The concern related to the procedures used by both CASA and Airservices to make changes to the AIP.
The reporter expressed a safety concern regarding the procedures CASA and Airservices Australia have in place when changes are made to the AIP.
The reporter pointed out that changes were made to the AIP on the 30 May 2013 in relation to the frequency which was to be used at aerodromes which did not have a specific CTAF [Common Traffic Advisory Frequency]. These changes contradicted other areas of the AIP (such as the definition of 'Multicom') and resulted in the likelihood of two aircraft operating to an aerodrome on different frequencies, diminishing the collision avoidance benefits of radio-alerted see and avoid, and creating additional radio broadcasts and over transmissions on frequencies used regularly by airlines. These changes were followed by a Civil Aviation Advisory Publication (CAAP) released in December 2013 again contradicting statements within the AIP. The CASA safety advisors do not seem to have been consulted or made aware of the changes, leaving them giving again contradictory messages as to which frequency should be used.
The Regional Airspace and Procedures Advisory Committee (RAPAC) was not consulted about these changes. The frequency confusion caused by non-aligned documentation and lack of industry education has existed for more than 12 months.
Airservices Australia (Airservices) appreciates the opportunity to respond to the reported concern regarding the changes made to the Aeronautical Information Package (AIP) on 30 May 2013 in relation to the frequency to be used at aerodromes which do not have a specific Common Traffic Advisory Frequency (CTAF).
Airservices clarifies that there is a formal process agreed by CASA and Airservices for amending the AIP, and in accordance with this process, the agency (CASA or Airservices) initiating the change is responsible for assessing the impact of the change and taking relevant actions such as industry consultation and education to manage any associated risks.
Where AIP changes are initiated by Airservices they are managed in accordance with Airservices Safety Management System (SMS). By applying our SMS, Airservices ensures that the impact of the change is clearly understood and any associated risks to air traffic management are identified and managed appropriately. Once approved by Airservices and CASA, changes are sent to Airservices Aeronautical Information Service (AIS) group who are responsible for publishing updates to the AIP.
As the change referred to by the reporter was initiated by CASA, Airservices suggests that CASA would be best placed to respond to the specific concerns raised in this REPCON.
Airservices notes that as a result of a CASA Post Implementation Review (PIR) of the implemented AIP change and associated Civil Aviation Advisory Publication (CAAP) additional amendments were made to the AIP. These changes are to be published on 21 August 2014 (AIP issue AL80) and address the reporter's concern.
There is a documented process in place to affect changes to the AIP as well as agreed procedures between CASA and Airservices to progress change requests to the AIP which is:
- The procedures for approving changes to the AIP are included in a manual which is stored in CASA's corporate records management system;
- There is a Letter of Agreement between CASA and Airservices on how both organisations progress approval of changes to the AIP;
- A standard template has been developed to facilitate AIP changes;
- AIP changes within CASA are approved by a selected group of senior managers who consult within their teams;
- Approvals for AIP changes are recorded in CASA's corporate records management system; and
- Only changes approved by CASA can be published in the AIP.
In relation to this specific change, the original change to the AIP regarding CTAF, Broadcast Areas (BAs) and Area VHF frequency was initiated on the request of CASA's Aviation Safety Advisors to clarify to pilots which frequency they should be on in the vicinity of a non-controlled aerodrome and away from aerodromes. It did not seek to introduce a change in procedures or frequency.
Generally, changes to AIP are not consulted with RAPACs. RAPACs are used as a vehicle to review frequencies in use at an aerodrome or by a group of aerodromes and may recommend establishing a discrete CTAF at an aerodrome, allocating a discrete CTAF used by neighbouring aerodromes or establishing BAs.