AFAP SAFETY & TECHNICAL - OCT 2018

AFAP SAFETY AND TECHNICAL BRIEFING – OCT 2018

The AFAP is an association of professional air pilots as well as being a Union. As an association of professionals, we maintain a focus on all aspects that affect our air pilot profession and for this reason, we are quite active in aviation safety and technical matters.

This S&T Briefing contains updates and information on our latest dealings with other aviation industry stakeholders. This includes with CASA and the regulatory reform process, the nature of our inputs to consultations and meetings, and any updates or recent changes of interest to our pilot members. The briefing also contains requests for inputs so to provide you with the opportunity contribute and have your opinions heard. In this issue we are specifically requesting input regarding CTA Steps and Safety Action Groups (SAGs). We hope you find the update interesting and informative however we acknowledge that it won’t be as humorous as the GA Herald.

The AFAP Safety & Technical Team.

CASA Consultative Business



RAPAC Meetings

Do you want to learn more about RAPAC and these meetings? CASA RAPAC Page

At the Southern QLD RAPAC meeting,

At the July meeting of the SQLD RAPAC, AusALPA sought an Action Item for CASA and the BOM to provide, by the next meeting, a proposed action plan/timeline for dealing with the outstanding Trend Review issue. At the SQLD RAPAC held in October, the CASA representatives weren’t able to provide any detail as to what this plan or timeline is. The Chair from the meeting promised to provide an update soon (out of session) in order to make good on the Action Item. Following this meeting, discussions with CASA indicate that we should be able to provide an update to members in our next S&T Briefing.

Out of session for the VIC RAPAC meeting,

Recently CASA and Airservices consulted with the RAPAC to a change to the airspace south of Melbourne to accommodate the new GLS Approach. The RAPAC reluctantly reached consensus that the control step would be lowered by 500 feet. This obviously affects the VFR transit lane underneath. However, there wasn’t a commensurate consultation for the altering of the direction levels that VFR aircraft should fly through this space in spite of these being altered to be the opposite to what they were previously. The charts are about to become active for this change and it is anticipated that this will be a hot topic of discussion at the VIC RAPAC meeting on the 19th of November.

Technical Working Groups (TWGs) CASA TWGs

Part 119 (Air Transport Operators - Certification and Management)

CASR Part 119 has now been consulted independently to Parts 121,133 and 135. The AFAP and AusALPA had suggested and requested this as we believed that there had been insufficient time and focus specifically applied to Part 119 during the previous TWGs. AusALPA had two participants, one from the AFAP and one from AIPA. In the lead up to this meeting representatives from both AFAP and AIPA meet with personnel from CASA to discuss the proposed alteration to the FDAP provisions. The meeting went well, and CASA understood our concerns that the proposed rules clearly outline the exceptions to the protection of FDAP data but don’t clearly outline the protections for it and what should happen if these protection obligations aren’t adhered to by operators and or the regulator.

Part 121 TWG (Commercial Air Transport Operations - Aeroplanes)

This CASR Part applies to operations of large fixed wing aircraft in air transport operations. The TWG agreed to endorse the Part with caveats that included CASA assurance that changes would be made if deficiencies or problems were identified before legislation, approx’ 2.5 years from now and that the Part 121 MOS is drafted and consulted with its own TWG.

TWG OUTCOMES

The TWG is to provide a concise summary to the ASAP recommending either:

a. That the ASAP endorse CASR Part 121.

b. That the ASAP endorse CASR Part 121 noting that further discussions are required in relation to certain provisions, including the publishing of a legal draft of the Part 121 MOS.
c. That the ASAP not endorse CASR Part 121 due to underlying policy inconsistencies or until the Part 121 MOS is legally drafted.

The TWG decided to go with option B.

