Recommendation

SUBJECT - PROVISION OF INFORMATION TO ATS FOR A HAZARD ALERTING
SERVICE

SAFETY DEFICIENCY

The current requirements for the completion of domestic flight
plan forms do not acknowledge whether pilots are approved to fly a
particular instrument approach. Consequently, holders of the
proposed Australian Private Pilot Instrument Rating (APPIR) who are
limited to the use of navigation aids for enroute operations, or
those holders of a Command Instrument Rating (CIR) not approved to
conduct an instrument approach, may not be afforded the appropriate
level of hazard alerting service.

FACTUAL INFORMATION

Privileges of instrument ratings

Holders of the proposed Australian Private Pilot Instrument
Rating (APPIR) may only be qualified to use navigation aids for
enroute operations. However, they may extend their basic
qualification in order to be endorsed to conduct any one of a
number of instrument approach types.

To hold a CIR, pilots only need to be qualified to conduct an
Non Directional Beacon (NDB) instrument approach, although they may
be approved to navigate by any one of a number of navigational
aids.

In addition, pilots flying in accordance with the privileges of
the proposed APPIR or a CIR, may not be entitled to conduct any one
of a number of instrument approach types if their recency on that
type of instrument approach has expired.

Requirements for the completion of a domestic flight plan form

The Aeronautical Information Publication (AIP) details
information that is required to be submitted on a domestic flight
plan, including navigational equipment that pilots are qualified to
use. While pilots may elect to include additional relevant
information in the remarks field, there is currently no defined
procedure for an instrument rated pilot to advise Air Traffic
Services (ATS) on the flight plan of the instrument approach types
that they are approved to use. Anecdotal evidence suggests that if
the symbol for a particular navigational aid is circled on the
domestic flight plan form, most ATS officers assume that the pilot
is qualified to conduct instrument approaches using that aid. The
AIP states that pilots must advise ATS if they are issued a
clearance which requires the use of navigation aids not available
to the aircraft, or which the pilot is not qualified to use. This
instruction implies that this advice would not normally be provided
until a clearance is provided that cannot be complied with.

Hazard alerting service

ATS provides pilots with vital operational information of an
unexpected and critical nature to assist them to avoid hazardous
situations. This information is broadcast on the appropriate ATS
frequency and is directed to those aircraft "maintaining continuous
communications with ATS at the time the hazard is assessed that are
within one hour's flight time of the hazardous conditions" (Manual
of Air Traffic Services). Among other things, a hazard alerting
service informs pilots if weather conditions at destination
aerodromes fall below alternate minima. The instrument flight rules
(IFR) alternate minima referred to in a hazard alert are usually
based on the navigational aid that provides the highest alternate
minima for an instrument approach to that aerodrome, usually the
NDB approach for the highest category of aircraft that may use that
approach. The level of hazard alerting provided to pilots is
normally determined by the information provided by the flight
notification process and is based upon the completion of a domestic
flight plan form.

ANALYSIS

The present system for flight notification to ATS for IFR
flights does not incorporate a defined process by which a pilot's
approval to fly a particular instrument approach procedure may be
advised. While pilots may elect to include additional information
in the remarks field of the domestic flight plan form, such
information is not routinely included. Therefore, it may not be
possible for ATS to correctly assess whether a particular level of
hazard alerting service is required for a flight on the basis of
the information presently submitted.

For example, a pilot may be the holder of the proposed APPIR,
but may only be qualified for enroute use of navigation aids.
Alternatively, the pilot may be endorsed to conduct instrument
approaches but may not consider that they are competent to conduct
an approach on the basis of lack of approach recency. While the
pilot can elect to plan the last route segment of the flight in
accordance with IFR, he would be required to fly visually below
lowest safe altitude (LSALT) for arrival at the destination. The
relevant alternate minima applicable for this flight would be no
more cloud cover than 4 octas at a ceiling below 500 ft above
LSALT. An appropriate level of hazard alerting for this example
would be that the pilot would be advised if weather conditions
unexpectedly deteriorated below this alternate minima.

The instructions contained in the AIP would require the pilot to
circle any navigational aid on their flight plan that they are
qualified to use. Unless the pilot detailed the limitations on
their use of navigation aids for approaches in the remarks field of
the flight plan, ATS would not know if a pilot was qualified to use
the navigation aids only for enroute navigation, or for instrument
approaches. Given that many ATS officers assume that pilots are
able to conduct instrument approaches whenever the relevant symbol
is circled on the flight plan, it is possible that ATS would not
provide an appropriate hazard alerting service, as they would not
know the alternate minima relevant to that flight. At best, pilots
may be advised when weather conditions deteriorate below the NDB
alternate minima. However, this alternate minima is considerably
lower than the visual alternate minima required by the pilot in
this example. Consequently, such advice would not be broadcast to
the pilot for some time after conditions had deteriorated below the
relevant alternate minima, if at all.

In addition, the in-flight requirement to advise ATS if a pilot
does not have a particular navigational aid available to them, or
is not qualified to use, does not provide sufficient protection as
this information is not likely to be communicated until ATC issues
an approach clearance. Such clearances are usually only issued
within 10-15 minutes of arrival at the destination. Such a
requirement to advise ATC would only apply to destinations within
controlled airspace. Pilots planning flights to destinations
outside controlled airspace are not likely to communicate such
information in the absence of the issue of approach clearances. A
more timely hazard alerting service would provide pilots with
sufficient time to consider alternates before fuel quantity becomes
a critical consideration.

The same limitation of the hazard alerting service as described
above would apply to holders of a CIR who, while rated on
instrument approaches in accordance with the privileges of the CIR,
may not have satisfied the approach recency requirements of the
rating and therefore could not legally conduct an approach.
Notwithstanding, the majority of command instrument rated pilots
maintain currency on those approach types that they are rated to
conduct, and hence this deficiency rarely occurs. However, under
the proposed APPIR, there is likely to be a significant number of
pilots who will not be qualified to conduct instrument approaches
using navigational aids for which they are qualified to use for
enroute operations.

This situation has the potential to have serious safety
consequences when pilots who are not capable of conducting an
instrument approach are not made aware of unexpectedly
deteriorating conditions ahead. Pilots may subsequently find that
they have limited safe options for alternative action on arrival
overhead their destination in the absence of an appropriate level
of hazard alerting.