CAA’s New Airspace Proposals Draw Fire

Commendably, the Authority states that “The challenge for the future is to implement an airspace system based on International Civil Aviation Organisation (Icao) classifications, which will mean the Australian structure will more closely resemble the airspace systems of other leading aviation nations.” (However, as outlined below, there is some debate as to whether this will be achieved by what is now proposed). The Caa also states that “Under the latest proposal there would initially be minimal change to the current operating procedures in most areas of airspace. Many areas of airspace would simply be relabelled using the Icao airspace designator which best reflects the level of service currently provided. Elsewhere, and particularly within radar coverage, where equipment and resources allow, the current level of service will be enhanced by the establishment of class E airspace.”

Following consultation with industry during 1994, eight design criteria were derived from the 14 negotiable criteria put forward for discussion, the eight criteria may be summarised as follows: The cost benefit methodology currently used by the Authority will determine the establishment or otherwise of control towers. A minimum of Class C service will be provided to Ifr aircraft at any aerodrome with an approach control radar service. Controlled airspace will be constructed in accordance with the Authority’s Airspace Design Standards. A minimum of en route Class B is to be provided above Fl200 — Class A preferred. A minimum of en route Class E airspace is to be provided above 10,000ft within radar coverage. Provision of en route (above 5000ft) Class E or higher airspace outside radar coverage will depend on traffic density, aircraft type and risk analysis. All high capacity/performance Rpt aircraft require an alerted see and avoid operating environment in terminal areas, to be provided by Classes A, B, C, or D airspace, pilot broadcast procedures (Mandatory Broadcast Zones, Mbz), or electronic means (unspecified). A minimum of an Ifr/Ifr Ats provided en route and terminal traffic information service is required for Rpt and Ifr operations.

Under the proposed new arrangements, the lowest level of airspace will now be Class F which is uncontrolled, but an Ifr to Ifr air traffic advisory service will be provided. The previous lowest level was Class G in which no traffic service was provided for Ifr aircraft.

Background

The Australian Aviation Industry Association (Aata), which represents the entire spectrum of airspace users from the airlines through to sport aviation (747s to hang gliders), had already advised in 1993 that the 11/11 proposals were agreed, subject to minor amendments and appropriate audit procedures. When a vigorous campaign led by Dick Smith stopped the introduction of the new system, concerns related mainly to Ifr operations into uncontrolled Mtaf (Mandatory Traffic Advisory Frequency) airports in G Airspace. Under the 11/11 proposal self separation procedures were to replace the Ifr to Ifr traffic information which had been provided by Flight Service.

The Caa Board, reacting to the campaign, stated that it was not prepared to endorse the proposed new arrangements in view of the apparent widespread opposition by the Ga sector of the industry. The whole future airspace question was then put back in the melting pot for another try.

Current Caa Airspace Proposal

In the latest round, the Caa reports that following the deferral of the proposed 11/11 arrangements, it initiated: “A wide ranging review of airspace management, involving experts from the operational divisions of the Authority, as well as from the Us Faa and Transport Canada. At the completion of this review, the Authority embarked on an extensive consultation programme, targeting all sectors of the aviation industry.”

Alternative Airspace System Proposed By Aopa

The Aircraft Owners & Pilots Association Committee, following examination of the latest Caa proposals has advised its members that this will result in Australia implementing a most restrictive and expensive (estimated at $20m more than the 11/11 proposal) airspace system. In particular: Class A airspace above Fl 200 excludes Vfr aircraft. There is no good reason for not making this Class B which would overcome the complexity and cost of obtaining exemptions for Vfr to operate above this level. The unnecessary and unjustified use of Class C airspace for non-radar terminal airspace such as Coffs Harbour. Other countries manage with Class D (Usa, Canada, Nz) or Class G (Uk); Class D is arguably sufficient for Australia. The replacement of what is presently uncontrolled airspace with Class E simply because the radar range exceeds what is necessary for traffic separation in Class C controlled airspace. Class E is not a no-cost utilisation of excess capacity and should not be introduced without justification. The introduction of mandatory radio requirements which are explicitly contrary to the Icao recommendations.