Part 133 TWG (Air Transport Operations – Rotorcraft)

Safety and Technical Officer Julian Smibert participated in a meeting for the purposes of reviewing the public consultation feedback on CASR Part 133. The Part 133 final report is with the ASAP as they prepare their advice to the DAS. The October 4th meeting reached a General Consensus with regards to the three questions asked of the TWG which were:

  • Does the TWG agree that the CASR and MOS will achieve the policy intent
  • Will the CASR and MOS be implementable
  • Does the TWG a endorse the policy intent of the draft CASR and MOS

Initially the third point was the subject of dissent as the original question appeared to ask for endorsement of the draft CASR and MOS when the final drafts had not yet been released. With the changing of the wording to policy intent this objection was addressed.

While the general thrust of Part 133 is acceptable, the drafting style and layout is consistent with other CASR Parts, in that they are not easy documents to read or interpret in many instances. Consequently, it remains to be seen how readily they are implemented by industry and at what cost. Much will depend on the clarity of the still to be produced guidance material.

Part 138 TWG (Aerial Work Operations – Aeroplanes and Rotorcraft)

This CASR Part applies to the operation of an aircraft for an aerial work operation if the aircraft is an aeroplane or rotorcraft and Part 101 (RPAS & Rockets) does not apply. This Part also doesn’t apply to aircraft if they are engaged in a police, national security or customs operation.

This TWG was held on the 10th and 11th of October for the Part 138 CASR. There will be a later working group meeting held for the Part 138 MOS, possibly by the end of the year otherwise it will be in early 2019.

The S&T team weren’t invited to participate in this working group however we anticipate providing a submission to CASA on Part 138 once the opportunity arises. If you are a pilot who operates under Part 138 type arrangements, and you would like to contribute some feedback and input to the Part 138 CASR and MOS consultation, then please get in touch with the S&T team to participate. technical@afap.org.au

Part 139 TWG (Aerodromes and Heliports)

CASA Aerodromes section held the Part 139 TWG meeting in early October. The Part 139 final report is with the ASAP as they prepare their advice to the DAS. Some of the prominent discussion items included:

  • The meeting participants discussed how the various CASRs inter-relate and that CASA should consider providing clearer understanding to industry on this. This has come up with most of the TWG meetings. CASA suggests that they will provide an exposition guide for complementary rule sets.
  • Visual approach slope guidance was discussed and AusALPA believes that the requirement for this (such as a PAPI) shouldn’t be predicated on whether or not an aircraft has jet engines. Our position is that this should be predicated on aircraft performance not engine type.
  • PANS Aerodromes – AusALPA would like to see this mandated or at least the criteria for the aeronautical study.
  • Wind shear needs to be identified as a greater hazard than plumes (which are regulated). Off-airport activities and structures can affect windshear however these aren’t considered for assessment. This includes development approvals across State and Local Government jurisdictions in relation to OLS.
  • Enhanced taxiway markings – recommended at international airports with RVR < 550m
  • Various lighting matters including assessment of apron floodlighting and the standards for the tone of colour of airport lighting.
  • How CASA will transition existing approvals/exemptions/variations including cost and process over to the revised rules.

Part 139.H TWG (Aerodrome Rescue and Fire Fighting Services - ARFFS)

Subpart H to CASR Part 139 will have its’ own dedicated TWG to discuss proposed changes and seek stakeholder consultation. CASA informs the AFAP that this is likely to occur early in 2019. In anticipation of this consultation and working group meeting, the Safety and Technical team have begun meeting with key stakeholders in the ARFFS area and initiated some joint collaborations.

The AFAP is concerned that some of our aerodromes in Australia have fallen below the ICAO SARPs guidelines for ARFFS.

CAO 48.1 TWG Fatigue Issues - Fatigue Rules Review



The new rules are coming:

CASA has amended the final transition date from the 31st of October 2018 to two later final transition dates. High capacity RPT operators will be required to transition to the new fatigue rules by the 30th of September 2019. All other operators will need to transition by the 26th of March 2020.

