AFAP SAFETY AND TECHNICAL BRIEFING – APRIL 2019
The AFAP is an association of professional air pilots as well as a union. As a professional association, we are able to corral our collective corporate and industry knowledge and focus this on all aspects that affect our air pilot profession and for this reason, we are 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, as working professional pilots, the opportunity to contribute and to have your opinions heard. We also have an update on the progress of the fatigue rules reform.
The AFAP Safety & Technical Team.
CASA Consultative Business
CAO 48.01 - Fatigue Rules Review
Public Consultation Campaign
Since our last update, we have been quite active in encouraging our pilot members to participate in the latest round of public consultation on the fatigue rules reform, which closed on February 10. The AFAP S&T team actively campaigned to encourage greater pilot participation than last time and did so through social media, emails, phone calls, video conference briefings and through the provision of an online information package outlining the proposed changes.
In the April 2018 public consultation, there were only 26 responses (total). This time around, there were 331 responses and of these, 300 responses (91%) were individual responses. CASA has noted that most of these individual responses appeared to be from operating pilots. We believe that the vast majority of these operating pilots are AFAP members who contributed as a result of our campaigning. Many of you forwarded your submissions directly to us as requested. We would like to thank all those that provided input to this important regulatory reform process.
The official AFAP response to the consultation is available here: AFAP Submission
To view some of the other submissions (39% allowed them to be shared) click here: Other Publically Available Submissions
Technical Working Group (TWG) meeting positions
- Simulator time:
The AFAP identified that there was an anomaly in the wording of the 2019 Instrument that meant simulator time could not be included as duty. Initially, CASA responded that many seemed to have misunderstood the rule. However after pressure to include this on the agenda and discuss this at the meeting, it was agreed that the way clause 10 was drafted was indeed needing review. CASA will review the wording so that your simulator time IS considered duty time.
- The proposal to exclude a “casual day” call-in from duty was rejected.
- Flight Duty Periods for Appendix 2 and 3 operations (current proposal)
- Daily Flight Time Limits (FTLs):
The TWG considered that there is a lack of scientific data to support the inclusion/retention of a daily FTL in addition to flight duty period limits. The regulatory approaches of FAA, EASA, Transport Canada and the CAO 48 Standard Industry Exemptions (SIEs) were examined with some members recommending a 10 hour FTL for two pilot single sector operations, based on the logic used to draft the 2013 instrument. We argued that the current SIE limits have no scientific basis, that the FAA provided a scientific argument to support their 9 hour FTL and we expressed concern regarding the limits that would apply to FDP extensions. Some members recommended retaining the proposed 10.5 hour FTL for two pilot single sector operations due to the paucity of scientific data available on daily FTLs. 10.5 hours represents the current limit available to be flown under the SIEs. The TWG agreed that the limit should be applied regardless of the number of sectors flown. CASA will decide a limit on the basis of its regulatory philosophy. We recommended that CASA include an explanation of the practical limits on flight time inherent in the flight duty period limits and that CASA monitor fatigue associated with flight time as part of ongoing fatigue evaluation.
- Augmented Crew Rest:
There was protracted discussion about Class 3 facilities being fit for purpose and CASA now only recognising this as “rest”. They rely on shortened definitions from other regulators that say “leg support” and “rest” whereas the guidance from these other regulators refer more specifically to “sufficient leg support”. Although subtle, it seems this position will allow JQ 787 Class 3 rest to continue in its deficient current form.
- Ultra Long Range Operations (ULR):
A longer discussion ensued regarding Class 1 & 2 facilities and CASA’s reticence to define Ultra Long Range operations. No ground was given as CASA now rely on QF’s FRMS trial around these operations. The QF trial has ignored the QF FSAG recommendations and has not included AIPA or FSAG reps in the data collection.
Where to next?
