AFAP SAFETY & TECHNICAL BRIEFING – DEC 2019
The AFAP is an association of professional air pilots as well as a union. As a professional association, we can gather our collective corporate and industry knowledge and focus this on all aspects that affect our air pilot profession. 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 Air services, details of our contributions to consultations and meetings, and any updates or recent changes of interest to our pilot members.
Of note in this briefing is an update on fatigue risk management issues. With the 2019 CAO 48.1 instrument finally being implemented, the AFAP will be developing more fatigue resources soon.
Make sure to follow us on LinkedIn and Facebook to keep up to date with the AFAP’s latest S&T and other news.
The AFAP Safety & Technical Team
S&T Director Stuart Beveridge
S&T Manager Marcus Diamond
S&T Officers Lachlan Gray and Julian Smibert
CASA Consultative Business
CAO 48.1 - Fatigue Rules Review
The introduction of the new Fatigue Rules - CAO 48.1.
The final CAO 48.1 (2019 Instrument) has been implemented with final transition dates varying for different operations but all operators must have transitioned no later than September 2020. By November 30 this year, all operators should have either provided CASA with their intended plans to transition to either the prescriptive rules (Appendices 1 to 6) or to an FRMS (Appendix 7).
- For high capacity regular public transport (high-cap RPT) operations, operators must transition to the new rules (either a trial Fatigue Risk Management System (FRMS), or prescriptive limits) no later than 30 June 2020.
- For those operators choosing to work under an FRMS, an application must have been submitted to CASA by no later than 30 November 2019 and be operating under a trial FRMS implementation approval (or revert to prescriptive limits) no later than 30 September 2020.
- For operators choosing to operate to the prescriptive limits, a transition plan is required to have been submitted to CASA no later than 30 November 2019.
In addition to this, by 30 November 2019, high-cap RPT operators must demonstrate to CASA that their Safety Management System (SMS) and human factors and non-technical skills programs are adequate to support fatigue risk management.
Read more on: CASA Fatigue Management
FRMS Forum - San Francisco
In early October, AFAP representatives attended the international FRMS Forum in San Francisco. This annual event showcases the latest in fatigue management approaches and science and is attended by regulators, operators, researchers, and pilot representatives from around the world. It is clear from the forum that Australia - both the regulator and operators - still lag behind best practice in many areas, and the AFAP representatives’ attendance will ensure that these standards will be brought back for consideration and introduction. Similarly, being aware of the various challenges in fatigue management implementation encountered around the world will assist representatives in dealing with similar problems back home.
FRMS and Fatigue Management going forward
The AFAP is working with pilot representatives to share our knowledge in this area so that it can have meaningful and positive effect upon the path forward for operators transitioning to the new fatigue management ruleset. We will be focusing on championing the genuine adoption of the intent of fatigue risk management principles from ICAO and on methods of building greater trust in the system by all. We continue to engage some operators on these matters too and the AFAP intends to play an ongoing role in these matters.
It should be understood that in transitioning to an FRMS (CAO 48.1 appendix 7), the method is to use the prescriptive rules from the other appendices (1-6) as a basis and then only alter what is needed. For example, if one duty requires an alteration to the minimum off duty period between, it would not be the case or expectation that all minimum off duty periods are then reduced by the FRMS. Also, such a scenario would require other offsets to be applied when altering the prescriptive limits in this manner. E.g. a requirement for greater off duty periods before and after a particular type of duty.
The use of FRMS must only allow greater flexibility for operations with an increased level of responsibility for fatigue management by the operator too. Otherwise the risks are increased without added risk controls/mitigations to offset the increased risk.
The regional airspace and procedures advisory committees (RAPACs) are primarily state based forums for discussion of all matters relating to airspace and related procedures in Australia. AFAP representatives attend RAPAC meetings around Australia.
