The skies above Mangalore will be increasingly congested with the premature closure of NDBs in Victoria. mangalore airport

Unintended consequences

NDB decommissioning too fast too soon

The RAAA continues to attract membership applications from flying training organisations (FTOs), highlighting an emerging demand for a single, unified voice for this sector. Coincidentally, the theme for our annual convention to be held in the Hunter Valley later this year is Strength in Numbers. Working with the RAAA ensures that key people from the FTOs have a strong and clear voice around the regulation development and amendment table.

FTOs are all too aware that CASR Parts 141, 142 and 61 have issues that currently have the attention of a hardworking team within CASA. Let’s hope the time and effort expended on the rewrite will produce workable solutions for industry that will be proportionate to the safety risks being addressed.

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However, there is a much more immediate and pressing safety concern that needs urgent attention. The Navigation Rationalisation Project aims to decommission a number of ground-based navigation aids across the country. On the surface this is a worthy project as the industry transitions to satellite-based navigation. However, one still needs to descend and make an approach to the intended destination. CASR Part 61 requires using navigation aids for IFR training and both 2D and 3D approaches are required to be tested – and therefore trained – in an actual aircraft. A significant amount of flying training is conducted in Victoria and FTOs are currently voicing their concerns that the rationalisation project will have an unintended consequence of dramatically increasing the likelihood of a near miss (or worse) over an increasingly congested airspace around NDBs in particular.

There are currently 21 NDBs in use in Victoria but the decommissioning project is set to reduce this number to four for the entire state. This will result in traffic congestion at Mangalore and Avalon and traffic conflicts with a mix of VFR and IFR traffic.

In addition, expect increased workload for ATC in IFR traffic separation and management and increased traffic congestion at Moorabbin as the only available NDB with a ‘prescribed airport approach procedure’.

Even worse and perhaps more frightening is that in WA there is only one NDB available outside CTA in the Perth basin, that being at Cunderdin.

As it stands Prescribed Instrument Procedures from the navaids earmarked to be decommissioned have already been removed from publication and by virtue the use of these aids is defunct. This will significantly increase congestion at remaining navaids.

To give some scale to the issue four FTOs have published the following data – collectively they have conducted 6,075 hours of IFR training including 13,810 approaches in the last 12 months.

In combination the CASA Manual of Standards, Part 61’s requirements and the Flight Test Office (Flight Examiners Handbook) require 20 hours of instrument training plus flight testing to be conducted in an actual aircraft, demonstrating competency in the approach. These figures do not include currency training or private or commercial operators actually using the aids.

The RAAA calls for a temporary moratorium on any further decommissioning. Clearly we need a collaborative approach to ‘take a closer look’ at the decommissioning dates until we can design a more considered and safety-focused approach, rather than a calendar-driven approach. An objective starting point would be the risk assessment data previously considered as part of the decommissioning change management plan and the risk mitigation procedures that were considered as part of the increasing IFR flights around decreasing aids. Next would be an assessment of the planned IFR training needs over the next, say, five years.

Together we should be able to determine which navigation aids should be retained, at least in the interim. The safety outcomes required are reducing the predictable ATC workload particularly at Avalon and Mangalore, reducing the risk of near misses in high traffic areas, and reducing traffic workload for approach and area controllers, permitting resources to be better allocated to airline traffic.

We all want a safe management plan for a transition to where and how IFR training is to take place as the required navigation aids are made redundant. Most importantly, we need an event-driven project plan where important mitigators are actually in place in a logical and safe sequence prior to any further decommissioning.

On the surface this is a worthy project.

 

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