[Peetwo]

RAOz up on criminal charges??

Via Oz Aviation:

Aviation body to face criminal investigation following fatal crash

written by Naomi Neilson | March 10, 2025



Recreational Aviation Australia has been referred to the Victorian Director of Public Prosecutions for allegedly withholding key documents from a coronial investigation into a fatal light aircraft crash.

Recreational Aviation Australia (RAAus) will be investigated by the Civil Aviation Safety Authority and the Victorian Director of Public Prosecutions for the alleged behaviour of key personnel during an investigation and inquest into the death of Matthew Farrell.

Neither Farrell or his light sports aircraft, a Jabiru J230-C (similar aircraft pictured), were equipped to fly into cloud, but he made the decision to venture into poor weather conditions to visit his father on 18 September 2022.

Farrell was airborne for 40 minutes before the aircraft crashed into remote and mountainous terrain in Victoria’s north-east.

By the time of the fatal crash, Farrell had 14.7 hours of flight training, but just 3.6 hours was solo. Of that solo training, 3.3 hours was completed on a single day and he was tested on 22 landings.

Among his many concerns, Coroner Paul Lawrie said it “beggars belief” Farrell – as a student pilot – could be “trained effectively to certificate standard in all the above aspects of flying in one day”.

Over one-and-a-half days, RAAus’ head of flight operations, Jillian Bailey gave often “combative” evidence about the validity of Farrell’s recreational pilot’s license and cross-country endorsements.

Bailey claimed she had no concerns regarding the extent of training or experience underlying Farrell’s cross-country endorsement, and did not consider auditing his trainer as a consequence of the crash.

Plus the UP spin off thread, from that update... Raa aviation body to face criminal investigation following fatal crash

KRviator

It isn't that RAAus is being made a scapegoat. No self-respecting fair-weather pilot would do what Farrel did, so RAAus is in the clear there. The extra flight training wouldn't have made a material difference to his actions that day, judging by (accurate) reports on his attitude & risk appetite.

RAAus is in the #### because they lied to the Coroner. Then, from what I can read into the Coroner's report, they lied about lying to the Coroner and the presiding judge is a trifle miffed about that. And rightly so.

Finally on a different subject I note that GlenB is back:

glenb

Why would the Cohort mislead that it was "sold"

WHY WOULD THE CASA COHORT MISLEAD THE OMBUDSMAN INTO FORMING THE VIEW THAT I “SOLD” THE BUSINESS, WHEN TRUTHFULLY CASA CLOSED THE BUSINESS DOWN

The CASA Cohort misled the Ombudsman into believing that I "sold" the business, rather than recognizing that "CASA closed the business." This misrepresentation likely served multiple purposes, all aimed at covering up misconduct or preventing me from obtaining justice.

If CASA closes a business, they have specific procedures that must be followed to ensure procedural fairness, an appeals process, and adherence to administrative law. By misrepresenting that I sold the business, it appears as a commercial transaction, negating the need for an appeals process.

These two scenarios—an owner selling their business versus having it closed by CASA—require very different approaches. I am confident that the CASA Cohort successfully misled the Ombudsman, concealing the fact that CASA did not grant me the procedural fairness I was entitled to, thereby covering up associated misconduct. CASA operated outside its own procedures in cancelling, changing, or varying a previously issued approval.

Each of the involved CASA employees is fully aware of the proper procedures for closing a business and knew that these were not followed in my case. By falsely representing that I sold the business, they concealed the truth. It should be clear that CASA closed my business, yet there remains significant confusion within the Ombudsman’s office after six years.

This confusion, engineered by CASA, can be resolved through witness testimony. Misleading the Ombudsman to believe I sold the business served several purposes. It implied I received compensation, which was not the case, and obscured the reality that CASA closed my business down on June 30th, 2019.

This can be easily proven. I had an interim approval to operate that extended only to June 30th, 2019. If I was able to continue after that date CASA should be able to produce the document that permitted me to continue operations on the morning of July 1st, 2019, if such a document exists.

