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Lowering Class E between Melbourne and Cairns


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Run your wheels along the ground and note the alt reading and add 1500 to it.  I give UP. What's 5 hours got to do with it?   Nev

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RF guy, RAA and other organisations HAVE to reject this proposal out of hand or otherwise they are conceding Airservices the right to make arbitrary decisions. We are then reduced to just being suppli

Dont fall into their trap. To consider any change before a complete justification statement can be proven true and correct gives them leverage. By suggesting other than the status quo at this time say

'Welcome to OneSky™ Australia, where we want everyone to be included.' To be included in 'OneSky'™ will cost you about ten thousand dollars per aircraft for initial installation, An annual f

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5 minutes ago, facthunter said:

Run your wheels along the ground and note the alt reading and add 1500 to it.  I give UP. What's 5 hours got to do with it?   Nev

 

Nothing - Was just thinking about long navs over various elevations as apposed flying around your home AD.

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1 minute ago, BirdDog said:

 

Nothing - Was just thinking about long navs over various elevations as apposed flying around your home AD.

Well I could be rather safe by flying on roadmaps and keeping my 1500ft.

Me following roads will mean no one is stupid as me, and I won’t crash into anyone:-)

By the way, I can chuck this out the window under the new proposal.
 

58AA3093-704F-4BC5-8A0D-64863ADC8EE0.jpeg

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Yep!  It's a head scratcher.   

 

So what happens when a few pilots are flying between ADs.  For example, many many many pilots simply follow the magenta line.   So let's pic 2 ADs..... We will call them Simpleville and Dopeyville.    These 2 ADs are popular and the route between them is a popular nav route on the way to other places.

 

How do pilots safely separate?  If you have even 2 or 3 aircraft travelling between these 2 ADs, remaining between 500ft AGL and 1500ft AGL how do they ensure they are not head on?  Everyone will basically sit on 1000ft.  Then what?

 

It's doing my head in!

Edited by BirdDog
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What Airservices propose and what eventuates are 2 different things if it happens at all. The proposal may be 1500 feet AGL but it will have to be expressed as all other height limits are as Height AMSL so in one of the so called medium or high density Class G areas, they are going to have to pick a height, probably the highest part of the proposed area, add 1500 feet to it and set that as xxxx feet AMSL for the Class E boundary. You can't have an airspace boundary with contours.

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Well I've made my submission of 10 major points to RA-Aus & will wait a few days to make a full detailed submission to Airf***ing Services. I wonder when CASA are going to get in on the act. At present they will be keeping their heads down dodging the Flak.

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1 hour ago, jackc said:

 

"Then there is the ‘Fresnel Zone’ that can stuff things up over terrain very close to 1500ft in our case.  Corrupted data comes to mind here."

NO. complete bollocks.  it will not come into the equation or be relevant  for these paths

 

"A dish needs to be on the correct azimuth and elevation to successful ‘scan’ me and pick up my transponder or EC."

YES, it rotates at 15 RPM,  and that's how it sees transponders and how it talks to some and not others.

 

" IF there is an 1800ft high hill between me and an ATC or another aircraft, they won’t ‘see’ me."

That is true if you are very close to the hill. If you are 5 to 10nm , you might diffract over it. 


:-)  :-) 

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30 minutes ago, RFguy said:

"Then there is the ‘Fresnel Zone’ that can stuff things up over terrain very close to 1500ft in our case.  Corrupted data comes to mind here."

NO. complete bollocks.  it will not come into the equation or be relevant  for these paths

 

I would like to experiment on this with a physical radio survey and a beaconing Data transmitter, with receiver in aircraft.

 

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On 26/01/2021 at 12:27 PM, extralite said:

More of a GA issue when flying IFR.

 

If a clearance cannot be obtained on the ground in places where ATC can't be reached on the ground, won't it involve having to stay under 1500ft until a clearance can be obtained? Depending on radio traffic and ATC load, this can take some time. So on an IFR flight plan, possibly with low cloud, can't ensure terrain clearance by planning a departure within the splay set out in ersa, or reverse approach etc.  If cloud is a factor, i think it would mean having to maneuver clear of cloud within the circling area which is not really idea. Or is there another approach?

