Lowering Class E between Melbourne and Cairns

[RFguy]

well, I have put my submission in. 3000' interface .
 

Please describe what changes you would like to see made to the proposal

 

make the class G-E interface at 3000 feet AGL, not 1500 feet AGL. This provides class G airspace users a far better safety margin for difficulty, such as an engine failure. An engine failurte at 1500 feet leaves pilots very very few options and provides approximately 90 seconds until on the ground.... Options for aircraft is much greater at 3000' AGL, Permits better choices of a landing area and time for some troubleshooting to be performed.

 

Do you have additional comments about the proposed airspace change?

 

Yes. In my opinion, the requirement for a transponder or ADSB-OUT equipment is NOT a an impediment. The use of a Mode A/C transponder IN CONJUNCTION with a cost effective ADSB-IN-OUT EC device with SIL>=1 such as a SkyEcho2 ($900) permits superior options for pilots and ATC to ensure separation and provide improved routing options for GA. While the low cost devices have a range of approx 20nm aircraft to aircraft (is 3 x further to an SSR site) , these are the range of distances that are relevant.

[BirdDog]

So I have Mode C Transponder in my bird, and wanted to know what the benefits are to getting my hands on a SkyEcho2?

 

Cheers

J

[extralite]

More of a GA issue when flying IFR.

 

If a clearance cannot be obtained on the ground in places where ATC can't be reached on the ground, won't it involve having to stay under 1500ft until a clearance can be obtained? Depending on radio traffic and ATC load, this can take some time. So on an IFR flight plan, possibly with low cloud, can't ensure terrain clearance by planning a departure within the splay set out in ersa, or reverse approach etc.  If cloud is a factor, i think it would mean having to maneuver clear of cloud within the circling area which is not really idea. Or is there another approach?

[RFguy]

BirdDog, assuming you read the whole forum topic : 

Others will add to this : 

Summary VFR -

Out of CTA/CTZ :

- RPT  and some GA (mostly commercial ops) will see you on their map , with your heading, speed, altitude (to the foot) and registration.

 - and you will see them on your map (if you have a Ipad etc attached) with same info. 
 

-Simpler resolution of aircraft sharing airspace . Much of the information that might be conveyed over radio is done in a data burst....

 

- Warnings between GA/RA aircraft  operating amongst eachother- the ADSB IN OUT functions as a highly accuration TCAS system. It doesnt have the TCAS integration - like TCAS  kit suggests course of action etc  , but will provide you with warnings, proximity alerts etc.

 

In CTA CTZ - ATC will have a high confidence of the location , heading, speed, altitude registration of your aircraft and all the benefits that go with that. 

 

[Yenn]

You don\'t have to have a clearance to fly in class E airspace. I think it is a stupid proposal and cannot see why it is necessary. Have there been any accidents which could have been avoided by having this change.

In my opinion it is just the bureaucrats at Airservices trying to spread their wings after seeing what has happened in the UK.

Their comment about making it ICAO compliant is farcical. I have seen them use this argument on other occasions and then at the end of their argument they will say it is not ACAO compliant. It is just something they use to prop up an argument that it doesn't apply to.

[Bosi72]

3 minutes ago, BirdDog said:

So I have Mode C Transponder in my bird, and wanted to know what the benefits are to getting my hands on a SkyEcho2?

 

Cheers

J

 

I found it as additional safety feature, however not bullet proof, neither reliable.  I have seen aircrafts appearing then disappearing from the screen, then mine doesn't start transmitting data out before ~700ft, then I had overheating issues..

 

Regardless, I have seen a number of aircrafts on the screen prior to identified them in the air, and I am sure many have seen me too.

 

Other than above, the integration with EFB's is looking "cool", providing some features found in $$$ expensive glass cockpit aircrafts.. 

 

Sorry for the poor photo quality.. That's Samsung Note 9 and SkyEcho 2 right above

 

 

 

 

 

[BirdDog]

Thanks lads.  Looks like it's a worthy investment.

[extralite]

1 hour ago, Yenn said:

You don\'t have to have a clearance to fly in class E airspace. I think it is a stupid proposal and cannot see why it is necessary. Have there been any accidents which could have been avoided by having this change.

In my opinion it is just the bureaucrats at Airservices trying to spread their wings after seeing what has happened in the UK.

Their comment about making it ICAO compliant is farcical. I have seen them use this argument on other occasions and then at the end of their argument they will say it is not ACAO compliant. It is just something they use to prop up an argument that it doesn't apply to.

You do need a clearance if IFR or SVFR.

