Lowering Class E between Melbourne and Cairns

[Flying_higher]

25 minutes ago, Bennyboy320 said:

Well I’ve just looked through the AIP & there is NO requirement to have dual VHF radios to legally operate in ANY airspace in Australia, looks like Airservices is just making things up as they go along.

I think the reason we will need the two radios is because you cannot operate in Class E whilst maintaining continuous two way radio communication with centre and also be on the CTAF. The two will overlap when you join the circuit at 2000. 

[jackc]

Just now, Flying_higher said:

I think the reason we will need the two radios is because you cannot operate in Class E whilst maintaining continuous two way radio communication with centre and also be on the CTAF. The two will overlap when you join the circuit at 2000. 

IF it all turns pear shaped at the proposed height......you will barely have time to use any radio, let alone two of them.

[planesmaker]

My submission to airservices

 

This proposal will not increase safety, likely to decrease safety, several issues that come to mind,
1) aircraft are not fitted with AGL meters, 500' agl is easy enough to questimate, but 1500' agl is a very vague figure, especially when operating around hilly terrain, just from where or how are pilots to ascertain where the limits are?
2) training schools are required to carry out stall training, according to the syllabus, stalls must be recovered by 3000' agl, in order to comply they will all have to be fitted with a transponder at a not insignificant cost (approx $5-7,000. Not to mention the on going rad47 costs every 2 years) A lot of training takes place in RAAus registered aircraft, most of which are not fitted with a transponder.
3) forcing all non transponder equipped aircraft below 1500' is a recipe for disaster, imagine flying near mountainous terrain and being caught in rotor, or the increased turbulence adding to pilots work load, and also extra airframe loading. With a higher concentration of aircraft below 1500' without hemispherical levels will increase chance of a midair. 
3) circuit height for high performance aircraft is 1500'agl  any aircraft overflying would also be forced to fly through the circuit area or detour around. Most midairs occur in the vicinity of aerodromes, this proposal increases this risk. 
4) there are a lot of recreational aircraft not fitted with transponders, the owners would incur significant costs if forced to fit transponders. 
5) Airservices has not presented a safety reason for implementing such a radical change in airspace. 

[Garfly]

9 minutes ago, Flying_higher said:

I think the reason we will need the two radios is because you cannot operate in Class E whilst maintaining continuous two way radio communication with centre and also be on the CTAF. The two will overlap when you join the circuit at 2000. 

Yes, this is probably their thinking.  We get a taste of it in this AIP-SUP:

 

BALLINA B'CAST AREA.pdf

 

Some relevant passages:

 

 

5.1.1  Pilots of Visual Flight Rules (VFR) aircraft fitted with two or more serviceable VHF radios and with a transponder and/or Automatic Dependent Surveillance- Broadcast (ADS-B) are strongly encouraged to request a flight following Surveillance Information Service (SIS) from Air Traffic Control (ATC) on the area frequency. This free service will enable ATC to provide enhanced traffic information to both VFR and IFR pilots. 

 

5.2.1 Aircraft are not required to be fitted with a transponder or ADS-B avionics to operate in the Broadcast Area. However, if an aircraft is fitted with a correctly functioning transponder and/or ADS-B avionics then it is required to be switched on and used. If the aircraft is fitted with a Mode C transponder (which is serviceable and approved for use), then it is to be selected to the Altitude position, unless otherwise directed by ATC. 

 

 

 

It's a grand, grand scheme. Someone, in some office somewhere, is staking their career on it..  I think this will be great fodder for a revamped ABC  "Utopia" series.  Although this might be too far fetched.

[Bennyboy320]

I’m guessing that rather than physically having two separate VHF radio’s having for an example the Macair VHF radio that can monitor two frequencies at the same time would fit the requirements, and yes if it fails you can sqwak 7600.

[jackc]

U.S Marines F4 flies VFR with no transponder and broken Radar etc etc

 

[walrus]

But wait! There's more costs! If AsA mandates transponders AND ADSB then add another $4000++ to the costs.

 

AsA requires that any transponder outputting ADSB signals MUST have a TSO'd GNSS position source (SIL=2).  The cheapest of those is over $2000. You are legally not allowed to use anything with SIL = 1 on a transponder, I currently output SIL = 0 which means ASA ignores it.

 

I can't see AsA making a Sky echo mandatory either.

[Roscoe]

9 hours ago, Bennyboy320 said:

I’m guessing that rather than physically having two separate VHF radio’s having for an example the Macair VHF radio that can monitor two frequencies at the same time would fit the requirements, and yes if it fails you can sqwak 7600.