For clarity I assert that the CASA Cohort misled the Ombudsman into forming the view that the business was sold to conceal that fact that CASA closed down my business, and in misrepresenting it as a Sold business it concealed the fact that CASA had not adhered to their own stipulated procedures in their manuals when they close down a business.

Those procedures are intended to ensure that the affected person is afforded procedural fairness.

The entire five-year Ombudsman investigation made no assessment against CASAs own stipulated procedures in their manuals when they close down a business.

My expectation was that an Ombudsman investigation would have commenced with an assessment of the procedures CASA followed against the stipulated CASA procedures and any anomalies would be identified and addressed.

It appears that no assessment against these procedures was ever made throughout the investigation.
With the documents that I obtained under FOI that clearly indicate that the Ombudsman was misled into believing that I “sold” the business it has become clear that the Ombudsman made no assessment because the Ombudsman mistakenly formed the view that the business was sold., when it most clearly was not “sold” it was closed down by Mr Aleck.

MTF...P2

[Kharon]

“Among his many concerns, Coroner Paul Lawrie said it “beggars belief”

Australian Aviation author Naomi Nieilson has (at last) shone a small, but significant light on an event which could bring some significant changes to the RAAus three ring circus. In the center ring we find the Victoria Coroner and his findings into an event which claimed one life and an aircraft. The 'report' may be found and read -HERE-. I suggest starting at about 'item 127' and going through to about the high mid 200 series. Only my opinion from here – but the Coroner has (I believe) seen, ruled on and eloquently elaborated many of the 'private' concerns many have held since RAAus inception.

While the spotlight is on the centre ring, the Coroner remains without the support part of his troop. The research offered to support his findings is 'narrow'; there exists some 'complexities' which, being fully understood and scrutinised, could have presented the authorising body (CASA) with some fairly curly questions to answer. The probity of the RAAus answers to some questions has been allowed to 'slide' around the details related to the event pilot which, once again could have provided a more 'positive' set of findings and brought in the changes required to prevent a recurrence of what was almost a perfectly preventable event. But this was no 'accident' i.e. ” unexpected event, typically sudden in nature and associated with injury, loss, or harm”.

Given the publicly acknowledged 'nature & demeanor' of this pilot, some form of 'event' was more than likely; there was nothing 'sudden' about the event; the forecast was there, the weather conditions were clearly visible; the act of persisting into unfavorable conditions was deliberate. The 'question' for our Coroner is how was this person authorised to conduct the flight? How, is a bloody good question.

Should Ms. Neilson, CASA or the Coroner be 'interested' in ripping the artful 'band-aid' off this boil, I suggest (humbly) that they begin 'at the beginning', with some basic, difficult questions.. For example:- from Coroners para 31 - on (interesting).

“Mr Farrell had 257.5 hours of paragliding experience.”

TO SUCCESSFULLY ACHIEVE THE SAFA PG2 LICENCE, YOU WILL NEED TO ACHIEVE THE FOLLOWING:-

Minimum of 6 flying days.
Minimum of 30 flights (launch & landing) from at least 3 different flying sites.
3 soaring flights of at least 15 minutes duration OR 10 flights of at least 5 minutes duration.
1 high flight of above 500ft.

Vic ?@ p 33 =  "Mr Wood applied for Mr Farrell to be issued a Converting Pilot RPC for Group A (3-axis) aircraft on the basis of his paragliding experience and claiming flight training of 11.1 hours dual and 3.6 hours solo flight time in Group A aircraft."

Aye, all well and good until you try to decipher the tangled mess within the RAAus 'accepted' Operations Manual. It is a horrible buggers muddle (and I am qualified to say that); however; always remember that Farrell wanted a 'Class A' RPC for three axis aircraft.

Class A  3 axis aircraft (E.g. Jabiru). 
Class B weight shift.
Class C Combined control.
Class D powered para .

