Airspace Application

[Bruce Tuncks]

Below is the airspace application I put in after many years of flying lower than necessary over the Adelaide Hills.

 

Of course this application was not successful, but I have yet to see any reply in writing.

 

Anybody care to guess at what they will say?

 

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Submission to St John Morris Regarding Airspace Amendment in the Adelaide Area.

 

From: R.B.Tuncks date: 23/2/2016

 

PURPOSE

 

To advocate an airspace change which would significantly improve safety for many users.

 

BACKGROUND

 

In a single-engined light aircraft, the most important safety consideration is the height above the terrain. The rougher the terrain, the more altitude is needed to glide to a safe landing site .

 

In a VFR aircraft flying outside of controlled airspace, it is possible to find yourself in an unnecessarily dangerous situation brought on by the very regulations which were intended to be made for the safety of all of us who fly.

 

There are many VFR and outside controlled airspace flights made between Gawler and Murray Bridge. There are significant numbers of light aircraft at each of these places, and many other locations such as Strathalbyn would have enhanced safety under this proposal.

 

The proposal is to refine the Adelaide control zone by adding a 6,500 ft step between the mid-point of the 4,500ft step and the 8,500 ft step.

 

This step would begin at a point NE of Lyndoch and adjoin R265A at that point. It would then curve through Bonfire Hill, Mount Pleasant, Callington and around to a point between Myponga Beach and Carrickalinga Head.

 

THE SAFETY BENEFITS

 

Consider a light aircraft that is flying in the area between Bonfire Hill and Eden Valley. At present, the aircraft is obliged to remain below 4,500 ft, and the landscape below has spot heights approaching 1900ft.

 

Typical engine-out performance of a light aircraft would be a glide-ratio of 10:1 at a speed of 70 knots. This means the rate of sink would be about 700 ft per min.

 

Now if flying at 4,400 ft initially and using the last 1000 ft above the surface to line up into wind, this means the following frightening events must take place in the event of an engine failure:

 

Time to arrival at the surface = 3 mins 34 secs ( maximum)

 

Radius of landing search area = 15,000 ft or about 3 miles (maximum).

 

If , on the other hand, the aircraft was initially at 6,400 ft:

 

Time to arrival at the surface = 6 min 25 secs

 

Radius of landing search area ( again leaving the last 1000 ft to line up into wind) = 45,000 ft or about 9 miles.

 

The area available for finding a landing place goes from about 28 square miles to about 250 square miles, an enormous improvement.

 

These figures demonstrate the truth of the statement that altitude is the single most important safety thing of all.

 

EFFECT OF THE PROPOSED STEP ON OTHER AIRCRAFT

 

The many aircraft which fly VFR and outside controlled airspace from Gawler, Murray Bridge, Strathalbyn, Goolwa and Aldinga would have greatly enhanced safety as a result of this proposal.

 

Aircraft appoaching Adelaide Airport would have NO CHANGE to their approach. For example, if an aircraft was flying the minimum-height controlled airspace from the east such that it was at 8,500 ft just west of Mannum and then 4,500 ft at Mt Barker, it would be at about 6,500 ft near Callington both before and after this proposal was implemented.

 

SUMMARY

 

The world of aviation has changed greatly in the last decade. RAAus now has about 9,000 members, and Gawler now is home base to more than 80 aircraft , gliders included. These aircraft fly daylight VFR and outside of controlled airspace. In general, the owners do not want to fly in controlled airspace and they are not interested in IFR flying.

 

At present, they are forced to fly in the "leftover" airspace remaining after the airlines and military have been well catered for. Nothing in this proposal would change that. The proposal would not change anything in their operations but would have a very significant safety enhancement for the many people who fall outside of the categories of airline or military.

 

It is easy to imagine a VFR aircraft flying outside of controlled airspace operating at a significantly raised risk level because of being trapped between high ground and low controlled airspace, and carrying this increased risk while the hereby sought after airspace went completely unused.

 

R B Tuncks , Adelaide, 24/2/2016

 

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RAPAC airspace submission - Copy.docx

 

RAPAC airspace submission - Copy.docx

 

RAPAC airspace submission - Copy.docx

[Yenn]

No. That is my answer and a statement that I would not like to guess what they say.

 

Seriously we all know that safety is not the main issue. Control is what it is all about and they will control all of us.