Would a Handheld Transceiver satisfy the 2 VHF Radio requirement?

Just a thought!

[jackc]

1 minute ago, Roscoe said:

Would a Handheld Transceiver satisfy the 2 VHF Radio requirement?

Just a thought!

I have 2 VHF Handheld radios, I am covered 🙂 

[Roscoe]

30 minutes ago, jackc said:

I have 2 VHF Handheld radios, I am covered 🙂 

I cant see the 2 Radio requirement being mandatory.

In fact this whole Class E matter will need need to be revised with CASA involvement.

 

[RFguy]

plenty of misinformation out of RAAUS : . I will address them where I think I have something useful to say :

per item...

   
     
    Aircraft conducting training manoeuvres such as stalling must operate above 1500’ AGL to ensure adequate room to recover from unintended operations. These aircraft would be required to fit transponders under this proposal simply to continue to operate as  normal

JUST FIT A TRANSPONDER ! A MODE A OR C IS CHEAP. No need for a Mode S. New GA installs must be Mode S, or S-ES, but not RA
     
    Should this proposal go ahead in the timeframe proposed, it is likely there will be insufficient equipment available to purchase. Additionally, there will be a shortage of qualified personnel to fit the required number of transponders in the time stated
PROBABLY TRUE
     
    Basic calculations to fit 2275 RAAus aircraft with a Mode-S transponder at an approximate cost of $7500 per aircraft results in a cost to the RAAus industry of around $17 million

TOTAL CRAP. putting labour aside :  where do they  get $7500 from ?

A Mode S-ES transponder is NOT required.

A standard Mode S  would be fine- new unit price 2-3k.  Mode S-ES (with adsb out ) unit price is about 4500 street price

A basic Mode A (no altitude encoder ) or Mode A/C together with an SKyecho would meet requirements. 

     
    The biannual calibration of these aircraft would amount to approximately $2.275 million, if a basic $1000 per unit fee is used, a significant and ongoing cost
That's total crap also.  Check of these aircraf tis no more than a  30 minute job for competent personnel !!! and there is no 'calibration' required , it works or it doesnt- digital stuff doesnt drift.  Old altitude encoders (AE)  can go bad but that's if really old, and then you can just run ModeA and not nother with the AE.
     
    Should the need to fit an additional VHF radio be required, as per the current proposal, the cost impact would be another on-off cost of approx. $17.4 million to the RAAus industry
That's crap also.  Crapola. $if $2000 a radio + $500 install, about 2000 aircraft, 4 mil bucks.

    This proposal introduces significant operational risk to pilots who do not have a serviceable transponder or radios in their aircraft. Pilots of affected aircraft will be required to operate at low levels over unsuitable terrain or around this newly classified  Class E airspace, with the resulting effect of turbulence and an increased effect of wind on safe operations

FIt a transponder, then !
     
    The proposed 1500’ lower limit has been put forward as Above Ground Level (AGL). It is not feasible for pilots to manage an AGL limitation. Even if a Lowest Safe Altitude (LSAlt) is the mandated management method, avoidance of airspace based on AGL will  result in a potential increase in incursions due to pilot workload, terrain variations and the industry standard use of altimeters referencing Above Mean Sea Level (AMSL)
Yes, the minimum should be 3000 feet as not to get mixed up with aerodrome ops.

     
    Insufficient time has been provided to allow industry to consider, consult and create alternative proposals, which could reduce the operational impact on aircraft operators and potentially reduce the cost
Maybe extend the compliance period.
     
    A significant reduction in safety will occur due to reduced time for adequate decision making for pilots when managing emergencies below 1500’AGL
true. hence 3000'
     
    An increase in complaints will occur as a result of occupants of dwellings registering concerns about increased aircraft noise and overflight of residential areas due to pilots of non-transponder equipped aircraft being forced to fly much lower than currently  permitted
Oh maybe....
     
    Airservices have not provided information as to how many VH- registered aircraft are affected. RAAus understands this data is not available from CASA
So what.
     
    Airservices have not provided confirmation adequate separation services can be provided for the airspace levels proposed
     
    A risk assessment has not been provided which adequately explains the need for the proposed lower limit of Class E
     
    ATC will still only be responsible for IFR to IFR separation. VFR operations in Class E will still be able to operate without flight plan or ATC knowledge
     
    Our sister organisations, the Gliding Federation of Australia (GFA), will be required to fit equipment to towing aircraft (gliders are exempt from the requirements) and the Sport Aviation Federation of Australia (SAFA, formerly HGFA) will also be impacted  by requirements to fit equipment to aircraft. This equipment cost is significant in comparison to the overall cost of some of these aircraft
     
    The overall safety benefit of the proposal will be negated if aircraft exempt from the airspace requirements are operating in the airspace
Gliders etc will need transponder and EC device.
     