The individual (tailored) 'training' and 'testing' required depended on the basic level and type of experience presented. For example the holder of a CASA Recreational Pilots License (RPL) on VH aircraft can, with very little 'training' be granted a RAAus equivalent, having ticked all the CASA boxes. Farrell only had a background in 'Paragliding'. The 'manual' is difficult to navigate even for experienced RAAus instructors; so, if the following is incorrect I appologise; but, it does seem to me to be the 'right' road toward what Farrell wanted was avoided; or, at best mapped in error. With only 'paragliding' on the record; to qualify for a Recreation Pilot Certificate (RPC) to operate 'Cross Country' - in a three axis aircraft; the following criteria must be satisfied:-

“Minimum 10 hrs dual cross country /-2 solo cross country/examination/  +1 test flight for 3 axis Class A aircraft.”

I may well have that wrong – the manual is confusing; and I can easily imagine how an instructor (any instructor) could confuse the 'qualifications' presented against the 'requirements' of the manual. Again, if wrong I appologise.

The Coroner is IMO righteously miffed; the sin of attempting to varnish over an error is likely to create more anger than the 'sin' itself. IF (big one) the instructor was led astray and if the manual confused him as much as it did me (on one read) then the forgivable 'error' issuing of a certificate for navigation without the required training is much less heinous than trying to baffle the Coroner with Bull-shit and convoluted operating manual 'allowances'.

Mistakes happen; the 'system' utilised should be as bullet proof as possible; as simple as possible and as complete as possible. For example; had the manuals been constructed to 'classify' the presented 'experience' : say a Class D pilot (powered para gliders) then, the training and qualifying course should immediately follow that experience; fill in the 'gaps' and get the job done in one fell swoop. As you qualify as 'Type D' these are your minimum training requirements and the modules to complete them. End of...........

IMO, the performance in the Coroners court will/ can only produce more restrictive practices. RAAus should get ahead of the game; sort out the internal operational mess and show CASA and the Coroner that the 'errors' have been rectified. 'A stitch in time saves nine?

Apologies for Errors and Omissions etc. But. like most events, this was preventable (almost). Sometimes – Shit happens…....

Toot – toot.

[Peetwo]

CASA FOI (non-) Disclosure Log Update?? - 

In recent times CM and I had noticed that CASA FOI disclosure log had not been updated since around about July 2024. We also had the concern that the CASA FDL had changed its published format to no longer include links to the 'publicly' released documents - courtesy CASA FDL:

Removal of CASA FOI Disclosure Log Hyperlinks - 26 August 2024 - All emails and other internal correspondence, meeting minutes or other notes taken, relating to the decision to remove, and the implementation of the decision to remove, from the CASA FOI Disclosure Log, hyperlinks to copies of documents disclosed by CASA pursuant to the FOI Act. Partial Release - s47F

---

Enquiry
I note that the CASA FOI Disclosure log has recently been updated (from 6 March entry onwards) and reformatted.

Unfortunately the new format does not include links for the FOI publicly released documents and has omitted the previously released (prior to 26 February entry) PDF weblinks . In case this is an administrative oversight issue, would it possible for all the new entries to have their released documents PDF web linked?

If this is for some reason not possible, could you at least release the documents for the 6 March 2024 entry: " Reports relevant to CASA's restricting of technical staff since 2010; 2021 CASA APS Employee Census Results; 2023 CASA APS Employee Census Results; Psycho-social safety climate survey conducted by University of South Australia in 2019 for CASA; The Internal Audit Report EAP - Enterprise Aviation Processing; and the most recent interim ICAO report on CASA. Exemption(s) applied: Full release..",

Thank you in advance

P2

Maybe due to some of our protagonist activities, recently the administrators of the CASA FDL started to update and catch up with the CASA FDL back log - see HERE minus the hyperlinks.

