Hi Allan,
Lowering Class E on the East Coast
Air Services Australia is the Government organisation with responsibility for controlling the air space, airports, and anything to do with aircraft in the in the air and on the ground.
They make recommendations for change to CASA which will consider the recommendations. CASA presents those changes in the form of legislation to the government which considers it in parliament and makes the laws for CASA to regulate. Air Services are the then empowered to enforce and apply the changes.
This process does take some time and is not a clear cut and open shut case of proposed changes being implement. However, it is highly expected that changes will be made to the air space in what is called the “J” curve. Now is the time for us to have our say in making sure our ideas and input are heard.
Air services Australia require constructive community input to their proposal for Class E changes. They are seeking input from all participants in the aviation sector that are affected by these proposed changes. The safety statement will be published after they have finalised their proposal.
SAFA has a voice in this discussion and as members we are encouraged to submit constructive and helpful comments and ideas and suggestion to Air Services Australia.
Key points:
Changes from the initial proposal:
The proposed changes to 1,500 and 4,500 AGL has been dropped and is no longer in consideration.
The committee in Air Services Australia that are advising on these changes do not have any sport aviation experience and limited knowledge in our type of flying. Only one is a GA pilot. All members on the committee are experienced and seasoned professionals in nationwide air service management. The first round of responses earlier this year opened the window of their understanding to the many sports aviators and our use of class G.
The “J” curve:
This is the airspace which extends from north of Cairns all the way down the east coast through Queensland, NSW and then a straight line from Sydney to Melbourne via Canberra and Albury.
Driver for change as explained by Air Services Australia:
In recent times there has been a relatively significant change in airspace usage and risk profile with a surge in general aviation activities. Air Services expect the traffic mix and interactions between diverse types of airspace users to continue to change dynamically in response to the Government support for tourism recovery and regional aviation development.
This increased airspace complexity requires a change to traditional service provision and ensure that we are proactively adjusting to new and emerging risks. We also have had the opportunity to learn from recent safety occurrences, particularly in areas where there is a reliance on pilots self-separation.
The primary driver of the proposal is to deliver a net safety benefit to industry with minimal adverse impact on access, cost and other needs of individual airspace users. We aim to achieve this outcome by:
- proactively reducing the conflict/collision risk between IFR and IFR aircraft in proposed airspace volumes that will be changed from Class G to Class E
- retaining a portion of Class G airspace to meet the needs of non-transponder equipped aircraft and as part of supporting the general aviation sector.
Safety Benefit
Today, a large portion of Australia’s regional enroute airspace is Class G, requiring pilots to actively assess the traffic situation, comply with the rules of air to self-separate and rely predominantly on see-and-avoid principles to avoid conflicts/collisions. Pilots on IFR flights are provided with traffic information about other IFR flights. These are long standing procedures which have been used for several decades.
As our surveillance network has expanded, we are now in a position to deliver a more effective risk control against collision/conflict risk by replacing a portion of Class G airspace with controlled airspace (Class E) that continues to allow appropriately equipped Visual Flight Rule (VFR) operators access to airspace without a clearance.
This change will replace up to 4,000ft of Class G airspace with Class E airspace where terrain allows. This airspace between 4,500ft and 8,500ft overlies numerous non-towered aerodromes on the eastern seaboard. Many of these aerodromes have IFR operations, requiring pilots to process large amounts of information while climbing or descending near an aerodrome.
Provision of an air traffic control service delivers positive control between IFR aircraft through the issuing of clearances and tactical intervention to maintain separation. This will deliver a net safety benefit, particularly in IFR conditions (Instrument Meteorological Conditions) to reduce the likelihood of potential aircraft conflicts (or conflicts with terrain) escalating to a collision.
Effect of the proposal in each state:
(NOTE: LL ASL = lower level Above Sea Level)
Queensland:
It extends about 80 NM around Cairns, Townsville, then about 100 NM inland from Mackay down to Brisbane extending out as far as about 110 NM in an arc west of Brisbane.
Most of the new area is proposed as Class E down to 4,500 FT ASL. The arc around Cairns and Townsville from about 30 NM to 80 NM to the west is Class E LL down to 6,500 ASL. There is a small arc of Class E LL at 6,500 ASL to the west of Mackay. Then all Class E LL 4,500 all the way from Mackay to Sunshine Coast inland to about 110 NM. Around Brisbane there is Class E LL 6,500 ASL from about 30 NM out to about 120 NM.
Green No change to existing
Light Blue New Class E LL 4,500 ASL
Dark Blue: New Class E LL 6,500 ASL
NSW:
NSW has two main corridors. The coast fringe from Ballina to Sydney coast to inland about 40 NM inland along the great dividing ranges Class E LL 4.500 Ft ASL.
The inland corridor from the west side of 4,500 to 6,500 in a curve from Tenterfield to Tamworth, Denman, Cowra.
