CAA Postpones Airspace Changes

The Board also acknowledged that, under the proposed change, services offered in Class G airspace would be limited, and concerns within the aviation industry over this particular aspect had to be addressed in the interests of safety.

The CAA would now seek further advice from the civil aviation administrations of the USA and Canada, undertake further consultation with industry, and give further consideration to safety aspects of the change.

Finally, Executive Management of the CAA would be required to report to the next Board meeting with recommendations which would include a timetable for implementation of the new airspace arrangements.

The Background

How did this remarkable situation come to pass? Before addressing this question, it must be acknowledged that Dick Smith, a past Chairman of the CAA and who was in the chair when proposals to implement the ICAO system in 1991 were first mooted, has been a voice in the wilderness in his opposition to what was ultimately proposed.

All along he has maintained that the blanket raising of the lower level of Class E (controlled) airspace to 5000ft (10,000ft in non radar areas), rather than down to 1200ft or circuit height as was intended in the original 1991 model has removed the safety backup for IFR aircraft and would ultimately result in a disastrous accident. Specifically his concerns relate to IFR aircraft making instrument approaches in IMC (Instrument Meteorological Conditions) to unmanned, uncontrolled airfields in Class G airspace, which is the uncontrolled airspace below Class E airspace.

The argument put forward by Dick Smith as to why the CAA insisted that Class E airspace be lifted to 5000ft is that unique to Australia, the CAA required VFR aircraft operating in Class E airspace to be “in the system” with a mandatory radio requirement. The CAA solution to prevent controller overload (or increased costs) was to raise Class E airspace to a base level of 5000ft; in doing so the problem outlined above for IFR traffic in the lower Class G airspace was introduced. Dick Smith maintains that VFR aircraft which operate at their own separate levels to IFR aircraft on a “see and avoid” basis, should operate in Class E airspace with the minimum level of communication to Air Traffic Services as is the case overseas. His concerns were downplayed by the CAA as scaremongering on the basis that representatives of the entire spectrum of aviation ranging from operators of 747s down to the Ultralight fraternity had been consulted and had actively endorsed the new system.

However, it was only when GA operators, and some re- gional airline pilots began to examine the practicalities of the new system and found that they would be operating over 90% of the time in uncontrolled airspace that the true implications of the proposals became apparent. Matters were brought to a head when, at a meeting of the Bankstown Airport Chamber of Commerce in late September, all GA operators at that airport unanimously agreed to oppose the airspace changes. The Bankstown meeting acknowledged that although our present system is safe, it is very expensive and inefficient, and as well it is significantly different to the ICAO system now used by most overseas countries and hence had to be restruc- tured. However, the meeting also maintained that the CAA proposals would take Australia from being one of the safest aviation countries in the world, to one of the least safe.

It was universally agreed at the meeting that the only course was to adopt the proven North American system which would bring us into line with the rest of ICAO.

Faced with a growing groundswell of opposition, albeit somewhat belated, the CAA had no option but to put the implementation of the total system on hold.

The Problem

As outlined above, the problem essentially relates to IFR aircraft operating in Class G airspace, in which to quote the CAA Bulletin of May/June 1993, “IFR aircraft operating in Class G airspace are not subject to ATC and will not receive a directed separation or traffic information service except where a Radar Advisory Service is available”. This also ap- plies to airfields in Class G airspace where MTAF or Mandatory Traffic Advisory Frequency procedures apply, which require all aircraft, both VFR and IFR to make certain mandatory calls and to arrange self separation.

Dick Smith, in his campaign, maintained that by removing the safety back up of an ATC service, a simple error in misdialing a frequency could lead to two aircraft carrying out an instrument approach at the same time at an uncontrolled (MTAF airfield), without either crew being aware of the dangerous situation that had developed. He maintains that an IFR flightplan, monitored by ATC would remove the danger by alerting other aircraft to the situation.

Clearly something went wrong with the consultation process. The full implications of what was being proposed appear not to have been understood by either the CAA or those asked to endorse the new airspace arrangements. In other words the right questions weren’t posed by the CAA, and the right questions weren’t raised by those involved in the consultation process. In hindsight, it is now clear that the proposal was never really fully thought through.

Somewhat belatedly, as outlined earlier, a groundswell of opposition to the new procedures began to emerge once GA operators and others came to appreciate the implications of the new proposals, namely that they would be operating completely uncontrolled for over 85% of the country.

