[Mr.Approach]

Houston - err nothing to see HERE??  - 

Via ATSB Aviation REPCON:

Peetwo - The staffing situation in Sydney TCU has been a problem for years. It probably started when Airservices moved all of the en-route sectors to Brisbane and Melbourne. This robbed Sydney TCU of the natural progression of controllers from their first rating and endorsement postions to terminal area positions requiring more experience and skill. (I.E. Airspace between 30 - 90 NM SYD, previously know as Arrivals  and the Approach/Departure controllers operating within SYD TCU 30NM of SYD airport.) Now Airservices has to fill the SYD TCU positions with transfers from outside Sydney. Frankly who would want to swap a pleasant control tower or modern Centre, such as Brisbane or Melbourne, for a long commute to an antedeluvian control centre at Australia's busiest airport? I think they still get paid a little more but that is probably eaten up by real estate prices and vehicle fuel bills. Airservices has tried to overcome this problem by dumbing down the management, (ATC qualifications no longer required) and/or minimising supervisory positions such as Traffic Manager (The TCU supervisor) and Flow Manager (an additional Approach Controller concentrating on manipulating aircraft routes and speeds before vectoring is required). The lack of these stress and workload relieving positions seems to be what the REPCONS are about. And, by the way do noy be fooled by Airservices comments "Our workforce plan states the mature number of ATCs for Sydney TCU is 47. Currently there are 47 operational ATCs employed at the Sydney TCU with up to 13 required to staff the TCU on any one shift." A workforce plan is simply that, a plan. It may not work very well, but it is still a plan, and easily quoted when controllers complain about staff numbers. Airservices plans are, of course, now written by and authorised by the same people who downgraded the local Risk Assessment from High to Low as quoted in one of the REPCONS. It is not how many in total are on the books, it is how many turn up on the day that matters. CASA's role should also be analysed. There are, I think, about three or four CASA ATC Inspectors, their job requires them to audit every civil ATC unit in Australia, about 25 I think. Unlike ATSB their reports are confidential and only shared with Airservices. So unless someone complains to ATSB, the public has no idea what the regulater is reporting about the service provider. To complete this arrangment, both CASA and Airservices are managed by the same Minister. At best the inspectors will do a snapshot audit at each major ATC unit once a year, others only once every two or even three years. On top of that they have to prepare a three-yearly review of Airservices to justify re-issuing the Part 172 authorisation. Can you imagine the Minister's CASA pulling the operating licence of the Minster's Airservices? No...me neither. So therein lies the relationship problem. Keep listening to the controllers. They are whistle-blowing and probably easily identified within the workforce. Civil Air can only provide some protection and ATSB is only as strong as it wants to be. Finally, what happens to a REPCON? First of all it is de-identified, see above, but then disclosed to CASA and Airservices for comment. ATSB, as far as I am aware, has no inspectors capable of investigating an ATC related issue. As far as I can tell, ATSB then moves onto the next Cessna crash, and like all the Aviation offices relies on that great safety mitigator, hope it doesn't happen here, to protect the Minister.

Staffing levels at Sydney TCU

Reporter's deidentified concern
The ATSB has received a large number of REPCON reports from Air Traffic Controllers in the past 4 months. 15 of those reports have come from Sydney. By way of comparison, REPCON has received one report relating to Sydney in the past 5 years. 

Some comments from the reporters are below:

‘I write this report, because I can no longer sit back and watch the unsafe procedures and management practices taking place at Airservices Australia, particularly in the Sydney Terminal Control Unit (TCU).
When highlighted that rules and procedures are being broken, the rules and procedures are changed with the stroke of a pen, by unqualified people, to give the appearance of compliance. Any information contrary to Airservice’s (ASA's) desired result will be omitted and disregarded’.

‘After paying 20% of the staff to retire, now everything is back engineered to achieve a final result or timeframe predetermined by management, regardless of policy or procedures’

‘I have grave concerns as to the safety of Air Traffic Control operations within the Sydney TCU... I have been an unfortunate witness to the systematic degradation of service we can provide due to the continual cutting of locally based managers, cuts to the traffic manager roll and a reluctance to try and increase the intake of controllers into the TCU’

‘Our only way out of this mess is to get more staff.  Quite frankly I am apprehensive about continuing to work’

‘I'm writing out of severe concern at the way Air traffic control is being managed in Sydney, specifically Sydney RADAR Terminal Control Unit (SY TCU). As an experienced Air Traffic Controller, I find myself struggling to articulate the seriousness of the erosion of safety measures this most pre-eminent unit of professional Air Traffic Controllers are being made to accept’

‘ATC is severely understaffed. It’s been this way, but functional for years. However, the last 3 months have been particularly bad. The Retirement Incentive Scheme (RIS) that ASA offered last year has taken us to unprecedented levels of staffing and is pushing the system way beyond its limit..’