You don’t need clearance to fly in Class E. 

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Second time someone has said that...second time same answer..you do if you are on an IFR flight plan.

 

"Except in an emergency, a clearance is required for all flights in Classes A, C, and D airspace, restricted areas and for IFR flights in Class E airspace, except when operating in accordance with IFR pick-up procedures. Clearance is not required for VFR flights in Class E airspace."

 

https://vfrg.casa.gov.au/operations/controlled-airspace/general-2/

Edited by extralite
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You don't need a clearance for class E VFR but you do need a transponder and radio. If they just did a rule change to allow Skyecho or similar to be used instead almost everyone would be happy. 

I do have a transponder however making everyone fit a heavy, expensive, out of date piece of gear so they can fly the coast is crazy talk when we have cheap tech that will do the job just fine.

Also ATC have shown in a few recent incidents that they  cannot  be trusted in making any decisions other than what type of coffee they should be drinking.  

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20 minutes ago, SplitS said:

You don't need a clearance for class E VFR but you do need a transponder and radio. If they just did a rule change to allow Skyecho or similar to be used instead almost everyone would be happy. 

I do have a transponder however making everyone fit a heavy, expensive, out of date piece of gear so they can fly the coast is crazy talk when we have cheap tech that will do the job just fine.

 

I agree.

You make perfect sense, proposing a logical,simple and cheap solution which,if added to an increase (well, really a decrease) to Class E LL5000, would be acceptable.

Anyone transponderless would still be able to have the 1000 ft separation when tracking opposite directions.

 

Yeah, I know. Crazy talk

 

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I put my 10 point submission to RA-Aus & the new CEO actually replied that they would be used in his submission. That is a first. One of my points was getting rid of the Transponder requirement as at 1500 feet in many circumstances ATC will not get the signal & it will increase their workload. Airservices proposal does not mention Transponders once but mentions ADSB several times. If they insist on ADSB in/out I suggested it be subsidised 50% by them. They could do a bulk deal with Uavionix & get them for probably $3-400 anyway so cutting out all the middle men & retailers it would not cost them much at all if anything.

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They don’t need to change the airspace classification for everyone to start using EC devices and to get the safety benefit. Just use them as an aid to see and avoid and this includes RPT and other IFR pilots when Flying VFR. CASA only change the regs last July. Give it a chance first and I’m sure the problem is solved. Imho

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11 minutes ago, graham brown said:

They don’t need to change the airspace classification for everyone to start using EC devices and to get the safety benefit. Just use them as an aid to see and avoid and this includes RPT and other IFR pilots when Flying VFR. CASA only change the regs last July. Give it a chance first and I’m sure the problem is solved. Imho

Yeah, I agree with the safety benefit, but...

 

1) The Airservices proposal (Q & A section --> https://engage.airservicesaustralia.com/lower-base-class-e-east-coast?tool=qanda) states

   This change is proposed to proceed with the current equipage requirements as per the existing regulations. This change does not require an ADS-B mandate for VFR aircraft in order to proceed.

 

2) In the same document under "Benefits"

       "Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management."

       The US requires Mode A transponders in Class E airspace

 

3) As per CASA advisory circular https://www.casa.gov.au/sites/default/files/advisory-circular-91-23-ads-b-enhancing-situational-awareness.pdf, page 18

         For an EC device, under Transponder modal interactions,  it has No transponder function

        Thus, an EC, by CASA's own  definition, is not a transponder (And no, I am not going to get into an argument re the technical stuff about Integrated TABS - this is just my reading of the regs etc)

 

Executive Summary?

  • Airservices says there is no need to change ADS-B regs, and as per USA, assume they want (at least) Mode A transponders
  • Sky Echo (EC device) is not recognised as a transponder
  • Sky Echo thus does not meet the proposed changes to Class E

Please tell me I'm wrong.

 

 

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38 minutes ago, horsefeathers said:

Yeah, I agree with the safety benefit, but...