Some noteworthy points:

Review of consecutive early starts and disrupted rosters - CASA will develop additional mitigations to deal with consecutive early starts and back of the clock transitions using the approach in CAO 48.0 as a starting point and seek TWG feedback. Following feedback, amendments to the rules may be proposed. The AFAP has and will strongly oppose the current draft rules provisions which don’t provide any mitigations for consecutive early starts.

Window of Circadian Low (WOCL) definition - CASA will consider whether there is benefit in explicitly defining the WOCL and seek TWG feedback. Originally some TWG members, including the AFAP, suggested a definition of 0200-0600; however at the July meeting, there was unfortunately no consensus on the need for a definition, the associated time period or the additional mitigations that should be associated with the definition. We believe that there must be appropriate special recognition of this time period in the rules in recognition of the natural human wakefulness cycle and so that appropriate fatigue mitigations can be devised and applied, such as those associated with consecutive early duty starts. The latest meeting (last week) indicates that we may be moving closer to an agreed definition and inclusion.

Fatigue surveys - CASA will commission regular third-party surveys of pilots to establish a fatigue baseline, assess the impact of fatigue rules and identify further continuous improvement opportunities. This is a measure that the AFAP has been particularly vocal on. In 2017, we took the initiative to sponsor such a survey to demonstrate both the need for it and the benefits of it. This has been a particularly good win for sensible fatigue data collection as the data will help identify further continuous improvement opportunities. Regular periodic surveys will no doubt build upon that.

Fatigue Management and SMS integration - CASA will amend guidance material to encourage operators to have an appropriately scaled SMS prior to applying for an FRMS. In any event, the introduction of CAR Part 119 in March 2021 will require such an approach anyway. Furthermore, CASA will integrate the fatigue training requirements for tier 2 appendices with non-technical skills training. I.e. NTS training will cover Fatigue Management training too.

Flight Duty Periods - For appendix 2 and 3 operations, CASA intends to amend the prescriptive limits for flight duty period within CAO 48.1 Instrument 2016. Prior to the recent meeting of this TWG, CASA had proposed a new table but given that there now need to be consideration of other aspects such as the WOCL and consecutive early starts, the duty limits related to start times and sector quantity is yet to be finalised.

CASA intends to retain the prescriptive limits for flight duty period within CAO 48.1 Instrument 2016 for Appendices 1, 4, 4A, 4B, 5, 5A and 6.

Fatigue Assessment and Definition - CASA intends to form a working group with an independent body such as a university and selected industry participants to develop a definition and methodology for reporting and assessing fatigue within safety incidents and occurrences. This will hopefully lead to a decrease in the subjectiveness and inconsistency of understanding of what is a ‘fatigue-related safety occurrence’.

Next steps: The Fatigue Rules Review TWG has been reconvened to review the CASA proposed changes. This TWG meeting occurred from the 31st of Oct to the 2nd of Nov. Progress was made during this meeting however, more work is required still. It is likely that the next public consultation will occur prior to a reconvening of the TWG in mid-January. That way, the public consultation feedback can be reviewed by the TWG prior providing a position to the ASAP. The TWG could then meet a further two times during early 2019 to finalise any outstanding matters.

We will provide members with further updates on the Fatigue rules Review process in the following S&T Briefings.





AusALPA Safety & Technical Updates


AusALPA is a safety and technical partnership between the AFAP and AIPA. In line with the committees of IFALPA, AusALPA focuses its attention and work through the Committees AAP, ADO, AGE, ATS, HUPER, LEG/PGA, SEC/DG. Various working pilots have volunteered to contribute to the progress of safety and technical matters through becoming a S&T Rep. Reps help to provide a broader perspective on matters than would otherwise be the case through the S&T staff alone. We thank these dedicated aviation professionals for their contributions and insight. Professional development, networking opportunities and the ability to affect positive change are all reasons cited by the S&T reps as benefits of being part of the S&T team and cause.

