AusALPA's submission on CASA's recent consultation for sport and recreation aircraft emphasized a strategic, risk-based approach and proportional access to Class C and D controlled airspace. We urged clear regulations on pilot competencies, medical fitness, and aircraft equipment. Meanwhile, the ongoing Pilbara airspace issues persist, with the August 2023 revised draft Airspace Review acknowledging the problem but lacking in realistic reforms. AusALPA highlights the flawed justification for lowering Continental Class C and identifies the crucial issues of surveillance and VHF communications coverage.
Proposed access to Class C and D controlled airspace for sport and recreation aircraft – AusALPA advocates for a fair approach, equitable access and appropriate risk mitigation measures.
AusALPA expressed overall support for the proposed changes to controlled airspace access, particularly focusing on Ballina Gateway Airport. We suggested that the proposal should ideally be a part of the broader Australian Future Airspace Framework (AFAF) and its Technical Working Group (TWG) process, which is currently under-resourced, emphasizing the need for a strategic approach to ensure fairness and safety in controlled airspace access.
AusALPA's submission stems from its advocacy for risk assessment and the establishment of a Control Terminal Area (CTA) at Ballina Gateway Airport. We are pleased with the decision to transition Ballina to a CTA. However, discussions revealed that the sport and recreation sector supported this change, contingent on rule amendments to facilitate fair access to Class C and D CTAs. Anticipating varied stakeholder views on "access and equity," AusALPA aims to clarify its stance within the international and Australian regulatory frameworks.
AusALPA aligns with the ICAO’s Manual on Air Traffic Management System Requirements (Doc 9882) regarding access and equity. Whilst emphasising minimization of access restrictions and prioritizing system performance, we highlight the importance of setting and meeting minimum operational requirements for airspace users.
AusALPA’s feedback on Access Criteria:
- Pilot Competencies: we support consistent competency standards for all pilots operating in the same controlled airspace and advocate for exceptions based only on specific operational contexts, ensuring effective traffic segregation and separation to avoid unnecessary restrictions.
- Radio Competencies and English Language Proficiency: we agree that competency standards for radio transmission should be aligned with those in Part 61 before permitting access to controlled airspace.
- Medical Fitness: we call for a risk-based approach to medical standards for controlled airspace, dependent on airspace users mixing with air transport operations. We oppose allowing "self-declared" medical status for access to Class C and D airspace, emphasising safety considerations and advocate a need to meet the same minimum medical certification requirements as those who operate VH- registered aircraft.
- Aircraft Equipment: While supporting objectives for specified (radio and surveillance) equipment, we urge explicit standards to minimize exceptions and ensure compatibility. Consistency in minimum surveillance equipment requirements is crucial for ensuring ATM safety and efficiency and should be the basis of establishing priority of access to Class C and D airspace.
- Priorities for Airspace Access: we emphasise the need for a balanced perspective, integrating considerations of fair access and equity with a risk-based mitigation approach.
AusALPA calls for urgent overhaul of Pilbara region airspace management.
AusALPA expressed disappointment with the August 2023 version of the Pilbara Region Airspace Review, stating that it lacks realistic reforms for resolving critical issues. This latest draft has removed recommendations present in the March 2021 release, which is particularly concerning, is inadequate and requires rectification to address safety and efficiency concerns in the Pilbara airspace. AusALPA also questions the modelling used to support the lowering of Continental Class E and urges a comprehensive re-evaluation of its validity.
AusALPA acknowledges the confirmation of existing problems in the draft review but points out that it falls short in analysing potential solutions. The draft appears to work on the basis of minimal incremental change as the best achievable approach. AusALPA draws attention to its comments from 2021, stressing the need for a more strategic and comprehensive resolution of issues consistently plaguing the Pilbara airspace. We agree with the draft report's analysis that existing problems will intensify with the projected increase in traffic and aerodrome development (forecast includes up to six additional airports by 2028).
AusALPA placed a particular emphasis on two critical issues: a lack of surveillance coverage and insufficient VHF communications coverage in the Pilbara region. We stressed anticipated impact on terminal instrument flight procedures (TIFPs) and compliance issues due to overlapping procedures. In addition, our concerns such as combined air traffic control (ATC) sectors, limitations to VHF radio communications, and delays experienced on HF due to congestion were highlighted, emphasising potential consequences on safety and efficiency, particularly for aircraft operating below 5,000ft AMSL and the challenges associated with continuous climb operations.
AusALPA is disappointed with the revised 2023 version of the draft report, asserting that it is inferior to the 2021 version, which included critical recommendations addressing the heart of the problems – our critical Recommendations #1 and #2 from the March 2021 report called for increased VHF infrastructure and enhanced ADS-B coverage. We are deeply concerned about erasure of these recommendations in the current version, and advocate for clear and assertive directives for improved infrastructure.
Drawing attention to various feedback from Pilbara airspace stakeholders and operational experiences, AusALPA questioned the accuracy of Airservices' modelling and insisted on a thorough review of its validity. The association pointed out that operational experiences significantly differ from the modelled projections, indicating a need for a re-evaluation of the modelling used in Australian airspace changes. Additionally, we emphasized the importance of transparency in safety decision-making and called for the release of safety cases to ensure accountability.
In conclusion, AusALPA’s opinion is that the latest draft Pilbara Region Airspace Review falls short in addressing the ongoing extensive issues identified and proposes insufficient solutions. We advocate for a significant rethink and the withdrawal of the current review until it can comprehensively address Pilbara airspace infrastructure needs, emphasising the urgency for a safety-focused approach and putting the needs of airspace users at the core of any reconsideration.
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