” Mr Weber said.

For the last five years, Mr Hood has served as Chief Commissioner and CEO of the Australian Transport Safety Bureau (ATSB), Australia’s national transport safety investigation agency. 
   
He has more than 41 years’ experience in the transport industry, beginning his career with almost a decade of service with the Royal Australian Air Force (RAAF). He has since had a wide range of operational, training and leadership roles across the civil aviation industry.

In accepting the role, Mr Hood said, “I am greatly honoured to be appointed as Deputy Chair of Airservices, which has an excellent international reputation for air traffic management and aviation rescue fire fighting service delivery.

“I hope to be able to contribute positively to the well-established safety and service culture within the organisation as we navigate through the introduction of OneSKY, focus on the management of noise and the environment, and work with industry partners to safely manage the expansion of remotely piloted aircraft systems.” 

Mr Hood also holds qualifications as a glider and powered aircraft pilot, and is a Fellow of the Royal Aeronautical Society, a Freeman in the Honourable Company of Air Pilots, and a Life Member of the Qantas Founders Museum. 

Mr Hood replaces Air Chief Marshall Mark Binskin AC (Ret’d) who resigned in July 2021 to take up the role of Chair of the Civil Aviation Safety Authority (CASA).

Hmmm...join the dots to this post:

Million dollar Harfwit's (non-)consultation on East Coast lowering of Class E - WTF?   

Hmm...in the House of Passing Strange coincidences when you consider this: Mooney Crash ATSB + (via the Oz) Airspace changes ‘would have stopped fatal crash’

And even this (still outstanding) ATSB investigation: Hooded Canary releases Mangalore mid-air prelim report 

Presumably HC has been privy to a level of intel on the (still outstanding) ATSB investigation which is reported to be at the final report internal review phase: 

Final report: Internal review

Final ATSB investigation reports undergo a rigorous internal review process to ensure the report adequately and accurately reflects the evidence collected, analysis, and agreed findings of the Safety Factor Review. Final investigation reports also undergo other technical and administrative reviews to ensure the reports meet national and international standards for transport safety investigations.
If a review identifies any issues with a report, such as information that needs to be expanded or findings that need to be modified, investigators will look to collect new evidence or conduct additional examination and analysis of existing evidence.

This means that there is still the external or DIP review phase to come: 

Final report: External review phase
To check factual accuracy and ensure natural justice, Directly Involved Parties (DIPs) are given the opportunity to comment on the final report before it is approved to ensure their input has been accurately reflected.

DIPs are individuals or organisations outside the ATSB who possess direct knowledge of the circumstances surrounding the incident or accident. DIPs can only comment on the factual accuracy of an investigation, not its analysis and findings.

This process is consistent with international transport safety investigation conventions, including those published by the International Civil Aviation Organization, International Maritime Organization as well as the Transport Safety Investigation Act 2003. DIPs are provided from five to 28 days to provide their comment and present evidence in support of their comments. This timeframe can be extended to allow DIPs based overseas to provide comment.

Feedback from the DIPs could prompt an investigation to return to the evidence collection, examination and analysis, and report drafting phases of an investigation.

One of the DIPs to this accident is obviously Airservices and another would be CASA, so who would be the perfect individual to provide politically correct topcover for both the ATSB final report and the whole Mangalore airspace schmozzle??? 

MTF...P2 

[Peetwo]

Su_Spence eases off the (MOAS) Koolaid on Ballina Airspace?? 

Via Oz Flying:

Ballina-Byron Gateway is now has an active Surveillance Flight Information Service (SFIS). (Google Earth image)

Airspace Review recommends CTA for Ballina

16 June 2022


A review into the airspace around Ballina Byron Gateway airport in northern NSW has recommended controlled airspace (CTA) be established with special access for sport and recreational aircraft.

CASA's Office of Airspace Regulation (OAR) released a draft report this morning that made nine recommendations, which included establishing a Class D tower no later than 30 November 2023.

OAR conducted the review of the Ballina-Lismore-Casino airspace after an increase in aircraft movements since 2017 was noted and the Australian Transport Safety Bureau recorded 41 safety occurences from 1 July 2020 to 31 July 2021.

Among those occurences were 15 communication issues, five separation issues and one collision with terrain.