Learn more about RAPAC and these meetings from the CASA RAPAC Page
At the October meeting, Gladstone Airport sought RAPAC members feedback on a proposal to change the aerodrome reference code from 4 to 3 and decommission the ILS. There are a variety of issues with the current code and RWS and OLS intrusions. However, the current DA height is already above 250’ AGL and it appears that Gladstone Airport were unaware that, from a standards perspective, the ILS is already technically a non-precision instrument procedure and therefore a reduction in the runway strip with need not necessitate a decommissioning of the OLS. Gladstone Airport hasn’t been charging for the use of the ILS and, given that this is a Class G aerodrome, it is unclear how they would identify which flights have used the ILS so to commence cost recovery initiatives. It is unclear to what degree these aspects are driving the proposals for ILS decommissioning.
The November meeting was held at the CASA office in Melbourne on 14 November. The BOM presented on the restructure of the aviation weather service and the establishment of the Global Space Weather Service (GSWS), which became operational on 7 November. The GSWS monitors space events such as solar flares, in order to predict anomalies in communications and GNSS operation.
CASA flagged proposed changes to the provision of reg services – which sounded like a rehash of the existing Reg Service Centre rather than a wholesale overhaul of the system.
A proposal was put forward to change the format of RAPAC from the existing three meetings per year to a single face-to-face meeting with ongoing work being conducted online out of session as much is already done, with ad hoc online meetings being called as required. While it was agreed to trial this system for 12 months there is the potential for the relevancy and participation of RAPAC to be significantly diminished by these new arrangements.
AusALPA reps and S&T staff have been working on a proposal for a broadcast area for the upper Spencer Gulf region of South Australia. The aim of this is to enhance safety by combining these aerodromes on the one frequency. Currently there exists a risk of aircraft being in close proximity to each other whilst on different frequencies. This risk is most prominent when aircraft are transiting between the local aerodromes. The broadcast area is yet to be finalised (including the dimensions and frequency) but is currently open for consultation and comment by emailing: firstname.lastname@example.org.
Contact email@example.com if you would like background information.
Commencing from 7 November, a broadcast area has been introduced within 10 nautical miles of Ballina Aerodrome. The Broadcast Area is intended to enhance communication in the vicinity of Ballina and reduce the incidence of unknown VFR aircraft conflicting with RPT aircraft.
AusALPA has also assisted with a proposal for a broadcast area to the north of Ballina and south/southwest of the Gold Coast.
Kimberley-Wyndham Broadcast Area (BA). Altered dimensions so to standardise the upper level of A100 with that of the BA north of Broome.
Technical Working Groups (TWGs) CASA TWGs
CASR Part 121 TWG, MOS
Although Part 121 Australian air transport operations - larger aeroplanes regulations are now in legislation - the Manual of Operational Standards (MOS) will be completed in 2020, there are seven “tranches” or stages to this work.
Tranche 1 and 2 were discussed with CASA in November. This included discussions on:
- CAO 20.7.1B: This has been replaced with Chapter 3 of Part 121 MOS Technical Draft was part of public consultations of Part 121 of CASR in 2015 and 2018 is now substantially complete and in final legal drafting. This chapter is largely in line with CAO 20.7.1B. with some modified elements relating to en-route drift down obstacle clearance requirements that have been broadly aligned with EASA requirements.
- EFBs: CASA intends on capturing the majority of the existing Appendix 9 to CAO 82.0 within Part 121 Guidance Material.
- Fuel and Alternate requirements: These have been drafted to more closely align with ICAO. The use of a single runway will require an alternate. This may capture airports with crossed runways if a blockage at the crossing point precludes a landing for your aircraft.
- Minimum and MAYDAY Fuel Declarations: The Part 121 TWG deliberated on the ICAO 15-minute minimum alternate fuel requirement to align more with international practice and alleviate, with a buffer, the minimum fuel declaration.
- Operator compliance statements (or not?): The operators propose that their amended expositions are/will be compliant with the new regulations under Part 121 and therefore they do not need to provide an updated compliance statement. CASA would like to see evidence and a compliance statement is a good way to do this. A compromise may be reached where the operator submits revisions and states compliance.