Curious about some of the FDL entries I requested copies of what should now be publicly available documents. Finally after a month I got this reply:

OFFICIAL
CASA Ref: F25/1749

Dear P2,

I refer to your email of 10 February 2025, requesting access to the following documents that are published on CASA’s FOI Disclosure Log webpage:

Requesting copies of documents released under disclosure log entries:
1. F25/374 - CASR Part 43 and ICAO Annex 6 5 - February 2025
2. Surveillance and Safety Reports for N619SW (Boeing 737-3H4) -24 December 2024
3. CASA documentation regarding accident that took place on 4 July 2020 in Broome, WA - 2 July 2024
4. CASA advice to the Department of Infrastructure regarding Moorabbin Airport. - 28 June 2024

Please find attached the documents you have requested.

I apologise for the delay in providing you access to these documents.

Kind regards,


Amy George
Freedom of Information Officer
Advisory Section
Legal Services Branch
CASA – Legal, International and Regulatory Affairs

13 17 57
GPO Box 2005 CANBERRA ACT 2601
www.casa.gov.au

Anyway for those interested here are AP links for those released FOI documents:

1. https://auntypru.com/wp-content/uploads/...-FINAL.pdf
2. https://auntypru.com/wp-content/uploads/...cument.pdf
3. https://auntypru.com/wp-content/uploads/...-FINAL.pdf
4. https://auntypru.com/wp-content/uploads/...uments.pdf

 Hmm...creating hyperlinks, that took me all of about 2 minutes...  

MTF...P2   

PS: Please bombard Handy Andy and his minions with multiple requests for FDL documents...

[Peetwo]

April CASA BOLLOCKS: WTF? - Su_Spence reinvents SRPs...  

Via casa.gov.au:

Director of Aviation Safety, Pip Spence

Information is the lifeblood of today's world but it is particularly vital to safety-critical industries such as aviation.

Our industry has long mined the rich vein of data provided by aircraft and other systems to improve areas such as predictive maintenance, real-time monitoring, navigation and communication.

We've all read about how the vast amounts of data generated by modern jetliners have improved safety and costs by allowing operators and manufacturers to monitor aircraft health and address potential failures before they occur.

The need to collect and utilise data is also an imperative for modern regulators and we've been working to ensure Australia is ahead of the curve in this important area.

One way we're doing this is through our world-leading Airspace Risk Management System (ARMS), a computer-based quantitative risk modelling tool that is important to our oversight of, and our decision making in relation to, airspace that's attracting international interest.

Operational for about 3 years, ARMS allows us to use data to help inform our decision making rather than relying solely on a more subjective manual process.

Subject matter expertise remains an important part of the mix but by itself does not provide a complete risk picture. By its nature, it will always contain an element of subjectivity whereas a computer-based quantitative model is free from bias and gives us another perspective.

ARMS also replaces manual processing with automation that is quicker and more cost-effective.

Combining both analytics and human experience strongly increases our ability to make well-informed decisions around aviation safety.

ARMS determines risk by analysing the behaviour of air traffic - what aircraft are actually doing within airspace and how close they get to each other.

This means looking at variables such aircraft movements, aircraft types and speeds.

Crunching these numbers not only assists us with major airspace reviews involving bigger strategic pictures, such as the Pilbara and Ballina, but also allows us to tactically monitor specific locations.

If there's an aerodrome we think requires safety investigation, but we’re not sure, we can run an ARMS assessment to determine if further action is required.

We can also use the system to identify locations that may benefit from a safety review but which might not have been considered previously.

Although a big step forward, ARMS is still relatively new and continues to evolve as people use the system and identify additional risk modelling capability and we get access to more data.

Australia’s leading approach in this area has already attracted interest from our overseas counterparts and we have demonstrated ARMS to several national aviation authorities, including those from Canada and New Zealand.

ARMS is one of several areas where we’re building our data analysis capability, as well as improving transparency around our operations.

Over the last 18 months we have been publishing the data we on how long specific applications take to process, which we hope will help you understand what to expect.

The information we collect in our National Oversight Plan will be analysed and used to inform future decisions based on risk.

And as I’ve previously mentioned, we’re now publishing safety sector risk profiles (SSRPs) on our website for various sectors of the aviation community.