   " RAAus is unaware of a safety case having been presented to industry to increase the amount of Class E airspace"
     
    While hemispherical operations are not required below 5000’ AMSL, effective separation between east and west flights will not be possible in operating outside the lower limit of Class E, leading to an increased possibility of collision
So fit the equipment
     
    The proposal effectively ‘shuts out’ a large percentage of RAAus operators and training schools, and an unknown number of pilots in GFA, SAFA and VH- registered aircraft

That's crap. just fit a transponder, A,C, S, ES .
     
    The duration of consultation phase is not sufficient to provide assurance that equitable access to airspace for all users has been considered
     
    There has been no information communicated at this time nor does it appear there is any awareness of the cost this proposal imposes on industry
     
    No Regulatory Impact Statement has been provided by Airservices
     
    CASA must consider all these items in order to justify to Government this proposal and the associated cost to industry is reasonable
     
    A suitable proposal must be created that cohesively and nationally manages the expected increase in drone traffic (VTOL and beyond line of sight) to ensure adequate separation from aircraft
GOOD POINT
     
    Government support in the form of funding to ensure all aircraft operate with transponders could remove many of the current objections

 

 

Edited February 10, 2021 by RFguy

[Kyle Communications]

What does make me laugh at this is if it goes ahead then effectively you are in CTA......so just fitting a transponder is not the only thing...how many RAA pilots have CTA endorsements...does this mean that ok I get my transponder and then I have to get a CTA endorsement as well because I am now allowed in Class E airspace?????

 

[Thruster88]

No clearance is required for VFR pilots in class E.

[Garfly]

As I understand it, Mark, we can make use of Class E right now without need of any clearance as long as we have a transponder. (At a minimum, one that is capable of triggering an old fashioned TCAS unit.)

So if affordable EC devices (did I hear 'TABS'?) become available (which are allowed as substitutes for full-on transponders in Class E) in the end this whole situation might turn out better for everybody.  For example, as the ATSB report into the recent Coffs tragedy says, if the AMP (Airspace Modernisation Program) proposal goes ahead then one outcome could be that (ADSB equipped) VFR craft could transit Coffs without a clearance.)

So this whole situation could have and should have been begun with public discussion along the lines "Is it time for all aircraft to move towards being ADSB-out equipped? And, if so, how can we make this possible technically without many VFR flyers needing to spend half the value of their aeroplane just to comply?" 

But no, ASA wanted to throw a cat among the pigeons just to make sure they - and their powers - were being noticed.

Of course, they know all the arguments against the proposal way before they published it.  One feels a bit duped, being forced to rebut what is really only a clumsily made ambit claim.

 

Edited February 10, 2021 by Garfly

[jackc]

Two words......giant shambles 😞

[RFguy]

certainly, there is plenty of 'comment' back to ASA and RAAus about this, I doubt anything will change in a hurry.

 

[jackc]

4 minutes ago, RFguy said:

certainly, there is plenty of 'comment' back to ASA and RAAus about this, I doubt anything will change in a hurry.

 

Plans cannot be made in absence of the final proposal outcome.

We can only guess our requirements until the final day.

It MAY all end up in the too hard basket and we continue on as normal, until ASA have another brain seizure, in 5 years time.  One can only hope 🙂

 

[SplitS]

Just buy a transponder is a B.S response.

The radar coverage along the coast would be about 30% at on below 5000' on a good day.

So we force everyone to carry an expensive paper weight for most of the flight when they could have 100% coverage for other aircraft if they where ADSB equipped. 

It's not just the cost of the transponder it's the ongoing certification.

Transponders require an ATC operator to see you and vector IFR aircraft around you they have demonstrated recently that this is a failure point.

ADSB is the future they should just embrace it now the Skyecho's in class E airspace would be a good start.

This proposal is so stupid the bureaucrat who proposed it should be fired. Won't happen they will probably get promoted.

 

[kgwilson]

1 hour ago, RFguy said:

plenty of misinformation out of RAAUS : . I will address them where I think I have something useful to say :

per item...