 

 

[ben87r]

The area that you talk about is right under the ILS so traffic would be heavy.

 

There isn't any blaring reason that I can see as to why it couldn't be done but I wouldn't be surprised if there was a reason why it couldn't due the ils. Maybe it could start further south if it was the case?lobethel south? Flown the area many times myself and agree that you are pretty low. Done Parafield dct Strathalbyn 2.5k a few times, that isn't very comfortable.

 

 

[turboplanner]

Good submission Bruce.

 

 

[Bruce Tuncks]

Good try ben87, you may win the cigar. But would not your point also apply to the Mount Barker 4,500 point and to Mannum on the Murray at 8,500ft? We have lived with those for many years. Also, Adelaide is not as busy as the Brisbane-Sydney-Melbourne routes.

 

I'll share the reply when I get it. In the meantime please keep guessing.... But I reckon the reply will be vague.

 

 

[Captaincoop]

I applaud what you are trying to do. There is a chunk of Amberley control airspace that needs 2 miles of trimming to stop forcing VFR right against the hills at low level. Not only a problem for engine out, but also for turbulent conditions in moderate winds.

 

 

[Bruce Tuncks]

Thanks Captaincoop, but if you google "Adelaide approach 4,500 ft step" you will find that the 2.5 degree approach profile clears the 8,500 ft step at Mannum by about 1000ft, and the 4,500 ft step near Mount Barker by the same amount. If there were a 6,500 ft step at Callington , the same 2.5 degree approach profile would clear this step by the same amount. The map I am referring to is the approach from the east, although the NE is no different.

 

The only way this airspace could be used would be for the airliner to dive steeply just after passing Mannum and then levelling out again.

 

You are right about the request being denied, that has been leaked to me. I am just waiting to hear of the reasons.

 

 

[Mike Borgelt]

Some years ago we had as a dinner guest one Bill Charney who was leisurely flying around world in his Beech 17 Staggerwing. Bill is also know as "Captain Biff Windsock" to United airlines passengers (he figured they pay more attention to his safety announcements that way) before he retired. After he had flown around SE Queensland for a while he said that "you sure have a lot of controlled airspace in Australia".

 

After 5 years on SA RAPAC I wouldn't hold out any hope of getting that through, Bruce. Australian officialdom just loves control and the only people worse than Australian civil controllers are the Australian military ones. Yes, I've had one or two helpful ones but it isn't common.

 

 

[Bruce Tuncks]

Here's what I expect for a reply ( if any... no reply really helps to make me understand how important I am )

 

Dear Mr Tuncks,

 

thank you for your submission, I regret to inform you that it was not successful due to important technical safety reasons.

 

In particular, your submission was contrary to safety standards endorsed by the airspace safety authorities worldwide.

 

Thank you for your interest in this matter.

 

Yours in safety, etc

 

Here's a translation:

 

Dear Mr Tuncks,

 

who do you think you are? Do you think that IMPORTANT LINES on OFFICIAL MAPS would be moved to suit the likes of no-account people like you?

 

Don't bother us again.

 

Yours etc

 

 

[Bruce Tuncks]

It has been suggested to me that if my proposal had been endorsed by the RAAus, it would have been harder to sweep aside.

 

Another idea, suggested on another topic on this forum, is that VFR safety corridors through what is now unnecessary controlled airspace be argued for repeatedly over the years.

 

Many of us can remember how flights to Tasmania had to be done under 5,000 ft. This was an example of the safety regulator acting contrary to safety for reasons of control, but it was overcome after years of work. I reckon the battle should be an ongoing one.

 

 

[scre80]

It has been suggested to me that if my proposal had been endorsed by the RAAus, it would have been harder to sweep aside.Another idea, suggested on another topic on this forum, is that VFR safety corridors through what is now unnecessary controlled airspace be argued for repeatedly over the years.

Many of us can remember how flights to Tasmania had to be done under 5,000 ft. This was an example of the safety regulator acting contrary to safety for reasons of control, but it was overcome after years of work. I reckon the battle should be an ongoing one.

Agree with you Bruce, have you spoken to RA Aus yet? When you do, would be good to know their feedback.

 

 

[Bruce Tuncks]

Have sent off stuff to RAAus with no reply as yet, but they have acknowledged it with courtesy.

 

Recently my son flew into Archerfield for the first time ever. He was impressed with the guys in the Archerfield tower, he said they were helpful and friendly.