AusALPA Safety & Technical Updates
AusALPA is a safety and technical partnership between the AFAP and AIPA. In line with the IFALPA standing committees, 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 and 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.
Safety and Technical Induction training, 25th March 2020, South Melbourne
The AFAP will host a day of AusALPA Safety and Technical Induction training at its South Melbourne office on 25 March 2020. This training is for both new volunteer representatives and current reps that would like a refresher and help participate in the training.
For more information, or to become a Safety and Technical representative, contact firstname.lastname@example.org
Accident Analysis & Prevention (AAP)
ATSB Review Work
The AFAP has begun discussions with the ATSB about the possibility of furthering their previous review and research work into the benefits of SMSs. The ATSB has previously conducted review into this are back in 2011 but that report provided more questions than it answered regarding SMS. It may be timely for the ATSB to now consider how it can pursue those loose ends identified in the report.
Aircraft Design & Operations (ADO)
Single pilot operations
A number of the pilot associations around the world have prepared position papers on the manufacturers’ plans to reduce airline flight deck crew to one pilot.
ALPA-I warns that, “some entities have begun to advocate for reducing the flight crew present in large aircraft, possibly down to even a single pilot. Those promoting single-pilot operations argue that reducing crew size will lead to cost savings. However, the current body of evidence and experience, including more than a decade of study by the National Aeronautics and Space Administration (NASA) and the Federal Aviation Administration (FAA), shows that the safety risks and challenges associated with single-pilot operations far outweigh its potential benefits.” Read more on “The Dangers of Single-pilot Operations”: http://www.alpa.org/-/media/ALPA/Files/pdfs/news-events/white-papers/white-paper-single-pilot-operations.pdf?la=en
IFALPA’s statement on Reduced Crew Operations was released in Berlin, Germany in April: “The 2019 IFALPA Conference fully supports any developments that improve the current safety standards in commercial air transport. Our enviable safety record and culture is based upon two properly rested, fully qualified, and well-trained pilots. It is imperative that any future evolution of this benchmark improves upon it and does not degrade the safety and security level in any area.”
The AFAP support both of these positions. Because reduced crew operations carry significant additional risks over existing dual pilot operations, they will result in a serious reduction in flight safety. It is essential to fully address these risks and safety shortfalls before the industry accepts changes to the standards which have built the safest transportation system in history.
B737 Max Update
At the annual AFAP Convention in mid-October, Boeing attended and provided an update and answered questions from staff and the pilots attending. The Boeing Chief Test Pilot talked on many aspects of the related issues, and acknowledged that they can and should do a better job to engage with aviation stakeholders directly, including pilots. The AFAP will maintain regular contact with Boeing in the future and to facilitate more events like this presentation.
The final report into the Lion Air crash has been released and the Indonesian National Transportation Safety Committee (KNKT) has identified nine factors that contributed to the crash. These are detailed on page 215 of the report. IFALPA believes that the investigation team has provided a high quality investigation report. Read the report here: Lion Air report
In August the AFAP jointly hosted a forum for the purposes of progressing government policy on Unmanned Traffic Management (UTM) systems for the Australian airspace system. Other hosts of the event included Civil Air, IAL&PG and the association of Australian Certified UAV Operators (ACUO). The ATSB kindly provided facilities for the event.
The forum resolved that the Australian Government should prioritise a policy framework for this burgeoning aviation sector, devote sufficient resources, and that Australian should lead the Asia Pacific in developing a UTM framework.
Aerodrome & Ground Environment (AGE)
National Runway Safety Group (NRSG)
The NRSG has been revitalised by CASA after previously being chaired by Airservices. AusALPA participated in this latest meeting. The overall aim of the NRSG is to identify nationally relevant airport safety issues and make suggestions on how to overcome these.
AusALPA National Runway Update to IFALPA
In preparation for the IFALPA AGE Committee Meeting, AusALPA submitted an AusALPA National Runway Update to IFALPA which briefs the Federation on a number of issues currently occurring in AusALPA.
