Unintended Consequences

A weekend ring-around to senior staff of GAAP-based flying schools told us they’re unanimous that CASA Director John McCormick’s Class D airspace directive is the most positive step GA has seen from the regulator for many years.

But our survey also revealed serious unintended loose ends that need to be fixed very quickly. Most of these don’t spring from Mr McCormick’s Class D edict, but from two related issues.

One is the across-the-board decision to limit the number of aeroplanes in the circuit for a particular runway to six, and the other is the resulting practice of controllers turning back inbound traffic to hold outside their zones until the numbers of aircraft in the circuit area of the runway they are controlling are reduced. This is alarming because those already-congested points are made more dangerous as inexperienced student pilots, some of whom have limited English, are not provided with an alternative or told for how long they’re required to remain outside controlled airspace. And the alternatives open to them are now severely limited by the closure of Hoxton Park, and the increased pressure on Camden’s limited capacity from the Bankstown overflow.

To make it worse we still have specified inbound reporting points, in some cases effectively only one or two, which are not a feature of Class D airspace, and that also needs immediate review.

There’s been some confusion because AIC (Aeronautical Information Publication) 09/09 says:

5.            THE FUTURE

5.1            The CASA Director of Aviation Safety has directed that the following actions be undertaken by 21 April 2010:

a. The implementation of International Civil Aviation Organization (ICAO) Class D airspace where GAAP Control zones currently exist.

(i) Implementation will enhance safety by standardising Class D procedures nationally and aligning Australia with ICAO requirements.

AICs however are issued not by CASA, but by Airservices Australia, and the AIC seem inconsistent with Mr McCormick’s directive as set out in CASA Instrument 209/09, which does not mention ICAO. The directive did not address ICAO/USA differences, but Mr McCormick has confirmed his preference for the FAA system, and says CASA is “working very closely with Airservices on the implementation plan for Class D.”

While the USA, Canada and New Zealand are non-compliant with ICAO, each has filed a “difference” with ICAO and in that context it is relevant that the USA alone has more Class D airspace than the rest of the world put together.

We also told CASA of the very strong industry support for the Class D directive, but pointed out the deep industry concern over two resulting issues:

1. The immediate effects of runway rationing in the apparent absence of ameliorating measures that appear to be available. One example is Camden, which I’m told has a 7am curfew, which means there would be a lot of thumb-twiddling in the tower on a summer morning; and
2. The question of whether it is intended to apply Class D as per ICAO which I am told would virtually shut down all six airports because of vertical clearance from cloud, or to apply Class D as in the USA, Canada and NZ, which works. I don’t think that has been spelt out anywhere in the media releases or instructions to Airservices.

CASA promptly responded:

1.      “The ameliorating measures are:

a.            CASA is actively encouraging operators to program their activities to avoid traffic peaks. By doing so circuit overload and arrival peaks can be avoided.

b.            operators have been asked to remind their pilots to have a plan of action in the event that entry into the control zone is not immediately available.

c.            CASA has reinforced to Airservices the fact that ATC has flexibility in managing the circuit cap. Whilst safety remains paramount a temporary increase is permitted, for example, to accommodate sudden arrival peaks to reduce the need for denying access to the control zone. The circuit cap Direction provides controllers with the clear and unambiguous authority to limit activity within the control zone, an issue that has been subject to debate in the past.

d.            CASA is closely monitoring activity at other locations. For example, the OAR has already commenced traffic data collection process at Camden.

2.            The vertical clearance from cloud requirements differ slightly between ICAO and the FAA. The Director has stated that his preference is to follow the FAA system: “CASA can see no reason why Australian airports should be adversely affected by the clearance from cloud requirements. It works in the USA so it should work here.”

The Director has also told us: “The statement of ‘ICAO Class D’ is a working definition and does not override the implementation plan being developed by Airservices. CASA will ensure that the specifics of the Class D introduced into Australia best reflect the Australian operating environment.”

The differences are all-important to the final outcome.

ICAO Class D requires 1,000’ vertical separation from cloud for VFR flights, which means that under those requirements, more than 4/8ths of cloud at 1900’ AGL would (at least theoretically) close any of the six GAAP airports to VFR operations. In contrast, the Class D airspace used by the three nations replaces that limitation with a requirement to remain clear of cloud and within sight of land or water – as does the customary “special VFR” clearance.

