Mandatory carriage of radios

[Admin]

Dear RA-Aus Members,

 

 

As you may already be aware, a Notice of Proposed Rule Making (NPRM) was issued on 28th September by CASA on the dual topics of:

 

-mandatory carriage of radios at non-towered aerodromes or in the vicinity

 

-changes in CAR 166 & 166A governing operations at or near non-controlled aerodromes .

 

 

Regulatory amendments are not expected to be effective until early 2010, if the changes go ahead. A brief summary of the proposal and CASA’s view point is given below but we do recommend you read the NPRM yourself for full details. (There is a neat, single page, summary of proposed changes on page 8 of the document.)

 

 

This is your opportunity to express your opinions to CASA. So follow the link below to the CASA website, read the NPRM and have your say. CASA will accept comments via email, fax, post or through CASA’s online comment facility – details of these can be found at the bottom of this webpage: Civil Aviation Safety Authority - NPRM 0908OS - Carriage and use of Radio and Circuit Procedures at, or in the vicinity of, Non-Towered Aerodromes The deadline for replies to CASA is close of business, 23rd October 2009. Please do not reply to this email as the address is not monitored.

 

 

In essence, the proposed changes to radio procedures are:

 

·For all pilots to make recommended, standard radio calls (as published in CAAPs & the AIP) when at or near non-towered aerodromes. (Key Proposal 1)

 

oMaking the appropriate calls is to be a performance based regulatory requirement for pilots flying radio equipped aircraft and qualified to use the radio.

 

oIt will be the Pilot in Command’s responsibility to broadcast on the aerodrome frequency whenever necessary to avoid collision or the risk of collision.

 

·For operations at or near certified, registered or other designated aerodromes (as published in ERSA) it will be compulsory to carry a serviceable VHF radio and be qualified to use it. (Key Proposal 2)

 

oPortable VHF transceivers will still count.

 

·New rules covering the arrival and departure of aircraft which have no radio communication – either because they are not radio equipped, the radio is unserviceable or the PIC is not qualified to use the radio. (Key Proposal 3)

 

 

The NPRM also proposes to withdraw the following paragraphs from the “Civil Aviation Regulations 1988 - Reg 166 - Operating in vicinity of a non-controlled aerodrome”:

 

·(2) (d) & (4) - It would now be permitted to join on base leg. (Key proposal 4)

 

·(2) (g) - There would no longer be a requirement to have a minimum length for final approach. (Key Proposal 6)

 

·(3) (a) - It would not be required to carry a VHF radio when conducting straight-in approaches (except at certified,

 

registered or other specially designated aerodromes). (Key Proposal 7)

 

·(3) (b) - There would no longer be specific mandatory broadcasts for straight-in approaches (although such broadcasts would still be recommended in other publications). (Key Proposal 8)

 

and proposes to amend these paragraphs:

 

·(2) (f) - if the aircraft is able (and permitted to by its flight manual) landings & takeoffs may be made on runways which are not into wind. (Key Proposal 5)

 

·(3) (d) - The minimum distance from the threshold for an aircraft to be lined up on final approach would be no less than 3 miles. (Key Proposal 9)

 

 

In the NPRM there are several different options for how the radio carriage may be implemented, and several options for how the radio use may be implemented. Section 3.4 “Key changes proposed in this NPRM” contains further information on what CASA would like to implement.

 

 

CASA’s stand, with respect to radio carriage:

 

“Option 1 – Mandate radio carriage for operations into registered or certified non- towered aerodromes (as published in ERSA) and other aerodromes designated (and published in ERSA) by CASA on a case-by-case risk basis:

 

·would give greater protection to all aircraft users of registered or certified aerodromes;

 

·would capture all high capacity RPT-serviced aerodromes;

 

·could be applied to capture all passenger transport operations;

 

·would serve to amalgamate CTAF and CTAF® aerodromes;

 

·would be a much broader mandate than the current requirement;

 

·would not be harmonised internationally.

