Output Number
Approval Date
Published Date Time
Recommendation type
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Date released
Background Text

SUBJECT



Safety Concerns Relating to the Class G Airspace
Demonstration.



BACKGROUND



Australia is harmonising with elements of the International Civil
Aviation Organisation (ICAO) air traffic services standards and
recommended practices. ICAO has developed an alphabetical airspace
classification system ranging from A to G. Each classification
indicates the level of air traffic control service provided, with
Class G airspace having the least service.



The plan for Australia's move to this harmonised approach is known
as 'Airspace 2000'. The implementation of Airspace 2000 commenced
on 26 February 1998 with the demonstration of Class E airspace in
the Canberra-Ballina region.



Airspace 2000 is altering some long-standing practices unique to
the Australian aviation industry.



An important aspect of the Airspace 2000 program is its
integration with The Australian Advanced Air Traffic System
(TAAATS).



On 22 October 1998 the Civil Aviation Safety Authority (CASA)
commenced a demonstration of new operating rules and procedures for
Class G Airspace. The demonstration is being conducted in the
Canberra-Ballina region in Class G Airspace below 8,500 feet.



Key features of the demonstration are that it:



removed directed traffic information (DTI) provided by flight
service;



introduced a national advisory frequency (NAF); and



introduced a radar based traffic information service subject to
radar coverage and air traffic controller workload.



The Bureau of Air Safety Investigation (BASI) is conducting a
systemic investigation of the demonstration. The investigation is
part of its normal systems safety investigation role.





SAFETY DEFICIENCY



The overall program management of the Class G Airspace
Demonstration has been deficient because critical safety issues
have not been addressed.





FACTUAL INFORMATION



Related occurrences



9805078 - The crew of a BAe Jetstream was maintaining the aircraft
at 5,000 ft for separation from a descending Beechcraft King Air.
The sector controller transmitted radar information on the
Jetstream to the pilot of the King Air. This transmission was not
acknowledged by the King Air pilot and was subsequently reported to
have been over-transmitted by another pilot. The King Air was
observed on radar to descend through the level of the Jetstream.
The two aircraft passed each other with approximately 600 ft
vertical separation and 0.5 NM horizontal displacement. The
investigation is continuing.



9804984 - Prior to departing Lismore the pilot of a Beechcraft
King Air transmitted taxi and departure reports on the
Lismore/Casino/Ballina mandatory broadcast zone frequency (MBZ) but
received no replies. He then contacted Brisbane Centre for a radar
information service and was advised that there was no radar
observed traffic. The pilot of a SAAB 340, which had just departed
Casino, was monitoring the Brisbane Centre frequency and heard this
report. He then contacted the pilot of the King Air to arrange
separation. Shortly after, the pilot of the King Air saw the SAAB
340 pass underneath his aircraft. Subsequently, the pilots
established that they had both transmitted the required MBZ reports
but neither had heard the other's transmissions. The SAAB 340 pilot
was not required to monitor the Brisbane Centre frequency, but by
doing so he enhanced the crew's situational awareness. The
investigation is continuing.



In both of these incidents, prior to the introduction of the Class
G Airspace Demonstration, the crews would have been alerted as to
each other's existence through the provision of directed traffic
information.





Project monitoring



As part of the Bureau's monitoring of the Class G Airspace
Demonstration, an investigation team was formed to collect and
analyse information relating to the development and conduct of the
demonstration. The team conducted interviews with staff and
obtained data from the Civil Aviation Safety Authority (CASA),
Airservices Australia and the aviation industry.



The Bureau's investigation team has noted that CASA had a safety
case process for the Class G Airspace Demonstration, and that CASA
is closely monitoring the operational progress of the
demonstration.



However, the Bureau's initial analysis of the information obtained
identified a number of major safety concerns:



a) The independent review process for the introduction of airspace
changes was removed when CASA, as the regulator and safety auditor
of the airspace system, also actively assumed the primary role for
the design, safety analysis, promotion and management of the
Airspace 2000 program from Airservices Australia in late
1997.