[Garfly]

Yes, I can see this could also be a problem for GA pilots choosing to fly IFR who, under current arrangements, would file, or amend, their plans once airborne in Class G.  

[Bosi72]

I hope they won't start charging $ to justify increased workload..

[Yenn]

As I stated before you don't have to have a clearance and of course if you are IFR or special IFR you will need a clearance.

We need to state the obvious and prepare an argument to stop this.

What is the need for a lowering of the E class level?

Have there been any accidents caused by E class not being low enough?

If I remember correctly, the last mid air collision involved two aircraft on IFR flights. That means that Airservices were monitoring them. How could Airservices do a better job when they have more airspace to oversee?

Airservices mention that they want to be ICAO compliant, but from what I see of Airservices that is only just talk. After they make amendments there will be a statement that it is not ICAO compliant. It has a precedent, so can be expected.

The selection of 1500' is not sensible because that is the top of circuit height for airstrips. There is no ability to overfly without coming int conflict with traffic in the circuit.

1500' is also not sensible, because most of the East coast has hills and ridges rising 3000'  from the surrounding country. For example, my home strip at 100', which would give an E level of 1600' has 2500' hills within a few miles.

How would a 1500' limit be policed? I would expect that it would be impossible for Airservices to police a 1500' limit, unless the plane was using a transponder, in which case it would be legal in Class E.

Is Airservices doing this because similar things have been done in the UK, with massive areas of airspace denied to GA traffic.

I reckon I can come up with more reasons that it is a stupid idea, but if you are going to put in your thoughts, go ahead and add mine if you think they are valid and also post here any extras you can think of.

At the moment I am having trouble getting to Airservices site as they won't accept my password, although I cann still get NAIPS service.

[graham brown]

It is all 8500 LL on the charts to 1500agl which makes no sense and is not practical. Have a look at the charts!

No benefit to safety to RPTs except to reduce the sky’s of the vfr traffic.

Increased risk to all vfr traffic being sandwiched into 1500 agl in those areas which is most of eastern Australia.

Full tso’ed and certified equipment is required and Airservices says that’s a matter for CASA if we want changes. 

Airservices say they have been consulting on this but they haven’t. No presentation to ASTRA or RAPAC. No email to industry or those on their engagement email list.

 

[RFguy]

yes, I put in another sub. used the email as the website is a bit uncooperative.

**

You are likely aware of a few problems with the website  with submitting feedback and submissions.

I seek to provide a further submission / information :

1) The east coast great dividing range periodically extends very close to the ocean, and is of rugged terrain.

Trying to put a number of the height above ground for the Glass G - Class E interface in these rugged areas is not practical.  IE where the ground height may vary from 100 feet to 3500' over a few kilometers north and south. 

It is simply not possible to put a fixed number on height above ground that is constant for more than a few hundred meters in any direction. * The only place that is going to work is out to sea over the ocean, at a sufficient minimum  distance from the coastline . *

 

2) 1500 feet AGL is at the circuit height on aerodromes. This is the wrong height, in my opinion for a transition height.

A height of 3000 feet AGL is far more practical. This is 1500 feet above the circuit height

It would be a management headache if  local airspace users conducting circuits of their local airstrip were to be popping in and out of class E airspace.

 

3) Training  areas around aerodromes, even minor aerodromes, often extends to the regional Class E boundary of 8500' AGL. This will need to be considered by ATC when placing IFR traffic... Training areas need carte-blanche.

 

[Garfly]

 

 

1 hour ago, graham brown said:

It is all 8500 LL on the charts to 1500agl which makes no sense and is not practical.

//  ....  Full tso’ed and certified equipment is required ...

 

 

Graham, are you saying that CASA are lying to us with this "apart from" assurance?  (and accompanying chart)

 

 CASA ADVISORY CIRCULAR AC 91-23 v1.0 

"Apart from an integrated TABS device able to substitute for a transponder in Class E & G airspace, lower cost options are not intended to overcome any existing requirement to carry a transponder, in any class of airspace."

Edited January 27, 2021 by Garfly

[RFguy]

are they saying a SkyEcho alone wont cut it, needs to be a ModeA/C transponder +Skyecho etc ?
Mode A is a very low base, dont even need an altitude encoder (less to maintain) . 