   
     
    Aircraft conducting training manoeuvres such as stalling must operate above 1500’ AGL to ensure adequate room to recover from unintended operations. These aircraft would be required to fit transponders under this proposal simply to continue to operate as  normal

JUST FIT A TRANSPONDER ! A MODE A OR C IS CHEAP. No need for a Mode S. New GA installs must be Mode S, or S-ES, but not RA
     
    Should this proposal go ahead in the timeframe proposed, it is likely there will be insufficient equipment available to purchase. Additionally, there will be a shortage of qualified personnel to fit the required number of transponders in the time stated
PROBABLY TRUE
     
    Basic calculations to fit 2275 RAAus aircraft with a Mode-S transponder at an approximate cost of $7500 per aircraft results in a cost to the RAAus industry of around $17 million

TOTAL CRAP. putting labour aside :  where do they  get $7500 from ?

A Mode S-ES transponder is NOT required.

A standard Mode S  would be fine- new unit price 2-3k.  Mode S-ES (with adsb out ) unit price is about 4500 street price

A basic Mode A (no altitude encoder ) or Mode A/C together with an SKyecho would meet requirements. 

     
    The biannual calibration of these aircraft would amount to approximately $2.275 million, if a basic $1000 per unit fee is used, a significant and ongoing cost
That's total crap also.  Check of these aircraf tis no more than a  30 minute job for competent personnel !!! and there is no 'calibration' required , it works or it doesnt- digital stuff doesnt drift.  Old altitude encoders (AE)  can go bad but that's if really old, and then you can just run ModeA and not nother with the AE.
     
    Should the need to fit an additional VHF radio be required, as per the current proposal, the cost impact would be another on-off cost of approx. $17.4 million to the RAAus industry
That's crap also.  Crapola. $if $2000 a radio + $500 install, about 2000 aircraft, 4 mil bucks.

    This proposal introduces significant operational risk to pilots who do not have a serviceable transponder or radios in their aircraft. Pilots of affected aircraft will be required to operate at low levels over unsuitable terrain or around this newly classified  Class E airspace, with the resulting effect of turbulence and an increased effect of wind on safe operations

FIt a transponder, then !
     
    The proposed 1500’ lower limit has been put forward as Above Ground Level (AGL). It is not feasible for pilots to manage an AGL limitation. Even if a Lowest Safe Altitude (LSAlt) is the mandated management method, avoidance of airspace based on AGL will  result in a potential increase in incursions due to pilot workload, terrain variations and the industry standard use of altimeters referencing Above Mean Sea Level (AMSL)
Yes, the minimum should be 3000 feet as not to get mixed up with aerodrome ops.

     
    Insufficient time has been provided to allow industry to consider, consult and create alternative proposals, which could reduce the operational impact on aircraft operators and potentially reduce the cost
Maybe extend the compliance period.
     
    A significant reduction in safety will occur due to reduced time for adequate decision making for pilots when managing emergencies below 1500’AGL
true. hence 3000'
     
    An increase in complaints will occur as a result of occupants of dwellings registering concerns about increased aircraft noise and overflight of residential areas due to pilots of non-transponder equipped aircraft being forced to fly much lower than currently  permitted
Oh maybe....
     
    Airservices have not provided information as to how many VH- registered aircraft are affected. RAAus understands this data is not available from CASA
So what.
     
    Airservices have not provided confirmation adequate separation services can be provided for the airspace levels proposed
     
    A risk assessment has not been provided which adequately explains the need for the proposed lower limit of Class E
     
    ATC will still only be responsible for IFR to IFR separation. VFR operations in Class E will still be able to operate without flight plan or ATC knowledge
     
    Our sister organisations, the Gliding Federation of Australia (GFA), will be required to fit equipment to towing aircraft (gliders are exempt from the requirements) and the Sport Aviation Federation of Australia (SAFA, formerly HGFA) will also be impacted  by requirements to fit equipment to aircraft. This equipment cost is significant in comparison to the overall cost of some of these aircraft
     
    The overall safety benefit of the proposal will be negated if aircraft exempt from the airspace requirements are operating in the airspace
Gliders etc will need transponder and EC device.
     
   " RAAus is unaware of a safety case having been presented to industry to increase the amount of Class E airspace"
     
    While hemispherical operations are not required below 5000’ AMSL, effective separation between east and west flights will not be possible in operating outside the lower limit of Class E, leading to an increased possibility of collision
So fit the equipment
     
    The proposal effectively ‘shuts out’ a large percentage of RAAus operators and training schools, and an unknown number of pilots in GFA, SAFA and VH- registered aircraft

That's crap. just fit a transponder, A,C, S, ES .
     
