Sunny Coast shows up aviation safety bollocks - 
Via 20/20 inquiry submissions page:
45 Flight Path Forum Inc (PDF 797 KB)
Executive Summary
Flight Path Forum (FPF) is an incorporated community association formed in 2019 in response to a
failed consultation process by Airservices Australia in relation to changes to airspace and flight paths
to support operations forum runway 13/31 at Sunshine Coast Airport.
Since April 2019, FPF has focussed on researching many aspects of the Civil Aviation Safety Authority
(CASA) and Airservices Australia’s (ASA) ’s environmental and risk assessment processes for changes
to airspace and flight paths., including regulatory frameworks and national operating standards and
most importantly engagement between the two agencies on these issues. Concerns over the
assessment process for environmental risks to aviation safety have arisen and FPF believes it
necessary to set before the Senate Inquiry the full context of the particular circumstances
surrounding new airspace and flight path designs for runway 13/31 at Sunshine Coast regional airport
and to call for an immediate review of the Civil Aviation Safety Authority’s (CASA) aviation safety
management functions and aviation safety frameworks.
Whilst FPF appreciates the current inquiry is mainly focussed on Australia’s general aviation industry,
decisions made by CASA in conjunction with other relevant Australian Government agencies, in this
case ASA, in relation to airspace changes and new flight paths have had a ripple effect on the safety of
general aviation operations occurring in the vicinity of Sunshine Coast Airport (SCA).
As the safety regulator for Australian airspace, every decision CASA makes in relation to airspace
changes, to accommodate flight paths for Regular Passenger Jet (RPT) aircraft, has the potential to
create a knock-on effect for all airspace users including general aviation (GA) operators and it is for
this reason FPF now presents this submission as a ‘related matter’.
CASA’s engagement with ASA, on the issue of aviation safety, is of particular concern in the case set
out below. FPF is of that view that any Inquiry related to aviation safety frameworks and relative risks
must consider the circumstances that have recently unfolded on the Sunshine Coast...
From pg 9/...
...ICAO’s Risk Management framework articulates the following process for risk assessment:
• Identify the risk
• Evaluate the consequence of the risk eventuating
• Determine the likelihood of the risk occurring
• Determine acceptability of risk
• Either accept the risk or act to mitigate the risk
It appears that neither CASA/OAR or ASA have undertaken any of the above in relation to
safety conflicts between bird strike, blasting operations at KRA 54 and the proposed new
approach and departure routes for 13/31 other than the final point, to accept the risk. This is
a failure of process.
ICAO also articulates the following risk mitigation strategies:
a) Exposure Avoidance. The risky task, practice or operation or activity is avoided
because the risk exceeds the benefits.
b) Loss reduction. Activities are taken to reduce the frequency of unsafe events or the
magnitude of the consequences.
c) Segregation of exposure (separation or duplication). Action is taken to isolate the
effects to the risk or build in redundancy to protect against the risks, i.e. reduce the
severity of the risk (for example, protecting against collateral damage in the event of
a material failure, or providing backup systems to reduce the likelihood of total
system failure). 1
To maintain compliance with ICAO principles, risk assessment of both bird strike and blasting
operations at KRA 54 should be subject to an approved and documented process in order to
inform the Safety Management System (SMS). The potential loss of an airliner, passengers,
crew and other consequences, as outlined in Section 2.2, would in any rational circumstance,
present as an intolerable risk. Whereupon ICAO asks the primary question:
Can the hazards and related safety risk(s) be eliminated? 2
Cleary the answer in the case of new flight paths for runway 13/31 at SCA, is yes.
So why have these risks not been eliminated through the development of alternative flight
paths? Perhaps for one of the following reasons?
• The risks were not identified by anyone
• The risks were assumed to have been identified and assessed by another entity.
ICAO states that the optimal solution should be found. 3
ASA’s proposed flight paths cannot be regarded as the optimal solution, not just for safety
reasons alone but also due to constraints which will necessarily be imposed on RPT airlines
and GA businesses operating from SCA in order to accommodate the risk from KRA 54 in
particular.
Failure to follow ICAO’s SMS risk management process 4 which would have resulted in the
identification of the optimal solution should be regarded as a systemic failure.
CASA/OAR and ASA have made no attempt, through the evaluation of alternative routes, to
avoid the risks, instead electing to accept them unnecessarily and thus ignoring the existing
opportunity to mitigate through exposure avoidance as espoused by ICAO. This appears to be
a conscious decision by CASA/OAR and ASA and as such should be regarded as a systemic
failure.
ASA have elected to increase air traffic movements directly over the quarry site. Use of a
curved approach and departure procedure, which is widely agreed to be a critical, high work
flow phase of flight means this design adds a layer of complexity for pilots. According to
aviation experts this contrary to preferred operating procedures for both pilots and Air Traffic
Control (ATC), that is, complexity should be reduced wherever possible, not increased
unnecessarily.
