See report `Systemic Investigation into the Class G Airspace
Demonstration'
The Bureau of Air Safety Investigation recommends that the Civil
Aviation Safety Authority (CASA) review regulations, policies,
practices and procedures with a view to ensuring that prior to the
implementation of any change to the aviation system, including any
initiatives undertaken by CASA, an appropriate safety analysis
process consistent with the degree of change is undertaken.
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 R19990139 have been
addressed.
