The reporter has raised safety concerns related to the published En Route Supplement Australia (ERSA) Special Procedure SP 7 - Ayers Rock, Standard scenic flight procedures.
Specifically, the reporter states on multiple occasions aircraft have followed the procedure at non-compliant altitudes resulting in at least two incidents with miscommunication and separation issues (the ATSB provided occurrence reference numbers to named party).
The reporter further states some operators will at times conduct the standard SP 7 in reverse during sunset and when the wind is favouring runway 31 at Ayers Rock aerodrome.
At the time of the Gold Coast helicopter incident [mid-air collision accident on 2 January 2023], the Aerodrome operator, in consultation with the Certified Air/Ground Radio Operator (CAGRO), raised concerns with the local fixed base operators that they were conducting the standard published scenic ERSA Special Procedure SP 7 in a reverse procedure.
The aerodrome operator at Ayers Rock airport states, the local fixed based operators (FBOs) have always done what they wanted to, especially relating to SP 7. This became an issue when the FBOs were conducting a reverse scenic while itinerant (regular) operators from another location were conducting the (correct) published scenic pattern. This resulted in a convergence issue that the Aerodrome operator believes was reported to CASA and the ATSB.
In January 2023, the Aerodrome operator sent a communication to the FBOs – [multiple operators] explaining the concerns the airport operator has (also supplied to the ATSB).
Suffice to say, the response was disappointing and all the FBOs continue to fly their own altitudes and conduct reverse scenic flights.
This makes it confusing for itinerant pilots who are following the correct published procedure.
If [Operator 1] were to conduct a standard overhead departure and arrival as is normal, it would resolve these issues. [Operator 2] already conducts arrivals and departures over the southern end of the general aviation apron, creating its own issue.
Publishing a second component to SP 7 will increase the already congested radio communication adding to more potential for a conflict, especially if the CAGRO is not on duty.
The wind can change quickly from one active runway to another which would in turn create more confusion as to who is flying what direction in the scenic pattern.
There is no benefit in publishing a reverse SP 7 in the ERSA and the aerodrome operator will not be submitting that change request.
The reporter has raised safety concerns related to the published standard scenic flight procedure – SP 7 - Ayers Rock En Route Supplement Australia (ERSA). Specifically, the reporter states on multiple occasions aircraft have followed the procedure at non-compliant altitudes. This has resulted, on at least two occasions, in miscommunication and separation issues [ATSB occurrence reference numbers].
The reporter further states local operators will at times conduct the standard scenic flight procedure in reverse during sunset and when the wind is favouring runway 31 at Ayers Rock aerodrome.
In response and noting the above, CASA acknowledges these concerns.
Special Procedure 7 (SP 7) is a recommended practice that balances aviation safety with the environmental concerns of the park owners. SP 7 as noted in 7.1.3 was developed by the park management and local operators to maintain an acceptable level of aviation safety.
While SP 7 is a recommended practice rather than mandatory procedure, pilots are reminded not to operate contrary to recommended practices unless operationally necessary, due to the potential increased risk to pilots flying into the Ayers Rock Aerodrome who are not familiar with common local practices (such as, conducting standard scenic flight procedures in reverse during sunset and, when the wind is favouring runway 31 at Ayers Rock aerodrome).
Additionally, when SP 7 is not followed (because for example, conditions do not allow pilots to follow the procedure, such as prevailing weather conditions, the need for different flight paths to facilitate viewing of sunrise and sunset, aircraft technical issues, a pilot’s decision not to fly into the sun at different times of the day, etc), pilots are still required to operate under, and act in accordance with, Civil Aviation Regulations.
As such, and as Ayers Rock is not a controlled air strip, pilots are still subject to compliance with Civil Aviation Safety Regulation 91.055 from the Civil Aviation Safety Regulations 1998 (CASR) where aircraft are not to be operated in a manner that creates a hazard and pursuant to CASR 91.215(2)(b)(i) and (ii), the pilot in command of the aircraft has final authority over and must ensure the safety of persons on the aircraft and the safe operation of the aircraft during the flight.
This will be followed up through future surveillance.
The ATSB has consulted with the local scenic operators on the concerns raised.
Some operators acknowledge they fly the procedure at a higher altitude in order to increase separation as they are operating a slower aircraft.
All local operators acknowledge it would be beneficial for the reverse procedure to be published in ERSA particularly for the benefit of itinerant pilots not familiar with the procedure.