The AusALPA Presidency alternates between the AFAP and AIPA Presidents every two years. The AFAP currently holds the AusALPA Presidency and as such, Louise Pole also steps into the AusALPA Presidency as a result of becoming the current AFAP President.

For more information, contact the S&T team by emailing: technical@afap.org.au

Accident Analysis & Prevention (AAP)

IFALPA AAP committee meeting

AusALPA is hosting the IFALPA AAP committee meeting this November in Sydney. Delegates from many nations will be attending to discuss the current trends and hot topics in this area. ICAO Annex 19 is likely to be discussed and this relates to Safety Management Systems. From an Australian perspective, Annex 19 will lead to CASR Part 5. This is yet to be drafted and thus, this AAP meeting may be a great opportunity to share ideas between professional pilots from different nations on application of Annex 19 into civil aviation regulation.

The Commissioner of the ATSB, Greg Hood, will be attending the meeting too.

Safety Action Groups

Are you a member of your organisation’s Safety Action Group (SAG)? Would you like to contribute to SMS matters in a more meaningful way? We’d like to hear from you. ICAO has recently updated its guidance material for SMSs including for SAGs. At some point in the not too distant future, CASA will introduce clearer regulation in relation to AOC holder’s SMSs (CASR Part 119). Also, CASA will draft a CASR (Part 5) to better align Australia with the ICAO SARPs on SMS (Annex 19).

If you are an AFAP member and are involved in your organisation’s SAG, please email technical@afap.org.au

Aircraft Design & Operations (ADO)

Manual of Standards (MOS) for CASR Part 101 - RPAS and Rockets

CASA is proposing a MOS for Part 101 operations and is now consulting for further input to these proposed rules. In May, AusALPA Rep Will Stamatopoulos participated in a TWG meeting for this purpose. AusALPA intends to provide further comment through a submission to this consultation. The new rules are looking to:

  • prescribe requirements for RePL (Remote Pilot Licence) training course administration including requirements for RePL training instructors
  • prescribe aeronautical knowledge and practical competency standards, for RePL practical training courses
  • impose examination requirements for RePL training course theory components

  • prescribe requirements relating to the operation of an RPA or model aircraft below 400 ft in controlled airspace or near controlled aerodromes

  • prescribe requirements for extended visual line of sight (EVLOS) operations
  • impose recordkeeping and notification requirements for the operator of an RPA

For recreational RPAS flyers, the rules will largely remain the same unless access to controlled airspace is sought.

To date, CASA now has a total of 21 RPAS Flight Operations Inspectors (FOIs), at various locations around the country to assist and facilitate organisations operating in this sector of the aviation industry.

RPAS Impact Testing on an Aircraft Wing



While tests on bird strikes have been conducted for decades, what kind of damage an RPAS would cause was still virtually unknown…until now. This is a link to a YouTube video of testing and data collecting of hobby size RPAS colliding with the leading edge of a light aircraft wing. YouTube link: RPAS Impacts Wing

CASA is currently open to consultation on the RPAS CASR Part 101 MOS. The standards cover a range of issues including training, extended visual line of sight operations, record keeping, notification requirements and operations in controlled airspace. This link will take you to the relevant CASA Consultation page: RPAS Rules Consultation This consultation is open until the 18th of November 2018. Alternatively, provide your thoughts to the AFAP prior to that date: technical@afap.org.au

Fuel Rules

CASA is providing existing AOC and Part 141 certificate holders more time to comply with the new fuel requirements under the CAR 234 amendment by issuing a new exemption.

You will now have until 28 February 2019 to comply with the requirements of the new regulation and CASA Instrument 29/18 (the Fuel Instrument). To read more about these changes, click here: Fuel and Alternate Requirements Project


Aerodrome & Ground Environment (AGE)

Melbourne Multi Taxi Lane (MTL) Proposal

APAM (Australian Pacific Airports Melbourne) will be seeking approval from CASA for the establishment of Multi Taxi Lanes (MTLs) on two of the aprons at Tullamarine. AFAP S&T staff attended a risk assessment workshop in September to provide professional pilot input into the consultation process.