    The duration of consultation phase is not sufficient to provide assurance that equitable access to airspace for all users has been considered
     
    There has been no information communicated at this time nor does it appear there is any awareness of the cost this proposal imposes on industry
     
    No Regulatory Impact Statement has been provided by Airservices
     
    CASA must consider all these items in order to justify to Government this proposal and the associated cost to industry is reasonable
     
    A suitable proposal must be created that cohesively and nationally manages the expected increase in drone traffic (VTOL and beyond line of sight) to ensure adequate separation from aircraft
GOOD POINT
     
    Government support in the form of funding to ensure all aircraft operate with transponders could remove many of the current objections

 

 

This is not misinformation. It is what you have interpreted it to be.

1. The whole concept around recreational flying and enshrined in CASA regulations is exempting Recreation Aircraft from costly equipment, airspace rules and operations. Why should 3263 RA aircraft (some do have them I agree but the majority by far do not) be compelled to fit transponders, a 75 year old technology when they have not been required before. Even GA do not have to fit them unless they fly in controlled airspace.
2. Your comments regarding cost are again a broad statement. Many aircraft are located in remote areas and the cost of getting the installer to them or vice versa can be considerable. Also most Instrument LAMES charge like wounded bulls so $ 500 for fitting is way under done. That wouldn't even pay for their travel to the aircraft and back.
3. No-one including gliders should be forced to fit equipment that is not currently required due to a proposal that has no demonstrated evidence based safety benefits.
4. 1500 agl is not a legal lower airspace level. When I requested where the medium and high density areas of the J curve were they referred me to the proposed WAC charts. If the whole area is to be Class E then the lowest level will have to be above the highest point Bimber Peak is  6276 feet. That would make the LL a minimum of 7800 feet, hardly worth the change. This won't happen. Basically they don't have a clue where the medium and high density areas are. RPT generally cruise between 15,000 and 35,000 feet and it is only on descent/departure in IFR that they go through Class G. At major airports they descend/depart through the ATC approach levels which we already keep clear of.

This proposal if implemented in it's current form is a MAJOR safety problem for ALL airspace users. The current rules are not causing problems. If they subsidise ADSB like they have in the UK traffic awareness will be greatly enhanced. It is only near major regional airports like Ballina that there are any traffic issues and this is being dealt with separately with the MBZ and the glorified Unicom. Their failure to allocate a discrete frequency is the only real problem and over transmits in the area are common & that is due to the 4 aerodromes in the area using the same frequency.

Edited February 11, 2021 by kgwilson

[Garfly]

An imaginary dialogue:

ATSB (to ASA): Colleagues, our investigation of the 2019 fatal air-crash west of Coffs reveals that, despite the best of intentions, the over-design, plus the over-servicing of airspace can, sometimes, lead to more harm than it averts.

 

ASA (to ATSB): Hold my beer, sonny!  How's THIS for over-design?  How's THIS for over-servicing?

Edited February 11, 2021 by Garfly

[RFguy]

I did ask air services about what constituted  "1500 feet AGL' on a  direct path  between Gunnedah  and Port Macquarie, given that the terrain varied 1000 feet inside 1nm, and asked them what height I needed to fly at to be under Class E at  1499 feet AGL.

 

I got a reply that they were 'going to get back to me'

 

The 1500' is nonsense. will get mixed up also with last airstrip circuits, unnecessary complication.

 

 

 

Edited February 11, 2021 by RFguy

[RFguy]

24 minutes ago, kgwilson said:

This is not misinformation. It is what you have interpreted it to be.

1.  

Yeah I agree, misinformation was a bit strong. . I retract that word. 

 

[RFguy]

The $64 unanswered question is  - with any boundary  lower than say 8500 feet , what is going to determine AGL in rough terrain ?

 

There isnt an firm , non rubbery answer to that.

 

 

 

 

[Garfly]

The other big Q is: When can we expect E-approved low-cost "integrated TABS" devices being available?  If this point alone was cleared up, much of this the mayhem might be averted.  And there may then be no need to mess with the airspace so much.

Making mayhem might be fun for some; the down side being that it erodes constituent trust in the regulators.

Maybe they feel that it's only the politicians they have to play to.

But that can come back to bite them.

[Viz. the Senate enquiry into the CASA/ATSB response to the Pel-Air accident.]

Edited February 11, 2021 by Garfly

[RFguy]

If the D airspace (in the cone above a CTZ aerodrome)  above the class C in CTZ was simply changed to E airspace, and we could transit without a clearance, as long as we had EC and transponder, that would be cool.

 

The idea of extending class E space into the great divide inland is nonsense.