SSRPs group operators conducting the same or similar activities and identify current and emerging aviation safety issues, hazards and risks specific to each sector.

Our first SSRP meeting for 2025 took place with the business aviation sector in February and provided a valuable platform for operators and agencies to discuss the issues and risks business aviation is currently facing.

Data has always played a critical role in aviation safety but we believe programs such as ARMS and SSRPs will allow us to further harness the power of trends and statistics to make us all safer and better informed.

All the best,

Pip 

Hmm...SSRPs? Would that be like the SRPs that was originally vogue back in about 2013-2015 and especially when Skidmore was the CEO?

From 06:06 min:

And:

• Sector risk profile for the aerial mustering sector (PDF 416.62 KB)
  
• Sector risk profile for the aerial application sector (PDF 583.67 KB)
  
• Sector risk profile for the aerodrome sector (PDF 1.24 MB)
  
• Sector risk profile for the small aeroplane transport sector (PDF 911.92 KB)
  

 Hmm...but of course the Pup_Spence initiative is more techy and new age inspirational - FFS?? 

Extra hmm...funny how the Kiwis don't refer anywhere in their SRP methodology to the wonderful Ozzie ARMS:

Sector risk profiles

We monitor aviation safety performance and risk in line with international practice.

The risk profile we create for a sector will include:

the knowledge, experience, and perceptions of the sector
evidential data.

Profiles are sector-based because, while something like power lines might be a risk to agricultural operations, they're less of a risk to airlines.

How are sector risk profiles used?

Sector risk profiles help us target our actions and resources, but some risks are beyond our influence.

Their greatest value comes from the sector understanding and minimising the risks it faces.

Learn more about sector risk profiles in the video below:

About SRP projects

The approach

We'll engage the industry through workshops and surveys, identifying hazards and risks relevant to the sector. Further engagement between industry and we will identify risk owners and possible controls and treatments. This work will culminate in a treatment action plan that will assist ongoing continual improvement in safety of the sector.

Wider stakeholder engagement

In addition to Air Operator Certificate (AOC) holders, there are many stakeholders in the industry and the wider community with whom engagement is essential to a successful sector risk profiling exercise. We will work closely with these stakeholders to identify and understand the risks to the sector.

Safety benefits

The safety management system (SMS) rules require organisations to proactively identify hazards and associated risks, and then manage those risks to ensure the safety of their operations. The information gathered for the SRP will further support participants in determining which risks are relevant to their organisation and include them and any treatment in their day to day SMS.

Developing a SRP is also a valuable means of addressing some key safety issues that the Authority considers to be a priority for aviation in New Zealand, such as: loss of control in flight; runway excursions; airborne conflict; and Queenstown operations.

The SRP will support and enhance our risk-based approach to safety oversight. The risks identified through the SRP can be used to inform our future certification and surveillance activities, ensuring efficient and effective focus on areas of higher risk. The risks identified through the SRP may also provide an opportunity to initiate and inform 'theme-based' initiatives to improve sector safety.

MTF...P2

[Peetwo]

Request For Change - YCTM - RWY 34

Courtesy CM, via AP emails:

Hi Pip and Jonathan

I’m writing to you, directly, in an attempt to bring to an end some unnecessary risks created by CASA at Cootamundra aerodrome (YCTM). All it would take is the deletion of some words from ERSA, but that ostensibly simple outcome has proved difficult to achieve for a protracted period.

Subsequent to correspondence with CASA, the latest of which occurred on 25 March 25 (below), I have found out that the change to right hand circuits during hours of daylight (HJ) on runway (RWY) 34 at YCTM was the result of a thought bubble on the part of a CASA aerodrome inspector, Mr Iain Bailey. Mr Bailey apparently decided that the change was justified because of his perception of the risk of, and his perceptions of the consequences arising from, different pilots coming to different conclusions as to whether it is HJ or HN (hours of night) at the same location at the same point in time.