Our telephone survey

The viewpoints below are de-identified because nobody wants to be sent to the end of the takeoff queue or to appear in someone’s ‘random audit’ program, but they all come from senior training industry experts. Both CASA and Airservices need to start listening to what these industry people are saying, and to cooperate in whatever needs to be done to make the interim system work.

Archerfield

When we published this a week ago we had trouble getting anyone from Archerfield to cme to the phone, and one receptionsist suggested: “Maybe they’re all holding at Target [the inbound reporting point] waiting until Airservices finds another controller.”

When we did find a couple of people they had plenty to say:

• If you look at all the millions of movements at GAAPs since it was implemented in 1982, the number of midair accidents has been negligible. If we’re going to apply the same standards we’d have to put a 50 metre separation between every car on the road.  CASA has gone willy-nilly into this and created a whole lot of confusion without looking at any of the consequences, I think they’ve been told to” shut these weekend warriors up because we don’t want all this activity at these airports.”
• The Ambidji consultation was a farce. I’d been flying at GAAP airports since the 1980’s they didn’t want to listen to me, they had their Lloyds risk management guys there and they talked about “unacceptable societal risk.” They love that expression. The more they ask for consultation in emails and web sites the less the industry is going to be interested, they have more on their minds. They’ve driven industry out of consultation because people know they’re not going to be heard so they don’t turn up. That gives them the opportunity to say we’ve tried to consult industry and they weren’t interested, People are so bombarded with all this jargon about threat & error management and DAMP programs they don’t have time to do the stuff they’re required to do.
• The biggest worry is the fact that John McCormick might be getting set up because he hasn’t spelt out clearly and unequivocally that he intends to implement Class D as in the USA. He says he is, but I believe that in all its manpower planning, Airservices is working on ICAO Class D and that’s what their documents seem to reflect. That simply won’t work for two reasons – the cloud separation issue, and the operation of parallel runways, which is even more important because the runways are too close together for ICAO and you’d be limited to a single runway. And that of course would mean only six aircraft in the circuit – and only one air traffic controlller.

Bankstown – several comments

• They’re often understaffed, and last week we had one person in the tower who is doing ground, tower and everything – arrivals, departures, circuits – the lot.It’s unbelievable that controllers are turning back inbound students. That situation needs to be looked at urgently by CASA before there’s another collision. There’s got to be a better solution.

• Once you’ve started the engine the student’s typically paying over $200 an hour. They’ll let you go to the holding bay to wait, but when that’s full they won’t let you start up. They can’t give you much of an estimate of how long you’re going to be there for, but it’s a real issue.
• We had a meeting, and a Canberra guy who was up there for Airservices said they’d advertised for controllers on the web and 400 people applied. They knocked 200 out in the application process, they finally took 20 to interview, and hired four (and they’re recruiting for the whole of Australia!!)
• They’re totally understaffed. Saturday morning is THE time for flying training at Bankstown and they’re limited to two people! Arriving and departing aircraft take care of a lot of the capacity so you may have just two aircraft in the circuit, and on a Saturday morning that’s just unbelievable!
• The most stupid thing they’re doing at Bankstown is to clear everybody via 2RN. The other thing is telling them to hold outside controlled airspace. That’s not only ludicrous, it’s extremely dangerous. CASA is the safety regulator, and it’s certainly about time they took that on board because it’s a serious safety issue.
• We only basically have one runway here; we do have a grass runway but once the main runway gets a few aircraft on it we can see that the controllers are not going to give us operations onto the grass runway for tailwheel work or crosswind landings.

Camden – several comments

We previously had a good relationship with the controllers but now – I’m not saying it’s fallen apart yet but I have a feeling it might fall apart. The working relationship was such that we might have three or four aircraft on the main runway and they’d still let us fly one or even two aircraft on the crossing runway. I can see that this is simply not going to happen because their whole attitude is that we’re not going to handle more than six aeroplanes, come what may.

But the other issue is that the AIC that was put out by Airservices (why not the OAR?) that they didn’t want the GAAP to be transferred from the reporting points requirement in Class G. And that’s exactly what’s happening.