 

He also said that the airspace forced him seriously low over houses, and that an engine failure would have put him down among them for sure.

 

 

[rhysmcc]

Aircraft inbound to Brisbane overfly archerfield around 3-4000ft quite regularly (basically join the ILS overhead).

 

 

[Bruce Tuncks]

rhys, what would be the height if you were going to land at Archerfield?

 

 

[frank marriott]

Have sent off stuff to RAAus with no reply as yet, but they have acknowledged it with courtesy.

Bruce

 

If you expect a considered reply from the now "Canberra Aero Club" I wish you luck.

 

 

[storchy neil]

Fm shorten that to CAC Neil

 

 

[rhysmcc]

rhys, what would be the height if you were going to land at Archerfield?

My guess would be 1000-1500 ft. When an RNAV approach is required depending on the runway config at Brisbane they need a slot (takes up a brisbane arrival slot on RWY 01)

 

 

[DWF]

Archerfield Control Zone is Surface to !500ft amsl.

 

ERSA for BRISBANE/Archerfield page FAC B-47 states: "ARRIVALS 5.1 Entry into the Archerfield CTR shall be at 1,500FT."

 

 

[Bruce Tuncks]

From how far out do you have to be 1500ft?

 

 

[Roundsounds]

Below is the airspace application I put in after many years of flying lower than necessary over the Adelaide Hills.Of course this application was not successful, but I have yet to see any reply in writing.

Anybody care to guess at what they will say?

Bruce, did you know you could legally operate a motor glider maintained by you, flown by you holding a certificate issued by Gliding Australia holding an airspace endorsement, on a self certified medical through the airspace you currently cannot fly through in your current aircraft? No GA licence, medical or flight review required. Seems like RAAus pilots are being treated unfairly, I believe there is a clause in the Civil Aviation Act stating there should not be any unfair limitations on the use of airspace.

Privately operated balloons enjoy the same privileges as glider pilots with respect to CTA.

 

Maybe some research and a well written letter might gain approval. CASA have previously issued an exemption to a pilot operate his RAAus registered aircraft, holding only RAAus qual's in CTA. A search of the CASA list of exemptions should find this exemption.

 

 

[Roundsounds]

CAO 95.4 regarding glider ops: (Glider equivalent to RAAus 95.55 and 95.32)

 

Civil Aviation Order 95.4 - Exemption from the provisions of the Civil Aviation Regulations 1988 - Gliders, powered sailplanes & power-assisted sailplanes (12/12/2004)

 

Note: no limitations on operations in controlled airspace, as opposed to those found in 95.55. If you go to the Gliding Aust website and look at their ops manual (page 25) it has some mention of CTA training, but certainly not a detailed syllabus as per the Part 61 MOS.

 

http://doc.glidingaustralia.org/index.php?option=com_docman&view=download&alias=1198-gfa-operationalregulations-ops-0001&category_slug=mosp-part-2-operations&Itemid=101

 

I cannot understand why RAAus could not adopt an identical process to allow controlled airspace access.

 

 

[Captaincoop]

From how far out do you have to be 1500ft?

Prior to entering the class D airspace one would assume

 

 

[DWF]

From how far out do you have to be 1500ft?

Bruce, check out "ON TRACK" on the CASA web site

Click on the symbol near Brisbane then select Archerfield and "inbound" etc.

 

There is probably more info here than you ever wanted (or need) to know.

 

 

[nomadpete]

Another case illustrating the value of all recreational flying groups sticking together in an effort to get a collectively fair operational environment. We would do well to join forces with the likes of GFA

 

 

[Bruce Tuncks]

Thanks guys. A real bugger that Archerfield is in line with that Brisbane runway.

 

Very interesting that bit in the act about unfair allocation of airspace. To my mind, what is being done is grossly unfair. It's a good point to know.

 

But many people, even including well-educated people, are quite irrational about " aircraft safety".

 

This friend of mine, who was a university senior lecturer, once saw a 35,000 ft airliner flying over Gawler, and he was amazed that we were allowed to fly at Gawler with what was to him an obvious risk of a mid-air. He was completely impervious to any arguments I tried to make to explain why there was no risk here.

 

I reckon a lot of people have a deep-seated but suppressed fear of heights and this makes them irrational. It would be just my luck to come up against a judge like this.