I bring to your attention the following points about that perceived risk and its perceived consequences, and the reality, all of which should have become obvious if a proper risk assessment had been conducted by competent persons before the change was made at YCTM.

First, the probability of pilots coming to different conclusions as to whether it is HJ or HN at the same location at the same point in time is remote, particularly so in the 21st century. The information is now literally at pilots’ fingertips via an EFB.

That remote probability then has to be multiplied by the probability of those pilots arriving in the same circuit area at the same time, then multiplied by the probability of those pilots being unaware of each other in the vicinity of a certified aerodrome in the vicinity of which carriage and use of serviceable radios are therefore required, all of which results in a very remote risk.

And in the event of that very remote risk becoming reality and even assuming the pilots choose to do a circuit for the same runway rather than a straight-in approach, which straight-in approach they can now do, irrespective of the mandated circuit direction, the outcome at YCTM – prior to the decision resulting from Mr Bailey’s thought bubble – would be that they end up on downwinds on opposite sides of the runway. One would be on a right downwind for RWY 34 (that pilot believing it’s HN) and the other would be on a left hand downwind for RWY 34 (that pilot believing it’s HJ), thus separating them by a substantial distance.

Then that very remote risk must be multiplied by the probability the pilots not seeing each other during their respective downwinds, nor during their base legs when they are ‘head to head’ at slow (flaps extended) speed. At least one of them thinks it’s HN, so at least one aircraft’s landing lights and strobes are on. (Or do we add ‘forgetting to turn on the landing and anticol lights’ and ‘failure of the landing light and anticol lights’, to the list of remote risks?)

All the while, the pilots are apparently oblivious to whether it is, in fact, HN or HJ where they are, in fact. Looking out the window has somehow escaped, or is been avoided by, the pilots.

All of those probabilities multiply to an infinitesimally small risk, which infinitesimally small risk is obvious to most pilots with a modicum of experience, including all of the pilots with whom I’ve discussed this issue. Our combined aeronautical experience adds up to centuries and tens of thousands of hours.

I understand Mr Bailey has around six thousand hours of ‘commercial experience’. However, I also understand that he has not flown as pilot in command at all in the last six or so years. I suggest that Mr Bailey may have either forgotten some of what he learnt during that commercial experience, or that his experience didn’t include many hours operating in and out of non-towered aerodromes around the end of civil daylight. I’m happy to stand corrected, of course.

I am not aware of any recorded accident or incident caused by pilots coming to different conclusions as to whether it is HJ rather than HN or vice versa at the same certified non-towered aerodrome at the same point in time. I would therefore welcome and read with keen interest any report of an investigation of that kind of incident.

Also obvious to experienced pilots are the risks created by CASA’s decision resulting from Mr Bailey’s thought bubble (even setting aside the infringing obstacle issue, to which issue I will return).

The first of those risks is that in circumstances of zero-to-little wind, it is possible - and common - for pilots to choose different runways. If one pilot chooses to use and join downwind for RWY 16 at YCTM and another chooses, at the same time, to use and join downwind for RWY 34, the outcome of Mr Bailey’s thought bubble is a high risk scenario: aircraft joining opposite downwinds ‘head to head’ at high speed, each being a stationary speck in the other’s windscreen. One is joining a right hand downwind for RWY 34 and the other is joining a left downwind for RWY 16. That risk would not arise if the circuit direction for each RWY were the ‘default’ left hand. It is true that there is a remote risk that the aircraft in this scenario would end up landing ‘head to head’, but in that event they end up at low speed on the runway before the potential collision. More time to ‘see and avoid’, and less damage if they don’t.

If the legitimate mitigators for that risk are the use of radio and see and avoid, they are legitimate mitigators for the risk arising from pilots coming to different conclusions as to whether it is HJ or HN at the same location at the same point in time. However, the substantial difference is that the probability of different pilots choosing different runways in circumstances of little-to-no wind is not remote whereas the probability of pilots coming to different conclusions as to whether it is HJ or HN at the same location at the same point in time is remote. The decision resulting from Mr Bailey’s thought bubble has therefore created at least one new risk with greater probabilities than the one perceived as justifying the change.

