Some points to consider making in your own objection to CAR166 (mandatory VHF at non towered aerodromes)
E-learning on the topic is here
comments can be provided dircetly from the home page:
an exmple follows in read more
I am angry that CASA have chosen to ignore the interests of hang gliding as represented by ASAC. I aim to outline that the carriage and use of VHF radios on hang gliders will not be a workable system, it is counter productive to safety and is already hurting our sport. Hang gliders rarely carry VHF radio and with good reason. It is a big problem to comply with the regulations and I ask that you see that CASA provide an exemption for hang gliders to CAR166.
Hang gliders do not taxi or make taxi calls, hang gliders do not join circuit, they fly a small and slow circuit within the GA circuit. In complying with the new CAR166 regulation to carry and use a VHF radio, I am about to contribute to making “noise” by making transmisions that will not add value to other airspace users. At best the new compulsary use of radio for hang gliders around non towered aerodromes will be useless. At worst it will choke the radio band and make it unsable for other airspace users. This will occur on a number of fronts.
At 2 favorite flying sites that I frequent, I ridge soar and I will cross the 10nm boundary 20 times or more, never arriving at the airfield, nor conflicting with other users. I make landings on cliff tops routinely, operating circuits within a 100m radius of an unprepared landing zone, I will announce my circuits as prescribed, making 5 calls every minute for an hour while performing landings within the non towered aerodrome radius. Multiply this radio chatter by 20 of my friends during normal club operation or with 100 competitors at a competition and you can see that the use of the VHF radio as prescribed will fill the band with useless information.
During free flying and in competition, Hang gliders use a UHF radio for team flying and communication with my ground crew and with competition organisers for safety (usually for stopping tasks due to weather related hazards). I am required to operate using the UHF radio for safety, team performance and logistical reasons. The FAI rules prohibit any more than one transmitter per competitor. The new CAR 166 regulations are in direct conflict with our operations.
Radio equipment in my hang glider is “set and forget” I can not change channels or volume. This is a problem when my flights regularly take me to the edge of 2 aerodrome vicinities. I am not permitted to have more than 1 transmitter in my aircraft.
Australian hang gliding competitions are being threatened with boycott from our large international contingent of competition pilots, solely in response to the issue of CAR166. Our manufacturers stand to loose a large portion of income due to the lack of incoming pilots.
To comply with the regulations our club members will have radio operators licenses due to the cross country routes in our area being on the edge of the 10nm radius. Once equipped with VHF radios our local club will not have so far to travel to conduct our aerotowing operations. We will have club towing operations out of non towered aerodromes on weekends. This will create a large increase in traffic density and VHF radio chatter.
I have safely operated out of aerodromes while conducting aerotow operations and have safely arrived at non towered aerodromes to conduct a small hang gliding circuit for landing without use of a VHF radio. In trainining operations and mixed operations with other disciplines, we have integrated with the local traffic using a licensed VHF radio operator on the ground using 1 VHF radio and the ability to relay information to UHF. Each hang glider has a UHF radio to receive local traffic information. It is possible for these types of activities to coexist with GA operations, without the mandatory use of VHF radios in each hang glider.
Competitions offer additional complexity to being able to effectively relay to UHF, as multiple UHF channels are used. Operations directly beside GA, skydiving and ultralight activities are safely managed by prescribed operating areas and prohibited regions. Integration with other airspace users has been successfully managed in each case.
The CAR166 is:
it decreases safety,
it is very difficult to comply with from an operational veiwpoint,
it is killing the sport of hang gliding.
We have only months to have a rollback of the rules before the international competition pilots book their tickets for Australian competitions this year. If there is no change in the requirements from CASA, I fully intend to make my point by complying with the requirement. In the first instance of operating (it will be very difficult for us) the situation be seen to unworkable, we will actively seek to have the General Aviation sector make complaints and petition CASA to have the REG166 rolled back for hang gliders.
I recommend that a sensible way forward is:
1. Hang gliders may choose to comply with the regulations where they are operating in a way that they need to integrate with the aerodrome users using VHF radio. This may be implemented in cases such as where the HGFA operations manual prescribes a duty pilot. (this is as it works now)
2. Notams may (continue to) be used for hang gliding competitions operating out of non towered aerodromes.
3. Hang gliders be exempted from the regulation.