From Cowra it drops down to 4,500 down through Temora, Narrandera to the Vic boarder. Canberra and Albury steps remain mostly the same except for the western side. The 6,500 LL extends to the coast between Canberra and Sydney in an arc from Batemans Bay to Kiama.
Red no change to existing Class E LL 8,500 ASL
Green no change to existing
Dark Blue Class E LL 6,500 ASL
Light Blue Class E LL 4,500 ASL
Victoria.
Victoria has an arc extending from Melbourne to Ararat in the west to the NSW border town of Echuca 93 NM in the north around to Wilson Prom national Park entrance in the south east of new Class E LL 4,500 with a small exception in the east in the Mansfield to Moe area. Bright and Corryong remain in the 8,500 ASL area as at present.
Are you affected?
Class E LL 4,500 ASL areas
Most of the coastal flying areas are in the proposed Class E LL 4,500 ASL area.
In Queensland most of the Queensland inland flying areas from the coast to inland 80 -110 NM are in the proposed Class E LL 4,500 area. Popular flying areas around Maryborough and Canungra are in the proposed Class E LL 4,500 ASL area.
Dalby is not affected.
In NSW, the coast areas between Sydney and Ballina are proposed as Class E LL 4,500 which will include popular flying areas of the hunter valley, central coast and Port Macquarie and Byron Bay and Lismore areas.
Some areas of the inland NSW will be in the proposed Class E LL 6,500 which at the moment are Class G to 10,000 or 8,500 ASL. Affected flying areas will be central West NSW, Temora, sections of the upper hunter valley including the area around Denman and Muswellbrook.
Manilla is just outside the area and is not affected unless flying easterly.
In Victoria, a large portion of the state which includes most of the favoured inland sites north and west and south east of Melbourne will be in the proposed 4,500 area. Bright and Corryong are not affected. However, pilots on long XC flights from these sites will need to include possible incursion into affected areas into their flight planning and carry equipment accordingly.
What to do:
Rest assured the Ops Team will be doing whatever we can to maintain your operational freedoms. To ensure AirServices understand the impact of this proposal on affected SAFA members we urgently ask members to respectfully provide their feedback on the impact to their operations directly to AirServices Australia before 30th of April 2021 by emailing stakeholder@airservicesaustralia.com, or
by email at AMP Engagement ContactAMP@AirservicesAustralia.com or by filling in the form at: https://engage.airservicesaustralia.com/lower-base-class-e-east-coast/survey_tools/revised-proposal-feedback-form
What to say:
What type of aircraft do you fly?
Where do you fly? – (Be specific of the location and areas identified in relation to the J curve as shown.)
What heights do you fly at?
What impact will a LL 4500 or 6500 have on your flying?
What extra equipment will you have to purchase (e.g., VHF radio, vario with airspace warning capability)?
Do you have any constructive suggestion for technology use such as light weight ADS-B out transponders currently in use overseas?
To assist members in presenting their views, we have provided statistics and key points for members to consider as part of their response to Air Services.
- SAFA has 3556 current pilot members
- There are 49 SAFA flight training schools and all except 4 of these schools are based in the affected states of QLD, NSW, and Victoria
- Should the need to carry VHF radio be required, as per the current proposal, the cost impact would be approx. $1.1 million to SAFA members
- Pilots of our aircraft are not in enclosed cockpits. Carriage and use of VHF radios is extremely difficult from a practical point of view as we fly with gloves on – changing channels while piloting the aircraft through the changed architecture steps presents a safety risk.
- We commonly use UHF radios for communications between our aircraft and the ground. A forced change to VHF will lead to airwave congestion.
- Introducing a VHF carriage and use requirement due to the change in airspace architecture will lead to pilots losing access to currently available flight areas if they do not purchase these radios. It also conversely, runs the risk of fomenting a culture of non-compliance.
- Should members be required to purchase a flight instrument with airspace recognition capability as a minimum, the cheapest instrument currently available in Australia costs $560. Instruments with graphical representation of airspace cost well in excess of $800.
- The claimed “Low Cost” ADS-B devices are proportionally not low cost.
- The current devices being approximately $870.00, which is 25% of the cost of a Hang Glider or Paraglider.
- Indicating as such is comparable to advising a Jabiru owner that a $40,000.00 piece of technology is "low cost".
- By introducing this architecture large volumes of what is now Class G airspace will be denied to the HG/PG community who currently can utilise this airspace without entering Class E. Should you wish to operate a weightshift microlight with an electrical system in class E airspace you will have to fit a transponder (costing well over $2000+)
- This proposal introduces significant operational risk to pilots who do not have a serviceable transponder or radio in their aircraft.
- An increase in complaints will occur as a result of occupants of dwellings registering concerns about increased aircraft noise and overflight of residential areas due to pilots of non-transponder equipped aircraft being forced to fly much lower than currently permitted.
- There are no safety benefits to VFR aircraft. If anything, it increases the risk of conflict with increased IFR traffic using airspace volumes currently enjoyed by VFR aircraft.
- The proposal should be withdrawn.
Thank you,
The SAFA Op's Team.