 

1) The Airservices proposal (Q & A section --> https://engage.airservicesaustralia.com/lower-base-class-e-east-coast?tool=qanda) states

   This change is proposed to proceed with the current equipage requirements as per the existing regulations. This change does not require an ADS-B mandate for VFR aircraft in order to proceed.

 

2) In the same document under "Benefits"

       "Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management."

       The US requires Mode A transponders in Class E airspace

 

3) As per CASA advisory circular https://www.casa.gov.au/sites/default/files/advisory-circular-91-23-ads-b-enhancing-situational-awareness.pdf, page 18

         For an EC device, under Transponder modal interactions,  it has No transponder function

        Thus, an EC, by CASA's own  definition, is not a transponder (And no, I am not going to get into an argument re the technical stuff about Integrated TABS - this is just my reading of the regs etc)

 

Executive Summary?

  • Airservices says there is no need to change ADS-B regs, and as per USA, assume they want (at least) Mode A transponders
  • Sky Echo (EC device) is not recognised as a transponder
  • Sky Echo thus does not meet the proposed changes to Class E

Please tell me I'm wrong.

 

 

If you leave the airspace class g to 8500ft. There is no problem. The problems come about by changing it to class e. RPT’s and the like can get their separation and situational awareness themselves. Just like all the others flying vfr. We have the devices to do this now and so do they. No changes o airspace required.

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2 hours ago, horsefeathers said:

 

Executive Summary?

  • Airservices says there is no need to change ADS-B regs, and as per USA, assume they want (at least) Mode A transponders
  • Sky Echo (EC device) is not recognised as a transponder
  • Sky Echo thus does not meet the proposed changes to Class E

Please tell me I'm wrong.

 

 

HF, I now believe you have been right all along about the SE2 not being that 'low cost device' that CASA were referring to in their circular - as an allowable substitute for Class E entry.  In fact, it seems that there is no "Integrated TABS" device in existence in OZ at all.  So why announce the concession, then?  Maybe CASA are trying to prompt equipment makers to come up with something that would be I-TABS compliant (Could that be an SE3 we see on the horizon?  ;- )   Do we throw away our SE2s, at that point, then?  (If we want to fly in E - meaning, in practice, if we want to fly.)

 

Of course, I may be wrong again, but I wouldn't put it past them; holding their cards so tightly to their chest that ambiguity - and confusion - works to their bureaucratic benefit.

 

Anyway, as you say, the SE2 is an approved EC but [AFAIK now] does not meet all the standards of an Integrated TABS (Traffic Awareness Beacon) even though it is SIL=1 compliant (i.e, position integrity meets TAB standards).   

 

It's some consolation, I guess, that ours is not the only forum where confusion reigns (unchallenged by plain talk from our rulers). 

 

For example, this is a similar discussion on pprune last year

 

https://www.pprune.org/pacific-general-aviation-questions/633876-low-cost-ads-b-vfr.html

 

And this is a thread titled TABS Vs ADSB  from the UK's Flyer magazine forum.

 

https://forums.flyer.co.uk/viewtopic.php?t=110763

 

This particular post is by gaznav (who contributes here sometimes):

 
User avatar
By gaznav -  Sat Dec 29, 2018 5:22 pm
 
bookworm wrote: patowalker wrote:
 
My bold. I believe SkyEcho 2 is a TABS device."

No, it's not. TSO C-199 TABS devices have a transponder-like functionality when interrogated by TCAS. They also use a position-source for which is not as stringently specified as that needed to meet a requirement for ADS-B (including in the US). It's that aspect that has been picked up for "ADS_B light" use. Hence uAvionix says:

"SkyEcho includes a TSO-C199 GPS transmitting a Source Integrity Level (SIL) value of 1."

AFAIK the SE2 conforms to the TABS standard for ES except for the power output but has no transponder functionality. IIRC then TABS minimum power output is 70W and CAP1391 devices are just 20W.