• It’s encouraging to hear that what McCormick is proposing is not ICAO Class D, however maybe I’m cynical but I just can’t see that CASA is going to change things that quickly, and that we’re going to re-vamp the airspace system which people have been trying to revamp for the last 12-13 years, and we’re supposed to re-vamp it in the next six months.
• Our biggest problem is that there’s no Hoxton Park any more, and it’s forced the aircraft out of Bankstown down to Camden. We’ve got a situation that’s developed here where the controllers can’t handle more than six aeroplanes in the Bankstown circuit so we’ve had up to 8 or 9 aeroplanes floating around in the Camden circuit when it’s non-controlled. The controllers can’t handle more than six aeroplanes at a time in the circuit at Bankstown, but Camden has anything up to 9 or 10 without a controller!They need to leave us alone down here and provide the services at Bankstown so they can service the traffic up there and it doesn’t overflow to here. Basically they’re sending the aircraft into uncontrolled airspace because the controllers up there won’t manage aircraft what they were capable of managing in the past.

  It’s not necessarily the shortage of controllers; I reckon they’re working to union directives. If they’ve been working for an hour, the controller has to have an hour off. I was at Bankstown twice today, and both parallel runways were operating on the one frequency. Normally training operates on one frequency and arrivals/departures operate on a separate frequency. But today they were all operating on the one frequency so no one was allowed to do anything. So reporting inbound can I have circuits? [the answer is] ‘no, nothing is available.’

  That’s because they’re working to a rule and because they’ve only got two controllers and the roster says they give one an hour off for lunch, they close the other circuit down and make it all work on one frequency. So it doesn’t even work at Bankstown. They have five radio calls they have to do. We call:

1. Entering runway
2. Downwind
3. Base
4. Final
5. Clear of runway

• The radio here is just double transmission all day. Say there are eight in the circuit, nobody knows what’s going on because it’s all double transmission.

  In November two years ago they brought out that amendment to non-controlled aerodrome procedures. The recommendation was call turning downwind, turning base, turning final with intentions (you only announce your intentions when you’re turning final which is great when you have 3-4 aircraft following you plus one in front who suddenly decides he’s going to do a full stop on the runway, and then you have people calling taxying entering and exiting the runway.

  In the circuit (when we’re non-controlled) you’re getting at least three calls per aircraft in a six minute period, and you add six aircraft in the circuit doing that, you have 18-20 calls from aircraft every six minutes – three per minute – so you can imagine what that develops into.

  The solution is to go back to base call only. That worked perfectly. If we keep changing the system all the time as we do at the moment, with all these people claiming ‘oh we have to do this for safety’, I’d like to see the statistics on the number of accidents that justify these changes. The statistics are not there.

• We haven’t got aeroplanes smacking into one another but what we’re doing is creating an unmanageable system and eventually if it keeps going the way it’s going we’re going to have an accident probably at Camden or somewhere in the vicinity of Bankstown, over one of these reporting points. It’s due to be sorted out, but the way we’re going we’re likely to have someone dead before we get that far.
• Before we taxy we now have to get a startup clearance for circuits; they’ve now got three people working the Camden control tower where they only had two, and we’re told to hold because there are more than six in the circuit. We run our bookings on the basis of 90 minute slots – half an hour to brief the student and an hour’s flying, we call for a taxy clearance and we’re told hold position, clearance not available.So we have to leave our master switch on, sit in the aeroplane with our battery going flat, waiting for them to call us up and say ‘now you can start up and taxy, and report ready at the run-up bay.’ So there’s another radio call they have to cop. So when the booking’s finished, we have to bring the aeroplane home, we’ve done 15 minutes flying, paid a landing fee and a BAL airport movement fee of $20, and the poor kid’s flown only 0.3 or 0.4 hours but probably has to pay for an hour’s aircraft time.

  CASA is now saying all the GAAP airports when they go control Class D will have to be controlled from sunrise to sunset. But as one example we have a noise abatement requirement here until 7.15. So if they open the tower and put three controllers up here at 6 am when the sun comes up, they’ll have nothing to do until 7.15 because we can’t fly circuits anyway.

Jandakot – several comments

• There’s a hazard here already in that we only have three inbound reporting points and already we’re getting turnbacks because the circuit can’t cope. We have students and other pilots having to hold outside controlled airspace so it’s made matters worse overnight. It’s probably going to cost each operator at least $20,000 because we can’t get our students trained here any more. And the third thing is when we go to single runway (12) which we have to do in the summer time because of prevailing SE winds, ATC will be able to accept almost no circuit training at all, because the numbers will be taken up with inbound and outbound traffic. So there’s too much crosswind on the dual runways and we need a parallel runway. But the airport owners are dragging their heels on that saying they can’t justify the cost.It’s on the master plan, it’s all been approved, and they’re going to do it but they’re dragging their feet. My argument is that this has been slapped on us overnight, so why slap it on Runway 12 when there are going to be controllers in the tower who are going to be redundant when that runway’s in use? They’re not controlling anything else, so there’s plenty of sets of eyes and they should be able to handle at least what they were handling before.

