Notice of Final Rule Making NFRM 0908OS - Carriage and Use of Radio and Circuit Procedures at...

[Thx1137]

I have been just reading the NFRM that was published today at Civil Aviation Safety Authority - NFRM 0908OS.

 

I like how CASA responded to comments made by respondents and the writing seems clear enough. I haven't been through all of it yet but the rule changes seem ok to me.

 

 

[hihosland]

Radio part seems AOK to me.

 

The 500 ft circuit for 55kts and slower aircraft seems OK however circuit entry for slower aircraft is not well addressed and in all the diagrams of circuit patterns there is no clear indication as to how slow aircraft should enter the pattern.

 

Over fly at 2000 and then descend to 500?

 

or

 

enter mid field at 500?

 

it is not clear for either the slow aircraft operator nor for others as to what to expect from the slow aircraft.

 

at least that's the way that I read it

 

Davidh

 

 

[GraemeK]

... there is no clear indication as to how slow aircraft should enter the pattern ...

I agree some of the stuff is confusing. I hope they've got a proper education program planned for the next 6 weeks, because a lot of it is open to interpretation.

 

I think circuit entry for slow aircraft is covered in CAAP 166-1, 5.6.3:

 

Entry to the circuit should be at 500ft above aerodrome elevation as it is normally impractical to overfly the field above all other circuit traffic. Joining the circuit at 500ft above aerodrome elevation will provide separation from higher and faster traffic.

[antzx6r]

I read it that you enter at any of the normal entry points (midfield, down, 45 or base) at 500ft. And overfly at 500ft right thru the pattern. I'm guessing they feel that at <55kt you should be able to putter on up, shake hands and sort yourselves out as to who will land first.

 

4.6.4 in the CAAP 166 states that pretty clearly. 5.6 also goes into more detail on the matter. I particularly love the way 5.6.4 says that Ultralight pilots should consult AIP, ERSA, relevent charts and NOTAMS. As if that hasn't been the case in the past.

 

It also stated that those who chose to use an overfly method should remember that faster aircraft may be around. This raised a question in my mind. When overflying previously, if an aerodrome rarely or never recieved 150kn + traffic, the overfly was at 1500ft. Does that still apply or is the overfly now 2000ft for all? If this does still apply, does that go for <55kt traffic as well? i.e. 500ft circuits with 1000ft overfly?

 

Watch out for those 250kt RPT!

 

 

[Tomo]

there is no clear indication as to how slow aircraft should enter the pattern.

David, from what I understand -

 

4.6.4 For low performance ultralight aircraft and rotorcraft with

 

a maximum speed of approximately 55 KT it is recommended that

 

the aircraft overfly midfield at 500 FT above aerodrome elevation.

 

This will minimise the risk of conflict with higher or faster traffic

 

(see also paragraph 5.5 in this CAAP).

 

55kts is the max speed, so you'll already be doing only that speed, can't go any faster.

 

 

[Guest Crezzi]

If approaching from the active side , the recommended join is going to mean low performance aircraft having to fly at 500ft agl from some distance out. Not a good idea at the many airfields surrounded by bush (& illegal if its in a built up area). Doing a standard overhead join would be much safer

 

John

 

 

[Tomo]

Not a good idea at the many airfields surrounded by bush (& illegal if its in a built up area). Doing a standard overhead join would be much safer

Yes indeed...

 

Just look out for -

 

5.6.3 Ultralight aircraft pilots who choose to use the overfly

 

join procedure above the circuit altitude should be aware that:

 

• faster larger aircraft may not be able to see you easily;

 

• faster larger aircraft create significant wake turbulence;

 

• faster larger aircraft will not be able to slow to the speeds

 

of an ultralight aircraft and follow; and

 

• faster larger aircraft—prior to arriving in the circuit and

 

when below 10,000 FT —can be at speeds up to 250 KT.

 

Therefore, although aircraft should be at 200 KT

 

maximum in the circuit, an aircraft reporting at 20 NM

 

from the aerodrome could be in the vicinity of the circuit

 

within 5 minutes.

 

 

[Guest JRMobile]

Iam pleased we now have a definitive definition of the deference between recreational and GA pilots

 

"pilots flying recreational or sport aircraft for their own enjoyment, or pilots flying GA aircraft for their own leisure,"

 

CAAP 11.2

 

 

[Bryon]

Civil Aviation Safety Authority - NFRM 0908OS[/url].I like how CASA responded to comments made by respondents and the writing seems clear enough. I haven't been through all of it yet but the rule changes seem ok to me.

 

Key Proposal 7 – Withdrawal of CAR 166 paragraph (3)(a) carriage of a serviceable

 

 

 

 

 



VHF radio if making a straight-in approach no longer required (other than at

 

 

 

 

 



certified, registered and other designated aerodromes)

 

 

 

 

 

 

Disposition of Responses No. of Responses

 

 

 

 

 

 

 

 

Acceptable without change 58

 

 

 

 

 



Acceptable but would be improved if changed 5

 

 

 

 

 



Not acceptable but would be acceptable if changed 9

 

 

 

 

 



Not acceptable under any circumstances 99

 

 

 

 

 



Not stated 41

 

 

 

 

 

Total = 212

 

 

 

 

Key Proposal 8 – Withdrawal of CAR 166 paragraph (3)(b) - specific mandated

 

 

 

 

 



broadcast for straight in approaches deleted (although still recommended in

 

 

 

 

 



CAAPs/AIP)

 

 

 

 

 

 

Disposition of Responses No. of Responses

 

 

 

 

 

 

 

 

Acceptable without change 70

 

 

 

 

 



Acceptable but would be improved if changed 5

 

 

 

 

 



Not acceptable but would be acceptable if changed 9

 

 

 

 

 



Not acceptable under any circumstances 95

 

 

 

 

 



Not stated 33

 

 

 

 

 



Total = 212

 

 

 

 

 

 

It appears that CASA have really listened!!!!

