Recommendation

Firstly, we will be using our existing cost benefit formula
(which is based on the proven FAA Formula) to mandate Class D
airspace where traffic densities require.



CASA also proposes a complete package to address this important
issue. Unfortunately, unalerted see and avoid can not be eliminated
entirely, as even if primary and secondary radar, Class A airspace,
mandatory radio, TCAS and transponders were deployed, there can
always be a time, because of human factors or technical breakdown,
that unalerted see and avoid becomes the primary means of
separation.

The CASA proposal is to do everything we can, while still
allocating the safety dollars effectively, to reduce the chance of
unalerted see and avoid being the primary means of separation,
whilst at the same time educating pilots on how they can improve
their scan to improve the effectiveness of both alerted and
unalerted see and avoid.



In relation to our package to improve the availability of alerted
see and avoid, we have proposed to the airlines that in future, all
airports serviced by scheduled services of over 10 passengers must
have third party confirmation that the radio is on frequency. This
will reduce the chance of an airline/aircraft being on the wrong
frequency or the speaker is being deselected. We are also
encouraging the fitment of Aerodrome Frequency Response Units which
will operate 24 hours per day and reduce the chance of unalerted
see and avoid. We are proposing to increase the number of
recommended calls at non-tower aerodromes to seven, following the
USA procedure. This will greatly assist alerted see and
avoid.



In order to reduce the necessity to rely on see and avoid, we will
be training VFR pilots to remain clear of areas of IFR traffic
density, such as IFR air routes or IFR approach paths. These will
be marked on maps in future. In relation to IFR aircraft, we will
be training pilots to follow a recommendation to fly .1 nm to the
right of track when flying on a marked air route between
navigational aids or reporting points when the airway is used for
two-way traffic.



In places where a tower is not cost effective and that have RPT
services of over 10 passengers, we will have mandatory procedures
in relation to alerting.

At our meeting on November 3, I undertook to follow up CASA's
response to the outstanding recommendations contained in the 1991
BASI research report on the limitations of see and avoid. As you
would be aware, most of the recommendations - including those
concerning TCAS and the education initiatives - have been
implemented and continue to provide positive safety outcomes for
Australian aviation.



In respect of the remaining recommendations, CASA provides the
following response.



"The CAA should take into account the limitations of see-and-avoid
when planning and managing airspace...."



CASA agrees that the limitations of see-and-avoid should be taken
into account when planning and managing airspace. Where traffic
densities are such that see-and-avoid does not provide the required
level of safety, CASA will require Class D or a higher level of
airspace.



....and should ensure that unalerted see-an-avoid is never the sole
means of separation for aircraft providing scheduled
services."



CASA understands the intent of this recommendation but does not
agree with its absolute form. The wording of the recommendation
reflected its time and was prior to the 1995 Standards Australia
AS/NZS4360 Risk Management Standard. CASA also understands that the
use of the absolute "never" is not consistent with current ATSB
practice.



To accept the absolute form of the recommendation would require the
allocation of Class D or higher airspace wherever scheduled
services operate. This would result in an allocation of resources
that is not commensurate with risk.



ICAO Class E and G airspace specifically has no radio requirement
for VFR aircraft. ICAO has introduced both of these classifications
with the full knowledge of the limitations of see-and-avoid. ICAO
makes no recommendation in relation to scheduled services not
operating in these airspace classifications.



Overly discounting the effectiveness of see-and-avoid and devising
unique procedures has itself led to unintended consequences that
are unresolved. Pilots may scan significantly less and become over
reliant on radio alerting through a concept known as diffusion of
responsibility. The BASI report RP/93/01 (December 1993) and the
continuing incident reports that are being filed listing near
misses in mandatory radio Class E and G airspace may support this
concern. CASA believes that radio alerting is only effective when
the alerting area is small with readily identifiable reporting
points so that the alert is specific.