This includes AusALPA’s role in the Australian National Runway Safety Group (NRSG), Local Runway Safety Teams, airport developments at BNE, MEL, SYD, PER and ADL, the revised Part 139 (Aerodromes) and accompanying MOS, and the protection of airspace around airports.
Local Runway Safety Team meetings
Sydney Airport Runway Safety and Operations Group Meeting
August 2019,Sydney, attended by AusALPA representatives.
The main topic was a discussion on LVOs (Low Visibility Operations) and taxiing in visibilities below 300m. Sydney has taxiway centreline lights spaced at 30m which, according to aerodrome design planning standards, are suitable for RVR 350m and above only. CASA will almost certainly grant an exemption from the aerodrome design standard for CAT II Operations on 34L/16R down to an RVR of 300m (to “legalise” the existing practice), but still has concerns over the take off RVR, which has been reduced to 125m.
The meeting highlighted the disconnect between the local CASA inspectors and the CASA Standards Division, which supports the principle that only the runway limits are prescriptive.
The LIDAR wake turbulence research project was explained, B Greeves provided his experience based on its use in Hong Kong.
It has been discovered that Taxiway Hotel is noncompliant in terms of separation standards and its use will be limited when 25 or 07 are in use for landing; the latter being the most limiting.
Melbourne Airport Airfield Renaming Project (MAARP) Workshop
MEL Airport, 14 August, M Diamond on behalf of AusALPA
This workshop is one of a series of meetings to engage with stakeholders in the taxiway renaming project that is dependent on the 2038 MEL airport “end state” i.e. what do the RWYs in the future look like?
The intent of the project consultants is to adhere to the ICAO/IFALPA principles, guidance and naming conventions. Where naming is difficult or ambiguous, they will consult with the stakeholders.
The meeting was primarily a briefing of the current project planning and an opportunity to make suggestions, give feedback and declare any concerns.
It was agreed, at AusALPA’s suggestion, that simple explanatory documentation for pilots would be produced before, and additional to normal AIRAC/Notam information. Graphical and poster type information will be drafted and offered for comment before publishing. AusALPA will be able to publish this briefing material in each associations’ and IFALPA’s magazines/newsletters.
Buildings in the Vicinity of Airports
The National Airports Safeguarding Framework (NASF)
The NASF aims to ensure aviation safety requirements in and around airports are recognised in land-use planning decisions. These series of guidelines are currently under review and submissions on their effectiveness can be provided. AusALPA will be providing a submission to this NASF review.
Essendon Airport (EAPL)
Essendon Airport has recently drafted a master development plan that includes downgrading RWY 26/08 by painting a white delineating line to reduce the runway strip from 45m to 30m. This would legitimise the DFO infrastructure that infringes the 45m runway strip width and the newly built iFLY indoor skydiving building at the end of the hangars near the RWY 26 departure area.
An AFAP contingent met with the new CEO of Essendon airport in August and had robust discussions regarding the lack of safety cases and disregard for international and Australian standards in EAPLs development activities.
The downgrading of the runway, obstacle penetrations and degrading of the Essendon obstacle limitation surfaces was recently discussed at the IFALPA Asia/Pacific regional meeting in Bangladesh, where the participant countries Pilot member associations unanimously decided to escalate these deficiencies to critical (“Black Star”) at the next IFALPA conference in March 2020.
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 and separate investigation. The protection of airspace around our airports is a matter AusALPA considers to be of significant importance. The continuing and repeated delays around the release of this report are of concern!
As discussed above, after the QLD RAPAC meeting, AusALPA made a submission to Gladstone Airport Corporation regarding proposals to change the aerodrome reference code to Code 3 (non-precision) and the decommissioning of the ILS, specifying that AusALPA:
- Prefers ILS Instrument Flight Procedures (IFP) and 3D approaches over non-precision approaches and we advocate that they should be provided wherever they can be installed and retained if pre-existing. Our members find that ILS IFPs are an extremely useful approach type with significant safety enhancements over other approaches.
