CASA DP 1006AS - Proposed Strategy and Regulatory Plan

[Admin]

CASA wishes to advise that DP 1006AS - Proposed Strategy and Regulatory Plan in support of the Australian Government's Aviation White Paper - has been published and is now available for comment.

 

Comments close 30 November 2010

 

View the Discussion Paper on the CASA website:

 

Civil Aviation Safety Authority - DP 1006AS

 

 

[kaz3g]

How others are responsing to the ADS-B proposals in the CASA DP

 

Hi everyone

 

Time is running out... get a reponse in even if a very brief one.

 

I have asked RAAus what it is doing but haven't had a reply as yet.

 

Australian Flying has just posted a column that might help understand what is going on Australian Flying: ADS-B: an extinction level event?

 

The Australian Sport Aviation Confederation (ASAC) has provided a detailed reponse at http://2009.gfa.org.au/Docs/CASA/ASAC_DP1001AS_Response.pdf and organisations such as the GFA are making their concerns clearly known to the Regulator and Government. They don't seem to have picked up on the likely contraction of airspace available in G and E at this stage, however.

 

I haven't seen AOPA's response as yet.

 

kaz

 

 

[Guest basscheffers]

For a discussion about the real life implications of this for all of us, listen to an interview I did for the Plane Crazy Downunder podcast with site member, former AOPA president, gazzilion hour airline and GA pilot and hugely knowledgable person on this subject, Bill Hamilton.

 

Episode 48: ADS-B: C’est un pétard! – with Bill Hamilton « Podcasts « Plane Crazy Down Under

 

 

[DKM1]

Casa Discussion paper 1006AS closing date for comments, has been extended to the 14 December.

 

 

[kaz3g]

Hi everyone

 

I now have a copy of the RAAus submission to the DP. Not much meat on the bones and nowhere near as comprehensive as, for example those provided by ASAC, GFA or AOPA.

 

kaz

 

 

[Guest basscheffers]

Care to share?

 

 

[kaz3g]

Happy too but having problems uploading the file.

 

This is a copy and paste. Not so easy to read but you will get the drift

 

kaz

 

Phone: (02) 6280 4700 Fax: (02) 6280 4775 E-mail: [email protected]

 

VISIT US AT http://WWW.RAA.AS�.AU

 

20101130-RESPO�SE TO DP1006AS (ADS-B) PAGE 1

 

ABN 40 070 931 645

 

PO Box 1265 3/1 Pirie Street,

 

FYSHWICK ACT 2609 Fyshwick ACT 2609

 

30 November 2010

 

Mr. Peter Boyd

 

Executive Manager

 

Standards Development and Future Technology

 

CASA CANBERRA

 

By email: [email protected]

 

Dear Sir

 

RE: CASA’s PLA� FOR COMMU�ICATIO� �AVIGATIO� A�D SURVEILLA�CE

 

EQUIPAGE I� THIS DECADE – DOCUME�T DP 1006 AS – OCTOBER 2010

 

This letter is a replacement for the General and Specific Comments at page 34 of DP 1006AS.

 

Recreational Aviation Australia Inc. (RA-Aus) is concerned that the Discussion Paper (DP)

 

1006AS has been produced without sufficient consideration of safe operations and safety

 

mitigators outside of controlled airspace, without the use of ADS-B OUT capable Mode S

 

transponders.

 

RA-Aus have a membership of some 10,000 aviation enthusiasts and about 4,000 aircraft on our

 

books. The cost of equipping our aircraft with the appropriate transponders would, in many cases,

 

exceed the value of the machine. Whilst the DP (page 12) gives an indicative cost of re-equipment

 

(or initial equipment) for each aircraft of $6,000.00 there are other predictions of the cost being

 

well in excess of $20,000.00. Taking an average cost of say $15,000.00 to modify each aircraft,

 

our fleet-wide cost would be in the order of six million dollars. However, many of our aircraft are

 

space limited and could not be retro-fitted.