MTLs are to provide the ability for two Code C aircraft to operate parallel on an aerodrome apron at the same time, thus providing efficiencies for movements of aircraft to and from bays and aprons. Additionally, the same apron will also be available for utilisation in an alternate scenario of a single Code E or F aircraft operating on the same apron without other simultaneous aircraft movements.

Some of the proposed design features include:

  • Line colours to be as recommended by the Airports Council International (ACI) – Code C line colours are proposed to be; one orange line and one blue line. The central Code E/F line will be yellow (unchanged from the existing design).

  • Taxi-lane (TL) lighting circuits will be arranged so that either, both Code C taxi-lane lights will be illuminated, OR the Code E/F taxi-lane lights will be illuminated. The switching will be designed so that Code E/F and Code C lights cannot be illuminated simultaneously.

  • Code C taxi-lane lights will be one Code C taxi-lane with yellow lights and the other Code C taxi-lane with green lights.

  • The central Code E/F taxi-lane will have green lights.

  • MAGS (Movement Area Guidance Signs) will provide guidance to all taxi-lanes (Y1, Y2, Y3, J1, J2 & J3).
This first diagram below is the proposal for parallel Code C operations. The second is for single Code E/F operations. Note that the lights are only illuminated for the applicable operation and the alternate MTL options have the TL lights extinguished. These pictures also display the proposed colours. (Pictures and line spacings may not be to scale)



Currently, it is anticipated that the proposal will involve a procedure for a “follow me” vehicle for the entry and exit of the larger aircraft (Code E/F) to and from the apron and bays. A standard set of radio phraseology would also need to be developed.

National Runway Safety Enhancement Group (NRSEG) - Oct 2018


This was the second meeting of the NRSEG. The essential purpose of the NRSEG is to facilitate the cooperation and collaboration across the aviation industry to enhance runway safety performance in Australia. AusALPA had previously lobbied for the return of this national airport-based forum. We believe that learning and sharing lessons nationally helps progress improvements in a more efficient manner than would otherwise be the case. The airport representative present agreed.

With this in mind, Airservices will progress an online forum for the NRSEG stakeholders so that such information can be more readily shared and so the relevant people in various stakeholder organisations can be contacted.

One hot topic for discussion was regarding stop bars and the case study of the many non-compliances at Perth in April. There have been stop bar violations at various aerodrome locations but not to the level which occurred at Perth. Stop bar communication to stakeholders did occur in the lead up to their introduction at Perth. All 30 stop bar violations occurrences involved ATC issuing a clearance to enter the runway, without the stop bar being extinguished by the Controller and just as notably, not challenged by the Pilot(s). It has been a human-factors learning outcome from these occurrences that a verbal clearance is a stronger decision driver than the visual lit stop bar factor.

All pilots are reminded to not cross a lit stop bar and to always challenge ATC if you have been given a clearance to enter a runway but the stop bars aren’t extinguished.

Local Runway Safety Team meetings

News from the Darwin Airport LRST Meeting


This was the reintroduction of this local Darwin consultative meeting and AusALPA had participation through S&T Rep Rob Close. Some of the main discussion items included:

  • A detailed analysis of runway incursions. Darwin averages 10 incursions per year, aircraft incursions primarily involved incursions of RWY 18/36

  • During Exercise Pitch Black, displaced thresholds were used to create Operational Readiness Platforms (ORPs) at the end of runways 11 & 29. At the end of their deactivation period, there were times the full length was available but the displaced threshold PAPI was active, meaning there were two PAPI indications for the runway. The RAAF acknowledged this and committed to creating better procedures prior to next year’s exercises.

  • Low Visibility Operations at Darwin will be included in the next ERSA amendment. Runway Guard Lighting reliability has been improved since the completion of a project to upgrade the cabling for the lights.