Some members have asked why there has been such a focus on fixed wing/RPT type operations and less focus on other areas. This is because this is exactly where CASA has currently been proposing the greatest amount of changes from the 2013 Instrument. Also, high-capacity and RPT operations are expected to transition to the new rules earlier than the rest of the industry, hence the current focus. CASA has provided some indication that they may again focus on the non high-capacity/RPT areas however they have not provided a commitment to this.
The TWG meetings on Feb 25/26 were insufficient in time and a follow up meeting was held on March 29. Thus you can understand that this is all still a work-in-progress. A report from the meeting will be reviewed by the Aviation Safety Advisory Panel (ASAP) and they will either endorse the changes, reject or suggest some changes. When more details are available, we’ll inform members.
There are many issues that CASA has decided are too contentious to rule on prior to completing the 2019 fatigue rules Instrument. They intend to include such items in fatigue surveys that will be run both before and after the 2019 Instrument is implemented. The AFAP will again encourage the pilot membership to participate in these surveys so to enhance a valid and representative data set.
Do you want to learn more about RAPAC and these meetings? CASA RAPAC Page
VIC RAPAC meeting
The meeting expressed the opinion that the proposals for the proposals put forward by Airservices for changes to airspace management at Ayers Rock were unfit for purpose and the process was unsatisfactory in both content and implementation. (The consultation open period was exceedingly small and the original proposal was for Class E LL at 1200” AGL - The AFAP and AusALPA objected to both of these aspects).
Regarding the proposal for RAPAC to consider allowing Essendon to reduce the RWY strip width, the meeting also stated that in the absence of the expected risk assessments regarding changes to the Essendon 26 RWS, the meeting did not support reduction of the RWS from 300 to 180 metres. The ATSB report into the DFO/Buildings approval process is still pending. CASA notified meeting participants that they considered the matter closed due to Essendon Airport not being willing (or able?) to provide the safety-case documentation. However, Essendon Airport has recently announced that they are intending to reduce the RWY strip width regardless. This is quite a live matter and the AFAP is exploring other avenues to address this latest proposal by the airport operator.
QLD RAPAC meeting
An update was provided by Wellcamp Airport regarding the QF cadet school. It is anticipated that ground school training will commence in July. In September, flying training will commence with 4 aircraft with a progressive increase to 40 aircraft by the end of 2020. This will likely require some airspace changes such as the establishment of VFR waypoints and a danger area for training purposes. AusALPA reminded the meeting that the next viable AIRAC date will be November and the convenor should be cognisant of when the working group is actually established to discuss these matters, so that it can make recommendations in time for the AIRAC dates.
Archerfield Airport has a Major Development Plan (MDP), which includes the extension of the main RWY (at both ends) and strengthening, installation of PAPI, RGLs, RESA. Also there is to be some TWY improvements. TWY B will be upgraded to Code B.
WA RAPAC meeting
The WA RAPAC meeting had an interesting discussion on the use of frequency 126.7. It appears that there are many pilots not using area frequency and instead, just maintaining 126.7. This is likely due to the belief that there is meant to be a continuous use of 126.7 (sometimes known as Multicom across low levels). This is not so and CASA will soon have education material coming out on the topic. CAAP 166 outlines rules and recommendation for RT calls, the new AIP will also have the table from the CAAP and a revision to the VFRG is planned.
An issue with mapping has been raised in that it has not kept up with changes in introductions of new aerodromes. A mismatch exists between VFR and IFR charts for what aerodromes exist. All VFR charts will show all Y designated aerodromes, whereas all ERC charts will display all registered aerodromes. A change will be made for the colour coding to designate whether an aerodrome has validated or unvalidated data. Due to lead time required on new charts, not all changes will be made on the May AIRAC cycle charts.
NSW/ACT RAPAC meeting
Airservices is having increasing issues with ATC staffing levels to the extent that some enroute services are being curtailed and there will be reduced hours (and days) of operations at some regional tower airports and possibly enroute services.
Significantly more data will be available on the BOM site which raised the question of ‘how legal’ is it for pilots to use this data. Basic CASA answer was that data for aviation should be sourced via NAIPS, but the question was being reviewed.