At our meeting on November 3, 1 undertook to follow up CASA's
response to the outstanding recommendations contained in the 1991
BASI research report on the limitations of see and avoid. As you
would be aware, most of the recommendations - including those
concerning TCAS and the education initiatives - have been
implemented and continue to provide positive safety outcomes for
Australian aviation.



In respect of the remaining recommendations, CASA provides the
following response.



"The CAA should take into account the limitations of see-andavoid
when planning and managing airspace...."



CASA agrees that the limitations of see-and-avoid should be taken
into account when planning and managing airspace. Where traffic
densities are such that see-and-avoid does not provide the required
level of safety, CASA will require Class D or a higher level of
airspace.



....and should ensure that unalerted see-an-avoid is never the sole
means of separation for aircraft providing scheduled
services."



CASA understands the intent of this recommendation but does not
agree with its absolute form. The wording of the recommendation
reflected its time and was prior to the 1995 Standards Australia
AS/NZS4360 Risk Management Standard. CASA also understands that the
use of the absolute "never" is not consistent with current ATSB
practice.



To accept the absolute form of the recommendation would require the
allocation of Class D or higher airspace wherever scheduled
services operate. This would result in an allocation of resources
that is not commensurate with risk.



ICAO Class E and G airspace specifically has no radio requirement
for VFR aircraft. ICAO has introduced both of these classifications
with the full knowledge of the limitations of see-and-avoid. ICAO
makes no recommendation in relation to scheduled services not
operating in these airspace classifications.



Overly discounting the effectiveness of see-and-avoid and devising
unique procedures has itself led to unintended consequences that
are unresolved. Pilots may scan significantly less and become over
reliant on radio alerting through a concept known as diffusion of
responsibility. The BASI report RP/93/01 (December 1993) and the
continuing incident reports that are being filed listing near
misses in mandatory radio Class E and G airspace may support this
concern. CASA believes that radio alerting is only effective when
the alerting area is small with readily identifiable reporting
points so that the alert is specific.

At our meeting on November 3, 1 undertook to follow up CASA's
response to the outstanding recommendations contained in the 1991
BASI research report on the limitations of see and avoid. As you
would be aware, most of the recommendations - including those
concerning TCAS and the education initiatives - have been
implemented and continue to provide positive safety outcomes for
Australian aviation.



In respect of the remaining recommendations, CASA provides the
following response.



"The CAA should take into account the limitations of see-andavoid
when planning and managing airspace...."



CASA agrees that the limitations of see-and-avoid should be taken
into account when planning and managing airspace. Where traffic
densities are such that see-and-avoid does not provide the required
level of safety, CASA will require Class D or a higher level of
airspace.



....and should ensure that unalerted see-an-avoid is never the sole
means of separation for aircraft providing scheduled
services."



CASA understands the intent of this recommendation but does not
agree with its absolute form. The wording of the recommendation
reflected its time and was prior to the 1995 Standards Australia
AS/NZS4360 Risk Management Standard. CASA also understands that the
use of the absolute "never" is not consistent with current ATSB
practice.



To accept the absolute form of the recommendation would require the
allocation of Class D or higher airspace wherever scheduled
services operate. This would result in an allocation of resources
that is not commensurate with risk.



ICAO Class E and G airspace specifically has no radio requirement
for VFR aircraft. ICAO has introduced both of these classifications
with the full knowledge of the limitations of see-and-avoid. ICAO
makes no recommendation in relation to scheduled services not
operating in these airspace classifications.



Overly discounting the effectiveness of see-and-avoid and devising
unique procedures has itself led to unintended consequences that
are unresolved. Pilots may scan significantly less and become over
reliant on radio alerting through a concept known as diffusion of
responsibility. The BASI report RP/93/01 (December 1993) and the
continuing incident reports that are being filed listing near
misses in mandatory radio Class E and G airspace may support this
concern. CASA believes that radio alerting is only effective when
the alerting area is small with readily identifiable reporting
points so that the alert is specific.