 

[slb]

Well it does seem that RAAus is not impressed with the AirServices proposal and are asking for members to email them

 

Airservices Australia ‘Lowering of Class E on the East Coast’ proposal You may be aware that Airservices Australia (Airservices) is currently consulting on a proposal that would see a significant reduction in the lower limit for Class E airspace between Cairns and Melbourne. Released to industry last week, this proposal was communicated to industry via a Fact Sheet published on the Airservices Engagement and Consultation website and also publicised via the Aviation State Engagement Forum (AVSEF) website. RAAus CEO, Matt Bouttell and Head of Flight Operations, Jill Bailey, attended a ‘webinar’ hosted by Airservices today to gain greater understanding of the proposal given the impact this would impose on our members that operate in affected areas. See here for the Airservices presentation. In summary, this proposal is part of a broader Airspace Modernisation Program being developed by Airservices that seeks to lower the base of Class E controlled airspace between Cairns to Melbourne from a lower limit of 8500 FT AMSL to 1500 AGL and replace the existing Class G uncontrolled airspace. There are some key elements we need to be aware of: Australian Class E airspace has the mandated requirement for a serviceable transponder to be fitted to any aircraft operating in the airspace unless the aircraft does not have an engine driven electrical system capable of powering a transponder, and a serviceable VHF radio capable of ‘Continuous two way’ communications. Members are encouraged to refer to CAO 20.18 and AIP ENR 1.4 for specific information. Analysis of our aircraft fleet indicates less than 30% of aircraft operating in the affected geographic area are currently fitted with a transponder. Should this proposal go ahead, there is likely to be insufficient equipment available in addition to a shortage of qualified personnel to fit this many transponders by December 2021. This proposal introduces not only an inconvenience but significant risk to pilots who do not have a serviceable transponder or radio in their aircraft. Pilots will be required to ‘skirt’ under or around this newly classified Class E airspace. Airservices do not know how many VH-registered aircraft this also affects as this data is unavailable. Likewise our sister organisations, Gliding Federation of Australia, who will possibly be required to fit equipment to towing aircraft (gliders are exempt from the requirements as noted above) and Sport Aviation Federation of Australia, who have a presence of aircraft in affected areas, who will also be required to fit equipment to operate in reduced lower limit Class E airspace. CASA are responsible for regulating the airspace in Australia and therefore will need to take all consultation feedback into consideration prior to approving it. And it’s important to note that at this stage this is a consultation rather than fait de accompli. RAAus is unaware of any safety case presented to industry to increase the amount of Class E airspace which effectively ‘shuts out’ a large percentage of RAAus operators and training schools – and an unknown number of pilots in GFA, SAFA and VH- registered aircraft, due to the equipment requirements. RAAus is concerned the duration of consultation phase is not sufficient to provide assurance that equitable access to airspace for all users has been considered. There has been no information communicated at this time that there is any awareness of the cost this proposal imposes on industry, nor recognition of the requirement for a Regulatory Impact Statement to be provided by Airservices and/or CASA to justify to Government that this proposal's cost to industry is reasonable. Members are encouraged to refer to the Office of Best Practice Regulation. for more information. RAAus does not support this proposal at this time and we assure members that we will be working collaboratively with our members, Airservices, CASA, Government and other industry stakeholders to work through the issues and encourage the launch of a transparent airspace strategy development forum, or similar, so that Australia’s airspace is fit for purpose and does not ‘leave people behind’. RAAus is encouraging members to respectfully provide your views on this proposal in two ways. Firstly, please provide an email to RAAus directly via [email protected] by 10 February 2021. Your feedback will assist us with developing an organisational response to the consultation. RAAus also encourages you to lodge your own constructive submission to the Airservices consultation which can be done by emailing [email protected] by 15 February 2021.

[jackc]

I sure would like to help with a submission but my knowledge on the subject is not good enough.  Surely RAA know what’s needed, why don’t they deal with it as our representative peak body?  Yes there are members with the knowledge. Is it better for them to make individual submissions, or pool resources with RAA?

[Garfly]

I don't know much about it either but, for what it's worth, I shot this off to RAAus just now:

 

Dear RAAus team,

 

your update today regarding the proposal to lower Class E made no mention of what seems to be a relevant implication; the CASA ‘concession’ to recreational craft to substitute relatively cheap EC (Integrated TABS) devices for TSO’d transponders in Class E.

 

CASA ADVISORY CIRCULAR AC 91-23 v1.0 

Excerpt:

"Apart from an integrated TABS device able to substitute for a transponder in Class E & G airspace, lower cost options are not intended to overcome any existing requirement to carry a transponder, in any class of airspace.”

 

I’m not saying that this makes the proposal okay, not at all; but it does appear to be part of the grand CASA strategy (and a way to dampen resistance from the VFR crowd). Anyway I’d have thought that at least some engagement with this gambit ought to be part of any response. 