‘The company has eroded the collective experience level of the Controllers at Sydney by paying many to leave. This has left a significant void in our knowledge base. The list of misgivings is so long it's hard to articulate. It's overwhelming the way management is mitigating away safety standards and training requirements for staff.’ 

‘This is the worst position the company has been in since I have started, over [number] years ago. The only way to fix the problem is to train more staff.  Best case this is years away from being fixed. In the interim - I honestly have no idea. Probably permanently closing airspace over night or reducing operational hours or services. Then rebuild over the next 5 years, and slowly extend operational hours and services with the correct people. The alternative is to bumble along and hope no-one flies into each other. It's just a matter of time until we stop getting lucky’. 

‘I have grave concerns that on our present trajectory Airservices will become the next Boeing, with similarities between the [Boeing 737] MAX project and the current situation uncanny. It is only a matter of time before the current practices at Airservices result in a major aviation incident. As an experienced controller, I feel I am obliged to report these matters, as ASA's internal processes seem unwilling to hold themselves accountable... Eventually the holes in the cheese will line up, and I want to have a clear conscience, that I told someone of the unsafe practices Airservices has adopted.’

‘In my [number] years on the job I can’t think of a more dangerous situation than this’.
‘I implore the ATSB to send investigators to speak directly with Air Traffic Controllers (not management) to hear first-hand what the full and dangerous picture is’. 

‘I write to you because of the grave concerns I have in the way my organisation is operating in the TCU. I have over [number] years experience and cannot believe the risk taking that is occurring around me’

‘As a Controller with limited experience outside of Controlled Airspace, I have used the Traffic Manager during the nightshift to fill the gaps in my knowledge for the parts of the operation that we may see occasionally. I strongly voiced my concern as did many others. It fell on deaf ears and now I actively try to avoid working them if possible... I do not feel safe, nor do I think we would have the capability to deal with a major emergency in Sydney if the worst were to happen’. 

‘With the Traffic Manager role removed from the nightshift, we then got word of a potential pay out for some of Sydney's older and more experienced controllers to leave before the end of financial year 2021. Many voiced their concerns at the vital role this position plays in having knowledge of all aspects of the operation in Sydney and the devastation it would cause were the numbers to be halved. Our calls for concern were disregarded and we lost 75% of the traffic managers within 9 months. We have never recovered from this terrible decision and often run complex sequences with no supervision or guidance. Our fall back is to call a Melbourne supervisor who will advise us of the best call to make. This is a shocking way to run a safety critical operation. We have continually for the last 7 months relied upon a contingency scenario to cover the holes in supervision by requiring a controller to come off an active position to man the phones and change the roles required for differing Departures and Approach set ups. A terribly short training package was arranged to conduct OCA operations in lieu of a dedicated traffic manager. I do not feel comfortable in this position, I actively feel unsafe’

The majority of the reports have already been addressed in REPCONs RA2022-00053 and RA2022-00045; however, three separate reporters have recently raised a concern regarding the absence of a flow controller and traffic manager, and the subsequent downgrading of the risk assessment for that shift.

The reporters collectively state that on 5th December 2022, the situation arose where there was no flow controller after 20:30 due to being unable to replace a vacant shift that existed. There was also no evening traffic manager due to sickness. The reporters state that the absence of these positions is an unsafe scenario, but what made this specific shift particularly concerning, was the highly probable chance of thunderstorms in the Sydney basin.

One reporter states that the absence of a traffic manager during thunderstorms is a chaotic situation; but to have no flow controller as well, makes the situation unimaginable.

The reporters state that a risk assessment was created by the incoming traffic manager, who correctly assessed the risk as High, as this ‘really is the most dangerous situation that we could possibly experience in the Terminal Control Area (TMA)’.  Another controller relayed the seriousness of the situation to the senior manager located in Melbourne.  The reporters state that the risk assessment was subsequently reviewed in Melbourne, by managers that have no ratings or experience in air traffic control in Sydney, and the risk assessment was downgraded to a 'low' rating, basically concluding that the scenario was a non-event.