 

 

3.3.2.3 This option would be the broadest reasonable requirement for radio carriage and would have the advantage of obviating the need to address operational safety risks at non-towered aerodromes on a case-by-case basis, potentially at significant cost to CASA. The vast majority of aircraft flying into certified or registered aerodromes are already radio-equipped, so a regulatory mandate for radio carriage at these aerodromes could be expected to have very little cost impact on operators.

 

 

3.3.2.4 It should be noted when considering this option that it is intended to make provision for radio unserviceability and non-radio aircraft (see paragraph 3.4.1.1)”

 

 

And with respect to radio use:

 

“Option 2 – General regulatory requirements for radio broadcasts, with specific recommended standardised calls published in education and guidance material

 

·Would involve a relatively simple ‘use your radio’ regulation supplemented by the publication of education and guidance material/aeronautical information publications to explain what positional broadcasts are recommended.

 

 

3.3.3.3 A possible argument against this option may be that, whilst the supplementing educational material could be immediate (e.g. booklets, AIP, magazines), its effectiveness would not be easy to determine. There would also be a need for the educational process to be sustained over a period of time, by way of flight reviews for example.”

 

 

If you wish to submit your own thoughts, or perhaps suggest a preferable alternative listed as one of the other options, then your chance is NOW!

 

 

The RA-Aus stand on this:

 

We do not support mandatory carriage of radios. We do strongly recommend that pilots who use aerodromes with heavy traffic have radios, and obviously CTAF® aerodrome users are currently required to have and use radios. However, we also recognise that many of our pilots do not operate in busy or CTAF® locations and they shouldn’t be compelled to purchase something they’re unlikely to use.

 

 

With respect to the radio use, RA-Aus does not object to the commonsense approach shown in Option 2 above. Standardised calls would be recommended, but left to the individual pilot’s judgement to make depending on the circumstances.

 

 

As with anything, the more responses which are received by CASA, the more likely it is that you will be heard.

 

 

So to make life easy for you, here’s the link which takes you direct to CASA’s online response: Civil Aviation Safety Authority - Documents open for comment

 

 

Yours sincerely,

 

 

Lee Ungermann

 

Chief Executive Officer

 

 

[Guest Qwerty]

The rotten bastards.

 

And RAAus management wonder why "certain elements" of the membership get their knickers in a twist.

 

Where, when and on what grounds did RAAus management decide that "RA-Aus does not object to the commonsense approach shown in Option 2 above". Where is the compelling safety case for this.

 

I understand that this idea started with an independent consultat and has had an internal assessment by CASA, has been reviewed by the CASR Part 91 Control Board, the Standards Consultative Committee (SCC) and two of its Subcommittees but Where is the compelling case (based on hard numbers) for improved safety. I have yet to carefully the NPRM but what I did read raised a few questions that I would like put to CASA through RAAus.

 

 

 

 

 

 

 

1. What is the radio use/non radio use, related accident rate at non-CTAF® airports when compared with CTAF® airports and how is this proposal going to mitigate that problem.

 

2. How does this compare with the USA experience and given that Australia has significantly less dense airtraffic what quantum improvement in the accident rate is forcast if these measures are introduced.

 

3. What is the FAA (USA) and the ICAO position on this approach and why is it not standard industry practice world wide.

 

4. Where else in the world with similar airtraffic density has the introduction of this this type of legislation resulted in significant improvements in safety and what were the results.

 

Ian, would you please take these questions to RAAus on my behalf.

 

I am still cranky as hell about this.......Aircraft have been flying about for 100 years and NOW a bunch of useless pen pushers come up this this drivel. What next ADSB and TCAS???? just beacuse some airlines want to push thier weight around.

 

 

[Guest terry]

I'm with you on this qwerty, all four questions must be answered before we can intelligently comment on the proposals. I'm surprised that this hasn't been requested by our board at raa. or do they think they'll get the numbers for what they want so proper process goes out the door. I'm not into kicking our board but in this case they deserve it. Whatever the end result might be we should always be able to look back and say proper process has been followed.

 

 

[vk3auu]

Mandatory carriage of radio

 

I think is is a good idea and should have been bought in years ago. It is a much better idea than the one about the carriage of ELT's.