 

The SkyEcho2 device, for example, seems to qualify under this concession. As you know, it's a stand-alone portable unit that can even be moved between (uniquely registered) aircraft. So carrying one may indeed overcome many of the objections we, as a group, might otherwise raise.  It might even make some things better for our sector, such as clearance-free transit overhead Class D at Coffs. However, if, indeed, mandating this kind of device (at a minimum) is what CASA (in their obfuscating way) is intending, then why don’t they come out and say so?  

 

They should reveal their hand if they really want ‘consultation’.

 

 

BTW, this issue has been heavily canvassed in recent days on Recreational Flying forums but it seems none of us knows for sure what’s going on.

 

 

 

 

Edited January 27, 2021 by Garfly

[graham brown]

2 hours ago, Garfly said:

 

 

 

Graham, are you saying that CASA are lying to us with this "apart from" assurance?  (and accompanying chart)

 

 CASA ADVISORY CIRCULAR AC 91-23 v1.0 

"Apart from an integrated TABS device able to substitute for a transponder in Class E & G airspace, lower cost options are not intended to overcome any existing requirement to carry a transponder, in any class of airspace."

We have to ask CASA as Airservices say they don’t know. I was involved in the low powered adsb introduction through ASTRA and it was only intended for air to air surveillance so I doubt if CASA will approve. We can ask CASA but I would not expect an answer for a few years. It’s not already in the regulations so it’s not an easy change. Best to oppose this outright.

[jackc]

12 minutes ago, graham brown said:

We have to ask CASA as Airservices say they don’t know. I was involved in the low powered adsb introduction through ASTRA and it was only intended for air to air surveillance so I doubt if CASA will approve. We can ask CASA but I would not expect an answer for a few years. It’s not already in the regulations so it’s not an easy change. Best to oppose this outright.

CASA bang on about safety and MORE safety and their attention to furthering it, is slower than a snail in reverse?

Many people can die waiting for them to come up with a decent plan that give decent access to airspace and logical safety to go with it?

Or, have I totally missed something here?

[Garfly]

24 minutes ago, graham brown said:

We have to ask CASA as Airservices say they don’t know. I was involved in the low powered adsb introduction through ASTRA and it was only intended for air to air surveillance so I doubt if CASA will approve. We can ask CASA but I would not expect an answer for a few years. It’s not already in the regulations so it’s not an easy change. Best to oppose this outright.

 

Fair enough Graham, but my attempt at reading the CASA tea-leaves suggests that they reckon air-to-air in regional terminal areas will be acceptable (better than what we've got now in G) if all VFR aircraft in the space have some kind of ADSB conspicuity and all RPTs in the space have some kind of CDTI tech working (cockpit traffic display).  So ATC visibility might not be the only - or the primary - consideration when they made the EC (Integrated TABS) concession. 

Edited January 27, 2021 by Garfly

[jackc]

I put in a submission to which the RAA CEO politely replied saying I had valid points.

He did say they are doing up an FAQ on it all next week,  so things are moving 🙂

[graham brown]

18 minutes ago, Garfly said:

 

Fair enough Graham, but my attempt at reading the CASA tea-leaves suggests that they reckon air-to-air in regional terminal areas will be acceptable (better than what we've got now in G) if all VFR aircraft in the space have some kind of ADSB conspicuity and all RPTs in the space have some kind of CDTI tech working (cockpit traffic display).  So ATC visibility might not be the only - or the primary - consideration when they made the EC (Integrated TABS) concession. 

It’s too sensible to be adopted in the short term. 🤔

[John Robert]

In less than 10 years we will have pilot less drones & possibly pilot less regional passenger airlines. The Defence Forces are already using remotely guided 

offensive weapons. They can operate safely but only if all aircraft broadcast their location.

The height reduction of E class airspace may well be part of the need to plan for the future. Drones could replace  trucks for example rural mail delivery &

the live export rock lobster trade in our remote areas in WA. They will not be flying above 8500 ft, they are more likely to be at 3000 ft..   Regardless, the future will demand that all aircraft be able to broadcast & receive their position.  It is a very small step  to have that information used to automate traffic avoidance in auto pilot that would benefit many more VFR pilots.

Just maybe  our regulators are looking ahead for once. If this is sensible future planning it would make it much more acceptable if we were  simply told this is going to happen in the future & we need your support & we need to start planning  now.

John

 

[jackc]

CASA need to make the plan and in a reasonable time frame measured in months not years.  They need to consult with ALL stakeholders and LISTEN to them.

Otherwise it will breed uncertainty and confusion.