"Considerable growth in aircraft movements, particularly passenger transport movements is apparent since 2017 in the Ballina airspace," the OAR report states. "The risk profile has altered during that period driven by the introduction of new carriers and the provision of additional airline services.

"A number of successive risk mitigation measures have been introduced during that same period in a graduated fashion, with each intended to improve on the former. Incidents continue to be reported validating the concerns of many stakeholders and operators.

"Furthermore, these incidents indicate the prevalence of potentially unacceptable airspace risk despite the existing controls."
One such mitigation measure was to introduce a Surveillance Flight Information Service (SFIS) in August last year.

 Airservices also created a Broadcast Area around the airport operating in conjuction with Certified Air/Ground Radio Service (CA/GRS) already in operation.

The OAR report made nine recommendations, two of which have already been implemented.

1. Separate the Lismore and Casino Common Traffic Advisory Frequency (CTAF) from the Ballina CTAF by 16 June 2022.
   
2. Evans Head Airport should be allocated the common CTAF (126.7 MHz) by 16 June 2022.
   
3. CASA should direct Airservices to install an ADS-B ground station to improve surveillance as soon as practicable but no later than December 2022.
   
4. CASA should explore a suitable regulatory framework that can safely authorise sport and recreational aircraft and pilot certificate holders to operate in the controlled airspace associated with Ballina where pilot certificate holders meet CASA specified competency standards and the aircraft are appropriately equipped.
   
5. CASA’s Stakeholder Engagement Division should conduct additional safety promotion programs in relation to Ballina operations as soon as practicable, including reinforcing the mandatory radio calls required when operating within the Ballina MBA and providing guidance for ASAOs to might develop a suitable scheme and make application to CASA for approval, under the regulatory framework identified in recommendation 4.
   
6. Uncertified aerodromes and flight training areas around Ballina should be promulgated in AIPs to increase pilot situational awareness.
   
7. As an interim action pending the completion of Recommendation 8, CASA should demand CTA around Ballina with a base which is as low as possible. ATC services should be provided during all periods of scheduled Air Transport Operations and include an Approach Control Service to aircraft operating under the Instrument Flight Rules (IFR), separation between IFR aircraft, VFR traffic information to all aircraft, and sequencing of all aircraft to and from the runway. CASA and Airservices should jointly explore opportunities to detect non-cooperative aircraft or vehicles in the immediate vicinity of the runway. The services should be established as soon as practicable but no later than 15 June 2023.
   
8. CASA should make a determination that Ballina will become a controlled aerodrome with an associated control zone and control area as soon as practicable, but no later than 30 November 2023.
   
9. CASA should prepare and finalise an Airspace Change Proposal (ACP) for a control zone and control area steps in preparation for the implementation of Recommendations 7 and 8.
   

Recommendations 1 and 2 were implemented last month and came into effect today.

The OAR report recognised the impact a Class D tower would have on recreational aviation currently operating in and around the Ballina-Byron area.

"The establishment of a CTR around Ballina may also have a detrimental effect on operations from the private airfields in the area," it notes. "The sport and recreational aircraft which operate from these airfields may require an airways clearance when the aerodrome control service is active.

"The hang-gliding and paragliding operations at Pat Morton Lookout (Lennox Head) would be affected by the declaration of a CTR due to the proximity to Ballina, approximately 2.7 nm northeast of the Ballina non-directional beacon (NDB).

"Consideration of a Letter of Agreement between the hang-gliding club and Airservices or an exemption issued by CASA may address access issues for the club.

"Similarly, RPAS operated within the 3NM of the airport would require CASA approval and coordination with Airservices."

Airservices Australia has estimated the cost of establishing a Class D tower to be $17-20 million with annual operating costs of $4-5 million. OAR has noted that industry estimates for setting up a remote digital tower to be $4-5 million.

The OAR draft airspace review report is open for feeback until 17 July and can be accessed via the CASA Consultation Hub.

Next GF gives credit where credit is due on Ballina Airspace proposal, via the UP - 

Geoff Fairless

To carry on from the thread I started, "CASA and Government mates, invent a new airspace classification!" This review is a breath of fresh air!

It is recommending what I recommended to CASA about five years ago when they sent me to Ballina to start work on authorising a CA/GRO. A CA/GRO would only add radio congestion to an already busy frequency. This was compounded by the troglodytes running OAR at the time, when they thought that a broadcast area would fix the problem. They then doubled down by making it twice the radius. (Equals four times the area contained within the circle, hence capturing even more traffic chatter) About that time they stopped inviting me to the discussions with Jetstar and others!