The Tamworth ILS has been withdrawn (25/2/2019 until mid-2019+) for replacement of facilities.
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.
For more information, contact the S&T team by emailing: firstname.lastname@example.org
Accident Analysis & Prevention (AAP)
ATSB Safety message
The ATSB has conducted an analysis of wake turbulence occurrences at Sydney Airport (2012–2016). Sydney Airport is the only major Australian airport currently with parallel runways. The distance between these runways is such that they are treated as individual runways and do not require the application of the wake turbulence separation standard for aircraft operating to a single runway. However, the investigation found that at Sydney Airport, when the time between arriving aircraft (including those operating on parallel runways) is less than one per minute, the likelihood of encountering wake turbulence increased substantially, with Runway 34 Right (the shorter of the parallel runways) the most likely to be affected.
The ATSB has developed a safety message - When departing or arriving at Sydney Airport, aircrews need be alert to the increased likelihood of encountering wake turbulence especially during periods of high movement density or during parallel runway operations, when operating on Runway 34 Right with wind coming from the west or north-west, and/or following an Airbus A380. Click here to read the AusALPA Wake Turbulence Briefing Leaflet
Or to read more from the ATSB about this, click here: ATSB Sydney Airport Safety Message
Aircraft Design & Operations (ADO)
Magnetic Pole Variation and Magnetic North Vs True North
The Earth's north magnetic pole is on the move, unpredictably moving away from the Canadian Arctic and toward Siberia. It's moved so much recently that the current model of the entire globe's magnetic field, last updated in 2015, is now out of date. Thus, geologists have come up with a new model. The latest World Magnetic Model was designed to last until 2020. Some rough information on the magnetic pole movement is that prior to 1990, it was moving about 15 kms per year. Since then, it is more like 55 kms per year. This potentially has an impact on the calculations for magnetic variation, traditional navigation techniques and the accuracy of navigation charts that depict variation.
AusALPA Rep Ron Stacey has raised the issue of the shifting magnetic poles and the effect upon aviation navigation. Maritime operations already reference True North and have done so for some time. With the use of GNSS as the primary navigation source, there is a growing section of the aviation community that wants to transfer reference to True North. Realistically, this change would need to be an internationally recognised move with IFALPA support and input.
CASA now is mandating and updating the requirements for registration and education for RPAS and RPAS users. This is a win for AusALPA. The registration and accreditation requirements are proposed to apply (with certain exceptions) to the following RPA:
- RPAS more than 250 grams operated recreationally; and
- all RPAS operated commercially, including excluded RPAS operations, regardless of weight.
- flyers of RPAS weighing more than 250 grams will need to pass an online education course
A staged implementation is planned whereby registration and accreditation are progressively introduced:
- 1 July 2019 – RPAS operator certificate (ReOC) holders (registration only)
- 1 September 2019 – Excluded RPAS operators (Sub 2k and flying over your own land) (accreditation and registration)
- November 2019 – Recreational RPAS operators (accreditation and registration)
Aerodrome & Ground Environment (AGE)
Local Runway Safety Team meetings
Sydney LRST Meeting
Incursions largely due to call sign confusion, no clearance being given, and an increase in foreign pilots operating to Sydney. Overall a reduction when compared to 2017 figures. However, there is an increase during 2019 compared with same time last year.
AusALPA has expressed our concerns re the impact of the Port Botany development proposal on 16L/34R. The port’s proposal by consultants concluded that wind/turbulence would not be a factor, however SYD and AusALPA do not believe this and SYD airport has commissioned its own study which has indicated that turbulence appears to kick in at 22-23 kts. Unfortunately, SYD does not have sway with development as it is outside the OLS, except for cranes that might infringe on OLS.
Gold Coast LRST Meeting
The Gold Coast ILS approach has now been introduced. The ILS-Z approach became active Feb 28 with minima down to 330 AGL. However, due to ongoing noise issues, the ILS will be the least preferred approach. It also cannot be used for any flight training or recency requirements. Read more in AIP SUP H04/19.