Will these devices ever be allowed in CAS? I think that is where the CAA/NATS want to go in the future but it’s little steps to begin with and to see how far we can go with portable low-power ADS-B. The first thing is to get them fully cleared for use in transmit with Mode A/C and Mode S (non-ES) transponders - which is hoped (when updated in November) to have that in place by late Q1 2019.
Edited by Garfly
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What Airservices are doing could well be what the Unions do with wages. Put in a claim that is ridiculous and everyone gives a gasp of relief when only half of what they wanted is allowed. Maybe they really want to reduce class E to 5000', but if they had proposed that we would all have objected. Now they expect to get it and we are all happy. Standard procedure for anyone in control.

The real reason they want it is because they have seen what happens in the UK.

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In the Airservices proposal Transponders are mentioned only once (where it actually isn't one at all) and that is under changes needed when they say —" Increase use of low powered non-TSO ADS-B transponders to maximise infrastructure investment". In other words a SE2. The fact remains that now you do not require a radio or Transponder in class E if your aircrafts electrical system won't support these and they rabbit on about the US experience below.

  • Delivery of the AMP will ensure closer alignment to the International Civil Aviation Organisation (ICAO) system and proven United States practice of airspace management.

In the US you don't require a radio or transponder in class E under 10,000 feet. You also don't need a licence or pilot certificate for a basic rag & tube with no instruments & they fly in class E all the time.

 

Transponders are old technology and reading between the lines, not all that subtly either, they are pushing SE2  as it is a CASA approved portable device.

 

An ADSB in/out device will be way better at 1500 feet than a transponder as nearby traffic will know where you are and vice versa. A transponder probably won't even be seen by Airservices in hilly terrain like around Coffs Harbour at 1500 feet & if it is, because you do not require ATC clearance they won't know who you are anyway. Then if they see other traffic squawks it will increase their workload dramatically when they have to contact that traffic.

 

The transponder mandatory rule must go. They are encouraging ADSB so maybe that will become a requirement. If so it is a far better option. The fact remains though that 1500 AGL is too low but we have yet to be told where where all the high and medium density class G areas are. 

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I have just had a response from AirServices (posted on their Q&A section  --> https://engage.airservicesaustralia.com/lower-base-class-e-east-coast?tool=qanda)

 

Question: 

I fly an RAA registered aircraft, and use a Sky Echo 2 to provide both ADSB-in and ADSB-out facilities. Using Ozrunways as my EFB, I can see other ADSB enabled traffic. Will I be allowed to transit Class E airspace at all, given I have a Sky Echo device (assuming I stay under 10,000 ft) Or am I going to be limited to flying no higher than 1500 Ft (not an ideal height safety wise)

 

Response:

Assuming that the Sky Echo 2 device meets the requirements for aircraft operations as detailed in AIP, then yes, you will be able to fly in the Class E airspace.

IFR:

ADS-B OUT equipment specified for IFR aircraft (IFR ADS-B OUT)

VFR:

1. IFR ADS-B OUT; or

2. Mode S transponder; or

3. Mode A/C transponder; or

4. Integrated Traffic Awareness Beacon System (TABS) device

 

I leave any interpretation  to the reader, but it dont look good for SkyEcho

And it seems from a casual reading of the response that Airservices  doesnt know what a SkyEcho is

Edited by horsefeathers
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14 minutes ago, horsefeathers said:

I have just had a response from AirServices (posted on their Q&A section  --> https://engage.airservicesaustralia.com/lower-base-class-e-east-coast?tool=qanda)

 

 

 

Response:

Assuming that the Sky Echo 2 device meets the requirements for aircraft operations as detailed in AIP, then yes, you will be able to fly in the Class E airspace.

 

Why don’t they say it meets or does not meet the requirements and point to their relevant ruling?   Is this some kind of Million Dollar Minute Show, or something?

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The person responding doesn't know. They are just quoting existing rules and applying them down to 1500 feet.

 

As per their own proposal they say this

 

" Increase use of low powered non-TSO ADS-B transponders to maximise infrastructure investment"

 

That can only mean a SE2 as it is the only one approved by CASA.

 

 

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I am now convinced that these guys (Airservices) have no day to day knowledge of flying. They lack knowledge and/or understanding of current technology, and give not a flying f*** about the impact their decisions will have

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