The reporter has raised safety concerns regarding procedures during aerodrome works, the absence of NOTAMs and general airside driving and communication procedures at [Location] aerodrome.
The reporter states NOTAMs were not available while runway and apron works were being conducted on [date].
The reporter also states regular difficulties obtaining a response from the aerodrome works safety officer (WSO) while attempting to obtain runway serviceability status. On one occasion, a response was obtained whereby the radio procedures were ambiguous and not to the standard required of a VHF operator licence holder.
A further concern was raised whereby a vehicle drove in front of a taxiing aircraft on the apron without radio calls and proceeded to park in front of the aircraft.
The reporter is concerned there is not adequate communications to pilots, in particular pilots that reside on the aerodrome, in relation to airside movement area works.
Aerodrome management’s advice received following consultation with CASA, ATSB and Airservices Australia regarding the allegation made against recent works on the [Location] aerodrome. It is acknowledged the aerodrome remained compliant with all relevant regulations and standards and the complainant does not have a clear understanding of the regulations or standards for a certified aerodrome, as many if not all the allegation levelled against the aerodrome operations are clearly not required, not permitted or were compliant with the regulation.
The issue of a Notice to Airmen (NOTAM) for the works, (minor pavement repairs) complies with the standard under the Manual of Standards (MOS)-Part 139-Aerodromes - 15.03 (2) Time Limited works:
(2) A person must not commence time-limited works that require more than 10 minutes to restore normal safety standards to the movement area and remove obstacles, unless a NOTAM has been issued not less than 24 hours before the works commence.
The minor pavement works being carried out on the runway on the [date] are permitted under time limited works and complied with 15.03 (2) with less than 10 minutes required to return to normal safety standards, therefor a NOTAM is not required.
The concern regarding the general absence of NOTAMS is clearly due to the lack of knowledge of the standards of when they are or are not required or permitted.
The issue, regular difficulties obtaining response from WSO to obtain runway serviceability status and radio procedures:
All WSO’s are radio equipped, trained and hold the required Aeronautical Radio Operator Certificate (AROC).
Some flight crew’s radio procedures appear to contribute directly to the confusion of the WSOs. On the days identified a number of aircraft were operating at [Location], one being a training aircraft carrying out multiple touch and go's throughout the day. There were no issues with communication with these aircraft, and the WSO being able to accommodate all aircraft operations while still carrying out the pavement works.
The issue, vehicle drove in front of taxiing aircraft:
This comment implies the aircraft was moving and relates to works on the apron area on the [date]. The reporter was not the pilot concerned. The pilot concerned was contacted by phone and apologised for the hold up of less than five minutes while the attention of a truck driver delivering materials to the work site was gained and the truck removed.
The aircraft concerned was stationary on the aerodrome's main apron. The truck concerned was stationary on the local aero club apron blocking the taxi lane access between the two locations. It took a few minutes to gain the attention of the truck driver who had left the truck cabin, and direct the driver to move the vehicle. The truck moved into the work area and the aircraft was able to access the taxi lane and complete its journey. A number of additional aircraft accessed the same taxi lane during the works with no issues due to the appropriate and compliant markings required under the MOS.
A NOTAM was requested for sealing operations in the works area and denied by Airservices Australia, as a NOTAM is either not required or not permitted under the regulations for apron works as per ASA Data Quality Requirements (DQR) 12.3.4 Apron and Parking bays and marking of the works area in accordance with MOS 139 8.108 (3) Use of Unserviceability Markers is the limit of compliance.
To restore normal safety standards to the movement area and remove obstacles, there is nothing to suggest a vehicle can’t be driven on a taxiway or taxi lane to achieve this, with the aircraft safely stationary and holding on the main apron, there is and was no issue. A five minute wait is within the standards, MOS139 15.03 (2).
The issue raised, no adequate communications to pilots/residents in relation to airside works: For work requiring a NOTAM - following the issue of the NOTAM by Airservices Australia, an email is sent to 50 plus interested parties including the local aero club, CASA, charter and training operators and aerodrome residents with email addresses registered with the aerodrome operator. No email is sent for works that do not require a NOTAM.
CASA has reviewed the REPCON and the aerodrome operator response.
The aerodrome operator advises that the works referred to in the report were being conducted under the control of a 'time limited works' procedure using a recall period of 10 minutes to reinstate the movement area to a serviceable condition. The Part 139 Manual of Standards (MOS) permits this method of control to be used without a Method of Works Plan or requesting the issue of a NOTAM.
The work activity described is a maintenance process that is regularly conducted under the time limited works process. The MOS identifies minor pavement works to be suitable for applying 'time limited works' procedures.
CASA will review the aerodrome operator’s works control and personnel standards systems during any upcoming scheduled surveillance activity.