The Aopa Committee believes that an Icao system which closely follows the original 11/11 proposal should be the basis for any final system. This would, subject to the following minimum modifications, provide for an acceptable level of safety at significantly lower costs (as was shown by the Caa’s own study at the time): The provision of a “third party” air traffic service for Ifr aircraft at non-tower airports such as Devonport and Bathurst etc. The acceptance of the Icao radio recommendations for each class of airspace with no unique Australian modifications that add to cost and complexity without any justified improvements in safety.

The Aopa proposal in relation to Ifr in terminal areas would see the Atc service controlling traffic in the Class E airspace above, work load permitting, providing information on any known traffic which has previously reported to Atc. (Comment: this might present an industrial problem as it is unfortunately clear that much of what the Caa wants in its version of Australia’s airspace is related primarily to creating an operational environment built around maximising job opportunities within the Authority.)

Aopa believes that there is no considered need for the retention of Mtafs or Mbzs as they may be called, as there is no evidence that they result in more radio compliance and they can generate safety problems by providing a false sense of security. The Caa’s inability to enforce the current legislation against those not using radio to avoid landing charges (the red light running syndrome) is a classic example of the uselessness of unenforceable legislation.

Aopa Sponsored Meeting To Discuss The Caa Airspace Proposal

In a commendable move, Aopa, in mid January, called a meeting in Canberra of the various general aviation industry bodies to discuss the latest Caa airspace proposals and to put forward its counter proposal. There was unanimous endorsement by those present (most of the industry) of the Aopa alternative airspace system and agreement that the Caa proposal was overkill, and would result in an unnecessarily overcontrolled and expensive system. It was agreed that every effort must be made to bring some sense into the airspace debate and that a strong campaign would be mounted to achieve this.

Dick Smith’s Views On The Latest Proposals

Dick Smith, one of the very vocal objectors to the 11/11 airspace plan believes that the Caa has again failed with the latest proposals stating in a draft paper on the subject that “there is not one change proposed which gives any benefit to the industry; it’s not an Icao airspace system and it’s more complex and more expensive than our present system”. The core of Dick Smith’s objections is that he sees it as appeasement of the Caa’s industrial associations by modifying the Icao classifications to comply with existing Australian “make jobs” work practices.

He believes that the Caa document is misleading on two accounts. Firstly all en route airspace above 10,000ft which is presently controlled is now to become Icao Class C which, he believes, will result in present staffing levels being maintained. Secondly, he believes the document is misleading because of the difficulty in distinguishing the important “variance from Icao” details due to the use of italics which are indistinguishable from the normal text. He cites in particular “continuous two way” radio requirements for Vfr in Class E & F.

He is particularly scathing over the proposed Mbzs which he sees as a desperate bid to move back to the 1950s! He maintains that it is impossible to make any informed comment on what is proposed because of lack of details, however he makes the observation that the proposed size of the Mbzs is 15 times greater than Class D tower airspace in countries such as the Usa and Canada. Perhaps Dick’s views are best summed up by his statement that “the closer the airspace letter is to the start of the alphabet, the more staff intensive, the more restrictive and the more costly it is. In virtually all cases the 11/11 proposals have been changed to a higher classification”.

Comment

There is much to be said for Dick Smith’s oft stated view that one of the essentials to achieving and maintaining an acceptable level of safety within the Ga industry is to reduce its overheads. He maintains that once the industry is economically viable it would more readily be able to purchase new aircraft, which in his view, are fundamentally safer than those that constitute the present average 15 year old piston engine commuter fleet. A major part of those overheads is of course, the cost of air traffic and associated services.

However, with all the past political, industrial and emotional media hype distorting the facts, the problem is to determine just what level of service is required in any future airspace system for this country. So much was said and written about the alleged safety deficiencies in the 11/11 proposal that it is understandable that the Caa Board would wish to be seen to be introducing a system with a supposed higher level of safety whether it is necessary or not.

But clearly it would be wrong to saddle Australia with an airspace system that is out of kilter with the rest of the Icao nations, as can be clearly demonstrated, just to satisfy certain self interest groups, or as a face saving exercise for those who got it wrong last time. The issues have all been identified and thrashed around sufficiently for all to be aware of them; it is difficult to imagine anything new emerging from further study. With time running out for the introduction of Taaats, perhaps it is time for one big seminar to be held, to be attended by top level Caa management, and all the industry bodies, for all points of view to be heard, and a final consensus decision made.