[Peetwo]

TICK TOCK..Benalla, Mangalore, Ballina...NEXT?? 

Geoff Fairless (via the UP) provides an excellent, objective analysis of the Airservices Class E Elephant in the Sky...  :

Hi Alpha,

Your arguments are correct however they beg some questions, who analyses the existing system, how do they do it, and will the result become available to the public? I will only address Ballina.

ATSB will undoubtedly avoid the airspace and procedures aspect, the latent issues, as they normally do. In their defence I believe that is because they lack the expertise to make the analysis and have to rely on CASA and Airservices. Both of these organisations, however, have an over-riding goal, to protect their Minister (Information source two senior CASA executives). Hence they have a vested interest in defending the status quo. This is because, by default, they are obeying their ministerial statement of expectations, and, in terms of this argument, the Airspace Act/Regulations, and the Ministerial Airspace Policy Statement. It follows that if the Minister does not tell them to do something differently, then he/she has accepted that they are operating in accordance with his/her expectations.

Airservices has refused to release the safety analysis that it claims was done to justify SFIS at Ballina. CASA should have evaluated that analysis before approving the change from their recommended CA/GRO to SFIS. Why? Because the nature of the SFIS was argued to be simply an extension of the Class G (F?) traffic information service. However, it removed the CA/GRO's capability to visually monitor the circuit area and in particular the runway. This is arguably the most critical area for safety. I would like to see how Airservices treated that removal in their safety matrix and what CASA replied. Incidentally, the last CASA OAR review of Ballina airspace was 16 Aug 2017. There is no published analysis for the latest changes by Airservices.

The other obvious problem with traffic information services is radio clutter. This is particularly true in Australia where pilots have been taught for years that unalerted see and avoid does not work. To keep it simple, each pilot now has to make all the recommended calls, other pilots need to respond to those calls to affect separation, and the SFIS controller has to record the calls and make judgments about how the aircraft are related to each other, and then presumably make more calls to alert the pilots. Add to this the new requirements that force VFR pilots to become "full reporting" before taxiing and the increase in the radius of the MBZ to 15NM (10NM contains 78.5 Sq NM, and 15 NM contains 176.7 Sq NM) now there is a recipe for radio congestion!

It would be interesting to see the safety score on the matrix for that and what mitigation was suggested. The rules do not seem to contain any implemented mitigation other than "let's hope nothing goes wrong" and if it does then again we can say "All of the parts of the airspace system WERE NOT functioning as they should have been". As I understand the US system, it leaves VFR pilots to concentrate on flying, navigation, and watching for traffic, not talking continuously. (Old ATC advice to young controllers - you can't think while your mouth is open) IFR flights are controlled until they must proceed visually and are provided with traffic information on VFR when it is available.

Hopefully, I have demonstrated that there are at least two potential problems with the current Australian system and indicated how the US system has already identified those issues and mitigated them. There is of course much, much more, but time and space preclude going on. 

MTF...P2