Air Traffic Services (ATS)

Voluntary fitment of ADS-B technology in VFR aircraft

CASA has recently announced its proposals for the fitment of low-cost ADS-B equipment in VFR aircraft. AusALPA provided a submission in February 2018 to the public consultation on this topic. As we see it, two of the benefits for the broader aviation community are that there is an increased visibility of, and between, aircraft exposed to the risk of collision with other air traffic; and there is an increased visibility to ATC of VFR aircraft. We raised some concerns that there should be at least some minimum standard for the equipment to ensure that the safety and functional outcomes are not compromised. The minimum standard for VFR aircraft that CASA is proposing is for ADS-B 1090ES. For type certificated aircraft, ADS-B installations will be classed as minor modifications, eliminating the need for Engineering Orders. For non-type certificated aircraft (including amateur home-built and sports aviation aircraft), owners and operators will be able to install ADS-B avionics under self-administration arrangements. These measures are important to help promote the fitment of the equipment under the voluntary arrangement.

Many of the consultation respondents supported the initiative for lower cost ADS-B and could see the value of ADS-B being widely adopted across the VFR community. There was also strong support for technology that is compatible with different devices and to ensure that it meets an internationally recognised standard.

Implementing these changes will require some amendments to CASA’s legislation, including the ADS-B equipment information in CAO 20.18. An NPRM will need to be issued so that public consultation can be provided on the proposed CAO wording and scope.

To learn more about these changes, click here: CASA Low Cost ADS-B Consultation

BNE ACE (Aerodrome Capacity Enhancement) Meeting

AGE Chair Martin Smith attended this meeting on Oct 30th. This meeting is focused on aircraft flow efficiency and thus, there were a number of topics discussed related to this. Some of these discussions included:

  • RNP approaches and how these cause an issue due to technical limitation of ATC systems. RNP has a relative short final leg and currently there is no present method for the system to “ghost” the position of an aircraft on one RNP to the same distance on an opposing RNP (opposite side of the extended centreline), to allow for fine tuning of separation. Thus, separation adjustments can only be made during short final segment. ILS with a longer final makes for better late adjustments to spacing. There isn’t a present fix for this.
  • Ground Delay Program (GDP) By Exception - There is a move to introduce greater times when GDP will not be operating, unless required. The idea is that GDP may cause ground delays when none are required (ATC tend to achieve better than maestro rates). A trigger of 75% capacity is proposed. However this could cause increased airborne delays. AusALPA and BAC both asked for more data which is not yet available. The point was made that without data it can’t be said the system will be improved with expanded GDP By Exception.

Human Performance (HUPER)

PACDEFF - CRM and Aviation Human Factors Conference 2018

The AFAP was a founding sponsor and remains a principal sponsor of the PACDEFF conference. It is the largest CRM, NTS and Aviation Human Factors Conference of its type in the world. The forum is a non-profit, non-partisan opportunity for Human Factors practitioners to meet and discuss contemporary issues in the Human Factors field, with an emphasis on airline training. This year's conference will be in November and located in Sydney. http://pacdeff.com/ A summary of some of the presentations will be included in the next S&T Briefing.

The “My Health Record” and your options

The AFAP has been asked by members about the Government ‘My Health Record’ and what we recommend members should do about this. In late July, members should have received an email outlining what the AFAP believes are your options and why. To access that advice, please click here: Advice to AFAP members re the My Health Record

Since these earlier communications, the Federal Government has extended the deadline for this notification.

For those that don’t want a My Health Record, the completion date for the online process is now the 15th of November 2018. https://www.myhealthrecord.gov.au/ or call 1800 723 471.