- Believes that 3D and precision approaches provide the greatest amount of stability during an approach, contribute to effective risk reduction and increase the probability of a safer outcome in adverse weather conditions.
- Recommends that the Gladstone ILS be retained with appropriate regulatory relief.
You can read the AusALPA submission to the airport here.
Australian Aviation Wildlife Hazard Group (AAWHG)
AusALPA continues to be engaged in the AAWHG, which is the primary aviation wildlife hazard management reference body in Australia. Membership includes multiple aviation industry stakeholders and organisations, such as airlines, airports, Defence, air traffic control, government agencies, wildlife researchers, and service providers.
AusALPA took part in the recent AAWHG Workshop with AFAP member Esther Veldstra has been awarded a scholarship to attend. AusALPA continues to advocate for wildlife hazard training and education for pilots.
Air Traffic Services (ATS)
Airspace Review updates.
The CASA Office of Airspace Regulation (OAR) conducts reviews of airspace. These reports can be accessed here: Latest Airspace Reviews
Of the recent airspace reviews, AusALPA has provided feedback to reviews Tamworth, Hobart, Broome and Karratha, and Darwin.
Sydney Tower ATS
It has been brought to the AFAP’s attention that there are ongoing issues with ATC staff shortages for Sydney tower. From the information that we’ve received, it is likely that there will be up to 150 unstaffed shifts in SYD TWR over the Christmas/holiday period. Our members flying into/out of SYD should be aware that there may be major delays to ATS.
Human Performance (HUPER)
PACDEFF - CRM/NTS Conference
The AFAP attended the annual Pacific and Australasian CRM Developers’ and Facilitators’ Forum (PACDEFF), held on September 3-5. There was the usual broad mix of academic research, practitioners’ ideas, and safety agency reports. The nexus between mental health, CRM, and fatigue continues to emerge from this event but is yet to be adequately addressed by policy.
Fatigue management and FRMS were the topics of many presenters this year, which is not a surprise given the finalising of Australia’s reformed pilot fatigue rules. It was clear from some of the questions from the room that many operators are yet to get a working grasp of the changes. In particular, it was disappointing to hear a predominance of perspectives about how to maximise roster “optimisation” rather than a focus on the mitigation of fatigue risks.
Cabin Air Quality (Aero-toxicity) - GCAQE Conference (London)
The AFAP attended the annual Global Cabin Air Quality Executive (GCAQE) conference (17-18 September). The AusALPA partners remain active members on the GCAQE. This is highlighted by the recent election of an AFAP member to the board of the GCAQE
The objectives of the GCAQE are to improve the medical protocol response to affected crew, influence the design of future aircraft to use bleed free architecture, introduce effective bleed air filtration systems and reliable contaminated air detection systems on current air transport systems. There are three distinct points on the timeline for Cabin Air Events.
- Detection and reporting. We are here now.
- Filtration. Slowly becoming available to the market.
- Air supply from bleedless engines (787) - The end goal.
There are a number of filtration devices that are being developed and close to delivery to market, with cost per hour for airlines at around the US$8 per hour, per engine. These last about 5000 hours and cost about US$40,000 per unit. DHL has been the first “airline” in the world to filter the air going to the flight deck. Easyjet have donated access to fit an A320 and carry out ground and air tests on PALL filtration technology. The GCAQE conference was presented with the initial positive results from ground testing, it will be interesting to see if the air testing is just as successful.
The AFAP presented the results of organophosphate analysis from cabin air sampling of VH registered aircraft during fume events.
Global Cabin Air Reporting system (GCARS) tool trial:
The AFAP requests its members to trial the new GCARS reporting tool. The AFAP now has a board member on the GCARS oversight Committee and will work to adapt the GCARS report to allow a pilot member to state if they want a copy of the report to be sent to AFAP and /or CASA. The report is based on ICAO guidelines.
Please evaluate it at:
there is a demonstration video at:
CASA legal officers attended the AFAP pre-convention seminar in October and gave a presentation that included statistics on prosecutions and the process when a transgression may be advanced to a prosecution.