Previously Airservices Australia conducted these airspace change
activities and CASA had a clearly defined process for monitoring
and evaluating this process. However, when CASA assumed the role
formerly exercised by Airservices Australia, no system was put in
place to ensure that CASA's own work was similarly evaluated for
the Class G Airspace Demonstration. No such system is yet in
place.



b) The CASA safety case process did not provide an integrated
summary of all hazards considered, and their associated risk
levels, mitigators, and anticipated effectiveness of the
mitigators. In addition, the CASA safety case process did not
include a 'full qualitative and quantitative evaluation by
technical experts' of Airspace 2000 (which includes Class G
Airspace). Such an evaluation was proposed by the acting Chairman
of CASA in a letter to the Chairman of Airservices Australia
following the CASA Board meeting of 25-26 September 1997.



c) The pilot education programs of both CASA and the aviation
industry, as primary mitigators for hazards associated with the
airspace changes, were not implemented effectively (in terms of the
originally planned program, as well as the changes introduced
subsequent to the issue of Aeronautical Information Publication
Supplement 48/98). A lack of pilot knowledge continues to be a
major operational safety concern.



d) There has been a lack of support from elements of the aviation
industry for the conduct of the demonstration. Such a lack of
support had been recognised by CASA and a UK Civil Aviation
Authority review team (engaged by CASA), as a significant risk to
the success of the demonstration.



e) There are continuing problems associated with congestion of the
NAF, a planned primary mitigator for hazards associated with the
changes. This frequency congestion can prevent the transfer of
vital information between pilots.



f) The Airspace 2000 plan proposed the introduction of Class E
Airspace corridors through Class G airspace on any route where
traffic density required, or where such corridors were requested by
industry. These E corridors were a planned mitigator against the
removal of DTI, but were not implemented for the Class G Airspace
Demonstration.



g) There are safety deficiencies associated with the current
frequency management procedures, particularly during departures and
arrivals at uncontrolled aerodromes (as shown in the occurrences
described above). Pilots are required to monitor a number of
different frequencies during these high workload phases of flight
and may consequently not receive critical radio transmissions, or
may receive late advice of other traffic.



h) Pilots and air traffic services staff have been advised of
changes to the demonstration through numerous Notices to Airmen,
which have been issued in an ad hoc and reactive manner. This
continues to cause confusion among pilots and air traffic services
staff.



i) As yet, the investigation team has not found evidence to
indicate that CASA's safety case process has considered the
following safety issues associated with the Class G Airspace
demonstration:



the full impact of each of the changes to the Class G Airspace
Demonstration procedures and design that were implemented
subsequent to the issue of Aeronautical Information Publication
Supplement 48/98 on 13 August 1998;



the full impact of the removal of DTI, particularly the
potentially detrimental effects on situational awareness for VFR
pilots (for example a VFR pilot may now need to monitor two or
three frequencies to maintain awareness of IFR traffic, when
previously only one frequency was required); and



operational difficulties associated with two concurrent sets of
procedures, one for the demonstration airspace and one for the
existing system.



j) As yet, the investigation team has not found evidence to
indicate that there was:



a clear transfer of roles and responsibilities from Airservices to
CASA for the management of Airspace 2000 (which includes Class G
Airspace);



a comprehensive and systematic analysis of pilot tasks under the
Class G Airspace Demonstration model (including an examination of
the combined effects of all the changes on workload, situational
awareness and crew coordination, as well as the development and
testing of specific operational procedures);



a systematic comparison of the Class G Airspace Demonstration
model (including consideration of the Australian aviation system
and environment) with appropriate overseas airspace systems;



a clear rationale for conducting the demonstration prior to the
introduction of TAAATS; and



a proactive evaluation of the effectiveness of the pilot education
program prior to the introduction of the demonstration.



It is not possible at this stage to compare the overall safety
level of the Class G Airspace Demonstration with that of the
previous system. However, due to the safety concerns listed above,
the following interim recommendations are made.



For further information please see report `Systemic Investigation
into the Class G Airspace Demonstration'.

The Bureau of Air Safety Investigation recommends that the Civil
Aviation Safety Authority review program management policies and
procedures for current and proposed changes to the aviation system,
in the light of experience gained from the present Class G Airspace
Demonstration.

Organisation Response
Date Received
Organisation
Civil Aviation Safety Authority
Response Text

I refer to your letter of 17 August 1999 regarding finalisation
of the Class G Report and outstanding responses to IR980260 and
IR980261.

In relation to the both IRs, CASA is still awaiting formal,
consolidated advice on the results of the review conducted by the
Secretary of DOTRS last December. However, certain aspects are
becoming more lucid.

In a letter from the Assistant Secretary Aviation, DOTRS, to
CASA, dated 29 June 1999, CASA was advised that the Government's
decision is that "the regulatory responsibilities for the design,
declaration and management of airspace are to remain with
Airservices and not be transferred to CASA". CASA understands that
Airservices, in line with this decision, has been given direction
by the Government to develop, by December 1999, a program for
airspace reform.

