[Peetwo]

Harfwit & CO in a Class E all of their own?? 


Chair Senator Mack questions the Harfwit in Senate Estimates...

CHAIR: I've had a significant amount of contact around this—not positive—so I'll look forward to a demonstration of how this is going to maintain activity, particularly in general aviation, and what is the demonstrated safety case, because there was also another case—anyway, I have committed to not holding things up for too long. I am very interested in this topic, and I hope you'll include me in your advice as to when you are prepared to go to CASA.

Mr Harfield : Absolutely. I will admit that, as a result of the way we initially positioned some of our wording, some of the feedback that we got did give the impression a decision had been made when that was not the intention at all. That's why we are going through the process of making sure we have taken on board over 1,000 pieces of feedback. We're now back out again, and we'll make sure you see that. After that consultation, when we get to where we want to finalise it, we will put that out for comment as well.

AusALPA call 'BOLLOCKS' on the Harfwitted, tranpsarent, monkey in the room...  : Ref - AusALPA submission to ASA on class E proposal:    

...Transparency of risk identification and feedback processes

AusALPA is concerned that Airservices is exacerbating rather than repairing the perception that Airservices is rushing ahead with significant airspace changes based on an internal agenda rather than openly and transparently adopting an incremental
Australian Airline Pilots’ Association approach that is informed by the operational experience of the airspaces users, both in identifying potential hazards and post implementation.

In reviewing Airservices design and implementation safety case documents supplied to us under FOI provisions, we were disappointed to find significant parts of risk management discussions with industry representatives and others were redacted, far beyond anything vaguely associated with protection of personal privacy. The level of redaction indicates that the default Airservices position in regard to public exposure of the design and implementation safety cases for airspace changes is one of secrecy rather than the provision of transparent primacy to aviation safety.

AusALPA also notes that the consultation process for this latest proposal has bypassed ASTRA, the primary consultative body for these sorts of proposed changes. That decision is incomprehensible, especially given the level of industry representation and commitment to ASTRA, as well as the quality of advice demonstrably available.

Furthermore, the window for public consultation for such a far-reaching and significant change is inappropriately short, particularly at a time when many affected industry people are displaced from their primary occupations and desperately trying to survive. Coupling the short comment period with the very fact that Airservices intends to submit an ACP within 7 days of comment closure inexorably leads to the conclusion that Airservices has no intention or capacity to change the proposal to reflect industry feedback.

A number of our members have commented negatively on the attitude of Airservices representatives at the webinar intended to explain the proposed changes. They expressed to us the view that the process was box-ticking a consultation process for changes that, regardless of industry feedback, would be in place by December this year.

AusALPA considers the whole approach to this critical consultation to be arrogant, unsustainable and incompatible with appropriate aviation service provider governance.

We also note that, unlike many other agencies within the Transport and Infrastructure portfolio, Airservices does not publish stakeholder commentary or submissions. We view such public exposure of feedback by other agencies as a very positive feature of improving those agencies’ contribution to the Open Government initiatives of the Commonwealth government and we strongly recommend that Airservices reviews its somewhat recalcitrant view towards public scrutiny of its safety-related decision making...

...Conclusions


AusALPA does not support the proposal to lower the base of Class E airspace to 1,500ft AGL in medium and high density enroute airspace between Cairns and Melbourne in December 2021 and believes that a significant rethink is required. The proposal should be withdrawn.

The Design and Implementation Safety Cases for this proposal (and all elements of the AMP) should be made public and redacted only to the minimum extent required to protect individual (but not corporate) privacy.

Many, if not most, of the touted benefits of this proposal are more hubris than of substance. In some cases, the likely outcomes are the opposite of what is suggested.

The proposal continues what seems to be a myopic rush to install Class E as the default Australian airspace but without the subtleties and operational maturity of the US NAS system upon which it is based.

AusALPA has seen nothing in the way of post implementation reviews (with particular emphasis on the flight operations aspects) of the existing pockets of Class E with lowest levels of 700ft and 1200ft AGL. The current proposal should not be implemented in the absence of such reviews, given the significant consequences of the proposed changes.

We consider 1500ft AGL to be an inappropriate choice for the lowest level of the proposed Class E airspace.

Our previous comments about the management and direction of Airservices airspace projects remain apposite...

Hmm...hopefully AusALPA are keeping an active brief on this with Chair Mack and the RRAT committee??

MTF...P2