  These are the banalities that McCormick is not handling well. On one hand he allows what I consider the least safe aerodrome in Australia, Camden, to operate with extra gliders and all sorts of other things uninhibited. Since Hoxton Park closed Camden has become a bloody death trap. It has helicopter school training there now, it has gliding, everything, and they haven’t even got full ATC. Yet he gives them a concession to operate with gliders, but in Jandakot they even count helicopters in the circuit as part of our overall traffic.

• I think the numbers of aircraft in the circuit should be up to ATC who on some days allow us to have eight or nine in the circuit, and quite comfortably, that’s on the second runway, contra-rotating circuits on the parallel runways and there will be times when they have heavy traffic inbound and outbound, they won’t accept people onto the circuit for a while, but they regulate that for safety, and then when it goes to the single runway they’ll accept about 8 or 9 in the circuit plus arrivals and departures, and they’ve got more eyes and ATCs to handle it because there’s only a single runway. That’s been working well.
• YMMB has two overwater arrival points, namely Shoal and Bay West. These are probably the safest as they are also IFR reporting points. I personally always try to use them. The other points GMH (General Motors Holden – now an indistinguishable old factory) and Academy should be renamed as they don’t make geographical sense anymore and there are more prominent positions available. Everybody is taught to arrive at these points at 1500 ft. It would be better to stagger the heights as well, with the exact height being reported. It should further be insisted upon to listen out on the relevant approach point frequency for at least five minutes before ETA. Better still the use of two or three additional initial reporting points at a ‘distance’ of say 3 minutes out from the current points, with either a proceed or hold (according to a simple pattern) fanning into the primary (existing) point. This is a bit like slowing down approaching an intersection whilst driving. It gives pilots including students and strangers) a chance to become aware of the position of other traffic. By having say three points the risk of collision is approx 1/3^rd. or ½ with 2 points.
• When I’m inbound I usually stay higher than the required 1500’ and report my actual height. That lets other pilots know I’m there but also that I’m aware of the 1500’ requirement and will be there when I’m required to be. Some people including me use their landing lights which is a good idea, and I also report before the points, one mile south or whatever rather than right over the top.
• We’ve always only had outer harbour and the substation as reporting points, and that’s no problem because anywhere else is controlled airspace. The problem we have is that we have to book slots 24 hours in advance and if we forget to book a slot the training can’t go ahead. That means if somebody walks in off the street, even if you have an instructor and an aircraft available, you can’t fly. They reckon they’re too busy. We ring and ask to book a slot at a certain time and they say we haven’t got one at that time, how about this time? Take it or leave it.

Parafield – one comment

• That’s a pain in the (somewhere) because I don’t think they’re always so busy that they can’t accept another aircraft at short notice. This started about 12 months ago. Requirements like aerial photography or off-the-street charters can also be a pain. But it’s not as bad as what we hear about Bankstown.

Industry

• I think the answer may be for Airservices to move on to what they do best and for these towers to be operated by a private company using licensed controllers and contracted either to the airport or to a user group. I believe the regulatory framework is in place for that, and I think that would provide mature controllers with an opportunity to participate with a choice of either full-time or casual work, which would make the system more flexible. I also know that Airservices is providing tower services at airports in the USA, so they must be capable of being competitive.
• The many things that have not been mentioned by CASA regarding ICAO Class D include:

1) Under ICAO definitions all GAAPs would be reduced to a single runway, because minimum runway spacing for parallel runway operations cannot be achieved.

2) With the exception of Moorabbin, all the GAAP zones are too small for any form of radar control, leaving you with time based separation amounting to ten minutes between aircraft. There is little ability to implement vertical separation due to overlaying CTL.

The answer is:

1) Review the criteria for the use of F/N [frequency versus number of casualties – societal risk] curves, as in the Ambidji report. If you apply the current CASA/AA method, all FAA D airspace do/would show Intolerable Risk, and that is clearly not the case in practice.

2) Address the changes that have resulted in the stark contrast of the first 20 years of GAAP – NIL collisions, versus the record since – and several of us know what the underlying problem is – It is staring us in the face!!

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• 28 January 2010 -- CASA directed to issue Trans Air AOC
• 1 December 2009 -- Jandakot backlash at CASA directive