They gave a description on the internal CASA procedure and referral to the Director of Public Prosecutions for prosecution. The overall numbers are small, at less than 10 per year.
The CASA officials then participated in a moderated question and answer session with AFAP executive, attending members and staff. Discussing a wide range of matters including pilot medicals, prosecutions, the regulatory reforms and aircraft certification.
Unruly Passengers and the Montreal Protocol (MP14)
Aviation Legal Counsel Joseph Wheeler presented to the Asia Pacific Cabin Safety Working Group (APCSWG) in Canberra at their annual meeting on these unruly passenger laws and the new ICAO Manual. This Conference presented an opportunity to build bridges between flight crew and cabin crew safety associations, through the topical legal consideration of prosecution and prevention of unruly passenger events. The presentation was well received with a view to future collaboration on suitable safety initiatives now being a possibility between APCSWG members and AFAP.
At the time of the presentation, the MP14 had not entered force as it required 22 ratifications, and only had 21. Nigeria has now deposited its instrument of ratification so that the MP14 and thus amended TC63 will go into effect on 1 January 2020 for those States who have ratified.
A large number of unruly passengers do not face prosecution because of the deficiencies in Tokyo Convention 1963 (TC63), namely that the jurisdiction named for criminal offenders was (is) the state of registry of the aircraft. As such, TC63 has not been fit for purpose for dealing with unruly behaviours on international flights in the modern era. Therefore, ICAO Member States agreed upon the text of a new protocol in 2014 amending TC63 – called Montreal Protocol or MP14.
The benefits which the new protocol provides for governments, aviation operators, and passengers are:
- Expanding the jurisdiction of governments to include not only the State in which the aircraft is registered but also the State in which it lands, along with guarantees and conditions that legalise the exercise of jurisdiction.
- Clarifying what is prohibited on the flights of the airlines concerned.
- Recognizing the right of aviation operators to seek compensation for the cost resulting from the actions of an unruly passenger.
The introduction of MP14 means in practice that many more states will feel empowered by
international and their local law to deal offending passengers offloaded or deplaned in their
territorial jurisdiction. This in turn likely means greater prospects of prosecution and conviction, or other means of dealing with such offenders will be applied.
The guidance material (ICAO Manual) IFALPA has contributed to helps in a further regard. It provides a framework and encouragement for States to put in place an Australia/New Zealand -like administrative sanctions regime to provide alternate and faster means of bringing offenders to justice than the criminal law provides. As such it recommends a variety of fines and infringements for offenders should States wish to pursue such measures.
In our region, Singapore and Malaysia have ratified the MP14, which should be of some comfort to international crews operating there, in terms of the likely support from local authorities to bring offenders to justice no matter their nationality of residence.
Like all treaties the maximal use of them uniformly in international aviation comes from broad
ratification, so it is of more than symbolic significance if States like Australia and the United States ratify it, which is yet to occur. IFALPA broadly recognises and supports State ratification of MP14 for the better protection of crews.
Professional and Government Affairs (PGA)
IFALPA Asia/Pacific Regional Meeting - Dhaka Bangladesh.
At the recent IFALPA regional meeting the PGA committee ran an interactive workshop to reinvigorate and guide the IFALPA membership on PGA matters. Safety and Technical matters will always be at the heart of IFALPA activities but the world wide industrial and political landscape for pilots requires more focus in PGA from IFALPA.
Civil Aviation Act amendment (2019)
The AFAP made submissions to various politicians and advisors regarding this amendment. This will be the subject of an Air pilot article in the next edition and outline how we lobbied for revisions that included regarding the system as a whole rather than individual costs. The AFAP Position Paper can be read here.
Security and Dangerous Goods (SEC/DG)
AFAP security advocacy in Canberra
Aviation security matters now fall under the remit of Aviation Maritime Security (AMS) within the Department of Home Affairs. The AFAP recently met with the Assistant First Secretary of AMS and we have been invited to participate in a variety of future security forums and consultation events, including a National Security Summit which we have already attended. It is intended that the need of pilots involvement in the aviation security system will be emphasised in these forums, with the view that improved outcomes can be achieved for both security and pilots workplaces alike.
