That Broome's Class D airspace is overlain by Class E airspace
The reporter states that Broome's Class D airspace is overlain by Class E airspace which allows low performance VFR aircraft (usually piloted by less experienced crew) to be a necessary traffic concern to high performance IFR aircraft in both regular passenger transport (RPT) & charter operations during critical flight phases.
RPT aircraft broadcast any pending departure or descent on the relevant Centre frequency. The intent of this is to provide traffic awareness to potential conflicting VFR traffic. The reporter believes that RPT aircraft should not be placed in this position, when the arriving aerodrome is class D (like the structure of Class ADs in eastern states). While some opportunity for coordination may be afforded during descent, the effectiveness of the departure broadcasts is questionable as (presumably) the broadcaster is then dealing with Broome Ground and Tower frequency until they are climbing into Class E. When the broadcaster contacts Centre frequency, and becomes identified, it usually occurs well above 5,500 ft, which is too late for any avoiding action.
The reporter believes there is a safety risk in high performance aircraft having a gap between provided separation during a critical phase of flight. The reporter advises that points two and three of Broome’s ERSA flight procedures are insufficient and suggests the airspace be redesigned to provide Class C services down to at least the top of Class D altitudes on major arrival routing, as is procedure in eastern states.
Reporter's comments: “Overall, Class E airspace is quite a pointless concept but never so ridiculously applied as overhead a major destination between Class D and C airspace.”
Airservices Australia (Airservices) appreciates the opportunity to respond to the reported safety concern regarding the structure of controlled and non-controlled airspace associated with Broome international airport.
Airservices notes that the Civil Aviation Safety Authority (CASA) is the airspace regulator. In February 2014, CASA released a Post Implementation Review (PIR) of the Broome and Karratha airspace which did not indicate any issues with the Class E airspace model. The steps were specifically reviewed in respect of IFR movements and the PIR stated that "CASA considers that the Class E airspace steps are appropriate." Airservices notes that there has been no significant change in traffic or staffing since the PIR.
Additionally Airservices collects Air Traffic Management safety occurrence reports in our internal reporting system to meet the Transport Safety Investigation Act (TSI Act) reporting requirements. Mandatory and voluntary safety occurrence reporting also forms a key element of our Safety Management System, which supports our ongoing commitment to monitoring our safety performance, and to drive safety improvement.
Airservices has conducted a review of airspace related occurrences surrounding Broome airspace for the period of 1 July 2013 to 30 April 2018. Specifically, the review focused on aircraft conflict between IFR and VFR aircraft in Class E airspace. There were no aircraft confliction related occurrences identified in Class E airspace during that period of review.
Further comment on airspace structure may be sourced from CASA.
CASA has reviewed the REPCON and provides the following comments:
- CASA reviewed all incidents in the vicinity of Broome for the period 1 May 2013 - 30 June 2018;
- There were no reported incidents between a VFR aircraft and an IFR aircraft in Class E airspace during that period;
- CASA also reviewed stakeholder comments applicable to Broome Airspace Reviews and no comments were received regarding issues with VFR aircraft conflicting with IFR aircraft in Class E airspace;
- CASA is satisfied the Broome Class E airspace is safe and fit for purpose; and
- CASA continues to monitor traffic movements and airspace incidents at major aerodromes in Australia (including Broome) on a quarterly basis.