 

David

 

 

[Guest terry]

Hi David, The point I'd like to make is where's the process. Weather I'm convinced or not either way does not relieve raa of their responsibility.

 

we vote them in to represent us in these matters and the process is what vindicates them.

 

 

[Thx1137]

Clearly to talk sensibly about it we need to have access to the information used to put together the recommendations. I wouldn't expect to see all of it but summaries of the key facts would be good.

 

The US case sounds interesting to me based on the obvservations of a guy I know who did a lot of flying over there recently. Lots more aircraft, less rules and safe (he reckons safer but I don't know why...). At least thats the way he saw it.

 

 

[Mazda]

Let's have a read of the NPRM - I haven't yet.

 

Some interesting points to note though. While it says you should carry radio, from what is said above it sounds like it also introduces regulations about what do to if you DON'T have a radio. That is really sensible, because radios fail and it may also leave a way for non-radio equipped aircraft to operate legally. (In saying that, remember I haven't yet read the NPRM).

 

That was my big problem with mandating radio - it would mean if your radio failed you couldn't even depart an ALA to get the thing fixed, or if it failed without you knowing you could be breaking the law.

 

Note though the really big changes which will make us like the rest of the world - we will be able to join on base or on a shorter final! That will be fantastic. It works everywhere else in the world so I have no doubt it would work here.

 

Without having read it yet, it sounds like an approach with a bit of practical commonsense and it is moving towards the implementation of the airspace policy statement.

 

Things may need some adjustments, but at least McCormick has the courage to make some reforms.

 

 

[Guest Maj Millard]

I've just submitted the reply to the NPRM throught the CASA site, and I formulated my own answers as I see fit, without using the prompt by RAA. You all can do the same, and I highly recommend you do so. My feelings run in line with Quertys.

 

 

[Guest mike_perth]

I have discussed this topic at length with several RAA members off forum and yes mandatory carriage of radios for someone who lives in the bush and only flys out of their farm strip and NEVER goes anywhere near aerodromes we agree there is absolutley no need for radios - but for those that go to aerodromes then why wouldnt you want to carry a radio.......my only thinking is that you think youve been flying for 30 years without one and dont see why you should have to buy one.....in my opinion your crazy...I support the manadtory carriage of radio albiet there needs to be some restriction put in place i.e. mandatory carriage of radio if your within 80 miles of controlled airspace or if you are going to be operating into or out off a aerodrome (controlled or not) or within 20 miles of said aerodromes.

 

Simple in my opinion :stirring pot::stirring pot:

 

Support option ONE and support Aviation safety!

 

 

[Guest Maj Millard]

Within 80 miles of controlled airspace ?...wheres that come from, and for what reason ?.

 

 

[Guest mike_perth]

Its called an idea Maj...obviously within a certain boundry around any controlled airspace there will be a larger proportion of aircraft in operation it makes sense for these aircraft to be able to communicate with one another dont you think? 80 Miles was just an idea could be 30, 40, 50 miles but some boundry needs to be established to not mandate the carriage in all aircraft. Im all for everyone carrying a radio but I understand there are some people that would never venture away from their home strip on their farm so creating boundrys around controlled airspace and aerodromes is the only easy wasy to prevent this in my eyes.

 

 

[alf jessup]

There have been plenty of midairs in the circuts of controlled airports over the years all with radio comms i guess, how about we have a compulsory mandatory law of keeping your eyes 90%+ outside the cockpit looking out for other traffic when we fly.

 

Yes radios can assist very much in alerting you what maybe in your area and as long as the proper calls given by the pilots using them height, distance, correct direction they are inbound from ect and intentions they can help a lot, but nothing beats your eyesight in seeing something coming unless of course it is the bloke behind you who is going to run up your tooshy happens to be too fixated with what is going on in the cockpit instead of looking.

 

My 2 bobs worth if it means anything.

 

Cheers

 

Alf

 

 

[Yenn]

i havn't yet read and digested the complete NPRM, but I wonder why they went to the trouble of doing it. All they had to do was declare that all certified aerodromes are CTAF® and they achieve roughly the same aims, except for the relaxing of entry to circuit procedures.