Buildings in the Vicinity of Airports
AusALPA is still anticipating the report for the currently open and pending ATSB investigation (AI-2018-010). This investigation was initiated when the tragic Kingair accident at Essendon (February 2017) raised some buildings approvals process questions worthy of further investigation. The protection of airspace around our airports is a matter AusALPA considers to be of significant importance.
This investigation was originally due for completion in February but is now being flagged for completion in Quarter 2, 2019
Air Traffic Services (ATS)
Hobart airspace review update.
Over the last year, many AFAP members raised with us many issues related to the Hobart Airspace and procedures. From these discussions we were able to collate your concerns and influence the subsequent proposals and review. A thorough review of this airspace is nearing completion and some positive changes are being developed. These include
- the use of visual arrivals
- STARs with visual terminations
- more CTA to the north east (to facilitate more direct tracking to/from ports such as Sydney, Brisbane and the Gold Coast)
- SIDs and STARs for the north east tracks
- More consideration of community concerns of the previous concentration of noise footprints
The replacement the ground based navaids at Hobart is also nearing completion. These are currently operating in a test mode.
Tamworth Airspace Review
The CASA Office of Airspace Regulation (OAR) is conducting a review of the Tamworth airspace. The airspace review will assess the suitability of the airspace from ground level to 18,000 ft. AMSL within 45 nm of Tamworth aerodrome and review risks related to aircraft incidents. If you have any input or thoughts on these aspects, please email email@example.com
Hamilton Island Ground Based Navaids (C-VOR/DME)
Airservices have previously proposed that the Hamilton Is navaids, damaged by cyclone Debbie, not be replaced. There are some cost issues and the fact that the old VOR was a C-VOR, and the replacement would need to be a Doppler VOR, which requires a larger physical footprint. This is one of the challenges involved because this would mean that the top of the “VOR hill” would need to be lowered so to accommodate the D-VOR. During a recent meeting, the AFAP noted these facts and that this would likely trigger an EIS too. However we also noted that there are more things to consider with the overall proposal that were not being considered and were also not asked during the initial consultation. These included the option of only retaining the DME, the benefits of the DME for situational awareness and separation with IFR to VFR traffic, the use of the ground based navaids in updating nav position fixing by aircraft in the general vicinity and most importantly, that the removal/decommissioning of any single navaid in the Backup Navigation Network (BNN) must be considered with regard to the system as a whole. Currently, the consultation and proposal only considers the decommissioning of the navaids related to singular or local needs, whereas the AFAP position is that any decommissioning of any of the BNN navaids should be considered and assessed to the effect upon all the relevant parts of the aviation system and the BNN. No final decision has been made on the proposal to date.
Human Performance (HUPER)
Cabin Air Quality (Aero-toxicity)
The AFAP ran a cabin air quality meeting on Wednesday the 27th march. Attendees included S&T staff, industrial staff, pilot representatives and the GCAQE consultant Dr Susan Michaelis, who is a subject matter expert on the issue.
The AFAP will develop a white paper on cabin air quality with the aim of improving the reporting of fume events and guiding better maintenance and medical protocols for crew after fume events. A new AFAP board member was proposed to the GCAQE board https://gcaqe.org/ and a presentation will be prepared for the AIRCRAFT CABIN AIR International Conference 2019 to be held in September at the Imperial College London. https://www.aircraftcabinair.com/
The ATSB has previously published a research report on this topic area (May 2014). In that report they flag that many reports of fumes/smoke events are insufficient in detail for coding of the source or affected components. Good reporting by aircraft operators, to both the ATSB and CASA, will assist ongoing efforts to monitor the risk of fume and smoke events. The report on this research is available here: ATSB Research - analysis report on fumes and smoke events
The Bureau is currently surveying aviation meteorology users to gain an appreciation of their role in the industry. The AFAP is encouraging its members to undertake this survey. It will take no more than 10 minutes to complete and will be used to inform future Aviation related meteorological research and service improvements. BOM Aviation Wx Survey
The survey will close on 30 April 2019.
