Coral approach airspace design

Multiple reporters have raised safety concerns regarding the Coral approach airspace design. The new airspace requires Brisbane Air Traffic Services (ATS) resources, which to date has proven to be highly unreliable requiring Terminal Control Area (TMA) contingency procedures. This has been occurring on a regular basis and requires all pilots to gain verbal permission from Airservices via telephone. This in itself is a safety concern; however, along with the recent airspace design changes, the temporary restricted area (TRA) NOTAM adds further complexity and confusion for local pilots and controllers alike. Pilots see it as another classification of airspace that isn’t Class D nor Common Traffic Advisory Frequency (CTAF) nor quite traffic information broadcast by aircraft (TIBA) as it includes Mackay Tower.

The reporters have raised the following concerns as a result:

• Pilots re-entering late are denied clearance and therefore unfamiliar alternate uncontrolled airports or emergency fuel declaration considered.
• Teaching new student pilots in such a dynamic and complex airspace environment is near impossible. Mackay Tower is operating when airspace is closed, providing some services (i.e. occasional traffic information, take-off and landing clearances) leaving pilots confused.

The reporters collectively state that it is evident that short notice TRAs will continue to be the norm, and as such, the airspace arrangements around Mackay needs to be reviewed. 

The reporters state that the overlapping Class D and Class C procedures is confusing and significantly increases workload for general aviation (GA) pilots operating out of Mackay. It requires the use of a single frequency (125.65Mhz) over two classes of airspace above 1,000 ft AMSL. To operate above 1,000 ft a transponder code is required and a flight plan insisted upon by Approach controllers, despite this being procedural Class D airspace to 4,500 ft during tower hours.

Many GA operators are choosing to operate below 1,000 ft within the zone to remain on Tower frequency and avoid confusion. Above 1,000 ft there is confusion as to class of airspace and services provided by ATC on the common frequency 125.65. This is further exacerbated by controllers sometimes adopting Class C procedures between 1,000 ft and 4,500 ft while on other occasions aircraft will be instructed to contact and remain on Tower frequency. This situation is resulting in: 

• Less reliance on 'see and avoid' by ATC above 1,000 ft to allow efficient separation, radar separation occasionally implied for VFR aircraft in Class D.
• Unfamiliarity of Class C airspace procedures of local pilots, flight plans and Secondary Surveillance Radar (SSR) procedures.
• Confusion whether it is 'Mackay Approach 125.65' as per departure and approach procedures (DAP) or 'Coral Approach 125.65' as per AIC. Verbally they seem to be used interchangeably.
• Loss of situational awareness of circuit traffic due to larger ATO aircraft operating on a different frequency until approximately 5 NM final approach fix (FAF).

One reporter provided an example on [date], where they attempted to gain a clearance without a flight plan and was denied. They were told to descend to 1,000 ft. The reporter advised unable and 'require' a clearance due to cloud beneath. They were then instructed to hold outside control area (OCTA). The reporter states that this was due to one inbound jet aircraft which could have been resolved with a 'sight and follow'.  Instead, the reporter tracked coastal to descend. There was no delay once at 1,000 ft when speaking with Mackay Tower who gave them a clearance immediately.