Willy airspace proposal • Call for comment.

[walrus]

Turbo, I’m sure you are right. What you are saying, it seems, is that RAA pilots have no rights. That said, my point stands. With no rights, then the 60%+ of Australians living under CTA on the East Coast should not be flying RAA. You can fly suitably equipped RAA aircraft in CTA with a ppl, bfr and medical certificate).

 

‘’That begs the question of medical self certification for GA, if that happens then the floodgates are open for the RAA pilots with a PPL as well.

[mkennard]

11 minutes ago, walrus said:

Turbo, I’m sure you are right. What you are saying, it seems, is that RAA pilots have no rights. That said, my point stands. With no rights, then the 60%+ of Australians living under CTA on the East Coast should not be flying RAA. You can fly suitably equipped RAA aircraft in CTA with a ppl, bfr and medical certificate).

 

‘’That begs the question of medical self certification for GA, if that happens then the floodgates are open for the RAA pilots with a PPL as well.

You could also debate whether RAAUS is a direction towards recreational GA. 

[turboplanner]

2 minutes ago, walrus said:

Turbo, I’m sure you are right. What you are saying, it seems, is that RAA pilots have no rights. That said, my point stands. With no rights, then the 60%+ of Australians living under CTA on the East Coast should not be flying RAA. You can fly suitably equipped RAA aircraft in CTA with a ppl, bfr and medical certificate).

 

‘’That begs the question of medical self certification for GA, if that happens then the floodgates are open for the RAA pilots with a PPL as well.

No, I'm not saying RAA pilots have no rights, I'm saying the RA owners and pilots were exempted from some rules, training costs and areas in order to make possible grass roots, simple flying at a fraction of the costs of GA. If you want the rights o do all the things a PPL can do, then you need to throw away your exemption and train/fly in GA, or train and use a qualifying aircraft. There are some schoole who do this in the bigger cities.

 

2 minutes ago, mkennard said:

You could also debate whether RAAUS is a direction towards recreational GA. 

You could about ten years ago because that seemed to be the way it was headed, but judging by posts on this site that seemed to cool in both camps, and it's interesting to see rag and tube and local flying again being discussed in recent times.

[jackc]

5 hours ago, kgwilson said:

A better option is Coastal under 1000. Illegal at this stage for RA but you will be granted this transit most of the time if you call them. Coffs doesn't have a lot of traffic.

When I was training at Coffs, used to fly coastal South not above 1000 to the training area all the time and return.  Mixing it with RPT traffic etc.

[Garfly]

 

I believe that some flying schools had/have special dispensation to operate RAAus in Class Ds. 

 

[KRviator]

They do, yes, however, once you get your RPC, you can no longer fly there. Only in Oz would that make sense...

[walrus]

Turbo, I have a ppl and did the training. but $800 for a bfr and then a medical on top of that, just so I can “go coastal” once a year is crazy. Have you ever flown into LAX as a passenger in daylight? You would have seen all sorts of aircraft from a C172 upwards, mixing happily in that airspace, but not here.

[turboplanner]

4 hours ago, walrus said:

Turbo, I have a ppl and did the training. but $800 for a bfr and then a medical on top of that, just so I can “go coastal” once a year is crazy. Have you ever flown into LAX as a passenger in daylight? You would have seen all sorts of aircraft from a C172 upwards, mixing happily in that airspace, but not here.

I have, but only saw heavies. That could just have been the traffic at the time. These days the US is following ICAO standards as we are.

You could make the same argument about the cost of maintaining an IFR rating just in case you might want to get home in IMC, but it's equally invalid

The once a year extra cost of flight planning through a safer area would be a lot less than qualifying to fly through CTA.

As I recall, all you wanted to do originally was fly a STOL off an island in Gippsland?

[kgwilson]

CASA needs to get real. All you need in NZ is a CTR rating and you can fly RA into any controlled aerodrome. Why is it that at 4:59pm RA cannot fly coastal or enter CTR at Coffs but at 5:00pm you can. RPT continues regardless of the position of the minute hand. Although it is not legal Airservices will give RA aircraft permission to fly coastal at Coffs so why not all the time? The alternative is over mountains up to 5000 feet & often lots of cloud. At Williamtown the inland route can be scary with turbulence at the allotted altitude. How long has CTR access for RAA been on the table? It took CASA 10 years longer than everywhere else to provide  an RPL & then it is complelely different from everywhere else. Just pathetic.

[Student Pilot]

12 minutes ago, kgwilson said:

CASA needs to get real. All you need in NZ is a CTR rating and you can fly RA into any controlled aerodrome. Why is it that at 4:59pm RA cannot fly coastal or enter CTR at Coffs but at 5:00pm you can. RPT continues regardless of the position of the minute hand. Although it is not legal Airservices will give RA aircraft permission to fly coastal at Coffs so why not all the time? The alternative is over mountains up to 5000 feet & often lots of cloud. At Williamtown the inland route can be scary with turbulence at the allotted altitude. How long has CTR access for RAA been on the table? It took CASA 10 years longer than everywhere else to provide  an RPL & then it is complelely different from everywhere else. Just pathetic.