GAF and Reference Chart information
With the introduction of the GAFs, some pilots have found it difficult to correlate the associated locations referenced in forecasts with the weather information in the GAFs. The BOM provides PCA type charts so that this can be achieved. The locations are marked with the grid pattern overlaid so that each GPWT area can be matched to the locations.
These reference chart can be found in the Aviation Weather Services section of the BOM website at http://www.bom.gov.au/aviation/charts/grid-point-forecasts/#. You’ll need to click on each or any individual time step for each state/territory region (not the Aus time steps) and you will find a button for “Reference Chart PDFs”. We agree - they’re not easy to find so we suggest saving the links for future ease of reference to the areas applicable to your operations.
A sample extract
An ongoing discussion item at this meeting has been the progress of the TTF into a “rolling” TAF product, known as the Trend Review. CASA has now dedicated staff to the Trend Review project and time has been set side to get this moving. Initial impressions have CASA aiming for 2020 to remove the TTF. It is planned, the Trend Implementation Review Group will be reconvened, and AusALPA will be aiming to again be a part of this group.
Airspace Modernisation Proposal
AusALPA provided a submission on Airservices Proposal for Airspace Modernisation Link to Proposal Details. We believe that there should be a review of the lateral aspects of controlled airspace however, this is unlikely to be included in the current changes to airspace. We are hoping to alter this because such a review is long overdue. The current architecture of CTA steps dates back many years and since then, aircraft manufacturers have vastly improved upon wing and airframe designs so that drag is reduced. This in turn means that jet aircraft require a top of descent point earlier than was historically the case.
Airservice produced information and education
Pilots and Air Traffic Controllers have a unique working interaction that impacts on both safety and efficiency of operations. Improvements in both of these can, in part, be achieved by increasing awareness of the air traffic system and by understanding how pilot activities, decisions and operations can impact it. Some of the useful information provided includes:
- Using NAIPS for flight planning
- Communication with ATC
- VFR clearance requests
- Operating in Class D - including links to Metro Class D aerodrome specific info
- In-flight information - pilot responsibilities
To explore more, click here: Airservices - Working with ATC
Pilot Information Nights are available at Airservices facilities in Brisbane, Melbourne and Sydney. Click here to learn more: Airservices - Pilot Information Nights
IFALPA InterPilot Magazine:
The main feature articles in this edition include:
- Organisational Emergency Response Plans - would yours work in practice?
- RWY Surface Conditions - a discussion on the new reporting format
- Safe Drinking Water On Aircraft - the facts about potable water onboard
- IFALPA Safety and Technical news and updates
To read more, click here: IFALPA Interpilot E-magazine (2019 Issue 1)
Wind Turbines and Helicopters
Helicopter operations in the vicinity of Wind Turbines installations present challenges to the safety of these operations. The drive to renewable energy continues to gather pace worldwide and with that, a significant portion of this energy production is increasingly coming from a mix of onshore and offshore wind turbine installations. This strong growth rate presents significant opportunities for helicopter support companies, but creates unique considerations. IFALPA have developed a Wind Turbine Position Paper addressing these issue.
The ongoing issue of unruly passengers has led the aviation industry to consider proposals to mandate the installation of a CCTV system in commercial transport aircraft and remote pilot stations. IFALPA generally supports this installation for both safety and security reasons, provided the system is for the sole use of the flight crew and no downlinking or recording takes place. IFALPA have developed a CCTV Position Paper addressing this issue. Their use can be effective beyond cabin related issues and as an example, IFALPA supports the use of cameras covering the following exterior areas: wings, tail, control surfaces, cargo doors, landing gear, engines. Recordings made in commercial aircraft (such as CVRs) continue to be misused and therefore IFALPA strongly opposes any recording of CCTV images.