I'm not sure whether the trogs have moved on or whether the new CASA boss saw her public service career going down in flames, however here we are, at last!

The document describes Class E airspace above a Class D control zone, but somewhat confuses the possible with what would be nice to have. "The services should be provided during all periods of scheduled Air Transport Operations and include an Approach Control Service to aircraft operating under the Instrument Flight Rules (IFR), separation between IFR aircraft, VFR traffic information to all aircraft, and sequencing of all aircraft to and from the runway." The last few words will not be possible until runway controllers, (That is, a Tower) is in operation. The operating hours of the airspace will also require a revolution - currently Jetstar in particular, seems to prefer operating when already establish Towers are off duty.

I shall be replying to their request for comment and will publish my comments on this thread.

MTF...P2 

[Peetwo]

Airservices proposed lowering of Class E airspace on East Coast -    

Via AvSEF:

National - Proposed Lowering the Base of Class E Airspace on the East Coast

Proposal

Airservices is proposing to lower the base of Class E airspace from 8500ft to 6500ft AMSL along the east coast between Melbourne and Cairns where terrain permits.

The primary driver for this proposal is to enhance safety by reducing the collision risk between IFR aircraft through provision of separation services to IFR aircraft in greater volumes of airspace. Australia’s aviation safety system plays a vital role in ensuring a safe, efficient, and competitive aviation industry. Safety of air navigation is an integral part of airspace administration. Maintaining safety is paramount for all aircraft movements.

This proposal will ensure enhanced safety outcomes, reduced workloads for IFR pilots and greater separation assurance reducing collision risk. This change will provide greater protection to more than two million annual passengers who fly on Regular Public Transport (RPT) flights to non-towered regional aerodromes on the east coast of Australia.

Fitment of upgraded surveillance equipment for Visual Flight Rules (VFR) operators will enhance safety for their operations as well as the safety of other airspace users. Applications for the ADS-B Rebate Scheme are expected to open in August 2022. Further updates on the status of the program can be found on the ADS-B Rebate program website.

The fitment of surveillance equipment may enhance the visibility of some VFR aircraft to Air Traffic Controllers which will reduce reliance on visual “see and avoid” as the primary separation mechanism. Up to 95 per cent of VFR general aviation/recreational aircraft will be unaffected by these changes.

Leveraging Airservices investment in improved surveillance coverage through the lowering of Class E airspace will reduce collision risks while allowing for industry growth across the east coast of Australia.

This proposal, if implemented, will enhance overall safety and encourage the adoption of surveillance technology which is becoming increasingly essential to operate in today’s complex airspace. We invite industry to ask questions and provide feedback on the safety and operational impact of the proposal through the Airservices Engage website by 12 August 2022.

The resulting insights from this final engagement process will be provided to CASA as part of the ACP submission. Implementation of the proposal will be subject to the outcome of CASA’s ACP review and associated regulatory process.

Submitted by

MTF...P2 

[Peetwo]

OAR asks for feedback on Mangalore airspace draft report ? 

Via Su_Spence central:

Overview

The Office of Airspace Regulation (OAR) is now seeking industry feedback on the draft report of the aeronautical study of Mangalore.

The aeronautical study includes feedback from the survey conducted in 2021 on our Consultation Hub.

Further information about  airspace regulation and the airspace change process is available on the CASA website.

The draft review is available at the bottom of this page under the Related Documents heading. We suggest you right click and open in a new tab or window.

If you would like to provide further feedback, please email OAR@casa.gov.au Feedback submitted by email will be considered but cannot be published publicly.

Why your views matter

Why we are consulting

We are seeking feedback to understand industry and community issues, observations or positions regarding the information contained in the draft report. This may include effects on safety, efficient use of or equitable access to the airspace.

What happens next

Once the consultation has closed, we will register and review each submission received through the online response form. We will make all submissions publicly available on the Consultation Hub, unless you request that your submission remain confidential. We will also publish the final report on our website.

Information about how we consult and how to make a confidential submission is available on the CASA website.

To be notified of any future consultations, you can subscribe to our consultation and rulemaking mailing list.