Legal (LEG)



The ICAO Legal Committee comprises legal experts from all ICAO states and meets once every 2-3 years in addition to meeting as the Legal Commission during ICAO Assembly time. Aviation Legal Counsel for the AFAP, Joseph Wheeler, was nominated by IFALPA to attend and represent IFALPA as an official Chief Observer. Also, Joe has recently been elected to the (joint) role of Vice Chair of the IFALPA Legal Committee along with Jay Wells of US ALPA and Nerea from SEPLA (Spain).

The ICAO Legal Committee has set up a new Working Group to study emerging and current legal issues with RPAS. This is due to some uncertainty existing as to where small RPAS fit into the international legal regime headed by the Chicago Convention 1944. The Working Group will involve IFALPA as an observer.

IFALPA has been successful in adding the issue of ‘cyber threats to civil aviation’ to the work program of ICAO’s Legal Committee. However, the issue of civilian commercial space flight was a borderline issue for inclusion. None the less, the contributions by IFALPA to the discussions resulted in a majority of States agreeing to add certain aspects of civilian commercial space flight policy and regulation to the ICAO Legal Committee study program and to continue monitoring this aspect of airspace use for relevance to the Committee’s future considerations.

One legal and policy issue which was discussed and initiated by AusALPA to the IFALPA Legal Committee was the disjointedness in drafting styles of (at least the English) versions of various ICAO instruments and some other aviation-specific documents. In particular some air law instruments either indiscriminately or non-uniformly fail to use gender neutral language, which is generally required under the Guidelines for UN agencies’ drafting styles.

On this issue, there has been an unintended adverse consequence in Australia, where the same linguistic problem has led to potential identification of crew members in official air accident investigation reports. The concerns associated with the use of gendered pronouns are that identifying someone as a “he” or "she" may increase the chance for identification significantly. Secondly, placing objectively irrelevant gender identification into a report may lead to unconscious or conscious biases for some readers. Accordingly, one of the positions the Legal Committee decided upon was to request IFALPA’s Executive Board to revise or refine its own drafting policies in line with UNESCO so that IFALPA member associations don’t become part of any perceived “problem”. Furthermore, the avoidance of gendered language may also be something you want to consider the next time you have to write an incident or safety report.

Professional and Government Affairs (PGA)

The IFALPA PGA Committee plays a strong supportive role in industrial problems ranging from the Ryanair issues in Europe to the Avianca disputes in Colombia and involvement with the Committee ensures that all pilots take the benefit of learnings elsewhere into their industrial negotiations and lobbying efforts. We encourage AFAP members who are interested in this work to contact your AusALPA reps or the AFAP Safety & Technical team so to get involved.

MULTICOM frequency proposed for low level airspace



CASA has completed their consultation and has now provided that the recommended radio frequency to use in non-controlled airspace is as follows:

  • ‘in the vicinity’—within 10 nm, and at a height where your operations could be in conflict with other traffic—of any non-controlled aerodrome published on aeronautical charts, pilots should use the CTAF (126.7 MHz or discrete frequency) as published

  • anywhere within a Broadcast Area, pilots should use the dedicated Broadcast Area CTAF

  • in all other non-controlled airspace, pilots should be on Area VHF.
To affect this, a policy change won’t be introduced but rather, an education campaign. However, this will include changes to the AIP and CAAP 166-01.

To provide better situational awareness for pilots, the number of charted aerodromes on the visual aeronautical charts will be increased.




Controlled Airspace Steps - Do they contribute to your descent being “lumpy”?

We’re interested in your thoughts on controlled airspace steps and if they’re truly fit for purpose. Many of the current CTA steps are historical fixtures from many years ago however, there has been great improvements with modern aircraft aerodynamics, such as the introduction of winglets to a sizable portion of the domestic jet aircraft fleet. This has resulted in aircraft having reduced drag (which was the intention) however this also means that ideally, descent needs to be initiated earlier than it used to. An obvious challenge is that any operational/company requirement to remain within CTA is more difficult than it used to be in years gone by.

