The Directorate of Flying Safety - ADF and the Bureau of Air
Safety Investigation (ATSB) recommends that the Civil Aviation
Safety Authority, in conjunction with AusSAR and Airservices
Australia, determine appropriate separation standards for the safe
operation of aircraft involved in search and rescue operations.
Given the particular nature of SAR operations, CASA is of the
opinion that it would not be feasible to achieve a practical,
enforceable regime of "separation assurance" which would enhance
the safety of SAR aircraft operations without adversely impacting
on AMSA's overall SAR integrity.
The extent to which the matter of "separation assurance" is an
on-going problem to AMSA is not known. Without substantial evidence
of it being a widespread problem, CASA would be reluctant to
initiate legislation in this regard.
If AMSA were to consider it an imperative need that there be
greater provision of "separation assurance", it could be worthwhile
considering the imposition of temporary restricted areas as a means
of more closely controlling the airspace environment during search
action.
CASA and AMSA are working towards an MoU to clarify respective
responsibilities and interaction between the agencies. CASA is
prepared to engage in further discussions with Airservices and AMSA
to establish an agenda of items to be considered in this respect.
Out of these meetings, there may develop a working group suited to
exploration of operational issues in greater detail, one of which
might well be "separation assurance".
The Bureau has considered your response to the above
recommendation, dated 6 April 2000, and is of the opinion that
regulatory guidance for the separation of such aircraft is
warranted. As such, the ATSB has classified the response as - OPEN.
Your response indicates that although CASA is of the opinion that
it would not be feasible to achieve a practical, enforceable regime
of separation assurance, CASA would be prepared to consider further
discussions with Airservices Australia and AMSA on the issue.
Search plans often require aircraft to manoeuvre at a common
boundary. As the limitations of the "see and avoid" principle in
marginal VMC are often paramount in the minds of search organisers,
they construct plans that give some form of vertical separation as
a safety buffer. These buffers are based on their own experience
and there are no regulations to give authority for such
decisions.
The CASA position indicates that separation rules applicable to the
airspace involved are adequate. However, in controlled airspace,
this could mean that aircraft are conducting a search at 2,500 ft
above the surface, a height that could severely limit the chances
of spotting survivors.
In certain search situations, the ability of pilots to maintain an
adequate lookout is limited and if they revert to full IFR
separation procedures, the ability of the observers to locate a
target is again diminished.
If AusSAR were to produce a search plan which did not provide
formal IFR separation in circumstances where it was otherwise
warranted, then litigation resulting from an accident would be a
distinct possibility.
The Bureau considers that a working group consisting of appropriate
representatives of CASA, AusSAR and Airservices Australia should
look at the standards to be used in various search scenarios.
The ATSB therefore suggests that CASA review its earlier
decision.
CASA appreciates the concerns expressed by ATSB concerning
separation standards of aircraft involved in SAR operations, and
indeed more generally believes that other operational issues
associated with SAR operations require addressing. However, in
relation to the specific issue of separation standards, CASA
maintains that because of the nature of SAR operations it may not
be feasible to achieve a practical means of "separation assurance"
without adversely affecting the overall integrity and flexibility
of SAR operations.
Nonetheless, CASA endorses the ATSB suggestion that this issue be
explored further by interested organisations, namely CASA, ATSB,
AusSAR and Airservices. To this end CASA undertakes to initiate a
meeting of representatives in the future. Furthermore, CASA intends
to include the "separation assurance" aspects in a discussion paper
on CASR Part 138 -Search and Rescue, which will be inviting
industry input.
ATSB Note: The promised meeting was held on 3 September 2002 and
resulted in a working group of all parties to review the separation
criteria.