Security Screening Matters
Security screening at airports continue to lack consistency in their procedures which has impacted on several of our members going through airport screening points. AusALPA continues to liaise closely with Government agencies regarding this matter.
IFALPA Dangerous Goods meeting
AusALPA attended the IFALPA Dangerous Goods (DG) committee meeting recently. At this meeting, the committee produced a draft Position Paper on the ‘Carriage of Persons on All Cargo Aircraft [i.e. Cargo Aircraft Only (CAO)]’. At the moment, CAO provisions are being used to prevent individuals from travelling on cargo aircraft when cargo aircraft are carrying DGs not allowed on passenger aircraft.
IFALPA is opposed to removing any of the DGs information currently provided to the PIC on the NOTOC.Notwithstanding, at last year’s DG Committee meeting, a working group was formed to investigate the transition of the NOTOC to an electronic version. This work is continuing. Interestingly though, recent enquiries with local Aerodrome Rescue and Fire Fighting (ARFF) services staff reveals that they wouldn’t know what to do with a NOTOC if you handed this to them post aircraft evacuation. They would gain their DGs information from other sources.
CTAF operations: short survey
The AFAP is aware of recent reports of communications and separation incidents at Common Traffic Advisory Frequency (CTAF) airports around Australia.
The AFAP is conducting a short one-minute survey that will be shared with the ATSB on an anonymous basis. This information will help us feed back to the regulator and air services and will only take a minute of your time.
Please forward this link to any other pilots you think may be interested in providing feedback.
Complete the survey now by clicking here: https://www.questionpro.com/t/AJLXXZfzjI
Airspace Modernisation Project (AMP)
Airservices Australia has been working towards reforming aspects of the Australian airspace. Many of these proposals and reforms have been under the banner of the AMP. AusALPA has been a significant industry stakeholder and leader in addressing these proposals.
AusALPA has raised significant concerns with many of the proposals and has worked closely with the CASA Office of Airspace Regulation (OAR), airlines and other industry groups in addressing these matters.
Some of our concerns relate to:
- A lack of surveillance and detection of aircraft in many portions of airspace,
- The inappropriate use of Class E airspace over the top of Class D aerodromes.
- The use of “standardisation” as a reason for some changes even though the standardisation is causing complications and a deterioration to risk mitigation.
- A lack of consideration for Continuous Descent Operations (CDO) in the airspace architecture review.
- Airspace Containment of Instrument Approach Procedures (IAP) i.e. either wholly within controlled airspace or all outside controlled airspace.
- A lack of a holistic view of the whole AMP (a systems approach is lacking)
AusALPA will continue to press for practical and safe outcomes-based reforms and resist unsafe and impractical proposals. We are soon to meet with Airservices to discuss these and other matters further.
Information and Education about ATC and Airservices
Did you know…?
When on approach, you may sometimes be told to “continue approach”. Besides the thought that that was what you were going to do anyway, are you aware that this actually has some meaning? This RT is intended to inform the flight crew that a landing clearance is imminent however, ATC is unable to issue this at that time. The underlying purpose of this is to allow you to focus on your monitoring role rather than to be distracted by thoughts as to whether or not ATC have forgotten about providing you with a landing clearance or not.
Airservices - Pilot Information Nights are held regularly at Airservices facilities in Brisbane, Melbourne and Sydney.
AWIS Phone Numbers
The BOM has changed many AWIS phone numbers, effective August 2019. To find the new list of numbers Click Here.
TAFs and TTFs
The Trend review, or TAF3 project, is progressing. This is a project that aims to remove the TTF product and include it into the relevant TAFs. The first three hours of these particular TAFs will function like a TTF, such as the need for no buffer periods. AusALPA supports this initiative and has provided a submission to the recent CASA consultation on TAF3.