Everything said is spot on. That's the reason why nobody bothers to make submissions, CASA will not listen.

[turboplanner]

15 minutes ago, Student Pilot said:

Everything said is spot on. That's the reason why nobody bothers to make submissions, CASA will not listen.

Especially when the subject has nothing to do with CASA.

[jackc]

53 minutes ago, Student Pilot said:

Everything said is spot on. That's the reason why nobody bothers to make submissions, CASA will not listen.

Maybe it’s time for RAAus to help justify its existence, now we have an ex CASA CEO……

[turboplanner]

50 minutes ago, jackc said:

Maybe it’s time for RAAus to help justify its existence, now we have an ex CASA CEO……

Again, what does this have to do with CASA?

[jackc]

Turbs, CASA are part of the regulatory organisation for Aviation……Whilst they may not be directly responsible on the subject in discussion, I am sure their ex CEO may have a few clues to look into it and see what process could be instigated with ASA?
 

 

[Ian]

My main concern is that the recommendation on page 71 of the  JOINT CASA AND RAAF AERONAUTICAL STUDY OF WILLIAMTOWN AIRSPACEOctober 2015 states that

Finding 13 The Williamtown CTR could be reduced in size without compromise to operations.

Recommendation 13 An ICAO based CTR should be adopted at Williamtown.

 

Their recommendation was that an 8 NM CTR should be adopted. The proposal shows an 11nm design. This is basically 2x the area of the recommendation which would appear to be a bit of a scam.

They didn't justify why such as large deviation from the recommendation was required.

[APenNameAndThatA]

On 22/10/21 at 11:07 PM, walrus said:

Turbo, I have a ppl and did the training. but $800 for a bfr and then a medical on top of that, just so I can “go coastal” once a year is crazy. Have you ever flown into LAX as a passenger in daylight? You would have seen all sorts of aircraft from a C172 upwards, mixing happily in that airspace, but not here.

Really? Are you sure? 

[APenNameAndThatA]

Having an RPL and medical so I can share airspace with pilots with air transport licences, Class 1 medicals and hundreds of passengers does not seem like overkill to me. I’ve got an RPL and it’s not like I feel overqualified to try and fly to the Gold Coast or even transit.  

 

Flying to the GC to land it some work to stay on top of the frequencies, and it was much easier with two radios than it would have been with one. I did it three times and safely each time, but I’ve already forgotten how.  

 

I don’t think I would even try and go to the GC in a Foxbat. Transiting would be easier, but I would still be sharing airspace. 

 

We’re lucky they even let amateurs in 80 kt planes share airspace with 737’s if you ask me.   

[walrus]

Pen, regarding Los Angeles, there are VFR corridors right through the middle of controlled airspace, none of this skulking around the edges at 500 feet.

 

Regarding “mixing it with hundreds of passengers” - you do that when you use any CTAF with an RPT service already.  You arrange separation with the RPT pilots, they won’t bite your head off. When there is potential conflict,  I usually give them the courtesy of landing first on economic grounds by just extending downwind a bit.

 

‘’All PPL holders learn and are endorsed on controlled airspace procedures, it’s not rocket science.

 

‘’RAA students at Moorabbin have been using class D airspace for years.

 

Sure we all get rusty, but it’s not that hard.

 

‘’As for medicals, in the USA and UK they self certify without it raining flame and aluminium from the sky. Besides, what do you think ADSB, transponders and radios are for? ATC is there to help, not hinder.

[RossK]

On 23/10/2021 at 9:46 AM, turboplanner said:

Again, what does this have to do with CASA?

From the RAA Ops Manual

"Controlled Airspace may only be entered by recreational pilots complying with specific criteria as outlined in CAO 95.32 and 95.55, upon receipt of a clearance."

 

CAO 95.55 Section 7.3(d)

"(d) the aeroplane is flown by the holder of a valid pilot licence (not being a student pilot licence): (i) issued under Part 5 of CAR 1988; and (ii) that allows the holder to fly inside the controlled airspace;"

 

So RAA need to get CASA to amend CAO 95.55 and remove 7.3(d)

 

That's my understanding of the situation.

[turboplanner]

3 hours ago, RossK said:

From the RAA Ops Manual

"Controlled Airspace may only be entered by recreational pilots complying with specific criteria as outlined in CAO 95.32 and 95.55, upon receipt of a clearance."

 

CAO 95.55 Section 7.3(d)

"(d) the aeroplane is flown by the holder of a valid pilot licence (not being a student pilot licence): (i) issued under Part 5 of CAR 1988; and (ii) that allows the holder to fly inside the controlled airspace;"

 

So RAA need to get CASA to amend CAO 95.55 and remove 7.3(d)

 

That's my understanding of the situation.