The Dick Smith Solution

Dick Smith maintains that the solution to the problem is simple, go back to the original 1991 proposals which had Class E airspace (controlled) extending down to circuit level at unmanned airfields where safety analysis shows that traffic densities require it. This is in accordance with the proven international system and is what occurs in the US and Canada. Where traffic is significantly below that figure, MTAF procedures are acceptable.

In addition Dick Smith is adamant that the CAA should implement the change in eight, six month stages as originally planned, thoroughly testing and examining the effects of each phase before moving on to the next.

By way of comment, it is difficult enough to get everyone to understand a single change, let alone rolling changes over a period of some years. The practicality of this proposal is questionable.

The Cost

There can be little argument with Dick Smith’s proposals except cost.

Here it is difficult to pin things down. A figure of $30m annually to implement the Class E airspace down to circuit level was continually quoted by the CAA in their arguments against Dick Smith. This was the figure calculated as necessary to provide the controllers to operate the extended service.

Dick Smith refutes this maintaining that no real cost study has ever been carried out, and since enroute controllers are presently underloaded, it would be possible to implement the international scheme at nowhere near this figure.

All along it must be remembered that here we are talking in terms of savings, not additional costs. One of the main features of the proposed CAA system was that it would amount to a saving of over $50m annually. However, although the cost of extending Class E airspace to circuit level (where necessary), will amount to a lower saving, not an additional cost, someone must foot the bill. Less of a saving or a real expenditure someone is going to have to pay. In a backlash against GA for resisting the CAA proposals, it would not be too difficult to imagine GA being targeted.

A further argument put forward by Dick Smith relating to costs is that a full separation service for IFR aircraft in Class E airspace need only be provided in IMC. Often it would be possible for aircraft to climb VFR before entering the IFR system.

One final matter relating to costs is of course how much of the budgeted $18m for communicating the changes to the aviation industry has been spent to date. The question of reworking publicity, training, publications and maps and charts depends of course on the final outcome, but there is little doubt that it will run into some millions of dollars.

The Blame?

In discussions subsequent to the Board decision, Doug Roser, CAA CEO was firmly of the opinion that the consultation process had operated correctly, albeit perhaps a little late in the piece. He agreed that despite wide sweeping consultation across the whole aviation spectrum, it was clear that not all representatives were in tune with their constituents. He maintained that the CAA team had put forward a considered proposal, balanced in terms of safety and cost and had expected equal consideration of the proposal.

However, despite the present CAA view on the matter, it is a fact that those responsible for promoting the new arrangements maintained that the differences between what was being proposed for Australia and overseas were minor. In the subsequent real analysis, whilst the differences might have appeared on face value as minor, their implications were in fact, major.

Despite the above, if blame is going to be apportioned for share. A little better homework, a little earlier, might have the situation we are now in, the industry must accept its fair saved embarrassment all round.

Finally, it is difficult to see how a similar problem could be overcome in future except by direct communication with every pilot which would be a mammoth task, and would most likely lead to no better result.

Advanced ATC Technology will be the key to the future.

The Possible Outcome

It is unfortunate that a number of players in the present imbroglio have taken stances from which they will find it hard to back down.

For this reason, it is difficult to imagine even significant amendments to the proposed Class G Airspace and MTAF’s model as being acceptable, let alone minor modifications. mise is achieved to avoid a demand for a system that is super However, it is to be hoped that reasoned sensible comprosafe, but not really cost effective.

On face value (and unaware of the true costs) it would appear that the only system that could be proved as being safe to the satisfaction of all concerned is the North American model; to what extent this would need to be implemented, ie to what airports and how it would turn out in terms of cost would remain to be seen.

Finally, one other significant advantage of adopting the North American model is that it would bring us into line with international practice in a world fast moving towards global systems.

The CAA Board has taken a wise decision in deferring the introduction of the new system and in seeking overseas advice. The problem has been identified and the way ahead is now clear for a speedy resolution.

It is perhaps fortunate that other major matters such as the Budget, Mabo and the question of a Republic have all combined to take the political heat off the airspace question and it is to be hoped that it stays that way.

Whether the system as proposed would have been safe or not will now never be known. What is important is that what ever is brought in to replace it, is fully thought through, fully understood, and lastly, accepted by all.