 

Even if a significant number of our owners were to opt for the fitment there are not sufficient

 

qualified LAMEs to undertake the task in the next decade.

 

Another major concern created by the DP is the uncertainty of what will be recommended in the

 

associated NPRM and likely to be mandated in the NFRM. For example, Table 2 (page 26) of the

 

DP states in part: “all aircraft newly placed...on the register of recreational aircraft organisations”

 

will require the Mode S transponder. This statement implies that regardless of where the aircraft

 

is to be used the equipment will be mandated.

 

However, Table C1 of Annex C to the DP states the equipment will be mandated “at listed busy

 

regional aerodromes supporting RPT services.” What the criteria will be for an aerodrome to

 

become a listed busy regional aerodrome is unknown. Perhaps some directions are perhaps

 

contained in the Table 5 of the DP (page 28) where “designated aerodromes” are mentioned with

 

“safety criteria based on traffic density and having RPT services.” Nevertheless, this is still

 

somewhat nebulous and thus disquieting.

 

Also of concern to RA-Aus is the fact that the new generation MBZ or CTAF ® will have a

 

radius of “20NM of the designated aerodrome.” Why must so much lateral airspace be

 

encompassed? What industry consultation has there been on this matter?

 

Phone: (02) 6280 4700 Fax: (02) 6280 4775 E-mail: [email protected]

 

VISIT US AT http://WWW.RAA.AS�.AU

 

20101130-RESPO�SE TO DP1006AS (ADS-B) PAGE 2

 

Sadly lacking in the DP are safety mitigators at non-towered aerodromes that do not require

 

expensive airborne equipment such as:

 

• improved airmanship training and testing

 

• banning local aerodrome frequencies to initiate user charges

 

• AFRU

 

• CA/GRS

 

• UNICOM

 

• mandated carriage and use of radio (as currently in force)

 

• sole use by RPT during specified periods

 

• triggers for a control zone

 

CASA should produce a detailed safety case for its proposals and not simply situate

 

appreciations.

 

RA-Aus membership is totally opposed to the CASA plans detailed in the subject proposal and

 

will support the known opposition from other airspace user groups.

 

Yours sincerely,

 

SKH Tizzard

 

Chief Executive Officer

 

 

[Bill Hamilton]

Folks,

 

Any of you who put in a reply to DP1006AS by the CASA on line system, they all got lost somewhere in the electronic never never. and you need to resubmit by early February, see the CASA web site, if you haven't been contacted directly.

 

Regards,

 

 

[Guest burbles1]

I knew I couldn't trust online submissions - thank goodness I mailed a print copy.

 

 

[facthunter]

Kaz, the RAAus submission could have been worse. They haven't ducked the issue. ( I don't usually run as an apologist for RAAus). I wasn't sure the AOPA stand was as suitable for us as, I had hoped. I did still renew my membership, but not enthusiastically.. I should have contacted them and sought a personal assurance instead of giving them the benefit of the doubt. I have a horrible feeling that this is going to be a disaster for U/L flying. Nev

 

 

[Guest basscheffers]

I wasn't sure the AOPA stand was as suitable for us as, I had hoped. I did still renew my membership, but not enthusiastically..

I would have hoped AOPA to take a harder line, but there are two points in there that could save us all a lot of money. First of all: they are pushing for no new transponder mandate. This means they oppose the requirement for every aircraft new on the register from Dec 2013 to have an ADS-B capably transponder. Secondly, they are pushing for not requiring a TSO c145/146 GPS source for VFR aircraft for places ADS-B is mandated. If we can all use any existing Garmin with an NMEA output or a $100 serial-GPS, that would save us quite a bit of dough if the need arises to carry ADS-B.

Of course I would like to not have the requirement at all, any time, anywhere because it is trying to solve a problem that doesn't exist. Or at least one that TCASII plus mode-C doesn't already solve.