1. My comments relate to the Aviation State Engagement Forum by Airservices Australia which closes in six days time.

2. If you trawl through all the regulations we have to comply with there will be some links like the ones you point out, but in this case I don't think Airservices is considering any fundamental changes to the existence of RAA or other SAOs, or Controlled Airspace in general, just looking at one locality.

Edited October 26, 2021 by turboplanner

[RossK]

56 minutes ago, turboplanner said:

1. My comments relate to the Aviation State Engagement Forum by Airservices Australia which closes in six days time.

2. If you trawl through all the regulations we have to comply with there will be some links like the ones you point out, but in this case I don't think Airservices is considering any fundamental changes to the existence of RAA or other SAOs, or Controlled Airspace in general, just looking at one locality.

The conversation had drifted to CTA access for RAA certificate holders.

 

[Ian]

Back to the topic at hand, the point mentioned earlier related to the proposed 11nm CTR vs the recommended 8nm CTR. Does the smaller CTR free up addition flight paths which would provide safer routes through this airspace? Would anyone familiar with this airspace and associated terrain be able to comment? If there are benefits send an email to Airservices [email protected]

 

[APenNameAndThatA]

On 26/10/2021 at 4:40 AM, walrus said:

Pen, regarding Los Angeles, there are VFR corridors right through the middle of controlled airspace, none of this skulking around the edges at 500 feet.

 

Regarding “mixing it with hundreds of passengers” - you do that when you use any CTAF with an RPT service already.  You arrange separation with the RPT pilots, they won’t bite your head off. When there is potential conflict,  I usually give them the courtesy of landing first on economic grounds by just extending downwind a bit.

 

‘’All PPL holders learn and are endorsed on controlled airspace procedures, it’s not rocket science.

 

‘’RAA students at Moorabbin have been using class D airspace for years.

 

Sure we all get rusty, but it’s not that hard.

 

‘’As for medicals, in the USA and UK they self certify without it raining flame and aluminium from the sky. Besides, what do you think ADSB, transponders and radios are for? ATC is there to help, not hinder.

Regarding the VFR corridors, a) you have to be able to get the clearance to use them, which is not always forthcoming, and b) I'm not entirely sure you would get close enough to the FVR corridors in a RPT aircraft to see the C172's. I might be wrong though. 

 

Regarding "You do that when you use an CTAF with and RPT already". Yes I do, but the Class C and Class G aerodromes are different, hence the different airspace. The Class C aerodromes are busier and have bigger aircraft. While it is true that doing as ATC tells you is much easier than organising separation yourself, Class C airspace is so busy that if you stuff things up you will cause chaos. 

 

As for students using Class D airspace, that is true. They all need to have a medical and, of course, it is much easier to use a particular Class D when you have done hours and hours of training there. I trained at Archerfield, Class D, and feel more comfortable there than anywhere else. 

 

Regarding self-certification in the UK, I don't know anything about it. As far as I know, very few accidents (? none) are caused by medical issues, so I wonder if removing the medical certification requirement for all GA pilots would make much difference. On the other hand, you can drive a car if you have not had a seizure in the last 12 months if you have epilepsy. Question: how unhealthy to you actually have to be to not get a Class 2 medical? 

 

It is the easiest thing in the world to argue that regulations about training should be relaxed one step. For example, can anyone really demonstrate that RPL pilots should not be given the same privileges as PPL pilots? Another way of looking at it is that better training makes people better pilots so it could be argued that RAAus pilots should all be better trained, even if the medical standard stays the same. 

 

So, what you are saying is perfectly sensible, the issue is one of shades of grey. 

 

 

[Ian]

I'm not against medical assessments per se, as the person with the risk factors often doesn't perceive the risk well. However the reverse it also true where it's often difficult to discount a condition with a demonstrably low risk.

There is often an issue of perceived risk vs actual risk and this appears to be significantly higher when dealing with medical issues. For example I have very mild asthma, which tends to only flare up when I am ill and leads to me feeling uncomfortable rather than suffering respiratory distress. During my initial medical assessment my DAME agreed that it was so mild as to not present an issue and not to require any special controls. CASA required further investigations which led me to spending many hundreds of dollars which demonstrated that my Spirometry results were normal. However the recommendation was that I am to carry an inhaler when I fly. While this is a fairly minor embuggerence, I did review the literature as published by ATSB and FAA relating to the incapacitation of pilots during flight which spans over 50 years, both in Australia and the US and could not find a single case of pilot incapacitation due to asthma. Heart attacks, stroke, multiple instances of food poisoning,  aerobullosis (the bends), nausea, respiratory infection etc but not asthma. I did point this out to both CASA and the specialist however to no avail.

So apparently statistics is no match for the vibe when considering risk so I duly pack an asthma puffer in my flight bag even though I don't have one in the house, or car or when I travel.

 

pilot-incapacitation-atsb.pdf faa-in-flight-incapacitation.pdf

Edited October 29, 2021 by Ian

[facthunter]

THEY have to be SEEN to be doing something and will NEVER stick their neck out for your benefit. They do not pay their Aviation Doctor enough to get a good one.. Nev