Glen, are you're saying that you think the clarification I got from RAAus (as quoted above - and, in more detail, below) is wrong - have things changed?:
From: Gary ..........................
Sent: Wednesday, 27 January 2021 6:31 AM
To: RAAus Policy <
[email protected]>
Subject: Update on lowering of Class E airspace
Dear RAAus team,
your update today regarding the proposal to lower Class E made no mention of what seems to be a relevant implication; the CASA ‘concession’ to recreational craft to substitute relatively cheap EC (Integrated TABS) devices for TSO’d transponders in Class E.
CASA ADVISORY CIRCULAR AC 91-23 v1.0
Excerpt:
"Apart from an integrated TABS device able to substitute for a transponder in Class E & G airspace, lower cost options are not intended to overcome any existing requirement to carry a transponder, in any class of airspace.”
I’m not saying that this makes the proposal okay, not at all; but it does appear to be part of the grand CASA strategy (and a way to dampen resistance from the VFR crowd). Anyway I’d have thought that at least some engagement wit this gambit ought to be part of any response.
The SkyEcho2 device, for example, seems to qualify under this concession. As you know, it's stand-alone portable unit that can even be moved between (uniquely registered) aircraft. So carrying one may indeed overcome many of the objections we, as a group, might otherwise raise. It might even make some things better for our sector, such as clearance-free transit overhead Class D at Coffs. However, if, indeed, mandating this kind of device (at a minimum) is what CASA (in their obfuscating way) is intending, then why don’t they come out and say so?
They should reveal their hand if they really want ‘consultation’.
BTW, this issue has been heavily canvassed in recent days on Recreational Flying forums but it seems nobody knows for sure what’s going on.
https://www.recreationalflying.com/topic/37213-lowering-class-e-between-melbourne-and-cairns/
all the best,
Gary ..... (RAAus pilot/member)
On 27 Jan 2021, at 6:22 pm, RAAus Policy <
[email protected]> wrote:
G'day Gary,
Thanks so much for your email.
It totally agree with your notion that as an industry, and I mean all stakeholders including the regulator, need to work together to come up with solutions that work for all, with little or no impact. Of course the EC devices are a terrific situational awareness tool however, as you'll find in CAO 20.18, these are not able to be used by ATC and therefore do not meet the requirements of transponder fitment in Class E.
The safety benefits of EC devices are real for us pilots, but because of the technical standards we're told by the regulator and Airservices that the integrity of the positional source information and because of the low wattage of the SkyEcho2, for example, it's not suitable for use by ATC and therefore it's filtered out of their radar picture.
Happy to discuss further.
Cheers
Matt Bouttell
CEO RAAus
From: Gary ...........
Sent: Wednesday, 27 January 2021 7:45 AM
To: RAAus Policy <
[email protected]>
Subject: Re: Update on lowering of Class E airspace
Hi Matt,
Thanks for getting back.
So what do you make of the quote from the CASA circular that I included in my mail?
They clearly say that Integrated TABS (SIL<=1) - such as a SE2 - can be substituted in Class E.
Is it false? Has it been rescinded? What gives?
If you have clear info that contradicts the CASA statement above then it’s urgent that we know about it.
Even right now for ops in Class E.
Please refer to the Rec Flying forum I mentioned.
https://www.recreationalflying.com/topic/37213-lowering-class-e-between-melbourne-and-cairns/
I gather, from various CASA documents that it’s not only ATC visibility that’s in their thinking but also CDTI tech being aboard all regional RPT craft. I reckon they figure that if RPT all have ADSB-in info displayed they can take over some of their own separation responsibility in E (as they do now in G) as long as everyone in the space has some kind of conspicuity going. And, in any case, a SkyEcho2 type device is likely, in practice, to be visible to ATC in terminal areas low power notwithstanding.
What say you?
gary.
From: RAAus Policy <
[email protected]>
Subject: Re: Update on lowering of Class E airspace
Date: 27 January 2021 at 7:04:59 pm AEDT
To: Gary .......
Hey Gary,
An integrated TABS device is not an EC device, such as the SE2. These are two different things. If you take a look at CAO 20.18 Appendix XIII (for integrated TABS) or Appendix XIV (for EC device) you'll see that an integrated TABS device must meet the technical specifications for (E)TSO-C199. and have a SIL of 1.
I think this raised the issue of how complex this matter is. People are confused as to the proposal but also the requirements as they stand today.
We'll make mention of this to Airservices (whom I'm meeting tomorrow) and CASA at the earliest opportunity to ensure the current requirements are made clear.
I hope this helps.
Cheers
Matt