We’d like to initiate a conversation to begin to learn more about this, to identify the more challenging CTA steps and circumstances and hopefully progress the conversation so to address this problem. This won’t be a quick fix but with the right information, we can hopefully progress improvements so to relieve you of having to fly a lumpy descent sequence. Please be mindful that clear language and the accuracy of information provided will better assist in progressing this initiative. Responses can be submitted to technical@afap.org.au

Wagga Wagga Airspace Review

AusALPA provided some feedback to this airspace review after asking members for input. Some aspects of our feedback included:

  • The airspace has peak demands for access by RPT, local based training and transient training, in addition to the Charter and Private GA operations. Outside of peak demands it gets quiet.

  • Controlled services are preferred over Class G however commissioning of CAGRO facilities (certified air/ground radio operator) may be a helpful option too if a TWR operation isn’t feasible. Class E steps to a relatively low altitude could also be an improvement if the preferred option of Class C isn’t agreed upon.

  • Ground based infrastructure factors: With often full or congested circuits and frequency use, backtracking for Transport Category aircraft is a challenge for these aircraft and for others that need to accommodate these operations.

  • The alteration of the non-sealed strip has led to greater pressures on this congestion at times.

  • An up-grade of the main taxiway to become a full-length parallel taxiway (to allow Category C aircraft standard/Dash 8; Q400) would mean that all traffic could better sequence with each other.
The CASA OAR is due to release a report in the near future and further comment will be possible then.

Hamilton Island Ground Based Navaids (C-VOR/DME) - We Surveyed You

In 2017 tropical cyclone Debbie damaged the C-VOR and DME equipment at Hamilton Island. In late September this year, Airservices asked industry stakeholders for feedback on a proposal to permanently decommission these Navaids. These Navaids form part of the industry-agreed Backup Navigation Network (BNN) and as such, may not be decommissioned without completing a safety and risk assessment.

We surveyed our pilot membership to find out what you thought. Thank you to the many pilots who responded. We asked “from a safety and operational perspective, do you consider this Navaid removal to be reasonable and acceptable?” There was support both for and against this proposal and many of you elaborated on the reasons for your position.

The reoccurring themes from the responses were:

  • The Navaids provide a good back up to the GPS approaches and should remain in the BNN

  • IFR aircraft shouldn’t need these Navaids as the GPS approaches are sufficient in the modern IFR age

  • Airservices is just looking to “cost cut”

  • There are sufficient nearby alternates

  • RAIM issues have not been considered and nearby alternates would likely be affected in conjunction with a Hamilton Island RAIM outage

  • There are lessons which should be learnt from Hobart and the issues there

  • Some aircraft don’t have the equipment to use these Navaids anyway

  • The situational awareness and traffic separation benefits that these Navaids provide have not been considered or properly appreciated

  • The provision of the VOR and DME enhance safety and provide greater flexibility and efficiency
Whilst there were well reasoned opinions for each perspective, in our submission to Airservices, we supported the reinstatement of the Navaids. As noted in the proposal communication by Airservices, the Hamilton Island Navaids form part of the industry-agreed Backup Navigation Network (not just a local service) and from our own consultation of pilots who use Hamilton Island, there isn’t agreement to permanently decommission these Navaids.

A decision from Airservices is not yet forthcoming and when we learn of the outcome, we’ll share that in the following S&T Briefing to members.

Airservices News

Recently, the AFAP hosted some representatives from Civil Air at our annual convention. From their presentation to the AFAP, we learnt that there is now an ability for ATC to play back recent RT. This will reduce the occurrence of “say again” requests from ATC to pilots and other frequency users.




IFALPA September update

Download here


IFALPA’s InterPilot Magazine:

In this latest issue of InterPilot, the AFAP has an article outlining our involvement in early stages of IFALPA with a feature on Captain (retd) Ron Stacey’s work too. InterPilot 2018 Issue 4

BECOME AN AFAP MEMBER

Protecting Australia's Pilots

Get Involved with your federation

We are stronger together