In a draft working paper attached to the above mentioned letter,
it was stated that before making a decision 'Airservices would
provide CASA with formal safety cases justifying any changes,
including training and education of users'. CASA can review and, if
necessary, veto the change. The paper went on to say that 'This
acknowledges possible conflicts of interests which may arise were
CASA to be both regulator and the initiator of airspace
reforms'.

The paper gave CASA's role as setting minimum standards to be
applied to each particular class of airspace'. It did not restrict
CASA from initiating an upgrading of a class of airspace, however,
it stated that CASA must identify 'a clear safety justification'
and 'accompany any such proposal with evidence supporting the
safety issue'. An overriding requirement was''When CASA seeks to
change the classification of airspace, the DoTRS is to ensure an
independent analyst is engaged to consider, and publish comments
upon, the safety case made by CASK

CASA is willing to adopt the principles espoused in the above
and believes that acceptance of them by the three parties would
address the Interim Recommendations.

 

ATSB Response

The following correspondence was forwarded to the Civil Aviation
Safety Authority on 4 February 2000:

Further to our discussion, it appears that our respective
offices may have mislaid the letter reference the Class 'G'
investigation final recommendations. As you are aware, the ATSB
report on the investigation into the Class G airspace demonstration
was tabled in parliament and subsequently released to the public on
Tuesday 23 November 1999. In accordance with paragraph 11.14 of the
memorandum of understanding (MoU) between BASI and CASA, I draw
your attention to final recommendations R19990139 and R19990140. A
response in accordance with paragraph 11.15 of the MoU would be
appreciated.

Furthermore, you may have noted from the report that based on
information provided by CASA to date, interim recommendations
IR19980253 and 19980261 have been classified as 'closed -
accepted'; however, IR199980260 is still classified as 'open'. A
response to IR19980260, in accordance with paragraph 11.15 of the
MoU, would be appreciated at your earliest convenience.

 

 

Date Received
Organisation
Civil Aviation Safety Authority
Response Text

I refer to your letter of 4 February 2000 regarding
recommendations pertaining to the Class G Airspace demonstration.
IR19980260 and R19980139 are addressed in this letter. R19980140
will be the subject of separate correspondence.

CASA's policy for safety management of airspace change is in
accordance with advice received from DOTRS. This policy was
confirmed by Minister Anderson in his 1999 Charter Letters to CASA
and Airservices, and restated by him in his address, A Measured
Approach to Aviation Safety, in November 1999.

As further explanation, where Airservices, or another party,
proposes change, CASA will review the supporting safety case; CASA
would only pursue an airspace change where it could be clearly
justified on safety grounds and CASA would, of course, prepare a
safety case; this safety case would be subject to review by an
independent analyst appointed by DOTRS.

As you would be aware, CASA has issued two CAAPs on preparation
of safety cases which are available on the website. As regards
process for review of safety cases, CASA is documenting a procedure
and it is expected that this will be available around mid-2000.

I relation to IR980260, ATSB has previously given advice that
'where appropriate', 'project review processes' 'safety analysis
processes', and evaluation processes to assess the effectiveness of
safety requirements and mitigators, are required. These are matters
that CASA would expect to see addressed at project planning stage
and to be incorporated in each safety case.

CASA has distributed to industry a draft paper entitled Risk
Management Methodology, and Minimum Criteria for Airspace
Classification and Levels of Air Traffic Services (copy also
attached). This paper sets out CASA's policy on risk management as
it applies to airspace.

The above paper includes reference to airspace risk modelling
which takes into account identification and treatment of safety
factors brought about by changes in pilot workload, situational
awareness and crew coordination. It includes risk acceptability and
benefit:cost analysis. It also includes a process for the conduct
of an Aeronautical Study (safety case) to support proposals.
Feedback to date indicates this paper has been well accepted. When
finalised, it will be incorporated into the CASA Manual of
Operational Standards.

Regarding regulatory review, as part of the project addressing
the Minister's direction to provide the regulatory framework for
private and public sector provision of air traffic services, CASA
will promulgate CASR Part 71 - Airspace. This will give CASA an
appropriate power to set the criteria referred to above.

CASA has also refined its consultative processes. CASA Safety
Standards Division now has documented processes in the draft
Aviation Safety Standards Division Procedures Manual. These include
the Discussion Paper and Notice of Proposed Rule Making processes
for new regulations (a copy of the flow charts is attached). These
are applicable to all 'rule' changes regardless of whether
regulatory change is involved. Other consultation is conducted such
as the recent industry day held by CASA on 4 February 2000
regarding the latest airspace proposals from Airservices; this was
in addition to, and separate from, Airservices consultation on the
matter.

It is CASA's view that IR19980260 and IR19990139 have been
addressed.