Jandakot backlash at CASA directive
Pressure is now mounting from all GAAP airport users for a case by case review of CASA CEO John McCormick’s “Directive 329/09”, which applies uniform restrictions on all GAAPs regardless of major differences in airspace layout, traffic movements and other key issues.
In the most recent move Jandakot airport users have written to the Director claiming his decision was based on now-discredited advice, without an impact statement or appropriate consultation, battering their businesses and damaging the training industry’s international credibility.
Several independent experts have also criticised the language and the risk analysis methodology and assumptions of the “Ambidji Report” on which the decision was based. Jandakot users say they are now being locked out of meaningful consultation, with local officials refusing to discuss how Class D airspace is to be implemented.
Here’s their letter to Mr McCormick:
Mr. J.F. McCormick
Director of Aviation Safety
Civil Aviation Safety Authority
GPO Box 2005
Canberra, ACT 2601
CASA Directive 329/09 – Proposed Introduction of Class D Airspace
Dear Mr. McCormick,
Following our letter to you on August 12th 2009 and my subsequent telephone conversation with Terry Farquharson in September, we still have major concerns over this directive and the lack of consultation with the operators at Jandakot Airport.
Background
We represent the operators and users of Jandakot Airport. This is the most successful GA airport in Australia and the largest training base for GA in the Southern Hemisphere. Much effort has been invested by the WA government over the last 15 years to encourage overseas training organisations’ relocation to Jandakot. All training up to CPL/IR levels for Singapore Airlines and China Southern is based at Jandakot. This is in addition to another ten flying schools including the Royal Aero Club of WA. We understand that collectively, the training establishments at Jandakot represent close on half all new Commercial Pilots Licences issued in Australia.
Obligation To Issue A Regulation Impact Statement
Given the substantial business cost impact of your directive 329/09 to our members, you are obligated as a public servant to issue a Regulation Impact Statement. This we have yet to see. Our initial assessment shows a reduction in revenue of 20% and reduction in operators’ profits of up to 40%. This is not a “low impact” impost on business, including the $80 million export revenue generated by Jandakot training establishments.
In addition to the administrative requirement to issue a Regulation Impact Statement, you may also have obligations to address under Section 44ZZ et al, of the Trade Practices Act.
Rationale For Change Discredited
You issued this CASA directive following the publication of the Ambidji Review.
a) Independent assessments of the Ambidji Review call into serious question the statistical methodology (See appendix 1). In essence, the statistical basis is nonsense.
b) The anecdotal evidence in the report as it relates to Jandakot is flawed and is statistically irrelevant. 78% of respondents to the Ambidji survey questionnaire never operate at Jandakot airport. Of those respondents that do operate into Jandakot, only 7% visit the airport more than monthly.
c) As Jandakot Airport represents close on half all GA training activity in Australia, the Ambidji consultants should be directed to consult with our local aviation community before making spurious comments and using provocative language (e.g. intolerable risk ) in relation to the safety issues at Jandakot.
d) We are surprised CASA personnel did not review this report in a professional, measured and structured way. Instead, there appears to have been a knee-jerk reaction to a flawed report. This is not something the aviation community expects from what up to now has been a highly professional public service organisation.
Consultation
Your personnel have not entered into any meaningful consultation with the stakeholders at Jandakot Airport.
a) At meetings with our members, none of your staff is prepared to discuss why the successful extant GAAP procedures should not be retained or modified to perhaps improve safety and efficiency.
b) CASA staff are only willing to dictate to the members of the aviation community, and declare that Class D airspace will be introduced at Jandakot.
c) When asked how this Class D airspace will be implemented at Jandakot, they are reticent and will not outline how it will be done. It is almost as though CASA management is gagging its staff.
d) At the last WA RAPAC meeting, the state operators were so concerned about the process adopted by CASA to propose Class D airspace, that they voted a no confidence motion in the way CASA is handling the process.