 

I use a radio, but there are times when a radio is no help at all. I am thinking of the approach to Bundaberg at air show time. there was so much traffic that radio only told you to look out the window, which is what you should be doing in the first place. The other problem is when the radio is incorrectly tuned, you can be happily broadcasting intentions to nobody near you. I will be having a long hard look at the proposals, but already some seem to be reducing safety at first glance.

 

 

[Guest mike_perth]

I agree Alf there will always be accidents but Im sure that if these were busy airfields and there were a larger number of them that didnt have radio then the incidents could only be greater. I think the thing here is up until a few years ago flying was only for the rich and famous (or so to speak) so there were relativly only a few aircraft out and about on any one day - now with Rec aircraft being more accessable there are more people in the air meaning without communications there is surely a higher risk! Let alone if an aircraft gets into trouble and needs to make a forced landing how are they to make a Mayday call without a radio!

 

 

[Mazda]

Yenn, CASA has been trying to get rid of MTAF/MBZ/CTAF® for years, to avoid any confusion about procedures at non-tower aerodromes.

 

I've now read the NPRM and I think generally it is fantastic. It allows joining on base, it allows joining on final of 3 miles (not 5) with no mandatory radio call, and no mandatory radio requirement for non-certified airports. It allows a final of less than 500m. It allows landing on runways that are not into wind IF the flight manual allows it. It legally allows people with a failed radio to operate into or out of a certified airport. And it allows people with no radio, or no radio qualification, to fly into a certified airport in company with another aircraft with radio.

 

My only problems with it are that I'm not a fan of mandatory radio because people rely on it. However the NPRM does say people may not be on frequency. And I'm also concerned about additional costs for people, but there is a way in and out with no radio if you don't want to operate with a hand held.

 

But I can also see how the "vicinity" aspect could be a problem for a trike owner flying from a private strip relatively close to a registered airport. The NPRM does say that operating at 500 feet 10 miles from the airport is NOT in "the vicinity". Perhaps that's one for RA-Aus to discuss with members.

 

 

[alf jessup]

Mike'

 

I totally agree with what your saying, I am not at all against mandatory radios as I fly out of a CTAF® am I am radio equipped and make all the correct calls, I have found on many occasions aircraft inbound not giving the correct information when calling i.e inbound from the nth west when infact coming from the nth east' so here you are looking in the direction you think they are coming from when infact the come at you from a different one and it sort on hightens your awareness and scanning after it has happened to you a few times.

 

I think radio's are a great aid if used correctly nothing beats a good scan especially when in a high activity circut area like LTV on a weekend, I am lucky at west sale as we dont see that sort of activity most weekends.

 

A radio is as only good as the person operating it.

 

Cheers

 

Alf

 

 

[Guest mike_perth]

Alf

 

Once again I agree that correct use of radio is important but I think a bad call is better than NO call. I have frequently heard calls from a few international flying schools operating out of Jandakot that make bad calls and I have made comment on this before but at least when I hear them reporting that they are inbound for a reporting poiint from the wrong heading I start making a scan in the direction they "should" be coming from as well as their broadcast wring direction as part of my normak outside scan becasue as you say nothing compares to an outside scan!

 

 

[Yenn]

Yes Mazda. After a further look at the proposals I am in agreement with you. The "vicinity"question needs to be defined. Obviously an ultralight at 500' 10 miles out is not going to be much of a problem, but overflying at 4500' how does that go?

 

The strip I use is 15 miles from a CTAF® aerodrome and that causes problems, we fly on 126.7 and change to 118.8 if heading into the CTAF®, but most pilots coming into the CTAF don't know we exist and fly over at as low as 1500'. We could go to 118.8 same as the CTAF®, but that causes problems with the RPT traffic who wonder where we are. We could fly no radio, but than have no knowledge of what is above us or near us. Maybe the answer is to make radio usage non mandatory except in areas where it is mandatory. by that I mean do away with the requirement to use the radio if so equipped.