A model aircraft club maintaining a listening watch on an incorrect frequency

The ALA in question is not marked on aviation charts but is a clearly identifiable ALA with a runway having a runway length of 1,200 metres and being clearly delineated with the standard gable markers and other aerodrome markings.

CAAP 166-1(3) – Operations in the vicinity of non-controlled aerodromes defines the [location] ALA as a non-controlled aerodrome Class G airspace and as such the carriage of radio by aircraft operating at this ALA is not mandatory. As the ALA is not marked on aeronautical charts, the current direction is for aircraft to use the Area Frequency for operations in the vicinity of the [location] ALA. The Area Frequency above [location] ALA is [frequency]. However, less than 1 NM to the north the Area Frequency changes to [frequency].

The reporter of the REPCON expressed safety concerns in relation to the changes to CAAP 166-1(3) and the changes to the frequency that is to be used by manned aircraft operating at such an ALA that is not marked on aeronautical charts. NOTAM C119/14 Operational Frequency Requirements was published on 19 July 2014 with the contents of the NOTAM being incorporated into the AIP with effect as of 21 Aug 2014. This provided the following advice:

IN LIEU OF CURRENT AIP INFORMATION REGARDING OPERATIONS AT OR IN THE VICINITY OF NON-CONTROLLED AERODROMES, PILOTS MUST USE THE FOLLOWING FREQUENCIES FOR BROADCASTS:

A. IN THE VICINITY OF AN AERODROME DEPICTED ON AERONAUTICAL CHARTS, WITH A DISCRETE FREQUENCY, THE DISCRETE CTAF SHOWN (INCLUDING BROADCAST AREA CTAF), OR OTHERWISE;

B. IN THE VICINITY OF AN AERODROME DEPICTED ON AERONAUTICAL CHARTS, WITH NO DISCRETE FREQUENCY SHOWN, THE CTAF 126.7; OR

C. IN ALL OTHER CASES, AREA VHF.

The reporter of the REPCON further states that there is a formal instruction, from CASA, on file which requires them to monitor frequency 126.7 and that if an aircraft is approaching or taking off from [location] ALA, they must land the model aircraft.

The ‘instruction’ referred to in the REPCON appears to be a letter from a CASA officer dated 2005. The advice that had been provided to the club when commencing operations is not consistent with current CASA practices in that no formal Instrument of Approval has been provided to the club for such operations and as such, their operations are in breach of CASR 101.075 (2) because they are only allowed to operate over the runway of an aerodrome if they have a permission under CASR 101.080. CASA is following up this matter with the club.

The reporter states that due to being advised to monitor 126.7, they are now monitoring a different frequency to larger aircraft. What the reporter fails to mention is that under CASR 101.055 a person must not operate an unmanned aircraft in a way that creates a hazard to another aircraft, another person or property. Under CASR 101.075, a person must not operate an unmanned aircraft in such a manner as to create an obstruction to an aircraft taking off from, or approaching to land at, a landing area or a runway of an aerodrome. The reporter’s comments that the monitoring of a radio frequency is the means to avoid a conflict between a manned aircraft and a model aircraft is incorrect because the onus is on the operator of the model aircraft to ensure that they do not create a hazard or obstruction to a manned aircraft with or without monitoring a radio frequency.

One risk mitigator that was suggested to the [location] Radio Controlled Model Aero Club was for them to monitor the frequency that was being used at that time by aircraft using the [location] ALA to aid their situational awareness of manned aircraft operations in the vicinity of the ALA. That frequency is now not the correct frequency due to the change in operational frequencies brought about by the change in CAAP 166-1(3). The role of the club is to monitor the correct frequency to aid in the identification of aircraft that may be intending to land at the [location] ALA. It is a simple process for the club to switch their radio to the correct frequency to monitor it for traffic.

The safety concerns that have been raised are mitigated for manned aircraft if they operate in accordance with the current AIP and CAAP.

ATSB comment:

The ATSB questioned CASA further to ensure that no other model aero clubs had been given the incorrect advice.

There are a number of Model Aeronautical Association of Australia(MAAA) clubs in Australia that do have a listening watch on the CTAF frequency of 126.7 but only where this is the defined CTAF for a particular aerodrome and the club is located within 3 NM of such an aerodrome.  In other cases, a club is not required to undertake a listening watch on any aeronautical frequency as such model aircraft operations are conducted generally only up to 400 ft AGL, although there are some clubs that operate in Class G airspace that operate to higher heights AGL, with the responsibility being for the club to maintain a visual watch for any manned aircraft and in the situation that they identify a manned aircraft that may be approaching the airspace above the club field, then the operators are to take action to ensure that they either land their model aircraft or reduce height to below 400 ft AGL and to maintain at least a 600 metre distance from such manned aircraft.  Members of the MAAA do not generally hold a certification to use an aeronautical radio and so there is never a requirement on a member to broadcast but only to monitor to enhance their visual situational awareness of the operation of manned aircraft so that suitable separation can be maintained.  This system works extremely well and has not resulted in any airprox events between a member of the MAAA’s model aircraft operations at a club field and that of a manned aircraft that I am aware of over the past 3 years at least.

ATSB comment:

The ATSB has provided a copy of this report to the Model Aeronautical Association of Australia to ensure that this information is made available to as many model aircraft clubs as possible.

MAAA response:

On behalf of the MAAA, thank you for providing this information. I will put together a notice regarding the use of the Area Frequencies as opposed to the multicom frequency 126.7, and distribute it via our State Associations to all clubs.

When there are changes to frequencies such as this, unless specifically advised at the time of the change, clubs under MAAA have no way of knowing about the alterations. Clubs which are made up of normal members of the public, do not has access to NOTAMs as licensed aviation operators have.  This has been highlighted over the years with closure of airspace such as it was with the visit of the American President to Sydney some years back. Operators of model aircraft in the Sydney basin had no idea of airspace closures until they caught snippets of information in the press.

With the recent G-20 meeting in Brisbane, airspace was once again closed to all aerial operations in certain areas, however this time; we were at least aware of the situation and were able to work closely with the CASA representatives, to ensure there were no infringements by MAAA members.

MAAA has the ability to inform its members in a very short space of time about any changes; however we first must be made aware of these changes and would request that the MAAA be included in any relevant CASA notifications that may infringe on the operations of our members and clubs. This will aid safe skies for all.