BOM Consultative Meeting
Some of you may recall that the BOM ran a survey mid year to gauge aviation customer satisfaction with their work. AusALPA helped promote this survey to member pilots. The BOM thanked us in the recent consultative meeting for our contributions as it resulted in a higher response rate than previous surveys. A standout dichotomy from the survey was that 57% of respondents thought the BOM's current level of forecasting conservatism was appropriate. However in contrast, airline operators believe that the forecasts are too conservative. This is one of the interesting take outs from the survey and is represented in this graph:
The Vulcan Working Group discusses the impact of volcanic ash events on aviation in an effort to formulate improved responses. There has been some recent volcanic ash exercises run with an aim to test international collaborations across FIRs and jurisdictions. In essence, the exercises created fictional eruptions in areas where the ash clouds would disperse across multiple FIRs. This tested the manner in which different agencies communicate and coordinate with each other. Some learning outcomes were produced that can lead to better outcomes in the event of a real eruption of this sort.
The meeting also discussed the need for better reports from pilots regarding ash clouds. The AFAP strongly encourages all pilots to collect any data, photos and fumes smells and report them. Even if these are only in passing. The information is used to verify other input and detection information and this will lead to better predictive and analysis of volcanic activity in the future. Pilots are encouraged to provide more PIREPs and with more specific information including:
- Estimated height of eruption
- Altitude of aircraft (where the aircraft is in relation to the observation)
- Direction of travel (the ash plume and the aircraft)
- Time of observation
- Photos (if possible)
A recent eruption event for the Metis Shoal volcano in Tonga was much better tracked due to receiving pilot reports with photos. This was a crucial piece of evidence because the lack of volcanic ash from the plume meant that it was really difficult to track anything from a satellite perspective.
Recent IFALPA Publications:
Training and Education
Many States are still struggling with the world-wide implementation of the new SID/STAR phraseology. IFALPA recommend these ICAO tools to increase the knowledge level of personnel using the SID/STAR provisions as airspace users or air traffic controllers.
Handy SID-STAR phraseologies Leaflet:
SID-STAR Phraseologies Leaflet.pdf
SID/STAR phraseology examples in a scenario format:
SID-STAR Scenarios Text.pdf
ICAO letter to States:
State letter 54_Amendment 7 to PANS-ATM (1).pdf
IFALPA InterPilot Magazine:
The latest issue of InterPilot, the quarterly online journal of IFALPA, the latest news and updates on the IFALPA work at ICAO from the B737 Max Summit.
Read/Download Issue 3
Read/Download Issue 4
In-flight Flight Crew Rest Facilities - This position paper provides generic guidance for the design and specification of dedicated flight crew rest facilities provided for the exclusive use of flight crew on commercial transport aircraft operated with augmented flight crews. The main purpose of such facilities is to provide flight crew members with an adequate rest environment before commencement of the next in-flight duty period. IFALPA considers that seconded passenger seats are not satisfactory as flight crew rest facilities and should therefore not normally be used as such. IFALPA Crew Rest Facilities Position Paper
Reduced Runway Separation Minima for Night Operations - IFALPA is opposed to Reduced Runway Separation Minima being applied for Night Operations. The provisions to reduce runway separation have been agreed worldwide and should be used accordingly. With more and more utilisation of stable approach criteria and thus the increased possibility of conducting a missed approach, the separation standards between two succeeding departing aircraft should also apply between a departing aircraft and an aircraft conducting a missed approach. IFALPA Night Separation Minima Position Paper
Downlink of pilot selected levels (Mode S Transponders) - For some time now, several ATS Units (ATSUs) have been using an alert function that is based on data sent by the Enhanced Mode S transponder. This transponder version provides a down-link of various airborne parameters that includes the flight level or altitude selected by the pilots in the altitude window of the associated auto-flight system. If the pilot selected flight level or altitude does not correspond with the cleared level/altitude stored by the controller in the Air Traffic Management (ATM) system, an alert is triggered at the controller station. This warning is used by the controller to verify the pilot selected level/altitude and provides a valuable safety net. IFALPA Transponder Down-Link Position Paper