MTF...P2
Via 20/20 inquiry submissions page:
45 Flight Path Forum Inc (PDF 797 KB)
Executive Summary
Flight Path Forum (FPF) is an incorporated community association formed in 2019 in response to a
failed consultation process by Airservices Australia in relation to changes to airspace and flight paths
to support operations forum runway 13/31 at Sunshine Coast Airport.
Since April 2019, FPF has focussed on researching many aspects of the Civil Aviation Safety Authority
(CASA) and Airservices Australia’s (ASA) ’s environmental and risk assessment processes for changes
to airspace and flight paths., including regulatory frameworks and national operating standards and
most importantly engagement between the two agencies on these issues. Concerns over the
assessment process for environmental risks to aviation safety have arisen and FPF believes it
necessary to set before the Senate Inquiry the full context of the particular circumstances
surrounding new airspace and flight path designs for runway 13/31 at Sunshine Coast regional airport
and to call for an immediate review of the Civil Aviation Safety Authority’s (CASA) aviation safety
management functions and aviation safety frameworks.
Whilst FPF appreciates the current inquiry is mainly focussed on Australia’s general aviation industry,
decisions made by CASA in conjunction with other relevant Australian Government agencies, in this
case ASA, in relation to airspace changes and new flight paths have had a ripple effect on the safety of
general aviation operations occurring in the vicinity of Sunshine Coast Airport (SCA).
As the safety regulator for Australian airspace, every decision CASA makes in relation to airspace
changes, to accommodate flight paths for Regular Passenger Jet (RPT) aircraft, has the potential to
create a knock-on effect for all airspace users including general aviation (GA) operators and it is for
this reason FPF now presents this submission as a ‘related matter’.
CASA’s engagement with ASA, on the issue of aviation safety, is of particular concern in the case set
out below. FPF is of that view that any Inquiry related to aviation safety frameworks and relative risks
must consider the circumstances that have recently unfolded on the Sunshine Coast...
From pg 9/...
...ICAO’s Risk Management framework articulates the following process for risk assessment:
• Identify the risk
• Evaluate the consequence of the risk eventuating
• Determine the likelihood of the risk occurring
• Determine acceptability of risk
• Either accept the risk or act to mitigate the risk
It appears that neither CASA/OAR or ASA have undertaken any of the above in relation to
safety conflicts between bird strike, blasting operations at KRA 54 and the proposed new
approach and departure routes for 13/31 other than the final point, to accept the risk. This is
a failure of process.
ICAO also articulates the following risk mitigation strategies:
a) Exposure Avoidance. The risky task, practice or operation or activity is avoided
because the risk exceeds the benefits.
b) Loss reduction. Activities are taken to reduce the frequency of unsafe events or the
magnitude of the consequences.
c) Segregation of exposure (separation or duplication). Action is taken to isolate the
effects to the risk or build in redundancy to protect against the risks, i.e. reduce the
severity of the risk (for example, protecting against collateral damage in the event of
a material failure, or providing backup systems to reduce the likelihood of total
system failure). 1
To maintain compliance with ICAO principles, risk assessment of both bird strike and blasting
operations at KRA 54 should be subject to an approved and documented process in order to
inform the Safety Management System (SMS). The potential loss of an airliner, passengers,
crew and other consequences, as outlined in Section 2.2, would in any rational circumstance,
present as an intolerable risk. Whereupon ICAO asks the primary question:
Can the hazards and related safety risk(s) be eliminated? 2
Cleary the answer in the case of new flight paths for runway 13/31 at SCA, is yes.
So why have these risks not been eliminated through the development of alternative flight
paths? Perhaps for one of the following reasons?
• The risks were not identified by anyone
• The risks were assumed to have been identified and assessed by another entity.
ICAO states that the optimal solution should be found. 3
ASA’s proposed flight paths cannot be regarded as the optimal solution, not just for safety
reasons alone but also due to constraints which will necessarily be imposed on RPT airlines
and GA businesses operating from SCA in order to accommodate the risk from KRA 54 in
particular.
Failure to follow ICAO’s SMS risk management process 4 which would have resulted in the
identification of the optimal solution should be regarded as a systemic failure.
CASA/OAR and ASA have made no attempt, through the evaluation of alternative routes, to
avoid the risks, instead electing to accept them unnecessarily and thus ignoring the existing
opportunity to mitigate through exposure avoidance as espoused by ICAO. This appears to be
a conscious decision by CASA/OAR and ASA and as such should be regarded as a systemic
failure.
ASA have elected to increase air traffic movements directly over the quarry site. Use of a
curved approach and departure procedure, which is widely agreed to be a critical, high work
flow phase of flight means this design adds a layer of complexity for pilots. According to
aviation experts this contrary to preferred operating procedures for both pilots and Air Traffic
Control (ATC), that is, complexity should be reduced wherever possible, not increased
unnecessarily.
MTF...P2