The circumstances which justified the imposition, decades ago, of the right hand circuit requirement HN on RWY 34 at YCTM have changed substantially. In fact, the circumstances have changed such that there is increased risk in right hand circuits on RWY 34 at YCTM HN (as well as HJ). This should have been identified in a proper and competent risk assessment.

There is no longer a ‘commuter airline’ operating noisy piston twins out of YCTM. They’re decades gone. The number of movements each night at YCTM can now be counted on the fingers of one hand, and usually on one finger of one hand or no fingers at all. Further, the few HN movements almost invariably involve a straight-in approach, because it is no longer mandatory to fly three legs of a circuit. (My first take-off and landing as a pilot at YCTM was 39 years ago. I now live in and operate out of YTCM, and monitor the CTAF and area frequencies. I know of what I speak.)

The absence of night movements is why the current operator of YCTM, the local council, has not expressed any concern about night time air traffic noise in the vicinity as would justify right hand circuits HN on RWY 34 on noise abatement grounds.

Further, and more importantly, the tallest and closest of the infringing obstacles in the vicinity of YCTM – the telecom tower – was erected after the imposition of the right hand circuit requirement on RWY 34 HN. It is on a bearing of 137 degrees magnetic at a distance of 2,411 metres from the ARP, and infringes the HZS by 185 feet. Only a little further away and not too much shorter is a radio tower on a bearing of 138 degrees magnetic at a distance of 2,457 metres from ARP, which tower infringes the HZS by 146 feet. Both of those obstacles are under or close to the right base leg for RWY 34. There are no infringing obstacles under or close to the left base leg for RWY 34. (At least my original REPCON on this issue apparently precipitated an overdue survey of the terrain and obstacles in the vicinity of YCTM.)

Those infringing obstacles pose little material risk HN, first because of the lack of traffic noted above, secondly because of the use of straight-in approaches by what little traffic there is, again as noted above and, thirdly, because the obstacles are illuminated and, therefore, very easy to see at night. Nonetheless, it is important to note that the removal of the requirement for right hand circuits HN on RWY 34 would move the tiny amount of traffic that might fly a circuit HN away from the only infringing obstacles in the vicinity of its base leg to an area where there are no infringing obstacles.

Mr Bailey apparently takes a different to view than I do, and a different view to every other experienced pilot with whom I’ve discussed the issue, as to the difficulty of spotting obstacles on the ground from the cockpit in the air HJ. It is true that the tallest and closest of the infringing obstacles in the vicinity of YCTM is really easy to spot from the ground during the day. The next closest obstacle is a little more difficult to see from the ground, but still obvious if one knows where to look. And the lights on their tops make them really easy to spot at night.

However, unless one knows that the obstacles are there, they can be difficult to spot during the day, depending on where the sun is, what the cloud conditions are and the way in and direction from which aircraft join the circuit. Further, it is impossible to see anything through an engine cowling or wing. (I’ll stand corrected on the last point if you inform me that Mr Bailey has x-ray vision.)

Further still, lots of pilots will assume – reasonably I suggest – that no competent safety regulator would deliberately make or allow circuit arrangements so as to concentrate descending traffic near the only infringing obstacles in the vicinity of an aerodrome, when an available alternative is the ‘default’ left hand circuits that would result in descending traffic

nowhere near any of the obstacles. (Though I do note that if any right hand circuit is justifiable on any valid grounds at YCTM, it would be on RWY 28. That would not only take its descending base away from the only infringing obstacles, it would also move the only runway downwind leg that is currently above the Cootamundra township to above farm paddocks instead.)

