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Process continues – introduction rules without consultation [Case study]

Multicom frequencies:

Introduction without consultation, then CASA refuses to remove or “fix-up” the problems created.

As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.

The following discussion details serious changes being made to ‘rules”, without any safety case being expounded and avoidance of the processes set in place for the industry to be able to participate.

Again, CASA has made changes without proper safety cases. This process is continuing, despite the ASRR requirements.

Discussion below is by senior aviation people, who have posted in public fora.

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8th May 2015, 12:16   #26 (permalink)
Join Date: Jul 2001
Location: Australia
Posts: 2,631
Midnight,
Raised again, because CASA has got it wrong!! To the potential detriment of air safety outcomes. The CASA attitude is that they are the only soldier in the battalion marching in step.If we go back before all the recent sodding around with CAR 166, the policy intent (backed by an ICAO compliant safety case) was to keeplow level local traffic off ATC (by whatever name) frequencies.It was never the policy intent that traffic on uncharted strips should use the overlaying ATC frequency.

As to “charting” all the uncharted strips, this is a practical impossibility, even without consideration of map cycles etc.

Tootle pip!!

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Old 9th May 2015, 22:52   #42 (permalink)
Join Date: Jan 1999
Location: Queensland
Posts: 720
Quote:
AIP ENR 1.1 para 44.1:Quote:
Pilots of radio-equipped VFR aircraft must listen out on the appropriate VHF frequency and announce if in potential conflict. Pilots intercepting broadcasts from aircraft in their vicinity which are considered to be in potential conflict with their own aircraft must acknowledge by transmitting own call-sign and, as appropriate, aircraft type, position, actual level and intentions.Theappropriate VHF frequency stated in para 44.1 is:a.In the vicinity of an aerodrome depicted on aeronautical charts, with a discrete frequency, the discreteCTAF shown (including Broadcast AreaCTAF) or otherwise;b. In the vicinity of an aerodrome depicted on aeronautical charts, with no discrete frequency shown, the Multicom 126.7; or

c. In all other cases, Area VHF.

These procedures have been in place for many (the last 10+?) years. For CASA to try and undo them now would in itself present a safety issue.

In fact that is an extract of the present AIP, but prior to the recent change re unmarked airfields, the AIP made no mention of marked or unmarked airfields which was in accordance with the NAS introduced over a decade ago, where the MULTICOM was introduced. Much of that, it seems, those in CASA have either forgotten or were unaware of (??).

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Old 11th May 2015, 15:16   #50 (permalink)
Join Date: Jan 1999
Location: Queensland
Posts: 720

As some readers would be aware, the change to the MULTICOM in 2013 was conducted with no consultation and no risk analysis or safety case to industry knowledge.When the matter was raised with the OAR for discussion at the RAPACs it was rejected as not being an airspace matter.

For about the last year, all of the Industry RAPAC Convenors have been canvassed and included in a string of emails on the matter. There have over this time been a number of attempts to table the MULTICOM for discussion, but the subject has been rejected by the OAR.

Discussions have been held out of session as the OAR has refused to include the subject at the RAPACs and therefore it is unlikely you will find mention in the minutes, even when it was discussed, even briefly. The management of the OAR have to take responsibility for this debacle. Even correspondence from CASA has not addressed the subject in any detail or the safety issues that have been raised. As if they just don’t want to know?

Things seem to be changing somewhat since the new DAS entered the building and the MULTICOM has been subject to some further discussion of late. One can only hope that those responsible for this change are directed to place the matter on the table for open discussion, especially with the RAPACs.

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Old 11th May 2015, 00:52   #47 (permalink)
Join Date: Jul 2001
Location: Australia
Posts: 2,631
Folks,
Just as a reminder, EVERY RAPAC in the country rejected the current CASA interpretation of CAR 166 — and there is a very broad spectrum of representation atRAPACs —- doesn’t that tell you something.As Triadic has stated so clearly,the intent of NAS over a decade ago was very clear, CAR 166was amended for that purpose.Again, I thing Triadic is on the money, those in CASA who are responsible for this either have forgotten the very good reason for the decisions of that time, or never knew.

One of the really great difficulties in dealing with CASA is the abysmal lack of corporate memory, hence the continual flow of answers to questions that were never asked, the continual flow of solutions to problems that do not exist.

Some of the “reinventing the wheel” that is going on in Certification is another example.

Tootle pip!!

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