The reporters collectively claim that some of the ideas were to have a shift manager in Brisbane or Melbourne interact with the Maestro system to affect a runway change should it be required when there was no flow controller.  One reporter stated that 'this is a system people outside of Sydney have no training for and no idea of the grave implications of trying to do this without the understanding of what they're doing and the chaos that results. This is a situational tool that saves controllers during adverse weather occurrences, and if not done correctly will lead to incidents, or worse'. 

Another reporter stated that 'the fact that this was considered an option shows the complete lack of understanding of what occurs in the real-world environment and highlights the unqualified nature of the individuals signing off these risk assessments'. 

The reporters all state that the impending move of the TCU to Melbourne will only further exacerbate the critical staffing levels and will result in the loss of the limited experienced Sydney controllers that are left.

The reporters are seeking an urgent review of:

• the air traffic control service that can be provided at Sydney based on the current staffing structure. 
  
• the procedures, including risk assessments, associated with reduced staffing levels in the Sydney TCU; in particular, the absence of flow controllers and traffic managers.
  

Named party's response
Airservices appreciates the opportunity to respond to the concerns raised in the REPCON and provide the context regarding operations in the Sydney Terminal Control Unit (TCU).

Sydney TCU Staffing

The reports imply that the Sydney TCU does not have sufficient operational Air Traffic Controllers (ATC) to provide the necessary service. This is not correct. Our workforce plan states the mature number of ATCs for Sydney TCU is 47. Currently there are 47 operational ATCs employed at the Sydney TCU with up to 13 required to staff the TCU on any one shift.

Further, in June 2022, the Civil Aviation Safety Authority (CASA) undertook a surveillance event of the Sydney TCU and did not raise any findings against Civil Aviation Safety Regulation (CASR) 172.110 in relation to ATC staffing at the Sydney TCU. The CASA did raise a finding against CASR 172.115 in relation to supervisory personnel and we continue to work to address this, however, there have been a number of resignations and transfers that has affected the staffing on the Traffic Manager and Approach position. These staffing changes have not affected capacity for Airservices to provide safe and efficient air traffic management services at the Sydney TCU. These resignations and transfers are a normal part of roster management for Airservices and we are actively recruiting to backfill the departures.

Management of late-notice, unplanned absences

While Sydney TCU has the required number of staff, as with all organisations both within the aviation sector and broader economy, Airservices has experienced higher levels of staff unavailability due to COVID-19, influenza and other related sickness. This is resulting in occurrences of late-notice, unplanned absences that cannot be covered due to duty-time and other issues. As a result, there has been increased overtime shifts worked by some ATCs, but these are in line with pre-pandemic overtime hours worked.

When we are unable to cover the unplanned absences, we implement various traffic management procedures culminating in the TMA ATS Contingency Plan, ATS-CP-0085. The procedures allow the TCU to continue to provide services where the Traffic Manager/Shift Manager and/or Flow Controller is not available with different numbers of staff after implementing the mitigation actions contained within the procedures. These are safe and internationally recognised procedures that have been followed for many decades at the Sydney TCU without incident.

In addition to complying with the Contingency Plan In accordance the National ATS Administration Manual (NAAM), ATS-MAN-0013, requires that the Air Traffic Management (ATM) Director must complete a risk assessment where staff availability may result in a variation to the service level. In undertaking the risk assessment, the ATM Director may seek input from the Traffic Manager/Shift Manager. However, the responsibility for completion of the risk assessment sits with the ATM Director and the risk level associated with the situation determines who can accept the risk.

Each time the contingency Plan is activated there is a requirement to conduct a Post Activation Review (PAR). The PAR is used to identify areas for improvement in the procedures and the need to address unforeseen circumstances.

Airservices acknowledges the challenging environment in which we currently operate, however, the safety of air navigation is our primary consideration and we will not compromise on that. In situations where staff availability is reduced we enact robust procedures which ensure safety is maintained.

Regulator's response
CASA provided in response to RA2022-00045 that in June 2022, CASA conducted a surveillance event at the Sydney Terminal Control Unit (TCU) and identified number of safety observations and safety findings related to the reports with this REPCON. One finding raised was against Civil Aviation Safety Regulation (CASR) 172.115 in relation to supervisory personnel, which remains open.

Additionally, CASA has undertaken associated surveillance which identified the potential for issues with compliance with CASR 172.110 in relation to the obligation to have a sufficient number of suitably qualified and trained personnel to provide Air Traffic Services for each service it is approved to provide, CASA continues to work with the service provider on their planned actions to rectify non-compliance with CASR 172.115. 

CASA notes ATS-CP-0085 was amended by TLI_22_0308 in late December 2022.

MTF...P2