AIR SAFETY AUSTRALIA
admin@airsafety.com.au Fax: 08 8276 4666 Phone: 08 8276 4600
PO Box 172 Unley South Australia 5061
Dear Member of AIR SAFETY AUSTRALIA,
Time is nearly up to make an important submission about the future of Australian Airspace Management.
Click here to make your submission about NPRM 0401AS (circuit procedures at uncontrolled airports). After you click, you will be presented with a draft submission. You can change it in any way you wish, then when you are satisfied just hit the “Send e-mail” button and your submission is sent to CASA (with a copy to you for your own records). We’ve already filled in your name and address and all that routine stuff – all you have to do is click (and change the text if you wish).
The deadline is Friday 12th March so do it now, please. The total time required is less than 2 minutes.
NPRM 0401AS is about one thing, and one thing only - bringing Australian circuit procedures into line with most of the rest of the aviation world so that NAS stage 2C can be implemented. That requires that a Civil Aviation Regulation be changed - CAR 166.
The amendment allows for greater flexibility in operations and marks a significant move away from over-regulation towards trusting the good judgement of pilots. These procedures have been in use in the USA for a very long time and they work well - and safely - there. I do not subscribe to the idea that Australian pilots' judgement is worse than that of American pilots or that Australians are less trustworthy.
The proposed change is user-friendly because you do not HAVE to change the way you fly – you can still fly exactly as you do now, should you prefer.
The operational change is that it will no be longer compulsory to fly three legs of a circuit before landing at any uncontrolled aerodrome. You can continue to fly three legs if you wish. You already have to look out for aircraft making a straight-in approach because some aircraft are already permitted to do so - there is no change there, either. The bottom line is that no-one is being forced to do anything new, but there will be the flexibility to do things differently when appropriate if you wish.
The proposal introduces some new safeguards. There's a new regulation against cutting in and other poor behaviour in the circuit (CAR 166(2)(d)). There's also a regulation against flying left-hand circuits where right-hand circuits are specified (CAR 166(2)(c)(ii)) (at present there is no regulation against doing that).
In my experience there has never been a serious problem with people deliberately cutting in or deliberately flying left-hand circuits instead of right-hand circuits. And rules are only ever going to affect deliberate behaviour. But if there was a problem with either of those things they should now happen less, not more.
I see it as a significant benefit that the inflexible rule about flying three legs of a circuit is to be dropped. There are times when it is good airmanship to fly a straight-in approach at an uncontrolled airport (as airliners already do). There are also times when it is neighbourly to do so, because an aircraft on a constant descent coming straight in makes far less noise than one flying three or more legs of a circuit. There are also times when a straight-in approach is not good airmanship. That's what judgement is all about.
I urge all members of AIR SAFETY AUSTRALIA to support this proposal to substitute good judgement for prescriptive rules by clicking here..
THE PRACTICAL BENEFIT OF THIS CHANGE
The practical benefit is enormous. I will take my own case. When I arrive at Ward’s Mistake from the South to land on runway 01, I now have to perform five legs of the circuit, which take me over at least one neighbour’s house. Under the new rules I will be able to fly straight in. You may think it does not matter because I’ll never be caught, but that is seriously mistaken. If I were to break the rules a dobber might ring up CASA who then might lie in wait. And if I were to have an accident I would likely find my insurance was declared void due to “breach of air law”. One disobeys the law at one’s very real peril.
There are times when it is downright dangerous to fly five legs of a circuit when one would do. An example of that is at an unfamiliar country airfield on a moonless night with no lights on the ground except the airfield lights.
Boyd Munro, 9th March 2004
P.S. see http://rrp.casa.gov.au/download/04_nprm.asp for the entire NPRM
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