Problems Associated With The Introduction of Class D Airspace at Jandakot
a) The dimensions of the control zone are such that it would be difficult to implement effective Class D Airspace control.
b) The integration of IFR procedures under Class D between Perth Airport and Jandakot would result in significant delays for VFR operations and circuit operations.
c) Special VFR operations at Jandakot (e.g. retrieving students from encroaching weather in the training area) could impact RPT operations at Perth.
d) Because of the size and shape of the control zone at Jandakot it would be difficult to introduce Class D airspace as practiced in North America.
Proposal
a) In line with the Jandakot “HAZID” meeting recommendations, we would like to see movements and circuit traffic numbers continue to be controlled at the discretion of Air Traffic Control.
b) You as the regulator have a duty of care not to rush into dramatic airspace changes at Jandakot without due diligence, careful review, consultation with the stakeholders and sound numbers.
c) Jandakot, with a fine safety record over the last 40 years, can be seen as a model for good airspace design.
Yours faithfully,
Michael G. Braybrook
President, Jandakot Airport Chamber of Commerce
Your reporting of the serious issues raised with Mr McCormick by the Jandakot business community is very timely. I have perused copies of three reviews – perhaps the analyses that your article mentions – and it is clear that the depth of understanding of risk analysis that they reveal is at a far more professional, analytical and comprehensive level than what is in evidence in the Ambidji Report.
Each of the three analyses is critical of the original report and to various degrees they complement one another. However the most detailed of these, by Springside Engineering, the business of Mr Ian Bryce, BE, BSc, who has performed risk analysis for space launching projects and for Defence weapons trials and research flights, encapsulates with great precision the serious errors the report makes in every stage of its analysis.
All three reports are published on Dick Smith’s web site, http://www.dicksmithflyer.com.au/cat_index_54.php, and should be essential reading for any industry participant (including CASA) who is evaluating the related issues.
Also worth visiting is the Ambidji web site, which among other things details the backgrounds of its consultants, most of whom appear to have backgrounds “in the policy, regulation and operation of the air transport sector, particularly in the areas of airports, airspace, air traffic control, flight standards and airworthiness.”
Risk assessment and management is a profession in itself, but doesn’t get a mention in the summary.
Heres hoping Polar Aviation are successful in taking CASA & Faquharson to the cleaners. Great Web Site , regards Cliff
A LAME came over to see me last week saying that GA was being destroyed by CASA, property developers and others. He was getting out and looking for a new career direction and advised all us operators to follow. In short there have been a number of folk that gave up and out of despair or depression think that the fight is lost and that organizations representing GA have all lost the plot. I disagree with that last point but it will require a united front. Those left in this industry must unite, build bridges and stop bagging one another. I have never before seen so much of that in any other industry. During war time the worst thing that could happen was for people to gossip, badmouth and discuss all manner of confidential information so that enemy ears could tune in and act accordingly. All airports in Australia have a national security component and this must be the bottom line in a united fight in order to preserve pilot training, vital maintenance of our aircraft and everything else associated with GA which in many ways supports airline activity. The message is clear and must over-rule bureaucratic decision makers and those intent on ripping up runways and knocking us pilots out of the air. One of these days a national calamity will engulf us and the nation will need to make a timely withdrawal of its aviation resouces – that is if we have any left. To those that think the taxpayer can fund overseas pilots and planes just look at the fiasco associated with fighting bushfires and even providing air ambulance services. What a mess when we almost had it right.
It must be clear even to the last few remaining CASA apologists, if there are any, that our regulator is destroying what should be a great Australian industry. One only has to look at RA Aus to see what a fairly regulated system can achieve.
CASA’s rude, pre-emptive and patronising attitude is all too apparent, another example; the recent CASA statement about fuelling problems begins, “CASA is fed up with”…pilots not having sufficient fuel…
Well guess what, we are fed up with CASA. On the question of fuel, fuelling points are being closed all over the country making flight planning and in-flight decisions all the more difficult. Does CASA encourage airport operators or fuel companies to maintain re-fuelling facilities?
Until there is political willpower to remake CASA, mainstream GA will continue to die on its feet. There is no hope of internal change in CASA because the gravy train has no brakes and the culture of bash the industry is completely embedded.