 

 

[Guest Maj Millard]

I'd pay money to see anyone fly a circut at Shute harbour at 500 feet !!. You'd be diggin' dirt on the pattern entry about 300 feet below the top of the hills. Doesn't matter wether it's a right hand or left hand circut either !!.....................................................Maj..

 

 

[skybum]

cripes, I still shudder at the import of a third of respondants saying those two proposals are acceptable.

 

 

[Bill Hamilton]

----- It appears that CASA have really listened!!!!

Yes, but to who (or should that be "to whom")Any kind of reform of aviation activities (I don't want to use the word "procedures") in Australia is extremely difficult, with a very pronounced preponderance of nay-sayers to any change.

 

The objections to "risk based regulation" are very well entrenched in aviation circles, although risk based management has been adopted by almost the rest of Australian industry and their various regulators. In the aviation case, always in favor of the status quo, usually without any idea of how the status quo became the status quo.

 

Most of the objections to the CAR 166 changes, in favor of the status quo, have been entirley without regard to the various studies of actual pilot behavior at CTAF/CTAF®, earlier CTAF/MBZ. Further, without regard to studies of how "alerted see and avoid" works best ---- what really produces the least risk. aka best safety outcome.

 

"Mandatory xxxxx" does not produce the best kind of behavior --- where a pilot actually thinks about what to say --- as opposed to "chanting the mantra", putting all the verbal tick in the boxes of any analysis of the voice recorder. It is also pretty clear the "mandatory radio procedures" leads to an entirely false sense of security on the part of the participants, particularly when several pilots are indulging in a bit of do-it-yourself ATC, radio arranged separation (for which there is no legal imprimatur, or any requirement for a pilot to participate, regardless of the hectoring of any other aircraft) to the degree that other aircraft in the area can't get a word in edge-ways.

 

What the "traditionalists" can't get their mind around, as just one example, is that with very high levels of basic compliance with radio communications requirements ( I don't want to use the word "procedures") , making something "mandatory" does not increase compliance, because compliance rates are so high that most non-compliance is inadvertent, and if "compliance is mandatory", creating that animal first noted in the first Lane Report as an "inadvertent criminal".

 

John McCormick, in early testimony to a Senate Committee, acknowledged that "mandatory radio procedures" did not improve compliance, and there is quite a considerable body of evidence that rigid " mandatory procedures" actually increase risk (aka decrease safety) by inhibiting proper communications.

 

And that is why I don't want to talk about "radio procedures", but "radio communications", which is not the same thing.

 

The rest of the world "communicates", Australia has "procedures", and four or five times the "standard phrases" as recommended by ICAO. The alleged importance of complying "precisely" with "standard procedures", regardless of the appropriateness of "selected phrase or procedure" to the degree that it has been elevated to a potential BFR or License Renewal failure is a nonsense.

 

Good radio discipline and common sense is what is really required ---- not a straitjacket.

 

One of my favorites ---- those of us who know what has to be read back in a clearance on controlled airspace clearances will really appreciate this one --- and remember, I heard it myself, I was No2 behind the subject of the story; it went like this:

 

Sydney Kingsford-Smith early one morning, with one aircraft slow to vacate RW 16R:

 

Tower: QF xxx, expect late landing clearance.

 

QF xxx: Acknowledged tower advice.

 

A short while later ---with xxx on very short final ---

 

Tower: QF xxx, cleared to land, no readback required (Thinking controller there -- non-compliant phraseology in the interests of safety)

 

QF xxx: (readback) Cleared to land 16R, no readback required.

 

A wonderful example of rote adherence to "mandated procedures".

 

A bit of thread drift ---- but don't anybody be under any illusion about resistance the changes that made the RAOz of today possible --- the legislative changes that (amongst other things) introduced the various experimental categories.

 

One of these days the history will be written, of an unholy alliance between the nay-sayers of industry and CASA, who all knew that US style Experimental "wouldn't work" in Australia, that we couldn't cope with US style freedom, that Australians needed a stifling cloak of "control" to be "safe".

 

The history of the last twelve years has proven that to be absolute rubbish, to put it mildly, but the same "the only good change is no change" brigade is alive and well.

 

Thereafter, the expansion of AUF was explosive.

 

Regards,

 

 

[68volksy]

I mentioned it on another thread but if anyone's interested in attending a CASA briefing on the changes then you can contact one of their "Aviation Safety Advisors" (ASA's) who'll be presenting seminars over the next couple of months at various clubhouses and RSL's around the country. They're free and you usually get a feed also!

 

We have an ASA here in Goulburn who was at the airport on the weekend talking about the changes so if anyone would like to contact her for dates/times etc. you can email [email protected] .

 

 

[Guest ozzie]

This Bill Hamilton fella seems to have a good grasp on how things really are and how they really should be. Offer him the CEO job.

 

Ozzie

 

 

[poteroo]

Bill's already served a 'sentence' with AOPA many moons ago. I reckon he'd be happy to just burn some avgas in his Trojan and keep out of avpolitics. But you're right - he's a career heavy pilot and knows what goes on.

 

happy days,