Plus, via the Yaffa:

CASA publishes Mangalore Study Report

13 July 2022

CASA's Office of Airspace Regulation (OAR) today published a published a report on a study of the airspace surrounding Mangalore Airport in Victoria.

Mangalore is one of the largest airports in the state and sits in a high traffic area that also includes several other CTAFs and sport and recreational aviation areas. In February 2020, it was the site of a fatal mid-air collision between two twin-engined aircraft that were using the airspace for training.

OAR's study found that the current airspace classification was appropriate for the area around Mangalore and made only two minor recommendations following the study.

"The study found that the airspace classification remains appropriate however recommendations have been made to enhance the safety of operations within the area, through education, amending aeronautical information and opportunities to enhance situational awareness for all pilots," the report concludes.

The two recommendations are that CASA conduct a safety seminar in the area and that ERSA requirements to add 1000 feet to published data for practice approaches needs to be clarified or removed.

The OAR report also stated that documents such as the VNC and ERSA needed to be amended and updated to include more information about operations in the area.

OAR did not recommend a 20-nm Mandatory Broadcast Zone (MBZ) around Mangalore because "this will not address identified issues within the vicinity of a non-controlled aerodrome and will likely increase frequency congestion."

As well as flight training, helicopter operations and private flying out of Mangalore, the CTAF also covers parachuting at Nagambie and Euroa, gliding and powered operations at Wahring and hang gliding at several locations.

The airport is home to one of very few VOR stations left in the state, which attracts training flights that have little or no options for conducting VOR work anywhere else.

Mangalore is also at a pinch-point for pilots flying into and out of the Melbourne basin avoiding the Puckapunyal restricted area to the west and the high ground to the east.

Feedback to the CASA Consultation Hub in September last year showed that 59% of respondents considered the existing Mangalore airspace is safe or mostly safe, with 21% having no opinion either way and 19% believing the airspace as unsafe or mostly unsafe.

Respondents nomination frequency congestion as having a negative impact on situational awareness, caused by the number of aircraft operating in the area, use of non-standard phraseology and users from non-English speaking backgrounds requiring additional or repeat transmissions.

Mangalore was to have a Surveillance Flight Information Service (SFIS) operating from September last year, but it is believed that the volume and complexity of sport and recreational flying in the area prompted Airservices not to launch the service.
The full airspace study report is on the CASA Consultation Hub website, and is open for feedback until 11 August.

 
MTF...P2 

[Peetwo]

ASA to continue with YMNG SFIS; while OAR reject MBA -    

Via the Yaffa: 

Airservices to continue Safety Alerts at Mangalore

15 July 2022


Airservices ATC centre in Melbourne. A dedicated controller based there will provide safety alerting for Manglore. (Airservices Australia)

Airservices Australia will continue to provide a Safety Alerting Service (SAS) to cover Mangalore Airport after a report by the CASA Office of Airspace Regulation (OAR) failed to call for a Mandatory Broadcast Area.

Airservices established the SAS to cover Mangalore whilst the OAR completed its aeronautical study, which was published this week. The study did not support an MBA around the airport, which would have been necessary for Airservices to set-up a Surveillance Flight Information Service (SFIS) similar to that operating at Ballina-Byron in NSW.

The SAS was supposed to be an interim measure until an SFIS could start operating.

"The draft [OAR report] has determined that a MBA is not required, however, we continue to provide an enhanced service with a dedicated controller monitoring the CTAF and providing safety alerts as necessary," an Airservices Australia spokesperson told Australian Flying.

"From 0800-1800 local time, Airservices is providing a dedicated, sector endorsed controller to monitor the Mangalore CTAF 121.1 MHz from a stand-alone console within the Melbourne ATSC.

"The controller will only provide safety alerts as per AIP GEN 3.3 Section 3.5 but will not provide safety alerts between aircraft conducting circuits at Mangalore.

"The provision of FIS remains the responsibility of the Area Controller on 122.4. The CTAF Monitor's responsibility is to provide Safety Alerts on 121.1 for Mangalore when required.

"This is not a CA/GRS and Safety Alerting is already covered by AIP ...  within Class G airspace and within Airservices’ provider certificates.

"The only difference which should be seamless to pilots is that during the hours of operation of the Safety Alerting Service they will receive a safety alert if required on CTAF."

CASA has been contacted about the reasons why the MBA was not recommended.

MTF...P2