The pilot of a ‘low-performance aircraft’ doing a 500’ circuit, in accordance with CASA’s published guidance, in an aircraft fitted with an altimeter with VFR tolerances, would, I suspect, be surprised and perturbed to learn that someone in CASA decided it is okay to put the pilot on a potential collision course with infringing obstacles on a descending right base for a RWY, when there would be no potential for a collision with any infringing obstacles during a left base for that RWY. YCTM has an elevation of 1,110’. The top of the closest and tallest obstacle is under or near the right base leg of RWY 34. The radio tower nearby that obstacle is more difficult to see and only 41’ shorter. A ‘perfect’ 500’ above YCTM is 1,610’. That’s less than 200’ clearance above the top of tallest obstacle at 1,435’. And the aircraft’s altimeter could be up to 100’ wrong. That’s less than 100’ clearance above the tallest obstacle. And the aircraft could be descending.

Assuming I’m wrong about the difficulty in spotting the obstacles from the air HJ, and the obstacles are, in fact, obvious to all pilots in all circumstances, it does not follow that the obstacles do not pose any risk in any circumstances. Further and in any event, there is no logical or safety-based reason for concentrating traffic anywhere near those obstacles when there is a safer, available alternative in the form of left hand circuits.

What’s happened at YCTM is like prescribing a mandatory navigation route, for ships, across the shallowest water in a harbour, when the route could just as easily be across deeper water. It’s patently – I’m struggling for an adjective usable in polite correspondence, so I’ll opt for – silly.

There is a safety-based reason for the ‘default’ circuit direction being left hand, the corollary of which is that requiring right hand circuits entails, in and of itself, increased risk compared with left hand circuits. Many fixed wing aircraft have two seats in the front, and in most cases the pilot in command of those aircraft sits in the left hand seat. Left hand circuits give the pilots a better view of the manoeuvring area compared with right hand circuits. That is why Part 139 MOS says PAPI should be on the left side of a runway. That is why Part 139 MOS says a threshold wind indicator should be on the left side of a runway.

And those circumstances, among others, are why there should be a safety case supported by a risk assessment carried out by competent people, demonstrating that the reduction in safety inherent in a change to right circuits is outweighed by other considerations, before any decision to change to right circuits is made. My FOI request for access to documents relating to the change at YCTM did not result in the disclosure of any credible safety case or risk assessment in support of the change.

I note that there are many aerodromes at which the circuit direction HN is different to the circuit direction HJ. That fact is expressly acknowledged in CASA’s own advisory material. AC 91-10 v1.3 dated January 2025 notes at page 26:

“At many aerodromes, the circuit direction at night is different to the direction during the day. This is generally because of terrain, obstructions or noise abatement.”

If the potential for different pilots to make different decisions about when it’s HJ or HN at YCTM created risks so great that it justified the new risk of head-to-head downwinds HJ as well as concentrating descending traffic over the only infringing obstacles in the vicinity at YCTM, it would surely follow that the potential creates an unacceptable risk at all other non-towered aerodromes where the circuit direction HN is different to the direction HJ. Yet CASA has approved and is continuing to allow those circumstances to continue at many aerodromes. I am confident that those circumstances have been approved and continue because, among other reasons, the risk perceived by Mr Bailey is infinitesimally remote.

The outcome of CASA’s decision to require right hand circuits HJ on RWY 34 at YCTM is to create unnecessary risks, all of which could easily be avoided by a return to the simple, default rule which has a substantial safety basis. But I now learn that CASA expects to be provided with a risk assessment and justification before CASA will undo its decision. When the operator of the aerodrome issued a NOTAM in an attempt to undo the risks created by CASA, CASA quashed the NOTAM. This is Alice In Wonderland stuff. But pilots like me are put at risk in the real world.

CASA, alone, created unnecessary and avoidable risks at YCTM. And CASA, alone, is now prolonging the existence of those unnecessary and avoidable risks. You are now on actual notice of the circumstances.

Please just get some competent CASA officer/s to arrange for the deletion of a few words from the ERSA entry for YTCM, so as to clean up a mess created by CASA. Please.

I will be submitting another REPCON to ATSB on this issue because it is all a product of CASA’s corporate incompetence.

Regards

Clinton

MTF...P2